MINE CLOSURE TOOLBOX/media/Files/A/... · achieve its burning ambition and purpose, the closure team must deliver value through integrated, risk and opportunities based closure planning

aANGLO AMERICAN MINE CLOSURE TOOLBOX EXAMPLES VERSION 3

MINE CLOSURE TOOLBOX

EXAMPLES VERSION 3, 2019

FOREWORDAnglo American’s (AA) burning ambition is to be the most valued mining company in the world by 2023. The purpose of AA is to reimagine mining to improve people’s lives.

Mining plays a significant role in human and economic development and, without the mining sector, society would not enjoy a large number of the benefits that it does today. The mining industry’s rich history also carries some important lessons and one of these is the poor closure or abandonment of mines by the industry worldwide. If AA is to achieve its burning ambition and purpose, the closure team must deliver value through integrated, risk and opportunities based closure planning and execution, to establish safe, stable and non-polluting post-mining landscapes that leave a positive and sustainable legacy for stakeholders.

The updated Mine Closure Toolbox (MCT) (v3) has incorporated the Integrated Closure Planning System (ICPS) that was developed in 2015 and built on the existing toolbox (v2) that was released in 2013. Importantly, a Group wide closure standard was endorsed in June 2018 and this updated version of the MCT provides the guidance for AA operations to achieve the requirements outlined in the standard. The updated version of the MCT increases the emphasis on the importance of designing, planning, operating and executing closure at AA operations, with a focus on integration with Life of Asset Planning (LoAP). The updated MCT is targeted at people in our operations across a range of disciplines, the tools provide practical support as to how to achieve the desired integrated outcomes for AA. It is also important that a preferred future for the mine footprint post-production is developed in partnership with communities. The tool reinforces our desire for improved community relationships and engagement.

Some of the more immediate benefits from our updated MCT are increased integration with LoAP, potential lower closure liabilities, lower rehabilitation costs, more effective social investment and engagement, and enhanced value to AA and its stakeholders.

Together, we create sustainable value that makes a real difference.

Mark Cutifani Chief Executive November 2019

FRONT COVER:Kumba: Saldanha Iron Ore Terminal, South Africa.

ACKNOWLEDGEMENTSThe original report “Version 1, 2007” was developed by Peter Coombes and Rudolph Botha from the then Anglo Technical Division. The second version of the MCT was developed by Rudolph Botha of AA’s Technical Solutions with the support and inputs of various AA technical resources. This third version of the MCT was developed by Carl Grant and Rudolph Botha and from AA’s Group Technical and Sustainability.

The authors would like to thank the various individuals across the Group who provided comment, examples and factual data for incorporation into this revised document.

For more information contact:Dr Carl GrantHead of Mine ClosureGroup Technical and Sustainability201 Charlotte StBrisbane, 4000

Email: [email protected]

Telephone: +61 7 3834 1215

or

Mr Rudolph BothaLead Mine ClosureGroup Technical and Sustainability45 Main StreetJohannesburg, 2001

Email: [email protected]

Telephone: +27 1 638 2254

Published by Anglo American plc

Designed and produced by Creativity

CONTENTSEXAMPLE 1: ESTABLISHING THE ZONE OF INFLUENCE OF THE PROJECT 2

EXAMPLE 2: SWOT ANALYSIS 4

EXAMPLE 3: CLOSURE RISK ASSESSMENT 6

EXAMPLE 4: CLOSURE BENCHMARKING REVIEW 26

EXAMPLE 5: PHYSICAL CLOSURE COST CALCULATION SPREADSHEET AND DRAWINGS 30

EXAMPLE 6: COMPLETED GAP ANALYSIS AND ACTION PLAN 31

EXAMPLE 7: REHABILITATION STRATEGY AND FIVE-YEAR REHABILITATION PLANS 68

EXAMPLE 8: SUCCESS CRITERIA 70

EXAMPLE 9: SOCIAL TRANSITION RISK ASSESSMENT AND CASH FLOW 73

EXAMPLE 10: HEALTH CONSIDERATIONS IN MINE CLOSURE 98

EXAMPLE 11: KEPNER TREGOE OPPORTUNITIES ANALYSIS 102

EXAMPLE 12: DEVELOPING CLOSURE OBJECTIVES AND KPI’S FOR SENIOR LEADERS 105

EXAMPLE 13: CLOSURE CRITERIA EFFECTIVENESS REVIEW 108

EXAMPLE 14: PROJECT MANAGEMENT FRAMEWORK (PMF) – STUDY AND PROJECT EXECUTION PLAN TEMPLATE 112

EXAMPLE 15: QUANTITATIVE RISK SIMULATION AND ANALYSIS 118

EXAMPLE 16: EXECUTION PLANNING AND SCHEDULING 124

EXAMPLE 17: WORK BREAKDOWN STRUCTURE 126

EXAMPLE 18: DEMOLITION PLAN 136

EXAMPLE 19: CLOSURE MAINTENANCE AND MANAGEMENT PLAN 140

EXAMPLE 20: SUGGESTED STRUCTURE FOR ANGLO AMERICAN CLOSURE PLANS 142

ACRONYMS 147

1ANGLO AMERICAN MINE CLOSURE TOOLBOX EXAMPLES VERSION 3

2 ANGLO AMERICAN MINE CLOSURE TOOLBOX EXAMPLES VERSION 3

EXAMPLE 1: ESTABLISHING THE ZONE OF INFLUENCE OF THE PROJECT

INTRODUCTION

The Zone of Influence (ZoI) is the area within which a development has material impacts or can influence impacts. Typically the ZoI is unique to each project, is larger than the actual project footprint, and encompasses: • The area of direct disturbance that includes the

‘footprints’ of areas immediately adjacent to the primary and service infrastructure, such as power lines, pipelines, roads, railway lines, conveyors, borrow pits, disposal areas, construction camps.

• The area directly affected by the project’s adverse impacts, such as groundwater cones of depression, groundwater pollution plumes.

• The area affected by secondary, induced or cumulative impacts. Secondary impacts arise from other impacts

that are directly due to the development (e.g. loss of fisheries due to water contamination). Induced impacts are due to unplanned, unintended or secondary activities that are ‘catalysed’ by the development (e.g. illegal logging along access routes). Cumulative impacts are as a result of numerous individual activities, which may be insignificant on their own, but which can interact or combine to cause significant impacts.

• The development’s primary labour sending and money spending area(s) (i.e. the towns and communities that are likely to experience economic benefits from the project).

• Surrounding areas that could potentially benefit from the project through increased security such as sites of high biodiversity and protected areas.

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The Navigation Plant at Landau Collieries, South Africa.


Figure 1: Typical example of a Zone of Influence

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ZONE OF INFLUENCE

! Town/Major village Mine Lease Area

FenceRiver

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Associated facilities should also be considered when determining the ZoI. These are facilities that are funded separately by the company or third parties (e.g. government), but whose viability and existence depend almost exclusively on the project and whose goods or services are essential for the successful operation of the project.

APPROACH

For each component covered by the baseline investigations, the boundary of the project’s extent of influence is determined independently. Thereafter, based on a composite overlay of each component’s boundary, the boundary for the overall ZoI is determined. The purpose is not to define a sharp cut-off, but rather to define the area where the mine can make a real difference. The ZoI does not have to be a single area – non-contiguous, niche zones are acceptable. Spatial zones are most easily defined by administrative boundaries, however natural boundaries (e.g. catchments) and the dynamics of the environmental systems should also be considered.

The ZoI should not be enlarged to the extent that the project is in danger of becoming a surrogate government

but should be based on a sound business case established by considering the risks to the business. It is advisable to start with a small, uncomplicated zone and then to enlarge it and increase its complexity, if necessary.

In defining the boundary for the ZoI, the following should be considered:• The influence of the project on the surrounding area and

the influence of the surrounding area on the project.• Linkages with other developments in the area which

could cause ‘ripple effects’ (cumulative impacts) within the ZoI.

• The influence on spatial planning of government development plans and objectives.

• Other initiatives that may affect the ZoI, such as enterprise development.

Maps in a wide variety of formats, which contain spatial data on administrative boundaries, land-use, and biodiversity for example, will be obtained during the baseline investigations. To be useful as a planning tool, the spatial data should be consolidated into a Geographic Information System (GIS) (Figure 1).


EXAMPLE 2: SWOT ANALYSIS


Mogalakwena North Concentrator, South Africa.


INTRODUCTION

The purpose of the strengths, weaknesses, opportunities and threats (SWOT) analysis is to systematically evaluate the proposed project or existing operation within its unique, surrounding environment. The SWOT analysis evaluates the actual development (internal) and the broader surrounding environment within which the development is located (external). Through this evaluation, an understanding is developed of the internal or inherent strengths and weaknesses of the project and the external threats and opportunities that the surrounding environment imposes on or presents for the project. In this context: • Strengths are internal attributes inherent to the project

that can be used to exploit opportunities or reduce or overcome threats that the surrounding environment may offer or impose. Typical Examples are: physical location close to facilities and labour; internal technical knowledge; proven sustainable rehabilitation prescription; good availability of monitoring data; potential high value post-mining land-uses (PML’s); and low dependency rates on the mine in surrounding communities.

• Weaknesses are internal attributes inherent to the project that would lead to residual impacts and/or contribute to cumulative impacts. Concerted efforts should be made to reduce or eliminate weaknesses. Typical examples include: Lack of concurrent rehabilitation and proven sustainable prescription; presence of sensitive ecosystems or endangered species in the mine lease area; requirement for water treatment in perpetuity due to acid mine drainage; spontaneous combustion issues; and lack of conceptual surface and groundwater models for the closure scenario.

• Opportunities are favourable or unexploited external situations that the environment offers development, which can be harnessed for the project’s advantage by proactive management. Examples include unexploited market segments, communities seeking poverty alleviation, a high assimilative capacity of the natural environment, a need for rural water supply, a need for rural energy supply, rapidly growing market

diversification, good soil conditions, availability of good quality water.

• Threats are unfavourable external conditions that the environment imposes on development, which in the absence of proactive management could lead to the project’s underperformance or failure. Examples include high levels of unemployment and poverty in the area, lack of skills and low levels of education in the area, lack of other significant economic hubs in close proximity to the area.

Approach

To implement a SWOT analysis, the following steps are suggested:1. Give a presentation on the SWOT analysis technique, to

ensure that all participants have a common knowledge of the technique, process and expected end results.

2. Divide the participants into smaller sub-groups or work teams, ensuring cross-representation of expertise within each team.

3. Let each sub-group independently develop a list of strengths.

4. Within the full workshop format, combine the individual sub-team lists into an overall list that reflects the areas of consensus.

5. Through consensus prioritise the listed strengths, from what is considered to be most important to least important.

6. Repeat steps 3, 4 and 5 for weaknesses, opportunities and threats.

The most significant strengths, weaknesses, opportunities and threats should be identified. The project design and management strategy should aim to harness the key strengths and opportunities while avoiding/overcoming the threats and weaknesses. This should be reflected in the management plans.

The outputs from the SWOT analysis should influence the development of the closure vision and land-use plan.



EXAMPLE 3: CLOSURE RISK ASSESSMENT


General view of the Unki smelter across granulation to slag tapping in Zimbabwe.


INTRODUCTION

The purpose of this example is to illustrate and highlight the risk based approach of the MCT.

The following key actions must form part of developing risk-based closure criteria:• Identify the key risk that needs to be assessed (e.g.

erosion from waste rock dump batters, visual impact of tailings dam, local economic impact of mine closure);

• Once the key risks have been identified, list the most appropriate closure criteria.

• Evaluate the acceptability of a reduced risk compared to the associated cost of the implementation of the closure criteria.

• Assess the effectiveness of the selected closure criteria to mitigate the risk.

• The business case for the inclusion of every closure criteria should be demonstrated. If you are not reducing an unacceptable risk to an acceptable level, the cost of implementing the closure criteria may not be justified.

The example on the next page shows the change inthe risk profile, in terms of pre- and post-implementationof closure criteria.

It is recommended that only the consequence type with the highest predicted risk is rated to save time. If there are two consequence types that are seen to potentially have the highest predicted risk, then both should be rated.



EXAMPLES OF CLOSURE RISK ASSESSMENT

RISKS FOR TAILINGS FACILITIES AND DAMS AT CLOSURE

RATED AS RISK BEFORE IMPLEMENTATION OF CLOSURE CRITERIA

CLOSURE CRITERIA

POST-MITIGATION RESIDUAL RISK

ADDITIONAL MITIGATION

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SAFETY & HEALTH FINANCIAL

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1. Tailings Dam

i Seepage from tailings leads to surface or groundwater pollution from elevated metals or salts within the tailings.

4 4 21 1. Groundwater monitoring. 2. Groundwater modelling. 3. Geochemical testing of tailings.

4 1 10

ii Exposed tailings lead to air pollution from dust. 2 4 12 1. Potential waste rock cladding of 600 mm. 2. Topsoil to be applied at 300 mm. 3. Planting and seeding of thornveld species. 4. Fertiliser addition. 5. Weed control.

2 1 3

iii Geotechnical failure of tailings dam post closure. 3 3 13 1. Original design of tailings facility. 2. Pre closure and final geotechnical stability

review.3. Operational management control

maintained.

3 2 9 1. Post closure drainage design.

iv Erosion from the revegetated tailings surface leads to sedimentation of waterways.

4 4 21 1. Potential waste rock cladding of 600 mm. 2. Topsoil to be applied at 300 mm. 3. Planting and seeding of thornveld species. 4. Fertiliser addition. 5. Weed control.

3 3 13 1. Drainage and discharge strategy and surface hydrology design.

2. Undertake study to determne whether 600 mm of waste rock is required.

2. Pollution Control and Dirty Water Dams

i Liner failure leads to groundwater pollution. 3 4 17 1. Groundwater monitors to detect liner failure during LoA.

2. Removal of dam in closure.

3 1 6

ii Dam overflow or failure leads to soil contamination. 2 3 8 1. Removal of any contaminated soil to appropriate facility.

2. Removal of dam in closure (unless required for post-mining land-use).

2 1 3


RISKS FOR TAILINGS FACILITIES AND DAMS AT CLOSURE


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1. Tailings Dam

i Seepage from tailings leads to surface or groundwater pollution from elevated metals or salts within the tailings.

4 4 21 1. Groundwater monitoring. 2. Groundwater modelling. 3. Geochemical testing of tailings.

4 1 10

ii Exposed tailings lead to air pollution from dust. 2 4 12 1. Potential waste rock cladding of 600 mm. 2. Topsoil to be applied at 300 mm. 3. Planting and seeding of thornveld species. 4. Fertiliser addition. 5. Weed control.

2 1 3

iii Geotechnical failure of tailings dam post closure. 3 3 13 1. Original design of tailings facility. 2. Pre closure and final geotechnical stability

review.3. Operational management control

maintained.

3 2 9 1. Post closure drainage design.

iv Erosion from the revegetated tailings surface leads to sedimentation of waterways.

4 4 21 1. Potential waste rock cladding of 600 mm. 2. Topsoil to be applied at 300 mm. 3. Planting and seeding of thornveld species. 4. Fertiliser addition. 5. Weed control.

3 3 13 1. Drainage and discharge strategy and surface hydrology design.

2. Undertake study to determne whether 600 mm of waste rock is required.

2. Pollution Control and Dirty Water Dams

i Liner failure leads to groundwater pollution. 3 4 17 1. Groundwater monitors to detect liner failure during LoA.

2. Removal of dam in closure.

3 1 6

ii Dam overflow or failure leads to soil contamination. 2 3 8 1. Removal of any contaminated soil to appropriate facility.

2. Removal of dam in closure (unless required for post-mining land-use).

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EXAMPLES OF CLOSURE RISK ASSESSMENT (continued)

RISKS FOR WRD’s & STOCKPILES AT CLOSURE


CLOSURE CRITERIA



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1. Botha, Grant and Bell WRD’s

i Seepage from WRD’s leads to surface or groundwater contamination from leaching of metals or salts.

3 3 13 1. Geochemistry evaluated. 2. Groundwater monitoring. 3. Further leachate studies recently

conducted.

3 1 6 1. Review report on geochemistry of different waste rock types.

2. Geochemical kinetic testing of waste rock types if required.

ii Geotechnical failure of WRD. 4 3 18 1. Monitoring of WRD’s during operational phase.

2. Reshaping of WRD batters to 18 degrees.

4 1 10 1. Review geotechnical classification and design report.

iii Failure of rehabilitation leads to dust issues. 1 3 4 1. Monitoring of rehabilitation and maintenance.

1 2 2

iv Death or injury resulting from accessing WRD’s. 4 3 18 1. Security during mining operational phase. 2. Reshaping WRD’s to 18 degrees. 3. Fencing for game and cattle in post-

closure farm enterprises.

2 2 5

v Design and operational implementation for water contol is inadequate. 3 3 13 1. Reshaping of WRD batters to 18 degrees. 2. Topsoil to be applied at 300 mm. 3. Planting and seeding of thornveld species.

Fertiliser addition.4. Installation of structures according to

stormwater plan.

2 2 5 1. Strategy for each waste rock landform to be defined (e.g. retain, discharge, or partial retain and release in large storm events).

vi Over-dumping on WRD leads to increased rehabilitation costs. 4 4 21 1. Preparation of WRD dumping plans. 3 3 13 1. Establish in-field marking system for dump limits.

2. Use in truck alarms to indicate dumping limits.

vii Erosion from the revegetated WRD surface leads to sedimentation of waterways.

3 4 17 1. Reshaping of WRD batters to 18 degrees. 2. Topsoil to be applied at 300 mm. 3. Planting and seeding of thornveld species.


stormwater plan.

2 2 5 1. Install sediment traps in landform discharge areas.

2. Low Grade Stockpiles

i Seepage from stockpiles leads to surface or groundwater pollution from leaching of metals or salts within the stockpiles.

2 4 12 1. Groundwater monitoring during operational phase.

2. Removal of stockpiles at closure phase. 3. Golders residue and geochemistry studies. 4. Testing and removal of contaminated

material.

1 2 2

ii Erosion from closed rehabilitated stockpiles surface leads to sedimentation of waterways.

2 4 12 1. Retain pollution control dams until all stockpiles removed.

2. Stormwater design for plant area implemented.

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RISKS FOR WRD’s & STOCKPILES AT CLOSURE


CLOSURE CRITERIA



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1. Botha, Grant and Bell WRD’s

i Seepage from WRD’s leads to surface or groundwater contamination from leaching of metals or salts.

3 3 13 1. Geochemistry evaluated. 2. Groundwater monitoring. 3. Further leachate studies recently

conducted.

3 1 6 1. Review report on geochemistry of different waste rock types.

2. Geochemical kinetic testing of waste rock types if required.

ii Geotechnical failure of WRD. 4 3 18 1. Monitoring of WRD’s during operational phase.

2. Reshaping of WRD batters to 18 degrees.

4 1 10 1. Review geotechnical classification and design report.

iii Failure of rehabilitation leads to dust issues. 1 3 4 1. Monitoring of rehabilitation and maintenance.

1 2 2

iv Death or injury resulting from accessing WRD’s. 4 3 18 1. Security during mining operational phase. 2. Reshaping WRD’s to 18 degrees. 3. Fencing for game and cattle in post-

closure farm enterprises.

2 2 5

v Design and operational implementation for water contol is inadequate. 3 3 13 1. Reshaping of WRD batters to 18 degrees. 2. Topsoil to be applied at 300 mm. 3. Planting and seeding of thornveld species.


stormwater plan.

2 2 5 1. Strategy for each waste rock landform to be defined (e.g. retain, discharge, or partial retain and release in large storm events).

vi Over-dumping on WRD leads to increased rehabilitation costs. 4 4 21 1. Preparation of WRD dumping plans. 3 3 13 1. Establish in-field marking system for dump limits.

2. Use in truck alarms to indicate dumping limits.

vii Erosion from the revegetated WRD surface leads to sedimentation of waterways.

3 4 17 1. Reshaping of WRD batters to 18 degrees. 2. Topsoil to be applied at 300 mm. 3. Planting and seeding of thornveld species.


stormwater plan.

2 2 5 1. Install sediment traps in landform discharge areas.

2. Low Grade Stockpiles

i Seepage from stockpiles leads to surface or groundwater pollution from leaching of metals or salts within the stockpiles.

2 4 12 1. Groundwater monitoring during operational phase.

2. Removal of stockpiles at closure phase. 3. Golders residue and geochemistry studies. 4. Testing and removal of contaminated

material.

1 2 2

ii Erosion from closed rehabilitated stockpiles surface leads to sedimentation of waterways.

2 4 12 1. Retain pollution control dams until all stockpiles removed.

2. Stormwater design for plant area implemented.

1 2 2



RISKS FOR OPEN PITS AT CLOSURE


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1. Botha, Grant and Bell Pits

i Seepage from pit leads to ground water contamination. 4 4 21 1. Groundwater monitoring. 2. Groundwater modelling provided for

operational and high level closure estimates.

3 4 17 1. Post closure water balance prepared.

2. Water quality of pit lake modelled.

3. Potential to enhance recharge of pit lake by directing landform and surface runoff toward pits.

ii Long term impact of pit on groundwater levels. 2 4 12 1. Groundwater monitoring. 2. Groundwater modelling (50 years to

reach final water level).

2 2 5

iii Geotechnical failure of pit wall with insufficient relaxation zone leading to the abandonment berm being compromised.

5 4 24 1. Geotechnical monitoring during LoA. 2. Control pre-split blasting. 3. Top bench to be reshaped to 33% slope. 4. Location of access berm and trench

beyond the zone of relaxation.

3 3 13 1. Identification of Factor of Safety (FoS) 1.5 relaxation zone through modelling.

iv Death or injury resulting from accessing pit, pit wall rockfall, swimming or recreational use.

5 4 24 1. Pit Wall control - controlled blasting and catchment berms.

2. Install 2 m high berm with 1 m deep trench on perimeter of pit outside relaxation zone.

3 3 13 1. Install signage. 2. Cut access ramps.


RISKS FOR OPEN PITS AT CLOSURE


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1. Botha, Grant and Bell Pits

i Seepage from pit leads to ground water contamination. 4 4 21 1. Groundwater monitoring. 2. Groundwater modelling provided for

operational and high level closure estimates.

3 4 17 1. Post closure water balance prepared.

2. Water quality of pit lake modelled.

3. Potential to enhance recharge of pit lake by directing landform and surface runoff toward pits.

ii Long term impact of pit on groundwater levels. 2 4 12 1. Groundwater monitoring. 2. Groundwater modelling (50 years to

reach final water level).

2 2 5

iii Geotechnical failure of pit wall with insufficient relaxation zone leading to the abandonment berm being compromised.

5 4 24 1. Geotechnical monitoring during LoA. 2. Control pre-split blasting. 3. Top bench to be reshaped to 33% slope. 4. Location of access berm and trench

beyond the zone of relaxation.

3 3 13 1. Identification of Factor of Safety (FoS) 1.5 relaxation zone through modelling.

iv Death or injury resulting from accessing pit, pit wall rockfall, swimming or recreational use.

5 4 24 1. Pit Wall control - controlled blasting and catchment berms.

2. Install 2 m high berm with 1 m deep trench on perimeter of pit outside relaxation zone.

3 3 13 1. Install signage. 2. Cut access ramps.



RISKS FOR WASTE AT CLOSURE


CLOSURE CRITERIA



ENVIRON-MENTAL


LEGAL & REGULATORY

REPUTATION/SOCIAL/



LEGAL & REGULATORY

REPUTATION/SOCIAL/

COMMUNITY

Con

sequ

ence

Pro

babi

lity

Rat

ing

Con

sequ

ence

Pro

babi

lity

Rat

ing

Con

sequ

ence

Pro

babi

lity

Rat

ing

Con

sequ

ence

Pro

babi

lity

Rat

ing

Con

eque

nce

Pro

babi

lity

Rat

ing

Con

sequ

ence

Pro

babi

lity

Rat

ing

Con

sequ

ence

Pro

babi

lity

Rat

ing

Con

sequ

ence

Pro

babi

lity

Rat

ing

Con

sequ

ence

Pro

babi

lity

Rat

ing

Con

sequ

ence

Pro

babi

lity

Rat

ing

1. Sewage Works

i Groundwater contamination from sewage spill. 2 3 8 1. Groundwater monitoring during LoA. 2 2 5 1. Pipeline integrity testing and maintenance.

ii Soil contamination from sewage spill. 1 2 2 1. Test soil after demolition. 2. Identify contaminated soil. 3. Remove contaminated soil to bioremediation facility.

1 1 1

2. Domestic Waste Site

i Sterlisation of land from waste site footprint. 1 3 4 1. Reshaping of domestic waste site. 2. Topsoil capping of 300 mm. 3. Planting and seeding of trees and grasses. Fertiliser application. 4. Weed control.

1 2 2

3. Hazardous Waste Site

i Surface or groundwater pollution from hazardous waste site. 2 2 5 1. Groundwater monitoring during LoA. 1 1 1

ii Soil contamination from hazardous waste site. 1 1 1 1. Any residual contamination will be removed from site and disposed at appropriate facility.

1 1 1

4. Other Waste

i Disposal of contaminated building rubble onsite. 2 3 8 1. Testing of material for contamination. 2. Only clean material will be disposed on site. 3. Contaminated material will be transported to suitable facility and disposed.

1 2 2

ii Potential resource wastage by not recycling scrap metal. 3 1 6 1. Develop salvage strategy. 2. All scrap metal will be recycled.

1 1 1

iii Recycling of tyre stockpiles does not occur progressively during the LoA 3 3 13 1. Recycle tyres during LoA. 3 2 9 1. Develop disposal strategy if contractor does not meet their commitments.

v Radioactive Density Guages disposed of incorrectly. 4 2 14 1. Record location of radio-active waste. 2. Dispose of material to regonal supplier during closure.

4 1 10


RISKS FOR WASTE AT CLOSURE


CLOSURE CRITERIA



ENVIRON-MENTAL


LEGAL & REGULATORY

REPUTATION/SOCIAL/



LEGAL & REGULATORY

REPUTATION/SOCIAL/

COMMUNITY

Con

sequ

ence

Pro

babi

lity

Rat

ing

Con

sequ

ence

Pro

babi

lity

Rat

ing

Con

sequ

ence

Pro

babi

lity

Rat

ing

Con

sequ

ence

Pro

babi

lity

Rat

ing

Con

eque

nce

Pro

babi

lity

Rat

ing

Con

sequ

ence

Pro

babi

lity

Rat

ing

Con

sequ

ence

Pro

babi

lity

Rat

ing

Con

sequ

ence

Pro

babi

lity

Rat

ing

Con

sequ

ence

Pro

babi

lity

Rat

ing

Con

sequ

ence

Pro

babi

lity

Rat

ing

1. Sewage Works

i Groundwater contamination from sewage spill. 2 3 8 1. Groundwater monitoring during LoA. 2 2 5 1. Pipeline integrity testing and maintenance.

ii Soil contamination from sewage spill. 1 2 2 1. Test soil after demolition. 2. Identify contaminated soil. 3. Remove contaminated soil to bioremediation facility.

1 1 1

2. Domestic Waste Site

i Sterlisation of land from waste site footprint. 1 3 4 1. Reshaping of domestic waste site. 2. Topsoil capping of 300 mm. 3. Planting and seeding of trees and grasses. Fertiliser application. 4. Weed control.

1 2 2

3. Hazardous Waste Site

i Surface or groundwater pollution from hazardous waste site. 2 2 5 1. Groundwater monitoring during LoA. 1 1 1

ii Soil contamination from hazardous waste site. 1 1 1 1. Any residual contamination will be removed from site and disposed at appropriate facility.

1 1 1

4. Other Waste

i Disposal of contaminated building rubble onsite. 2 3 8 1. Testing of material for contamination. 2. Only clean material will be disposed on site. 3. Contaminated material will be transported to suitable facility and disposed.

1 2 2

ii Potential resource wastage by not recycling scrap metal. 3 1 6 1. Develop salvage strategy. 2. All scrap metal will be recycled.

1 1 1

iii Recycling of tyre stockpiles does not occur progressively during the LoA 3 3 13 1. Recycle tyres during LoA. 3 2 9 1. Develop disposal strategy if contractor does not meet their commitments.

v Radioactive Density Guages disposed of incorrectly. 4 2 14 1. Record location of radio-active waste. 2. Dispose of material to regonal supplier during closure.

4 1 10



RISKS FOR SURFACE INFRASTRUCTURE AT CLOSURE


CLOSURE CRITERIA

POST-MITIGATION RISK ASSESSMENT


ENVIRON-MENTAL


LEGAL & REGULATORY

REPUTATION/SOCIAL/



LEGAL & REGULATORY

REPUTATION/SOCIAL/

COMMUNITY

Con

sequ

ence

Pro

babi

lity

Rat

ing

Con

sequ

ence

Pro

babi

lity

Rat

ing

Con

sequ

ence

Pro

babi

lity

Rat

ing

Con

sequ

ence

Pro

babi

lity

Rat

ing

Con

eque

nce

Pro

babi

lity

Rat

ing

Con

sequ

ence

Pro

babi

lity

Rat

ing

Con

sequ

ence

Pro

babi

lity

Rat

ing

Con

sequ

ence

Pro

babi

lity

Rat

ing

Con

sequ

ence

Pro

babi

lity

Rat

ing

Con

sequ

ence

Pro

babi

lity

Rat

ing

1. Processing Plant:

i Resource wastage due to inability to sell or recycle components of the plant. 3 2 9 1. Develop asset disposal strategy. 2. Sell equipment as going concern. 3. Recycle material that cannot be sold as is.

2 2 5

ii Surface or groundwater contamination from processing plant chemicals and hydrocarbons.

3 3 13 1. Surface and groundwater monitoring during LoA.

2. Testing of residual soil material post demolition.

3. Removal of identified contaminated material during closure.

1 2 2

iii Air pollution from dust due to inadequate closure revegetation. 2 4 12 1. Topsoil applied at 300 mm.2. Planting and seeding of indigenous grass,

trees and shrubs. Fertiliser application.3. Control of weeds.

1 2 2

2. Workshops and Offices:

i Resource wastage due to inability to sell or recycle components of the workshop and offices.

3 2 9 1. Develop asset disposal strategy.2. Sell equipment as going concern.3. Recycle material that cannot be sold as is.

2 2 5

ii Surface or groundwater contamination from workshop and office materials. 3 3 13 1. Surface and groundwater monitoring during LoA.

2. Testing of material post demolition.3. Removal of identified contaminated

material during closure.

1 2 2

iii Air pollution from dust due to inadequate revegetation. 2 4 12 1. Topsoil applied at 300 mm.2. Planting and seeding of indigenous grass,


1 2 2

3. Electrical Sub-stations, Fuelling Stations and Explosives Magazines:

i Resource wastage due to inability to sell or recycle components of the electrical, fuelling or explosives magazine infrastructure.


2 1 3

ii Ineffective disposal of hazardous wastes from electrical sub-stations. 3 3 13 1. Identify locations of PCB’s.2. Dispose of PCB’s using appropriate

methods at an offsite location.

2 1 3

iii Surface or groundwater contamination from hydrocarbon spills at fuelling stations.

3 3 13 1. Regular leak detection.2. Testing of soil material for contamination.3. Identified contaminated material will be

processed through bioremediation plant.

2 1 3

iv Surface or groundwater contamination at explosives magazine. 2 3 8 1. Surface and groundwater monitoring during LoA.



1 2 3

4. Mine housing, accommodation and service infrastructure in town:

i Resource wastage due to inability to sell or recycle components of the town infrastructure.

4 4 21 1. Develop asset disposal strategy.2. Sell infrastructure as going concern.3. Lease or donate buildings to third parties.4. Demolish other structures and recycle

material.

3 3 13 1. Spread sale of houses out over the 20 year maintenance and monitoring phase to avoid market saturation.

ii Responsibility for service infrastructure is not taken over by municipality. 3 4 17 1. Municipality owns assets with site paying for operational costs.

3 4 17 1. Engage municipality in transition to operating these assets.




CLOSURE CRITERIA



ENVIRON-MENTAL


LEGAL & REGULATORY

REPUTATION/SOCIAL/



LEGAL & REGULATORY

REPUTATION/SOCIAL/

COMMUNITY

Con

sequ

ence

Pro

babi

lity

Rat

ing

Con

sequ

ence

Pro

babi

lity

Rat

ing

Con

sequ

ence

Pro

babi

lity

Rat

ing

Con

sequ

ence

Pro

babi

lity

Rat

ing

Con

eque

nce

Pro

babi

lity

Rat

ing

Con

sequ

ence

Pro

babi

lity

Rat

ing

Con

sequ

ence

Pro

babi

lity

Rat

ing

Con

sequ

ence

Pro

babi

lity

Rat

ing

Con

sequ

ence

Pro

babi

lity

Rat

ing

Con

sequ

ence

Pro

babi

lity

Rat

ing

1. Processing Plant:

i Resource wastage due to inability to sell or recycle components of the plant. 3 2 9 1. Develop asset disposal strategy. 2. Sell equipment as going concern. 3. Recycle material that cannot be sold as is.

2 2 5

ii Surface or groundwater contamination from processing plant chemicals and hydrocarbons.

3 3 13 1. Surface and groundwater monitoring during LoA.

2. Testing of residual soil material post demolition.

3. Removal of identified contaminated material during closure.

1 2 2

iii Air pollution from dust due to inadequate closure revegetation. 2 4 12 1. Topsoil applied at 300 mm.2. Planting and seeding of indigenous grass,


1 2 2

2. Workshops and Offices:

i Resource wastage due to inability to sell or recycle components of the workshop and offices.


2 2 5

ii Surface or groundwater contamination from workshop and office materials. 3 3 13 1. Surface and groundwater monitoring during LoA.



1 2 2

iii Air pollution from dust due to inadequate revegetation. 2 4 12 1. Topsoil applied at 300 mm.2. Planting and seeding of indigenous grass,


1 2 2

3. Electrical Sub-stations, Fuelling Stations and Explosives Magazines:

i Resource wastage due to inability to sell or recycle components of the electrical, fuelling or explosives magazine infrastructure.


2 1 3

ii Ineffective disposal of hazardous wastes from electrical sub-stations. 3 3 13 1. Identify locations of PCB’s.2. Dispose of PCB’s using appropriate

methods at an offsite location.

2 1 3

iii Surface or groundwater contamination from hydrocarbon spills at fuelling stations.

3 3 13 1. Regular leak detection.2. Testing of soil material for contamination.3. Identified contaminated material will be

processed through bioremediation plant.

2 1 3

iv Surface or groundwater contamination at explosives magazine. 2 3 8 1. Surface and groundwater monitoring during LoA.



1 2 3

4. Mine housing, accommodation and service infrastructure in town:

i Resource wastage due to inability to sell or recycle components of the town infrastructure.

4 4 21 1. Develop asset disposal strategy.2. Sell infrastructure as going concern.3. Lease or donate buildings to third parties.4. Demolish other structures and recycle

material.

3 3 13 1. Spread sale of houses out over the 20 year maintenance and monitoring phase to avoid market saturation.

ii Responsibility for service infrastructure is not taken over by municipality. 3 4 17 1. Municipality owns assets with site paying for operational costs.

3 4 17 1. Engage municipality in transition to operating these assets.





CLOSURE CRITERIA



ENVIRON-MENTAL


LEGAL & REGULATORY

REPUTATION/SOCIAL/



LEGAL & REGULATORY

REPUTATION/SOCIAL/

COMMUNITY

Con

sequ

ence

Pro

babi

lity

Rat

ing

Con

sequ

ence

Pro

babi

lity

Rat

ing

Con

sequ

ence

Pro

babi

lity

Rat

ing

Con

sequ

ence

Pro

babi

lity

Rat

ing

Con

eque

nce

Pro

babi

lity

Rat

ing

Con

sequ

ence

Pro

babi

lity

Rat

ing

Con

sequ

ence

Pro

babi

lity

Rat

ing

Con

sequ

ence

Pro

babi

lity

Rat

ing

Con

sequ

ence

Pro

babi

lity

Rat

ing

Con

sequ

ence

Pro

babi

lity

Rat

ing

5. Roads, Railways, Powerlines, Telephone lines, Pipelines and Fences:

i Compaction of roads not mitigated leading to poor establishment of vegetation.

4 4 21 1. Identify which roads are to remain and those to be removed.

2. Remove bitumen if necessary.3. Deep rip compacted surfaces (>1 m).4. Topsoil applied at 150 mm.5. Planting and seeding of indigenous grass,


2 2 5

ii Decommissioning and removal of railway system costs more than current liability allowance.

4 4 21 1. Currently removal of rail and recycle for first 11 km.

2. Removal of ballast.3. Shape and revegetate as per roads.

3 3 13 1. Confirm that responsibility for decomissioning will be transferred to landowners beyond the Min elease boundary.

2. Ensure that reshaping costs are included in the closure costing.

ii Resource wastage due to inability to sell or recycle components of railway, telephone, pipeline and powerline infrastructure.

3 2 9 1. Develop asset disposal strategy.2. Sell equipment as going concern.3. Recycle material that cannot be sold

as is.

2 1 3

iii Inability to protect and make secure offsite infrastructure assets in the closure phase.

4 4 21 1. None in current plan. 4 4 21 1. Include off-site security and safety strategy within mine closure plan and associated costing.

RISKS FOR BIO-PHYSICAL ASPECTS AT CLOSURE


CLOSURE CRITERIA



ENVIRON-MENTAL


LEGAL & REGULATORY

REPUTATION/SOCIAL/



LEGAL & REGULATORY

REPUTATION/SOCIAL/

COMMUNITY

Con

sequ

ence

Pro

babi

lity

Rat

ing

Con

sequ

ence

Pro

babi

lity

Rat

ing

Con

sequ

ence

Pro

babi

lity

Rat

ing

Con

sequ

ence

Pro

babi

lity

Rat

ing

Con

eque

nce

Pro

babi

lity

Rat

ing

Con

sequ

ence

Pro

babi

lity

Rat

ing

Con

sequ

ence

Pro

babi

lity

Rat

ing

Con

sequ

ence

Pro

babi

lity

Rat

ing

Con

sequ

ence

Pro

babi

lity

Rat

ing

Con

sequ

ence

Pro

babi

lity

Rat

ing

1. Biodiversity/Fauna/Flora/Protected Habitats/Ecosystems

i Loss of ecosystem composition, structure and/or function due to poor rehabilitation standards.

3 3 13 3 3 13 1. Reshaping of areas to blend in with surrounding topography.

2. Topsoil applied at 300 mm.3. Seeding and planting of native grasses,

trees and shrubs. Fertiliser application.4. Control of weeds.5. Monitoring and maintenance to return

grazing capacity.

2 2 5 3 2 9

ii Loss of species or ecosystems through clearing. 3 4 17 1. Voluntary offsets areas identified and in place.

2. Biodiversity action plans in place and being implemented.

2 2 5

iii Inadequate management (e.g. fire, weeds, erosion, grazing) of rehabilitation leads to failure.

3 3 13 1. Develop a rehabilitation strategy incuding a vegetation management plan.

2. Fire and weed management plans within biodiversity action plan.

3. Implement maintenance as required.4. Implement management plan.

2 2 5 1. Monitor rehabilitated areas against success criteria once developed.

iv Artisinal miners enter site and inadvertently destroy rehabilitated areas. 2 3 8 1. Maintain security during closure phase.2. Incorporate rehabilitated areas into game

farming enterprises with associated fencing and security.

1 2 2

v Loss or damage of archaeological and heritage areas during closure. 2 3 8 1. Implement heritage resourses management plan.

2 2 5




CLOSURE CRITERIA



ENVIRON-MENTAL


LEGAL & REGULATORY

REPUTATION/SOCIAL/



LEGAL & REGULATORY

REPUTATION/SOCIAL/

COMMUNITY

Con

sequ

ence

Pro

babi

lity

Rat

ing

Con

sequ

ence

Pro

babi

lity

Rat

ing

Con

sequ

ence

Pro

babi

lity

Rat

ing

Con

sequ

ence

Pro

babi

lity

Rat

ing

Con

eque

nce

Pro

babi

lity

Rat

ing

Con

sequ

ence

Pro

babi

lity

Rat

ing

Con

sequ

ence

Pro

babi

lity

Rat

ing

Con

sequ

ence

Pro

babi

lity

Rat

ing

Con

sequ

ence

Pro

babi

lity

Rat

ing

Con

sequ

ence

Pro

babi

lity

Rat

ing

5. Roads, Railways, Powerlines, Telephone lines, Pipelines and Fences:

i Compaction of roads not mitigated leading to poor establishment of vegetation.

4 4 21 1. Identify which roads are to remain and those to be removed.

2. Remove bitumen if necessary.3. Deep rip compacted surfaces (>1 m).4. Topsoil applied at 150 mm.5. Planting and seeding of indigenous grass,


2 2 5

ii Decommissioning and removal of railway system costs more than current liability allowance.

4 4 21 1. Currently removal of rail and recycle for first 11 km.

2. Removal of ballast.3. Shape and revegetate as per roads.

3 3 13 1. Confirm that responsibility for decomissioning will be transferred to landowners beyond the Min elease boundary.

2. Ensure that reshaping costs are included in the closure costing.

ii Resource wastage due to inability to sell or recycle components of railway, telephone, pipeline and powerline infrastructure.

3 2 9 1. Develop asset disposal strategy.2. Sell equipment as going concern.3. Recycle material that cannot be sold

as is.

2 1 3

iii Inability to protect and make secure offsite infrastructure assets in the closure phase.

4 4 21 1. None in current plan. 4 4 21 1. Include off-site security and safety strategy within mine closure plan and associated costing.



CLOSURE CRITERIA



ENVIRON-MENTAL


LEGAL & REGULATORY

REPUTATION/SOCIAL/



LEGAL & REGULATORY

REPUTATION/SOCIAL/

COMMUNITY

Con

sequ

ence

Pro

babi

lity

Rat

ing

Con

sequ

ence

Pro

babi

lity

Rat

ing

Con

sequ

ence

Pro

babi

lity

Rat

ing

Con

sequ

ence

Pro

babi

lity

Rat

ing

Con

eque

nce

Pro

babi

lity

Rat

ing

Con

sequ

ence

Pro

babi

lity

Rat

ing

Con

sequ

ence

Pro

babi

lity

Rat

ing

Con

sequ

ence

Pro

babi

lity

Rat

ing

Con

sequ

ence

Pro

babi

lity

Rat

ing

Con

sequ

ence

Pro

babi

lity

Rat

ing

1. Biodiversity/Fauna/Flora/Protected Habitats/Ecosystems

i Loss of ecosystem composition, structure and/or function due to poor rehabilitation standards.

3 3 13 3 3 13 1. Reshaping of areas to blend in with surrounding topography.

2. Topsoil applied at 300 mm.3. Seeding and planting of native grasses,

trees and shrubs. Fertiliser application.4. Control of weeds.5. Monitoring and maintenance to return

grazing capacity.

2 2 5 3 2 9

ii Loss of species or ecosystems through clearing. 3 4 17 1. Voluntary offsets areas identified and in place.

2. Biodiversity action plans in place and being implemented.

2 2 5

iii Inadequate management (e.g. fire, weeds, erosion, grazing) of rehabilitation leads to failure.

3 3 13 1. Develop a rehabilitation strategy incuding a vegetation management plan.

2. Fire and weed management plans within biodiversity action plan.

3. Implement maintenance as required.4. Implement management plan.

2 2 5 1. Monitor rehabilitated areas against success criteria once developed.

iv Artisinal miners enter site and inadvertently destroy rehabilitated areas. 2 3 8 1. Maintain security during closure phase.2. Incorporate rehabilitated areas into game

farming enterprises with associated fencing and security.

1 2 2

v Loss or damage of archaeological and heritage areas during closure. 2 3 8 1. Implement heritage resourses management plan.

2 2 5





CLOSURE CRITERIA



ENVIRON-MENTAL


LEGAL & REGULATORY

REPUTATION/SOCIAL/



LEGAL & REGULATORY

REPUTATION/SOCIAL/

COMMUNITY

Con

sequ

ence

Pro

babi

lity

Rat

ing

Con

sequ

ence

Pro

babi

lity

Rat

ing

Con

sequ

ence

Pro

babi

lity

Rat

ing

Con

sequ

ence

Pro

babi

lity

Rat

ing

Con

eque

nce

Pro

babi

lity

Rat

ing

Con

sequ

ence

Pro

babi

lity

Rat

ing

Con

sequ

ence

Pro

babi

lity

Rat

ing

Con

sequ

ence

Pro

babi

lity

Rat

ing

Con

sequ

ence

Pro

babi

lity

Rat

ing

Con

sequ

ence

Pro

babi

lity

Rat

ing

2. Groundwater

i Calcification of groundwater aquifer leads to reduced flow and availability of water to benificial users.

2 4 12 1. Install necessary monitoring. 2 3 8 1. Develop and run model to estimate calcification risk.

ii Permanent reductions in groundwater levels (close to pits). 2 5 16 1. Install necessary monitoring.2. Modle final pit water level.

2 5 16 1. Consider diversion of local run-off into pits.

iii Development of sinkholes (surface subsidence) due to dewatering of dolomite aquifers.

4 3 18 1. Dolomite (subsidence) risk management plan implemented.

2. Surface subsidence management procedure.

3. Areas are identified, isolated and backfilled.

3 2 9

iv Change in groundwater flow direction. 2 3 9 1. Install necessary monitoring.2. Model final pit water level.

2 2 5

3. Surface water

i Fragmentation of drainage lines impacts ecological functioning. 4 4 21 1. Temporary diversion structures are removed and origingal flowpath reinstated.

2. Permanent diversion structures engineered for 100 year ARI.

3. Quarterly flora and fauna monitoring in undisturbed areas to assess impacts.

3 2 9

4. Drought and Fire

i Drought leads to poor plant establishment and development of rehabilitation. 3 4 17 1. Water rehabilitated areas.2. Use drought tolerant species in the seed

mix.

2 3 8 1. Water retaining strategy to enhace rehabilitation, deep contour ripping with winged tynes, water bunding and/or water retention.

ii Fire leads to rehabilitation failure with poor regeneration. 3 3 13 1. Ensure that species mixes contain fire adapted and fire resistant species.

2. Continue to implement fire management plan in closure phase.

3 Retrain closure staff as fire fighting crew.

2 2 5 1. Fire control plan in place around rehabilitated areas to ensure wildfires do not enter rehabiiliitation too early.

5. Soil, land capability, land use

i Lack of topsoil leads to poor rehabilitation quality. 2 5 16 1. Directly place topsoil where possible.2. Ensure topsoil stockpiles are constructed

to standard and protected.3. Optimise utilisation of topsoil.4. Use thinner topsoil coverage (150 mm)

on the top of dumps.5. Use compost or cocoflex as a topsoil

substitute.

2 2 5

ii Poor topsoil stockpile management leads to lower availability and poor rehabilitation quality.

2 3 8 1. Directly place topsoil where possible.2. Ensure topsoil stockpiles are constructed

to standard and protected.3. Optimise utilisation of topsoil.

1 2 2

iii Proliferation of weed species in rehabilitated areas and surrounding vegetation.

3 3 13 1. Weed management is included in the Biodiversity Action Plan (BAP).

2. Monitor rehabilitated areas regularly and apply adaptive management.

3. Implement defined actions where weed proliferation is identifed.

2 2 5

iv Loss of agricultural land use from tailings dam footprint. 3 5 20 1. Rehabilitation processes for different domains with grazing as the primary land-use.

3 2 9




CLOSURE CRITERIA



ENVIRON-MENTAL


LEGAL & REGULATORY

REPUTATION/SOCIAL/



LEGAL & REGULATORY

REPUTATION/SOCIAL/

COMMUNITY

Con

sequ

ence

Pro

babi

lity

Rat

ing

Con

sequ

ence

Pro

babi

lity

Rat

ing

Con

sequ

ence

Pro

babi

lity

Rat

ing

Con

sequ

ence

Pro

babi

lity

Rat

ing

Con

eque

nce

Pro

babi

lity

Rat

ing

Con

sequ

ence

Pro

babi

lity

Rat

ing

Con

sequ

ence

Pro

babi

lity

Rat

ing

Con

sequ

ence

Pro

babi

lity

Rat

ing

Con

sequ

ence

Pro

babi

lity

Rat

ing

Con

sequ

ence

Pro

babi

lity

Rat

ing

2. Groundwater

i Calcification of groundwater aquifer leads to reduced flow and availability of water to benificial users.

2 4 12 1. Install necessary monitoring. 2 3 8 1. Develop and run model to estimate calcification risk.

ii Permanent reductions in groundwater levels (close to pits). 2 5 16 1. Install necessary monitoring.2. Modle final pit water level.

2 5 16 1. Consider diversion of local run-off into pits.

iii Development of sinkholes (surface subsidence) due to dewatering of dolomite aquifers.

4 3 18 1. Dolomite (subsidence) risk management plan implemented.

2. Surface subsidence management procedure.

3. Areas are identified, isolated and backfilled.

3 2 9

iv Change in groundwater flow direction. 2 3 9 1. Install necessary monitoring.2. Model final pit water level.

2 2 5

3. Surface water

i Fragmentation of drainage lines impacts ecological functioning. 4 4 21 1. Temporary diversion structures are removed and origingal flowpath reinstated.

2. Permanent diversion structures engineered for 100 year ARI.

3. Quarterly flora and fauna monitoring in undisturbed areas to assess impacts.

3 2 9

4. Drought and Fire

i Drought leads to poor plant establishment and development of rehabilitation. 3 4 17 1. Water rehabilitated areas.2. Use drought tolerant species in the seed

mix.

2 3 8 1. Water retaining strategy to enhace rehabilitation, deep contour ripping with winged tynes, water bunding and/or water retention.

ii Fire leads to rehabilitation failure with poor regeneration. 3 3 13 1. Ensure that species mixes contain fire adapted and fire resistant species.

2. Continue to implement fire management plan in closure phase.

3 Retrain closure staff as fire fighting crew.

2 2 5 1. Fire control plan in place around rehabilitated areas to ensure wildfires do not enter rehabiiliitation too early.

5. Soil, land capability, land use

i Lack of topsoil leads to poor rehabilitation quality. 2 5 16 1. Directly place topsoil where possible.2. Ensure topsoil stockpiles are constructed

to standard and protected.3. Optimise utilisation of topsoil.4. Use thinner topsoil coverage (150 mm)

on the top of dumps.5. Use compost or cocoflex as a topsoil

substitute.

2 2 5

ii Poor topsoil stockpile management leads to lower availability and poor rehabilitation quality.

2 3 8 1. Directly place topsoil where possible.2. Ensure topsoil stockpiles are constructed

to standard and protected.3. Optimise utilisation of topsoil.

1 2 2

iii Proliferation of weed species in rehabilitated areas and surrounding vegetation.

3 3 13 1. Weed management is included in the Biodiversity Action Plan (BAP).

2. Monitor rehabilitated areas regularly and apply adaptive management.

3. Implement defined actions where weed proliferation is identifed.

2 2 5

iv Loss of agricultural land use from tailings dam footprint. 3 5 20 1. Rehabilitation processes for different domains with grazing as the primary land-use.

3 2 9





CLOSURE CRITERIA



ENVIRON-MENTAL


LEGAL & REGULATORY

REPUTATION/SOCIAL/



LEGAL & REGULATORY

REPUTATION/SOCIAL/

COMMUNITY

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6. Topography/visual

i Decrease in landscape character due to poor landform design to blend in with surrounding topography

3 3 13 1. Reshape WRD’s to 18 degrees.2. Revegetation of WRD’s.3. Monitoring and maintenance.

2 1 3

RISK ISSUES FOR SOCIO-ECONOMIC ASPECTS AT CLOSURE


CLOSURE CRITERIA



ENVIRON-MENTAL


LEGAL & REGULATORY

REPUTATION/SOCIAL/



LEGAL & REGULATORY

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1. Economic

i Under estimation of closure liability. 4 3 18 1. Regular updates to closure costing rates. 3 2 9

ii Under estimation of preliminary and general costs. 4 4 21 1. The site uses 25% rate for P&G’s. 2 2 5

iii Increasing closure cost over time due to inadequate progressive rehabilitation.

4 3 18 1. Implement rehabilitation strategy. 2. Undertake rehabilitation activities using

own equipment.3. Bank guarantee provided to regulator.

3 3 13 1. Development of 10 year rolling rehabilitation plans and associated costing as required under new closure regulations.

iv Inadequate monitoring delays lease relinquishment. 2 4 12 1. Implement existing monitoring programme.

2 3 8 1. Develop closure monitoring programme aligned with success criteria.




CLOSURE CRITERIA



ENVIRON-MENTAL


LEGAL & REGULATORY

REPUTATION/SOCIAL/



LEGAL & REGULATORY

REPUTATION/SOCIAL/

COMMUNITY

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6. Topography/visual

i Decrease in landscape character due to poor landform design to blend in with surrounding topography

3 3 13 1. Reshape WRD’s to 18 degrees.2. Revegetation of WRD’s.3. Monitoring and maintenance.

2 1 3

RISK ISSUES FOR SOCIO-ECONOMIC ASPECTS AT CLOSURE


CLOSURE CRITERIA



ENVIRON-MENTAL


LEGAL & REGULATORY

REPUTATION/SOCIAL/



LEGAL & REGULATORY

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1. Economic

i Under estimation of closure liability. 4 3 18 1. Regular updates to closure costing rates. 3 2 9

ii Under estimation of preliminary and general costs. 4 4 21 1. The site uses 25% rate for P&G’s. 2 2 5

iii Increasing closure cost over time due to inadequate progressive rehabilitation.

4 3 18 1. Implement rehabilitation strategy. 2. Undertake rehabilitation activities using

own equipment.3. Bank guarantee provided to regulator.

3 3 13 1. Development of 10 year rolling rehabilitation plans and associated costing as required under new closure regulations.

iv Inadequate monitoring delays lease relinquishment. 2 4 12 1. Implement existing monitoring programme.

2 3 8 1. Develop closure monitoring programme aligned with success criteria.


PROJECTS RISK MATRIX CONSEQUENCE (Where an event has more than one ‘Consequence Type’, choose the ‘Consequence Type’ with the highest rating) CONSEQUENCE (Where an event has more than one ‘Consequence Type’, choose the ‘Consequence Type’ with the highest rating)

Consequence type 1 – Insignificant 2 – Minor 3 – Moderate 4 – High 5 – Major

Schedule. Less than 1% impact on overall project timeline. May result in overall project timeline overrun equal to or more than 1% and less than 3%.

May result in overall project timeline overrun of equal to or more than 3% and less than 10%.


May result in overall project timeline overrun of 30% or more.

Cost. Less than 1% impact on the overall budget of the project. May result in overall project budget overrun equal to or more than 1% and less than 3%.

May result in overall project budget overrun of equal to or more than 3% and less than 10%.


May result in overall project budget overrun of 30% or more.

Quality and Technical Integrity.

No significant impact on quality of deliverables or effect on production.

Quality issues that can be addressed prior to handover or could affect production by more than 1% and less than 3%.

Quality issues that can be addressed during ramp-up or could affect production by more than 3% and less than 10%.

Quality issues that require significant intervention to maintain performance or could affect production by more than 10% and less than 30%.

Quality issues that require significant intervention to achieve performance or could affect production by 30% or more.

Safety. First aid case. Medical treatment case. Lost time injury. Permanent disability or single fatality. Numerous permanent disabilities or multiple fatalities.

Occupational Health. Exposure to health hazard resulting in temporary discomfort. Exposure to health hazard resulting in symptoms requiring medical intervention and full recovery (no lost time).

Exposure to health hazards/agents (over the OEL) resulting in reversible impact on health (with lost time) or permanent change with no disability or loss of quality of life.

Exposure to health hazards/agents (significantly over the OEL) resulting in irreversible impact on health with loss of quality of life or single fatality.

Exposure to health hazards/agents (significantly over the OEL) resulting in irreversible impact on health with loss of quality of life of a numerous group/population or multiple fatalities.

Environment. Lasting days or less; affecting small area (metres); receiving environment highly altered with no sensitive habitats and no biodiversity value (e.g. urban /industrial areas).

Lasting weeks; affecting limited area (hundreds of metres); receiving environment altered with little natural habitat and low biodiversity value.

Lasting months; affected extended area (kiLoAetres); receiving environment comprising largely natural habitat and moderate biodiversity value.

Lasting years; affecting area on sub-basin scale; receiving environment classified as having sensitive natural habitat with high biodiversity value.

Permanent impact; affecting area on a whole basin or regional scale; receiving environment classified as highly sensitive natural habitat with very high biodiversity value.

Legal and Regulatory. Technical non-compliance. No warning received; no regulatory reporting required.

Breach of regulatory requirements; report/involvement of authority. Attracts administrative fine.

Minor breach of law; report/investigation by authority. Attracts compensation/penalties/enforcement action.

Breach of the law; may attract criminal prosecution, penalties/enforcement action. Individual licence temporarily revoked.

Significant breach of the law. Individual or company law suits; permit to operate substantially modified or withdrawn.

Social/Communities. Minor disturbance of culture/social structures. Some impacts on local population, mostly repairable. Single stakeholder complaint in reporting period.

On going social issues. Isolated complaints from community members/stakeholders.

Significant social impacts. Organised community protests threatening continuity of operations.

Major widespread social impacts. Community reaction affecting business continuity. “License to operate” under jeopardy.

Reputation. Minor impact; awareness/concern from specific individuals. Limited impact; concern/complaints from certain groups/organisations (e.g. non-governmental organisations (NGOs) period.

Local impact; public concern/adverse publicity localised within neighbouring communities.

Suspected reputational damage; local/regional public concern and reactions.

Noticeable reputational damage; national/international public attention and repercussions.

PROBABILITY RISK LEVEL RISK LEVEL

5 – Almost Certain >90%.

90% and higher likelihood of occurring.

11 (Medium)

16 (Significant)

20 (Significant)

23 (High)

25 (High)

4 – Likely 30%-90%.

Between 30% and less than 90% likelihood of occurring.

7 (Medium)

12 (Medium)

17 (Significant)

21 (High)

24 (High)

3 – Possible 10%-30%.


4 (Low)

8 (Medium)

13 (Significant)

18 (Significant)

22 (High)

2 – Unlikely 3%-10%.


2 (Low)

5 (Low)

9 (Medium)

14 (Significant)

19 (Significant)

1 – Rare <3%.

Less than 3% likelihood of occurring.

1 (Low)

3 (Low)

6 (Medium)

10 (Medium)

15 (Significant)

Risk Rating Risk Level Guidelines for Risk Matrix

21 to 25 High A high risk exists that management’s objectives may not be achieved. Appropriate mitigation strategy to be devised immediately.

13 to 20 Significant A significant risk exists that management’s objectives may not be achieved. Appropriate mitigation strategy to be devised as soon as possible.

6 to 12 Medium A moderate risk exists that management’s objectives may not be achieved. Appropriate mitigation strategy to be devised as part of the normal management process.

1 to 5 Low A low risk exists that management’s objectives may not be achieved. Monitor risk, no further mitigation required.

5 X 5 MATRIX NEW


PROJECTS RISK MATRIX CONSEQUENCE (Where an event has more than one ‘Consequence Type’, choose the ‘Consequence Type’ with the highest rating) CONSEQUENCE (Where an event has more than one ‘Consequence Type’, choose the ‘Consequence Type’ with the highest rating)

Consequence type 1 – Insignificant 2 – Minor 3 – Moderate 4 – High 5 – Major

Schedule. Less than 1% impact on overall project timeline. May result in overall project timeline overrun equal to or more than 1% and less than 3%.



May result in overall project timeline overrun of 30% or more.

Cost. Less than 1% impact on the overall budget of the project. May result in overall project budget overrun equal to or more than 1% and less than 3%.



May result in overall project budget overrun of 30% or more.

Quality and Technical Integrity.

No significant impact on quality of deliverables or effect on production.

Quality issues that can be addressed prior to handover or could affect production by more than 1% and less than 3%.

Quality issues that can be addressed during ramp-up or could affect production by more than 3% and less than 10%.

Quality issues that require significant intervention to maintain performance or could affect production by more than 10% and less than 30%.

Quality issues that require significant intervention to achieve performance or could affect production by 30% or more.

Safety. First aid case. Medical treatment case. Lost time injury. Permanent disability or single fatality. Numerous permanent disabilities or multiple fatalities.

Occupational Health. Exposure to health hazard resulting in temporary discomfort. Exposure to health hazard resulting in symptoms requiring medical intervention and full recovery (no lost time).

Exposure to health hazards/agents (over the OEL) resulting in reversible impact on health (with lost time) or permanent change with no disability or loss of quality of life.

Exposure to health hazards/agents (significantly over the OEL) resulting in irreversible impact on health with loss of quality of life or single fatality.

Exposure to health hazards/agents (significantly over the OEL) resulting in irreversible impact on health with loss of quality of life of a numerous group/population or multiple fatalities.

Environment. Lasting days or less; affecting small area (metres); receiving environment highly altered with no sensitive habitats and no biodiversity value (e.g. urban /industrial areas).

Lasting weeks; affecting limited area (hundreds of metres); receiving environment altered with little natural habitat and low biodiversity value.

Lasting months; affected extended area (kiLoAetres); receiving environment comprising largely natural habitat and moderate biodiversity value.

Lasting years; affecting area on sub-basin scale; receiving environment classified as having sensitive natural habitat with high biodiversity value.

Permanent impact; affecting area on a whole basin or regional scale; receiving environment classified as highly sensitive natural habitat with very high biodiversity value.

Legal and Regulatory. Technical non-compliance. No warning received; no regulatory reporting required.

Breach of regulatory requirements; report/involvement of authority. Attracts administrative fine.

Minor breach of law; report/investigation by authority. Attracts compensation/penalties/enforcement action.

Breach of the law; may attract criminal prosecution, penalties/enforcement action. Individual licence temporarily revoked.

Significant breach of the law. Individual or company law suits; permit to operate substantially modified or withdrawn.

Social/Communities. Minor disturbance of culture/social structures. Some impacts on local population, mostly repairable. Single stakeholder complaint in reporting period.

On going social issues. Isolated complaints from community members/stakeholders.

Significant social impacts. Organised community protests threatening continuity of operations.

Major widespread social impacts. Community reaction affecting business continuity. “License to operate” under jeopardy.

Reputation. Minor impact; awareness/concern from specific individuals. Limited impact; concern/complaints from certain groups/organisations (e.g. non-governmental organisations (NGOs) period.

Local impact; public concern/adverse publicity localised within neighbouring communities.

Suspected reputational damage; local/regional public concern and reactions.

Noticeable reputational damage; national/international public attention and repercussions.

PROBABILITY RISK LEVEL RISK LEVEL

5 – Almost Certain >90%.

90% and higher likelihood of occurring.

11 (Medium)

16 (Significant)

20 (Significant)

23 (High)

25 (High)

4 – Likely 30%-90%.


7 (Medium)

12 (Medium)

17 (Significant)

21 (High)

24 (High)

3 – Possible 10%-30%.


4 (Low)

8 (Medium)

13 (Significant)

18 (Significant)

22 (High)

2 – Unlikely 3%-10%.


2 (Low)

5 (Low)

9 (Medium)

14 (Significant)

19 (Significant)

1 – Rare <3%.

Less than 3% likelihood of occurring.

1 (Low)

3 (Low)

6 (Medium)

10 (Medium)

15 (Significant)

Risk Rating Risk Level Guidelines for Risk Matrix

21 to 25 High A high risk exists that management’s objectives may not be achieved. Appropriate mitigation strategy to be devised immediately.

13 to 20 Significant A significant risk exists that management’s objectives may not be achieved. Appropriate mitigation strategy to be devised as soon as possible.

6 to 12 Medium A moderate risk exists that management’s objectives may not be achieved. Appropriate mitigation strategy to be devised as part of the normal management process.

1 to 5 Low A low risk exists that management’s objectives may not be achieved. Monitor risk, no further mitigation required.


EXAMPLE 4: CLOSURE BENCHMARKING REVIEW


The main conveyor line from the stockpiles at the Saldanha Bay loading facility, South Africa.


INTRODUCTION

Closure criteria are identified through the risk assessment and gap analysis processes, to support the closure vision and objectives. Existing closure criteria may not always be the most suitable or may not reduce residual risk to an acceptable level. Undertaking a benchmarking exercise is a practical way of exploring alternative closure criteria that may be more effective in reducing residual risk. Ultimately, benchmarking seeks to reduce the closure risk, improve the closure outcome and realise financial improvements.

METHODOLOGY

A good way of identifying closure criteria that may benefit from benchmarking is to look at the risk assessment for residual risks that are significant or high. These should be listed and then discussed further with internal stakeholders to narrow down the list based on-site knowledge (Table 1). Three to five areas should be chosen on this basis

for further investigation through benchmarking. For each benchmarking topic, a team comprising a technical expert and a site person with relevant expertise should be identified. A high level search of existing studies from similar mining scenarios should then be conducted at an international, national, regional and local scale. These are summarised in a spreadsheet and then discussed further with the broader benchmarking team. A recommendation is then made for identified closure criteria that may be seen as being more effective than what is currently being proposed (Table 2). In some cases, a decision can be made immediately to substitute the existing criteria with the closure criteria identified in the benchmarking exercise. In these cases, it is important that the closure liability is updated to reflect the cost of the substituted closure criteria. More commonly, closure criteria with potential application will be identified that require further investigation as to their suitability at the particular operation. In these cases, the required studies should be identified and added to the Master Action Plan (MAP).

Table 1: Example of risk areas identified from the risk assessment that may be suitable for the benchmarking exercise. Those that were chosen after discussion with site personnel are in bold.

Risk area Comment

Viability of township. Consolidate with social transitioning.

Social transitioning.

FRD erosion risks.

Geotechnical pit failure. Consolidate with social transitioning.

Regulated waste disposal. Exclude as treatment options known.

Mining infrastructure re-use. Consolidate with social transitioning.

Groundwater depression and contamination.

Alternative growth mediums with topsoil deficit. Consolidate with Landform design and material charaterisation.

Hydrocarbon contamination treatment. Exclude as treatment options are known.

Capillary rise of salts in rehabilitation. Consolidate with Landform design and material charaterisation.

Rehabiitation not meeting land-use. Consolidate with Landform design and material charaterisation.

Landform design and material characterisation.



SITE ID LOCALITY INFORMATION

Number Country Region Operation Source of Information 1. Social Transitioning Comment Recommendation

1 SA Western Cape

Namaqualand 1) “Living Edge of Africa (LEAP)” info to be sources from De Beers (including Pre-Feasibility Study (PFS)).

2) Info from William McDonald.

3) https://en.wikipedia.org/wiki/Kleinzee.

4) https://mg.co.za/article/2011-11-18-diamond-mines-are-not-forever/.

5) siteresources.worldbank.org/INTOGMC/.../3-Post-Mining_Alliance-22Apr09.pdf.

Koingnaas and Kleinzee were proclaimed in around 2010.

Learnings on proclamation and selling of property, as well as partnerships with international NGOs and PFS study.

1. Develop town transformation and transition strategy.

2. Create a Future Forum to engage external stakeholders.

3. Investigate options for re-use of mining infrastructure post closure.

4. Investigate accommodation options in the game park.

5. Evaluate the viability of the airport as part of the game park and future tourism.

2 SA Northern Cape

Lime Acres 1) www.greenkalahari.co.za/index.php/lime-acres.

2) https://en.wikipedia.org/wiki/Lime_Acres.

Was established as a formal town in the early 1930, linked to Lime mining, and later diamond mining, which is still ongoing.

Maybe not really relevant to the current mining town.

3 Namibia West Coast

Namdeb 1) Oranjemund town transformation data (lots).

2) Freedthinkers projects and info.

3) www.travelnewsnamibia.com/destinations/facts-on-the-strange-town-of-oranjemund.

4) https://en.wikipedia.org/wiki/Oranjemund.

5) https://www.youtube.com/watch?v=IV0l3AMjwSc.

6) https://www.industryabout.com/.../diamond-mining/38589-oranjemund-diamond-min.

Original mine town (10 000 people – 2017), that was procalimed in 2011 and now town tranformation has been going on for the part three to five years, but progress is slow.

Very applicable to the mining town.

4 Canada North America (Ontario)

Elliot Lake 1) Retrospect findings (Report done by DeBeers).

2) https://www.theglobeandmail.com/globe-investor/retirement/elliot-lake-offers-simple-rugged-beauty-and-affordability-for-seniors/article1 934231/.

3) www.cityofelliotlake.com/en/cityhall/history.asp.

4) https://www.youtube.com/watch?v=mwBqmx3Dei0 5) https://en.wikipedia.org/wiki/Elliot_Lake.

A former boom-and-bust uranium town, Elliot Lake fell on hard times in the early 1990s when the last mines closed for good. Since then, with some success, Elliot Lake has promoted itself as a retirement community tailored for outdoors enthusiasts looking to stretch their retirement savings. Elliot Lake Retirement Living, a private non-for-profit organisation responsible for marketing the city to 50-plus retirees, manages more than 1,500 units of rental properties once owned by the area’s mining companies.

The learnings from Elliot lake, especially related to partnerships, funding and timelines could be of great value to the mining town.

Table 2: Social Transition – Example of benchmarking spreadsheet with recommendations for further work


Mafube Colliery, South Africa.


EXAMPLE 5: PHYSICAL CLOSURE COST CALCULATION SPREADSHEET AND DRAWINGS

INTRODUCTION

This example describes how to develop a closure liability estimate, by giving guidance on how to develop the closure criteria, including assumptions related to the cost estimate. It also describes how to ensure the full scope of the closure plan is covered, by linking structures and facilities on the general layout drawing to cost items in a spreadsheet. This example describes Mine A, that is a mine situated in Botswana and has a remaining life of asset of 24 years (2005 is the base date). The closure

estimate required for this mine is an “Improved class 5 estimate” (L: -20% to -50%; H: +30% to +100% with a contingency (P50) of 25% -40%). This example lists the closure criteria and the assumptions that were made in estimating the closure cost. The final LoA closure cost was determined, taking into consideration ongoing rehabilitation throughout the operational phase of the mine.

The details of this example can be viewed in the “Examples Document” of the Mine Closure Toolbox Version 2, dated 2013.


Mareesburg Tailings Facility which will be used to take material from the Mototolo Concentrator, South Africa.



INTRODUCTION

This example focuses on the information gaps that were identified during the gap analysis workshop (Tool 2 of the MCT) that took place at a small open pit mining operation in Southern Africa referred to as Mine B in June 2019. The completed “Gap analysis” spreadsheet is attached in Appendix A.

Tool 3 of the Toolbox identifies the detailed steps that must be taken to fill the gaps identified in the gap analysis. It has been used to identify the outstanding scope of work in updating the current mine closure plan. The various applicable “Tasks” and “Steps” from Tool 3 are noted in the “Master Action Plan” (MAP) as Appendix B.

The aim of the project is to upgrade the current mine closure plan from a “Preliminary Closure Plan”

to a “Draft Closure Plan” by the end of 2020. The proposed project schedule is attached as Appendix C.

CURRENT STATUS OF MINE CLOSURE PLANNING

Based on current mine planning, the mine is planned to be closed by the end of 2032. This means that the mine’s current level of mine closure planning should be at the level of a “Draft Closure Plan” as reflected in the “15-10 years” column of the spreadsheet contained in Appendix A. This is however not the case, as the mine currently does not have a mine closure plan that addresses all the requirements as defined for a “Draft Closure Plan”.

The process of developing a Draft Mine Closure Plan (Improved Class 5 estimate) over the next 18 months is reflected in the MAP in Appenidx B and its associated completion schedule in Appendix C.

EXAMPLE 6: COMPLETED GAP ANALYSIS AND ACTION PLAN

New filter press under construction at Mototolo Concentrator - part of the mitigation for the Helena Tailings Dam Project, South Africa.


EVALUATION SPREADSHEET: As completed on 5 June 2019

APPENDIX A: COMPLETED GAP ANALYSIS

Time remaining to scheduled closure More than 25 years 25-15 years 15-10 years 10-5 years 5-0 years 0-15 years

5-3 years 2-0 years 0 - 5 years 5 - 15 years

Item description Preliminary Closure Plan Draft Closure Plan Detailed Closure Plan Final Closure Plan Decommissioning Monitoring and Maintenance

Physical closure

Physical closure criteria

Infrastructure (on and off-site).The mine has one plant (10 ha), including workshops, offices, stores, plant fencing, and other infrastructure. The offsite surface infrastructure on the current property constitutes some power lines (17 km), overland water supply lines (30 km from a wellfield), unsealed roads (20 km) and some telephone lines (12 km).

The current mine property also contains eight management houses, a lapa with eight wooden cabins, four units at a caravan park, five mobile units, and three pre-fabricated units accommodating 90 employees). Most employees reside offsite.

Reference:Presentation by mine – June 2019; Preliminary Closure Plan and cost estimate (including detailed Basis of Estimate (BoE) for the mine – March 2019. Asset disposal register dated Feb 2019. Infrastructure maintenance plan dated April 2018.

Following a risk-based approach, a complete set of closure criteria has been developed and costed. The criteria used (BoE) in the closure cost estimate are based on experience and available information.

Relevant discipline experts have undertaken a desktop investigation into the closure methodology and criteria, to confirm the current criteria or to establish more appropriate criteria (BoE).

The closure criteria recommended by the relevant discipline experts have, where appropriate, been reviewed and updated by undertaking a site-specific investigation into the closure methodology. The granularity of the criteria (BoE) has improved and also includes infrastructure maintenance requirements, waste disposal and recycling requirements, asset disposal categories and an associated register.

GAPS:1) Demolition waste disposal and recycling requirements and volumes have not been defined in sufficient detail.2) The closure criteria are well defined, but no consultation has taken place with I&APs to confirm the acceptability of the closure criteria, especially related to social infrastructure (e.g. on-site housing).

The criteria have through onsite or industry execution been demonstrated and accepted to be successful. I&APs and authorities have been consulted and are in the majority satisfied with the closure and success criteria. A detailed asset register is available that differentiates between demolition, disposal and retention. An asset management strategy and plan, including the Stakeholder Engagement Plan (SEP), master action plan and schedule with cashflow, have been developed.

Closure execution planning, scheduling and costing have been completed to a Prefeasibility B “PFS-B” level, as per the AA Investment Development Model (IDM) requirements with the key execution documents being (but not limited to):

• Project Charter, Study Execution Plan, Project Execution Plan, Work Breakdown Structure (WBS), Detailed Execution Schedule, Project Risk Register; SEP, Legal Register, Financial Plan, Model and Report.

• Cost benefit analyses have been undertaken on alternative uses for infrastructure and equipment post closure (in line with the final land-use plan).

• Work packages have been costed and the execution plan scheduled and resourced. The trade-off study between owner vs. contractor execution has been completed.

• The relevant authorities have signed off the closure and success criteria. Other I&APs have been engaged to the appropriate level of influence.

The detailed closure execution planning, scheduling and costing have been completed and all execution documentation have been completed by improving the PBS-B study to that of a Feasibility Study (FS) level, as per the AA IDM requirements, that will contain the following additional deliverables (but not limited to):

• Logistics Management Plan, Change Management Plan, Engineering Management Plan, Procurement Management Plan; Environmental Management Plan, and Document Control Management Plan.

• Where appropriate, some of the work packages have gone out to tender and are ready for order placement and execution (especially the work as scheduled for the 1st year of decommissioning).

The decommissioning plan includes all the project management and risk controls associated with effective project execution and tracking in place. The success of the project is tracked against Key Performance Indicators (KPIs), such as budget, progress, community and regulatory acceptability and meeting the overall agreed success criteria.

See Tool 5 for details on project execution planning and management.

A detailed post decommissioning monitoring and maintenance plan is in place that tracks risk management, financial performance, ongoing progress, stakeholder engagement, success criteria and ultimately relinquishment of assets.






Physical closure


Infrastructure (on and off-site).The mine has one plant (10 ha), including workshops, offices, stores, plant fencing, and other infrastructure. The offsite surface infrastructure on the current property constitutes some power lines (17 km), overland water supply lines (30 km from a wellfield), unsealed roads (20 km) and some telephone lines (12 km).

The current mine property also contains eight management houses, a lapa with eight wooden cabins, four units at a caravan park, five mobile units, and three pre-fabricated units accommodating 90 employees). Most employees reside offsite.

Reference:Presentation by mine – June 2019; Preliminary Closure Plan and cost estimate (including detailed Basis of Estimate (BoE) for the mine – March 2019. Asset disposal register dated Feb 2019. Infrastructure maintenance plan dated April 2018.

Following a risk-based approach, a complete set of closure criteria has been developed and costed. The criteria used (BoE) in the closure cost estimate are based on experience and available information.

Relevant discipline experts have undertaken a desktop investigation into the closure methodology and criteria, to confirm the current criteria or to establish more appropriate criteria (BoE).

The closure criteria recommended by the relevant discipline experts have, where appropriate, been reviewed and updated by undertaking a site-specific investigation into the closure methodology. The granularity of the criteria (BoE) has improved and also includes infrastructure maintenance requirements, waste disposal and recycling requirements, asset disposal categories and an associated register.

GAPS:1) Demolition waste disposal and recycling requirements and volumes have not been defined in sufficient detail.2) The closure criteria are well defined, but no consultation has taken place with I&APs to confirm the acceptability of the closure criteria, especially related to social infrastructure (e.g. on-site housing).

The criteria have through onsite or industry execution been demonstrated and accepted to be successful. I&APs and authorities have been consulted and are in the majority satisfied with the closure and success criteria. A detailed asset register is available that differentiates between demolition, disposal and retention. An asset management strategy and plan, including the Stakeholder Engagement Plan (SEP), master action plan and schedule with cashflow, have been developed.

Closure execution planning, scheduling and costing have been completed to a Prefeasibility B “PFS-B” level, as per the AA Investment Development Model (IDM) requirements with the key execution documents being (but not limited to):

• Project Charter, Study Execution Plan, Project Execution Plan, Work Breakdown Structure (WBS), Detailed Execution Schedule, Project Risk Register; SEP, Legal Register, Financial Plan, Model and Report.

• Cost benefit analyses have been undertaken on alternative uses for infrastructure and equipment post closure (in line with the final land-use plan).

• Work packages have been costed and the execution plan scheduled and resourced. The trade-off study between owner vs. contractor execution has been completed.

• The relevant authorities have signed off the closure and success criteria. Other I&APs have been engaged to the appropriate level of influence.

The detailed closure execution planning, scheduling and costing have been completed and all execution documentation have been completed by improving the PBS-B study to that of a Feasibility Study (FS) level, as per the AA IDM requirements, that will contain the following additional deliverables (but not limited to):

• Logistics Management Plan, Change Management Plan, Engineering Management Plan, Procurement Management Plan; Environmental Management Plan, and Document Control Management Plan.

• Where appropriate, some of the work packages have gone out to tender and are ready for order placement and execution (especially the work as scheduled for the 1st year of decommissioning).

The decommissioning plan includes all the project management and risk controls associated with effective project execution and tracking in place. The success of the project is tracked against Key Performance Indicators (KPIs), such as budget, progress, community and regulatory acceptability and meeting the overall agreed success criteria.


A detailed post decommissioning monitoring and maintenance plan is in place that tracks risk management, financial performance, ongoing progress, stakeholder engagement, success criteria and ultimately relinquishment of assets.




APPENDIX A: COMPLETED GAP ANALYSIS (continued)




Physical closure


Mineral Waste Landforms:The mine has one fine residue deposit (FRD) that is 20 m high and 25 ha footprint, one coarse residue deposit (CRD) that is 40 m high with a 50 ha footprint and a 100 ha waste rock dump that is 60 m high (20 m benches).

Reference:Presentation by mine – June 2019; Preliminary Closure Plan and cost estimate for the mine – March 2019. General layout drawing dated January 2019. Cost benefit analysis dated September 2015.

Updated:Landform design dated April 2018. Detailed material balance dated January 2018.

Stormwater design and layout drawings dated January 2019. Geochem report by enviro lab dated January 2018.

Following a risk-based approach, the closure criteria and conceptual final landform designs are available and based on the planned LoA tonnage/volume of mineral residue and stockpile material. The landform designs also consider the following key components:

1) Material volumes and characterisation:A high-level material balance is in place, reflecting key mineral residue volumes over the LoA, including the required growth medium for rehabilitation purposes. Material characterisations have been undertaken at a high level to identify and quantify inert material vs. hostile material (e.g. potential Acid Metalliferous Drainage (AMD), spontaneous combustion, dispersive material, saline material).

2) Management of hostile material:The required management measures and closure criteria have been included in the landform design to address the long-term impacts of hostile materials (e.g. selective placement vs. capping and/or lining).

3) Availability of footprint:The landform design does take into consideration the current and future footprint requirements, especially considering final slopes. The requirements of the final landform designs are included in the LoAP parameters.

4) Landform stability:Landform stability has been evaluated through geotechnical and erosional studies. Key considerations include typical erosion challenges, possible flooding and where applicable earthquake conditions.

5) Water management:Conceptual water management planning has been undertaken and the closure requirements of these facilities included in the design and costing.

Relevant discipline experts have improved the landform designs. High-level cost benefit analysis has taken place to evaluate significant technical, environmental and operational considerations, and the potential impact on mining operations and costs. The landform designs were improved by undertaking the following:

1) Material volumes and characterisation:A detailed balance is in place for hostile and non-hostile material, reflecting all current and future mineral waste volumes and requirements.

2) Management of hostile material:Geochemical testing (at least static and kinetic tests) has been completed on the various hostile materials.

3) Availability of footprint:The final landform designs compliment the final land-use plan. Operational deposition strategies allow for reduction in future material double handling and optimisation of concurrent rehabilitation.

4) Landform stability:Landform stability has been re-evaluated, based on erosion modelling results and more detailed long-term flooding designs. A monitoring programme is in place to validate landform stability predictions.

5) Water management:Water management design ensures clean and dirty water separation post closure (e.g. storm water diversions).GAPS: 2) Management of hostile material: Only static geochemical testing has been completed on the various hostile materials.

4) Landform stability:Landform stability has been re-evaluated, based on erosion modelling results and more detailed long-term flooding designs, however a monitoring programme is not in place to validate landform stability predictions.

6) Current level of confidence for mineral waste landforms is not aligned with that required for a mine with between 15-10 years LoA (See Tool 2 requirements).

Relevant discipline experts have undertaken a site-specific investigation into the closure methodology and criteria, to confirm the current criteria or to establish more appropriate closure criteria. The executability of the closure criteria and the cost effectiveness of the designs have been demonstrated by onsite execution and rehabilitation. The landform designs were improved by undertaking the following:

1) Material volumes and characterisation:A detailed balance is maintained for hostile and non-hostile material (live system), reflecting no shortfall in materials to execute the closure plan.

2) Management of hostile material:Additional kinetic testing has been completed where required and the monitoring programme is demonstrating successful onsite containment and remediation.

3) Availability of footprint:Final landform execution is tracked to ensure it is aligned with the plan and sufficient space is available for concurrent rehabilitation. LoAP allows for sufficient available areas to undertake landform closure execution (shaping and rehabilitation).

4) Landform stability:Effectiveness of management measures and closure criteria are being tracked and monitored and required changes made to improve long-term stability and reduce costs.

5) Water management:The effectiveness and long-term sustainability of water management structures and measures are tracked and improved as required.

Final post closure landform design and execution is fully integrated into LoAP, as part of the ongoing deposition strategies. The cost of closure execution is tracked as part of the operational financial reporting and the benefit of integrated LoAP and closure strategies measured. The landform designs were improved by undertaking the following:

1) Material volumes and characterisation:Detailed balance is in place for hostile and non-hostile material and it can be demonstrated that the landform development sequencing considers scheduled material movements by waste type and costs are supported by equipment requirements.

2) Management of hostile material:Ongoing monitoring can prove landform stability and provides seepage analyses, as well as drainage/effluent waterquality projections.

3) Availability of footprint:I&APs and authorities have been engaged to the appropriate level of influence on the final landform designs and are satisfied with the closure and success criteria (majority agreement).

4) Landform stability:Final capping and or reshaping designs have been completed and costed, including construction sequencing requirements tomaintain long term physical and chemical stability.

5) Water management:The effectiveness and long-term sustainability of water management structures can be demonstrated.

Closure execution planning, scheduling and costing have been completed to a PFS-B level, as per the AA IDM.

The specific mineral residue and landform deliverables being (but not limited to):

• Final post closure landform designs, supported by detailed mine equipment requirements.

• Seepage analyses and the landform water balance and water management plan, for facilities and surrounding areas.

• Description of water management and diversion works in a post-closure condition, including risk assessment, and risk mitigation plan.

• The trade-off study between owner execution vs. contractor execution.

• The relevant authorities have signed off the closure and success criteria and other I&APs have been consulted.

• Execution planning, scheduling and costing have been undertaken and key execution documentation have been completed (see Infrastructure section for more details).

The closure execution PFS-B study has been improved to that of a FS level, as per the AA IDM. requirements. The specific mineral residue and landform deliverables being (but not limited to):

• Final agreed detailed landform designs, including selective placement of various closure phase related waste types (hostile and non-hostile material, generated due to closure activities, e.g. demolition rubble, contamination below infrastructure, etc.) and the geochemical stability of the facilities.

• Detailed engineering designs, including contact and non-contact water diversion and management, landform water balance, stability and seepage analyses, water quality and water treatment requirements, are included in the final design and costed.

• The detailed execution planning, scheduling and costing have been undertaken and all execution documentation have been completed (see Infrastructure section for more details).

(See Infrastructure section for detailed requirements).






Physical closure


Mineral Waste Landforms:The mine has one fine residue deposit (FRD) that is 20 m high and 25 ha footprint, one coarse residue deposit (CRD) that is 40 m high with a 50 ha footprint and a 100 ha waste rock dump that is 60 m high (20 m benches).

Reference:Presentation by mine – June 2019; Preliminary Closure Plan and cost estimate for the mine – March 2019. General layout drawing dated January 2019. Cost benefit analysis dated September 2015.

Updated:Landform design dated April 2018. Detailed material balance dated January 2018.

Stormwater design and layout drawings dated January 2019. Geochem report by enviro lab dated January 2018.

Following a risk-based approach, the closure criteria and conceptual final landform designs are available and based on the planned LoA tonnage/volume of mineral residue and stockpile material. The landform designs also consider the following key components:

1) Material volumes and characterisation:A high-level material balance is in place, reflecting key mineral residue volumes over the LoA, including the required growth medium for rehabilitation purposes. Material characterisations have been undertaken at a high level to identify and quantify inert material vs. hostile material (e.g. potential Acid Metalliferous Drainage (AMD), spontaneous combustion, dispersive material, saline material).

2) Management of hostile material:The required management measures and closure criteria have been included in the landform design to address the long-term impacts of hostile materials (e.g. selective placement vs. capping and/or lining).

3) Availability of footprint:The landform design does take into consideration the current and future footprint requirements, especially considering final slopes. The requirements of the final landform designs are included in the LoAP parameters.

4) Landform stability:Landform stability has been evaluated through geotechnical and erosional studies. Key considerations include typical erosion challenges, possible flooding and where applicable earthquake conditions.

5) Water management:Conceptual water management planning has been undertaken and the closure requirements of these facilities included in the design and costing.

Relevant discipline experts have improved the landform designs. High-level cost benefit analysis has taken place to evaluate significant technical, environmental and operational considerations, and the potential impact on mining operations and costs. The landform designs were improved by undertaking the following:

1) Material volumes and characterisation:A detailed balance is in place for hostile and non-hostile material, reflecting all current and future mineral waste volumes and requirements.

2) Management of hostile material:Geochemical testing (at least static and kinetic tests) has been completed on the various hostile materials.

3) Availability of footprint:The final landform designs compliment the final land-use plan. Operational deposition strategies allow for reduction in future material double handling and optimisation of concurrent rehabilitation.

4) Landform stability:Landform stability has been re-evaluated, based on erosion modelling results and more detailed long-term flooding designs. A monitoring programme is in place to validate landform stability predictions.

5) Water management:Water management design ensures clean and dirty water separation post closure (e.g. storm water diversions).GAPS: 2) Management of hostile material: Only static geochemical testing has been completed on the various hostile materials.

4) Landform stability:Landform stability has been re-evaluated, based on erosion modelling results and more detailed long-term flooding designs, however a monitoring programme is not in place to validate landform stability predictions.

6) Current level of confidence for mineral waste landforms is not aligned with that required for a mine with between 15-10 years LoA (See Tool 2 requirements).

Relevant discipline experts have undertaken a site-specific investigation into the closure methodology and criteria, to confirm the current criteria or to establish more appropriate closure criteria. The executability of the closure criteria and the cost effectiveness of the designs have been demonstrated by onsite execution and rehabilitation. The landform designs were improved by undertaking the following:

1) Material volumes and characterisation:A detailed balance is maintained for hostile and non-hostile material (live system), reflecting no shortfall in materials to execute the closure plan.

2) Management of hostile material:Additional kinetic testing has been completed where required and the monitoring programme is demonstrating successful onsite containment and remediation.

3) Availability of footprint:Final landform execution is tracked to ensure it is aligned with the plan and sufficient space is available for concurrent rehabilitation. LoAP allows for sufficient available areas to undertake landform closure execution (shaping and rehabilitation).

4) Landform stability:Effectiveness of management measures and closure criteria are being tracked and monitored and required changes made to improve long-term stability and reduce costs.

5) Water management:The effectiveness and long-term sustainability of water management structures and measures are tracked and improved as required.

Final post closure landform design and execution is fully integrated into LoAP, as part of the ongoing deposition strategies. The cost of closure execution is tracked as part of the operational financial reporting and the benefit of integrated LoAP and closure strategies measured. The landform designs were improved by undertaking the following:

1) Material volumes and characterisation:Detailed balance is in place for hostile and non-hostile material and it can be demonstrated that the landform development sequencing considers scheduled material movements by waste type and costs are supported by equipment requirements.

2) Management of hostile material:Ongoing monitoring can prove landform stability and provides seepage analyses, as well as drainage/effluent waterquality projections.

3) Availability of footprint:I&APs and authorities have been engaged to the appropriate level of influence on the final landform designs and are satisfied with the closure and success criteria (majority agreement).

4) Landform stability:Final capping and or reshaping designs have been completed and costed, including construction sequencing requirements tomaintain long term physical and chemical stability.

5) Water management:The effectiveness and long-term sustainability of water management structures can be demonstrated.


The specific mineral residue and landform deliverables being (but not limited to):

• Final post closure landform designs, supported by detailed mine equipment requirements.

• Seepage analyses and the landform water balance and water management plan, for facilities and surrounding areas.

• Description of water management and diversion works in a post-closure condition, including risk assessment, and risk mitigation plan.

• The trade-off study between owner execution vs. contractor execution.

• The relevant authorities have signed off the closure and success criteria and other I&APs have been consulted.


The closure execution PFS-B study has been improved to that of a FS level, as per the AA IDM. requirements. The specific mineral residue and landform deliverables being (but not limited to):

• Final agreed detailed landform designs, including selective placement of various closure phase related waste types (hostile and non-hostile material, generated due to closure activities, e.g. demolition rubble, contamination below infrastructure, etc.) and the geochemical stability of the facilities.

• Detailed engineering designs, including contact and non-contact water diversion and management, landform water balance, stability and seepage analyses, water quality and water treatment requirements, are included in the final design and costed.

• The detailed execution planning, scheduling and costing have been undertaken and all execution documentation have been completed (see Infrastructure section for more details).









Physical closure


Non-Mineral Waste:The mine has a small licensed domestic disposal site, but disposes the bulk of their domestic waste at the local municipal site. A 3rd party disposes of all hazardous waste (18 ton per quarter) and all hydrocarbon waste is recycled by the suppliers.

Reference:Presentation by the mine – 5 June 2019. General layout drawing dated January 2019. Non-mineral waste strategy dated June 2015. Live legal data base and permitting system called “Landfolio”. Cost benefit analysis dated September 2015. Offsite waste disposal capacity report by GES consultant, date January 2018. Update closure risk assessment dated February 2019.

Following a risk-based approach, a complete set of closure criteria has been developed and costed for the non-mineral waste facilities including long-term management.

Waste Identification and classification: Key non-mineral waste streams are known and estimated current and future volumes have been predicted.

Regulatory requirements: Regulatory requirements related to the various waste stream are known (e.g. permit conditions) and forms part of the closure criteria.

Waste disposal options: A decision on undertaking onsite or offsite disposal form part of the closure planning and costing.

Waste management and facilities: Non-mineral waste management procedures are in place, including the management of onsite waste disposal facilities.

Relevant discipline experts have improved the non-mineral waste strategy and plan by undertaking the following:

Identification and classification: All non-mineral waste streams have been identified and current and future volumes have been calculated.

Regulatory requirements: Regulatory requirements related to the various waste streams are known (e.g. permit conditions) and forms part of the closure criteria.

Waste disposal options: A high-level trade-off study has taken place to compare onsite vs. offsite disposal and the closure planning and costing have been updated accordingly.

Waste management and facilities: Operational costs associated with non-mineral waste management is known. Onsite waste disposal facilities are managed. The current capacity of off-site waste disposal facilities is known.

Closure criteria: The closure risk assessment has been updated and all risks have been classified as either significant, insignificant or unknown. The complete set of closure criteria have been updated to align with the success criteria.


Identification and classification: A Non-mineral waste register is in place and is actively managed.

Regulatory requirements: Regulatory requirements related to the various waste streams are tracked in a live legal and permitting system and forecasted changes in legislation are considered in the updated closure criteria (e.g. more stringent future legislation).

Waste disposal options: A detailed cost benefit analysis has taken place and the closure planning and costing have been updated accordingly.

Waste management and facilities: Operational success can be demonstrated and the costs associated with non-mineral waste management is tracked and used to improve the costing in the closure liability. Onsite waste disposal facilities are managed and the effectiveness of closure criteria is tracked. The current and future capacity of off-site waste disposal facilities have been investigated and forms part of the updated closure criteria. Closure criteria: The closure risk assessment has been updated and all previous unknown risks have been re-classified as either significant or insignificant. The complete set of closure criteria have been updated to align with the success criteria.

GAPS:Closure criteria: The closure risk assessment has been updated and all previous unknown risks have been re-classified as either significant or insignificant, but success criteria have not been developed.


Identification and classification:Studies have been completed on waste beneficiation and alternative solutions to waste disposal and management (e.g. reclassification of waste). A non-mineral waste register is in place and is actively managed.

Regulatory requirements: The authorities have been consulted to obtain agreement on the success criteria.Waste disposal options: The final waste management and disposal strategy (including permission for onsite disposal of inert waste) has been agreed with the authorities and the closure planning and costing have been updated accordingly.Waste management and facilities: Discussion has taken place with offsite waste disposal operators to secure future waste disposal capacity and corporate social investment projects are in place to facilitate future offsite disposal capacity. Closure criteria: The closure risk assessment has been updated and improved to be more quantitative than qualitative and by including I&APs inputs. The complete set of closure criteria have been updated accordingly.


The specific non-mineral waste deliverables being (but not limited to):

• Final non-mineral waste disposal strategy and option analysis.

• Detailed quantitative risk assessment (pre and post mitigation ranking) with appropriate closure criteria.

• Detailed specialist studies used to quantify risk and impacts (e.g. seepage analyses, geochemistry analysis, future predictive modelling).

• The relevant authorities have been involved in the finalisation of the closure and success criteria and other I&APs have been consulted.

• Detailed liability estimate covering decommissioning and post closure periods. Liabilities estimate to differentiate between latent, residual and current closure liabilities.


The closure execution PFS-B study has been improved to that of a FS level, as per the AA IDM. requirements (see Infrastructure section for detailed requirements).







Physical closure


Non-Mineral Waste:The mine has a small licensed domestic disposal site, but disposes the bulk of their domestic waste at the local municipal site. A 3rd party disposes of all hazardous waste (18 ton per quarter) and all hydrocarbon waste is recycled by the suppliers.

Reference:Presentation by the mine – 5 June 2019. General layout drawing dated January 2019. Non-mineral waste strategy dated June 2015. Live legal data base and permitting system called “Landfolio”. Cost benefit analysis dated September 2015. Offsite waste disposal capacity report by GES consultant, date January 2018. Update closure risk assessment dated February 2019.

Following a risk-based approach, a complete set of closure criteria has been developed and costed for the non-mineral waste facilities including long-term management.

Waste Identification and classification: Key non-mineral waste streams are known and estimated current and future volumes have been predicted.

Regulatory requirements: Regulatory requirements related to the various waste stream are known (e.g. permit conditions) and forms part of the closure criteria.

Waste disposal options: A decision on undertaking onsite or offsite disposal form part of the closure planning and costing.

Waste management and facilities: Non-mineral waste management procedures are in place, including the management of onsite waste disposal facilities.


Identification and classification: All non-mineral waste streams have been identified and current and future volumes have been calculated.

Regulatory requirements: Regulatory requirements related to the various waste streams are known (e.g. permit conditions) and forms part of the closure criteria.

Waste disposal options: A high-level trade-off study has taken place to compare onsite vs. offsite disposal and the closure planning and costing have been updated accordingly.

Waste management and facilities: Operational costs associated with non-mineral waste management is known. Onsite waste disposal facilities are managed. The current capacity of off-site waste disposal facilities is known.

Closure criteria: The closure risk assessment has been updated and all risks have been classified as either significant, insignificant or unknown. The complete set of closure criteria have been updated to align with the success criteria.


Identification and classification: A Non-mineral waste register is in place and is actively managed.

Regulatory requirements: Regulatory requirements related to the various waste streams are tracked in a live legal and permitting system and forecasted changes in legislation are considered in the updated closure criteria (e.g. more stringent future legislation).

Waste disposal options: A detailed cost benefit analysis has taken place and the closure planning and costing have been updated accordingly.

Waste management and facilities: Operational success can be demonstrated and the costs associated with non-mineral waste management is tracked and used to improve the costing in the closure liability. Onsite waste disposal facilities are managed and the effectiveness of closure criteria is tracked. The current and future capacity of off-site waste disposal facilities have been investigated and forms part of the updated closure criteria. Closure criteria: The closure risk assessment has been updated and all previous unknown risks have been re-classified as either significant or insignificant. The complete set of closure criteria have been updated to align with the success criteria.

GAPS:Closure criteria: The closure risk assessment has been updated and all previous unknown risks have been re-classified as either significant or insignificant, but success criteria have not been developed.


Identification and classification:Studies have been completed on waste beneficiation and alternative solutions to waste disposal and management (e.g. reclassification of waste). A non-mineral waste register is in place and is actively managed.

Regulatory requirements: The authorities have been consulted to obtain agreement on the success criteria.Waste disposal options: The final waste management and disposal strategy (including permission for onsite disposal of inert waste) has been agreed with the authorities and the closure planning and costing have been updated accordingly.Waste management and facilities: Discussion has taken place with offsite waste disposal operators to secure future waste disposal capacity and corporate social investment projects are in place to facilitate future offsite disposal capacity. Closure criteria: The closure risk assessment has been updated and improved to be more quantitative than qualitative and by including I&APs inputs. The complete set of closure criteria have been updated accordingly.


The specific non-mineral waste deliverables being (but not limited to):

• Final non-mineral waste disposal strategy and option analysis.

• Detailed quantitative risk assessment (pre and post mitigation ranking) with appropriate closure criteria.

• Detailed specialist studies used to quantify risk and impacts (e.g. seepage analyses, geochemistry analysis, future predictive modelling).

• The relevant authorities have been involved in the finalisation of the closure and success criteria and other I&APs have been consulted.

• Detailed liability estimate covering decommissioning and post closure periods. Liabilities estimate to differentiate between latent, residual and current closure liabilities.


The closure execution PFS-B study has been improved to that of a FS level, as per the AA IDM. requirements (see Infrastructure section for detailed requirements).








Physical closure


Mining areas (surface/underground/seaborne):The open pit area is approximately 200 m deep with a 150 ha footprint.

Reference:Preliminary closure plan and cost estimate for the mine – March 2019. General layout drawing dated January 2019. Current mine design dated December 2018.

A complete set of closure criteria has been developed and costed following a risk-based approach. The criteria used (BoE) in the closure cost estimate are based on experience and available information. The focus being on leaving behind safe, secure, chemically and physically stable structures, that will not continue to pollute the environment post long-term mitigation. The key critical closure criteria that must be covered includes long-term geotechnical and geochemical stability, safety, security and long-term impacts on the environment (e.g. ground and surface water) and people, and alignment with the final closure vision and land-use plan.

GAPS:1) Current level of confidence for the mining area is not aligned with that required for a mine with between 15-10 years LoA.

Relevant discipline experts have undertaken a desktop investigation and benchmarking (on high risk and high cost components), into the closure methodology and criteria, to confirm the current criteria or to establish more appropriate criteria (BoE). The key critical closure criteria must cover (but is not limited to) the following:

Stability:Specialist studies will be undertaken on long-term geochemical stability, using high level designs and available geochemical information.

Safety and security:Initial investigations into long-term relaxation zones (~breakback zones), covering people and the environment, including components such as possible solutions for long-term access control.

Relaxation:Relaxation zone is the geotechnical prediction of failure of pit walls based on an identified Factor of Safety defined by AA as 1.5.

Bio-physical (see bio-physical and social sections in Tool 2):Long-term impacts on surface and ground water resources (e.g. pit water quality, future decant management, interconnectivity of groundwater between pits/underground workings, long-term health impacts on people) are investigated.

Land-use:The impacts of the mining areas (i.e. final voids, shafts, adits) on the final closure vision and land-use plan needs to be assessed and aligned.

The previous closure criteria recommended by the relevant discipline experts have, where appropriate, been reviewed and updated by doing a site-specific investigation into the closure methodology as well as focused benchmarking. The granularity of the criteria (BoE) has improved and includes decommissioning, closure and long-term monitoring and maintenance requirements, and costs for each of the mining areas. The previously identified key critical closure criteria has been improved by undertaking the following:

Stability:Detailed geotechnical and geochemical stability design requirements, must form part of LoAP and execution, and a predictive model has been developed to quantify and manage the associated risks (e.g. identification of pit relaxation zones identification, subsurface support deterioration and subsequent surface settlement, long-term metal leaching due to AMD).

Safety and security:Detailed operation and closure designs to identify and maintain long-term relaxation zones, covering people and the environment, needs to be in place. Detailed security plans need to be in place to not only address operational risks but also the projected future closure and post closure risk components such as long-term access control and others safety and security risks.

Bio-physical (see bio-physical and social sections in Tool 2):Detailed studies must be completed, and plans must be in place to address long-term impacts on surface and underground water resources (e.g. pit water quality, future decant, interconnectivity of groundwater between pits/underground workings, health impacts on people).

Land-use:The closure criteria as defined and costed for the mining areas (final voids, shafts, adits) must align fully with final closure vision and land- use plan.

The criteria have through onsite or industry execution been demonstrated and accepted to be successful. I&APs and authorities have been engaged at the appropriate level of influence and are in the majority satisfied with the closure and success criteria. A detailed decommissioning and closure management strategy (including the SEP; master action plan/schedule with cashflow) have been developed to facilitate the successful execution of the mining areas. The previously identified key critical closure criteria have been improved by undertaking the following:

Stability:Long-term geotechnical and geochemical stability modelling has been improved by ongoing calibration to improve the predicted long-term impacts and to demonstrate the success of implemented closure criteria.

Safety and security:The successful management of long-term safety and security has been proven by continuously improving the delineation of the various zone of influences, covering people and the environment, including components such as long-term access control (e.g. sealing of shafts, installation of berms and fencing, dense vegetation and cut off trenches around final voids), prevention of illegal mining, and safety and security risks.

Bio-physical (see bio-physical and social sections in Tool 2):Long-term impacts on surface and underground water resources, and people have been monitored and the closure criteria updated to ensure an acceptable residual risk profile.

Land-use:The closure criteria as defined and costed for the mining areas (final voids, shafts, adits) are updated in line with the final agreed closure vision and land-use plan.

Closure execution planning, scheduling and costing have been done to a PFS-B level, as per the AA IDM requirements with the key execution document being (but not limited to): • Project Charter, Study Execution Plan, Project Execution Plan, Work Breakdown Structure (WBS), Detailed Execution Schedule, Project Risk Register, SEP, Legal Register, Financial Plan, Model and Report.

The detailed closure execution planning, scheduling and costing have been done and all closure execution documentation have been completed by improving the PFS-B study to that of a FS level, as per the AA IDM requirements.

The decommissioning plan includes all the project management and risk controls associated with effective project execution and tracking in place. The success of the project is tracked against the KPIs, such as budget, progress, community and regulatory acceptability and meeting the overall agreed success criteria.


A detailed monitoring and maintenance plan is in place that tracks risk management, financial performance, ongoing progress, stakeholder engagement, success criteria and ultimately relinquishment of assets.






Physical closure


Mining areas (surface/underground/seaborne):The open pit area is approximately 200 m deep with a 150 ha footprint.


A complete set of closure criteria has been developed and costed following a risk-based approach. The criteria used (BoE) in the closure cost estimate are based on experience and available information. The focus being on leaving behind safe, secure, chemically and physically stable structures, that will not continue to pollute the environment post long-term mitigation. The key critical closure criteria that must be covered includes long-term geotechnical and geochemical stability, safety, security and long-term impacts on the environment (e.g. ground and surface water) and people, and alignment with the final closure vision and land-use plan.

GAPS:1) Current level of confidence for the mining area is not aligned with that required for a mine with between 15-10 years LoA.

Relevant discipline experts have undertaken a desktop investigation and benchmarking (on high risk and high cost components), into the closure methodology and criteria, to confirm the current criteria or to establish more appropriate criteria (BoE). The key critical closure criteria must cover (but is not limited to) the following:

Stability:Specialist studies will be undertaken on long-term geochemical stability, using high level designs and available geochemical information.

Safety and security:Initial investigations into long-term relaxation zones (~breakback zones), covering people and the environment, including components such as possible solutions for long-term access control.

Relaxation:Relaxation zone is the geotechnical prediction of failure of pit walls based on an identified Factor of Safety defined by AA as 1.5.

Bio-physical (see bio-physical and social sections in Tool 2):Long-term impacts on surface and ground water resources (e.g. pit water quality, future decant management, interconnectivity of groundwater between pits/underground workings, long-term health impacts on people) are investigated.

Land-use:The impacts of the mining areas (i.e. final voids, shafts, adits) on the final closure vision and land-use plan needs to be assessed and aligned.

The previous closure criteria recommended by the relevant discipline experts have, where appropriate, been reviewed and updated by doing a site-specific investigation into the closure methodology as well as focused benchmarking. The granularity of the criteria (BoE) has improved and includes decommissioning, closure and long-term monitoring and maintenance requirements, and costs for each of the mining areas. The previously identified key critical closure criteria has been improved by undertaking the following:

Stability:Detailed geotechnical and geochemical stability design requirements, must form part of LoAP and execution, and a predictive model has been developed to quantify and manage the associated risks (e.g. identification of pit relaxation zones identification, subsurface support deterioration and subsequent surface settlement, long-term metal leaching due to AMD).

Safety and security:Detailed operation and closure designs to identify and maintain long-term relaxation zones, covering people and the environment, needs to be in place. Detailed security plans need to be in place to not only address operational risks but also the projected future closure and post closure risk components such as long-term access control and others safety and security risks.

Bio-physical (see bio-physical and social sections in Tool 2):Detailed studies must be completed, and plans must be in place to address long-term impacts on surface and underground water resources (e.g. pit water quality, future decant, interconnectivity of groundwater between pits/underground workings, health impacts on people).

Land-use:The closure criteria as defined and costed for the mining areas (final voids, shafts, adits) must align fully with final closure vision and land- use plan.

The criteria have through onsite or industry execution been demonstrated and accepted to be successful. I&APs and authorities have been engaged at the appropriate level of influence and are in the majority satisfied with the closure and success criteria. A detailed decommissioning and closure management strategy (including the SEP; master action plan/schedule with cashflow) have been developed to facilitate the successful execution of the mining areas. The previously identified key critical closure criteria have been improved by undertaking the following:

Stability:Long-term geotechnical and geochemical stability modelling has been improved by ongoing calibration to improve the predicted long-term impacts and to demonstrate the success of implemented closure criteria.

Safety and security:The successful management of long-term safety and security has been proven by continuously improving the delineation of the various zone of influences, covering people and the environment, including components such as long-term access control (e.g. sealing of shafts, installation of berms and fencing, dense vegetation and cut off trenches around final voids), prevention of illegal mining, and safety and security risks.

Bio-physical (see bio-physical and social sections in Tool 2):Long-term impacts on surface and underground water resources, and people have been monitored and the closure criteria updated to ensure an acceptable residual risk profile.

Land-use:The closure criteria as defined and costed for the mining areas (final voids, shafts, adits) are updated in line with the final agreed closure vision and land-use plan.

Closure execution planning, scheduling and costing have been done to a PFS-B level, as per the AA IDM requirements with the key execution document being (but not limited to): • Project Charter, Study Execution Plan, Project Execution Plan, Work Breakdown Structure (WBS), Detailed Execution Schedule, Project Risk Register, SEP, Legal Register, Financial Plan, Model and Report.


The decommissioning plan includes all the project management and risk controls associated with effective project execution and tracking in place. The success of the project is tracked against the KPIs, such as budget, progress, community and regulatory acceptability and meeting the overall agreed success criteria.


A detailed monitoring and maintenance plan is in place that tracks risk management, financial performance, ongoing progress, stakeholder engagement, success criteria and ultimately relinquishment of assets.








Physical closure

Physical liability estimate

Physical closure liability estimate: Preliminary closure plan and cost estimate for the mine – March 2019.


Class 5 estimate.

L: -30% to -50%.

H: +50% to +100%.

Contingency (P50) of 30%-50%.

Improved class 5 estimate.

L: -20% to -50%.

H: +30% to +100%.


GAP:1) Current level of confidence of the estimate is not aligned with that required for a mine with between 15-10 years LoA.

Class 4 estimate.

L: -15% to -30%.

H: +20% to +50%.


Class 4 estimate.

L: -15% to -30%.

H: +20% to +50%.


Class 3 estimate.

L: -10% to -20%.

H: +10% to +30%.


Class 2 estimate.

L: -5% to -15%.

H: +5% to +20%.


Class 1 estimate.

L: -3% to -10%.

H: +3% to +15%.


Class 1 estimate.

L: -3% to -10%.

H: +3% to +15%.

Contingency (P50) of 5% -10%.

Biophysical closure/rehabilitation

Biophysical closure criteria

Land-use and capability:The mine owns 5 300 ha of land, of which approximately 800 ha will be disturbed by the mining operation. The area has a low agricultural value, with a grazing potential of one unit of livestock per 15 ha. Previous land-use was grazing, game farming and some tobacco farming.Reference:Environmental impact study; Preliminary Closure Plan and cost estimate for the mine – March 2019. Land-use plan dated January 2018.

High-level land-use plan has been developed based on assumed impacts, primarily focused on the local land capability before mining. The land-use plan aligns with the initial closure vision. See Section 4F: Land access, displacement and resettlement

A detailed land-use plan has been developed by the relevant discipline experts and the impacts have been assessed. The land-use plan aligns with the updated closure vision (internally and externally developed).

The assessed impacts have been confirmed through additional studies and the land-use plan updated by also including focused inputs from I&APs and authorities. The land-use plan aligns with the agreed closure vision (internally agreed and broadly external acceptance).

GAPS:1) Although the authorities have been engaged regarding the land-use plan, I&APs have not been engaged to get focused inputs and subsequent broadly external acceptance.

The final land-use plan has been developed with I&APs and authorities through the appropriate level of engagement and influence and the closure criteria and success criteria updated accordingly. The land-use plan aligns with the agreed closure vision (internally agreed and majority external acceptance).

The authorities have agreed to the final closure vision and related rehabilitation methods to achieve the land-use plan and other I&APs have been engaged at the appropriate level of Influence, and majority agreement obtained.


The suggested rehabilitation methods to achieve the land-use plan are based on experience and known methods from other sites. The landform designs allow sufficient flexibility to accommodate future changes to the final land-use (e.g. benches are constructed wide enough to accommodate for increased shaping of batters to flatter slopes), concurrent rehabilitation and rehabilitation trials are taking place, as appropriate.

The suggested rehabilitation methods to achieve the land-use plan have been assessed by means of concurrent rehabilitation and/or rehabilitation trials on site (concurrent rehabilitation if LoM is more than 25 years) and improved or modified as required.

The improved or modified rehabilitation methods to achieve the land-use plan have been tested through on-site trials and/or concurrent rehabilitation, from which it can be demonstrated that they are successful. Appropriate research programmes are in place to investigate methods to establish required species (e.g. seed dormancy, plant propagation methods).

GAPS: Appropriate research programmes are not in place to understand seed dormancies.

The preferred rehabilitation method to achieve the land-use plan from the testing phase that was demonstrated to be successful is selected, and I&APs and authorities have been engaged at the appropriate level of influence and are, in general, satisfied with the rehabilitation method and results.

Closure execution planning, scheduling and costing have been undertaken to a PFS-B level, as per the AA IDM requirements.

The detailed closure execution planning, scheduling and costing have been undertaken and all closure execution documentation have been completed by improving the PFS-B study to that of a FS level, as per the AA IDM requirements.

The success of the project is tracked against the KPIs and meeting the overall agreed success criteria.


A detailed monitoring and maintenance plan is in place that tracks the success criteria and ultimately relinquishment of leases.






Physical closure

Physical liability estimate

Physical closure liability estimate: Preliminary closure plan and cost estimate for the mine – March 2019.


Class 5 estimate.

L: -30% to -50%.

H: +50% to +100%.



L: -20% to -50%.

H: +30% to +100%.



Class 4 estimate.

L: -15% to -30%.

H: +20% to +50%.


Class 4 estimate.

L: -15% to -30%.

H: +20% to +50%.


Class 3 estimate.

L: -10% to -20%.

H: +10% to +30%.


Class 2 estimate.

L: -5% to -15%.

H: +5% to +20%.


Class 1 estimate.

L: -3% to -10%.

H: +3% to +15%.


Class 1 estimate.

L: -3% to -10%.

H: +3% to +15%.

Contingency (P50) of 5% -10%.



Land-use and capability:The mine owns 5 300 ha of land, of which approximately 800 ha will be disturbed by the mining operation. The area has a low agricultural value, with a grazing potential of one unit of livestock per 15 ha. Previous land-use was grazing, game farming and some tobacco farming.Reference:Environmental impact study; Preliminary Closure Plan and cost estimate for the mine – March 2019. Land-use plan dated January 2018.

High-level land-use plan has been developed based on assumed impacts, primarily focused on the local land capability before mining. The land-use plan aligns with the initial closure vision. See Section 4F: Land access, displacement and resettlement

A detailed land-use plan has been developed by the relevant discipline experts and the impacts have been assessed. The land-use plan aligns with the updated closure vision (internally and externally developed).

The assessed impacts have been confirmed through additional studies and the land-use plan updated by also including focused inputs from I&APs and authorities. The land-use plan aligns with the agreed closure vision (internally agreed and broadly external acceptance).

GAPS:1) Although the authorities have been engaged regarding the land-use plan, I&APs have not been engaged to get focused inputs and subsequent broadly external acceptance.

The final land-use plan has been developed with I&APs and authorities through the appropriate level of engagement and influence and the closure criteria and success criteria updated accordingly. The land-use plan aligns with the agreed closure vision (internally agreed and majority external acceptance).

The authorities have agreed to the final closure vision and related rehabilitation methods to achieve the land-use plan and other I&APs have been engaged at the appropriate level of Influence, and majority agreement obtained.


The suggested rehabilitation methods to achieve the land-use plan are based on experience and known methods from other sites. The landform designs allow sufficient flexibility to accommodate future changes to the final land-use (e.g. benches are constructed wide enough to accommodate for increased shaping of batters to flatter slopes), concurrent rehabilitation and rehabilitation trials are taking place, as appropriate.

The suggested rehabilitation methods to achieve the land-use plan have been assessed by means of concurrent rehabilitation and/or rehabilitation trials on site (concurrent rehabilitation if LoM is more than 25 years) and improved or modified as required.

The improved or modified rehabilitation methods to achieve the land-use plan have been tested through on-site trials and/or concurrent rehabilitation, from which it can be demonstrated that they are successful. Appropriate research programmes are in place to investigate methods to establish required species (e.g. seed dormancy, plant propagation methods).

GAPS: Appropriate research programmes are not in place to understand seed dormancies.

The preferred rehabilitation method to achieve the land-use plan from the testing phase that was demonstrated to be successful is selected, and I&APs and authorities have been engaged at the appropriate level of influence and are, in general, satisfied with the rehabilitation method and results.

Closure execution planning, scheduling and costing have been undertaken to a PFS-B level, as per the AA IDM requirements.

The detailed closure execution planning, scheduling and costing have been undertaken and all closure execution documentation have been completed by improving the PFS-B study to that of a FS level, as per the AA IDM requirements.

The success of the project is tracked against the KPIs and meeting the overall agreed success criteria.


A detailed monitoring and maintenance plan is in place that tracks the success criteria and ultimately relinquishment of leases.










Rehabilitation (Strategy):No endangered species are present on the site and the area is not a biodiversity hotspot. Two pans in the area are not impacted on by the mining operation. The land-use plan is focused on reinstating game farming as the most prominent land-use, with some grazing and small-scale farming.

Reference:Updated rehabilitation strategy dated December 2018. Update 5-year rehabilitation plan dated December 2018.

A concurrent rehabilitation strategy and associated plans have been developed and signed off by site senior management, and action has been taken to ensure these are included in the closure planning process and implemented.

A concurrent rehabilitation strategy and associated five year plans with procedures (including the post production period) have been developed for ongoing inclusion in the closure planning process and relevant components implemented annually. Concurrent rehabilitation plans are included in the operational budgets and progress is measured, adaptively managed with mitigation as required and ongoing reporting is taking place.


The post production component of the rehabilitation strategy and associated plans (including maintenance and management plans) have been approved and executed accordingly. Plans are included in closure budgets and progress is measured and reported.

See Tool 5 for details on project execution planning and production period) have been developed for ongoing inclusion in the closure planning process and relevant.

Surface and Groundwater:The estimated post- closure impact from a water resource point of view is still in progress. The post- closure impact from evaporation from the pit needs further investigation.

Reference:Initial groundwater report dated – January 2015, done by GES Consultant. Initial surface water report dated – January 2014, done by GES Consultant. EIA completed December 2017 (excluded long-term post closure impacts on surface and groundwater).

The potential closure and post-closure impacts on surface and groundwater are based on general experience and are not supported by detailed technical investigations or significance ratings (unless it formed part of regulatory requirements for mines with a LoA of more than 25 years). The potential closure and post closure impacts have not been discussed in detail with the authorities or other I&APs, other than through the normal regulatory processes.

GAPS:1) Current level of confidence in the surface and groundwater impacts and required actions is not aligned with that required for a mine with between 15-10 years LoA.

The potential closure and post-closure impacts have been identified and assessed through an environmental impacts assessment of the mine closure plan and specialist investigations. All high, significant, medium, low and unknown risks have been identified.

Hydrogeological and geochemical surface and groundwater models are in place and are calibrated on a regular basis with operational data.

The potential closure and post-closure impacts have been confirmed through additional specialist studies and post-closure environmental assessments, and the significant and insignificant risks have been communicated to I&APs for comment. All unknown risks have been rated. A detailed solute transfer model with integrated surface and groundwater numerical components and geochemical model and associated storm water management structures and systems that are costed in the closure liability are in place.

The required closure criteria associated with significant surface and groundwater risks can be considered proven if historical evidence is available, reflecting that they have been successfully implemented in similar circumstances elsewhere, or the proposed closure criteria to address high and significant risks have been tested on site and demonstrated to be successful. I&APs and authorities are satisfied in the majority with the closure criteria. Numerical solute models are updated with further field data as it becomes available.

The relevant authorities have signed off on the surface and groundwater closure criteria and other I&APs have been engaged at the appropriate level of influence, and the majority agree with the closure criteria.

The post production component of the ground and surface water strategy and associated plans have been approved and executed. Plans are in closure budgets and progress is measured and reported. Long-term residual and latent Impacts are known and are being monitored.








Rehabilitation (Strategy):No endangered species are present on the site and the area is not a biodiversity hotspot. Two pans in the area are not impacted on by the mining operation. The land-use plan is focused on reinstating game farming as the most prominent land-use, with some grazing and small-scale farming.

Reference:Updated rehabilitation strategy dated December 2018. Update 5-year rehabilitation plan dated December 2018.

A concurrent rehabilitation strategy and associated plans have been developed and signed off by site senior management, and action has been taken to ensure these are included in the closure planning process and implemented.



The post production component of the rehabilitation strategy and associated plans (including maintenance and management plans) have been approved and executed accordingly. Plans are included in closure budgets and progress is measured and reported.

See Tool 5 for details on project execution planning and production period) have been developed for ongoing inclusion in the closure planning process and relevant.

Surface and Groundwater:The estimated post- closure impact from a water resource point of view is still in progress. The post- closure impact from evaporation from the pit needs further investigation.

Reference:Initial groundwater report dated – January 2015, done by GES Consultant. Initial surface water report dated – January 2014, done by GES Consultant. EIA completed December 2017 (excluded long-term post closure impacts on surface and groundwater).

The potential closure and post-closure impacts on surface and groundwater are based on general experience and are not supported by detailed technical investigations or significance ratings (unless it formed part of regulatory requirements for mines with a LoA of more than 25 years). The potential closure and post closure impacts have not been discussed in detail with the authorities or other I&APs, other than through the normal regulatory processes.

GAPS:1) Current level of confidence in the surface and groundwater impacts and required actions is not aligned with that required for a mine with between 15-10 years LoA.

The potential closure and post-closure impacts have been identified and assessed through an environmental impacts assessment of the mine closure plan and specialist investigations. All high, significant, medium, low and unknown risks have been identified.

Hydrogeological and geochemical surface and groundwater models are in place and are calibrated on a regular basis with operational data.

The potential closure and post-closure impacts have been confirmed through additional specialist studies and post-closure environmental assessments, and the significant and insignificant risks have been communicated to I&APs for comment. All unknown risks have been rated. A detailed solute transfer model with integrated surface and groundwater numerical components and geochemical model and associated storm water management structures and systems that are costed in the closure liability are in place.

The required closure criteria associated with significant surface and groundwater risks can be considered proven if historical evidence is available, reflecting that they have been successfully implemented in similar circumstances elsewhere, or the proposed closure criteria to address high and significant risks have been tested on site and demonstrated to be successful. I&APs and authorities are satisfied in the majority with the closure criteria. Numerical solute models are updated with further field data as it becomes available.

The relevant authorities have signed off on the surface and groundwater closure criteria and other I&APs have been engaged at the appropriate level of influence, and the majority agree with the closure criteria.

The post production component of the ground and surface water strategy and associated plans have been approved and executed. Plans are in closure budgets and progress is measured and reported. Long-term residual and latent Impacts are known and are being monitored.





More than 25 years 25-15 years 15-10 years 10-5 years 5-0 years 0-15 years





Visual/aesthetic:The maximum height of the residue facilities was set at 60m, with 18-degree side slopes and full vegetation cover. Dust monitoring is taking place.

Reference:On-site monitoring programme; Environmental impact study. Land-use plan dated January 2018.

Assumed visual and sense of place impacts were based on available information of the local mining area.

An environmental impact assessment (including social) was undertaken and the visual, sense of place and heritage impacts were assessed, covering the full life cycle of the operation, including post closure phase impacts.

GAPS:1) Current level of confidence related to visual impacts and required actions is not aligned with that required for a mine with between 15-10 years LoA.

All gaps and unknown risks have been addressed through additional specialist studies, including landscape studies (if, appropriate), and all unknown risks and gaps have been closed with appropriate mitigation identified.

The closure criteria have been proven to be successful by means of successful onsite execution, and I&APs and authorities have been engaged at the appropriate level of influence and there is majority acceptance of the success and appropriateness of the mitigation measures.

The final landform designs are aligned with the closure vision and final land-uses and the authorities have agreed on the mitigation and rehabilitation methods and I&APs have been engaged at the appropriate level of Influence and there is majority agreement.

The mitigation measures have been successfully executed according to closure execution plan.

The residual risk profile is acceptable to I&APs and the authorities and the long-term sustainability of the solution have been proven to be successful (e.g. through monitoring).

The required closure criteria have been developed based on available information on similar rehabilitation requirements in the industry.

Operational management measures are in place, and the closure criteria have been developed and costed.


Operational management measures and closure criteria have been updated, and trials have taken place to demonstrate the effectiveness of the mitigation measures.

Operational management measures and closure criteria have been updated, and successful onsite execution has taken place with majority acceptance of I&APs.

Closure execution planning, scheduling and costing have been done to a PFS-B level, as per the AA IDM.

The detailed closure execution planning, scheduling and costing have been done and all execution documentation have been completed by improving the PFS-B study to that of a FS level, as per the AA IDM requirements.

The closure and post closure component to address the visual impacts, as well as the associated plans (including maintenance and management) have been approved an executed. Closure budget is available, and progress is measured and reported. Long-term residual and latent Impacts are known and are being monitored.


Biophysical liability estimate

Biophysical closure liability estimate:Current estimate excludes long-term water management and mitigation liability as well as biodiversity offset costs.

Reference:Preliminary Closure Plan and cost estimate for the mine – March 2019.

Class 5 estimate.

L: -30% to -50%.

H: +50% to +100%.




L: -20% to -50%.

H: +30% to +100%.


Class 4 estimate.

L: -15% to -30%.

H: +20% to +50%.


Class 4 estimate.

L: -15% to -30%.

H: +20% to +50%.


Class 3 estimate.

L: -10% to -20%.

H: +10% to +30%.


Class 2 estimate.

L: -5% to -15%.

H: +5% to +20%.


Class 1 estimate.

L: -3% to -10%.

H: +3% to +15%.


Class 1 estimate.

L: -3% to -10%.

H: +3% to +15%.



More than 25 years 25-15 years 15-10 years 10-5 years 5-0 years 0-15 years





Visual/aesthetic:The maximum height of the residue facilities was set at 60m, with 18-degree side slopes and full vegetation cover. Dust monitoring is taking place.

Reference:On-site monitoring programme; Environmental impact study. Land-use plan dated January 2018.

Assumed visual and sense of place impacts were based on available information of the local mining area.

An environmental impact assessment (including social) was undertaken and the visual, sense of place and heritage impacts were assessed, covering the full life cycle of the operation, including post closure phase impacts.


All gaps and unknown risks have been addressed through additional specialist studies, including landscape studies (if, appropriate), and all unknown risks and gaps have been closed with appropriate mitigation identified.

The closure criteria have been proven to be successful by means of successful onsite execution, and I&APs and authorities have been engaged at the appropriate level of influence and there is majority acceptance of the success and appropriateness of the mitigation measures.

The final landform designs are aligned with the closure vision and final land-uses and the authorities have agreed on the mitigation and rehabilitation methods and I&APs have been engaged at the appropriate level of Influence and there is majority agreement.

The mitigation measures have been successfully executed according to closure execution plan.

The residual risk profile is acceptable to I&APs and the authorities and the long-term sustainability of the solution have been proven to be successful (e.g. through monitoring).

The required closure criteria have been developed based on available information on similar rehabilitation requirements in the industry.

Operational management measures are in place, and the closure criteria have been developed and costed.


Operational management measures and closure criteria have been updated, and trials have taken place to demonstrate the effectiveness of the mitigation measures.

Operational management measures and closure criteria have been updated, and successful onsite execution has taken place with majority acceptance of I&APs.

Closure execution planning, scheduling and costing have been done to a PFS-B level, as per the AA IDM.

The detailed closure execution planning, scheduling and costing have been done and all execution documentation have been completed by improving the PFS-B study to that of a FS level, as per the AA IDM requirements.

The closure and post closure component to address the visual impacts, as well as the associated plans (including maintenance and management) have been approved an executed. Closure budget is available, and progress is measured and reported. Long-term residual and latent Impacts are known and are being monitored.


Biophysical liability estimate

Biophysical closure liability estimate:Current estimate excludes long-term water management and mitigation liability as well as biodiversity offset costs.


Class 5 estimate.

L: -30% to -50%.

H: +50% to +100%.




L: -20% to -50%.

H: +30% to +100%.


Class 4 estimate.

L: -15% to -30%.

H: +20% to +50%.


Class 4 estimate.

L: -15% to -30%.

H: +20% to +50%.


Class 3 estimate.

L: -10% to -20%.

H: +10% to +30%.


Class 2 estimate.

L: -5% to -15%.

H: +5% to +20%.


Class 1 estimate.

L: -3% to -10%.

H: +3% to +15%.


Class 1 estimate.

L: -3% to -10%.

H: +3% to +15%.








Social transition (including health)

Social transition criteria



Employees and their dependants:The mine currently employs 1000 permanent staff and 500 contract staff. The employees dependants have been estimated at a 1 to 4 ratio.

Reference:Presentation by mine – 5 June 2019. HR strategy and detailed 5 year plan dated December 2018.Detailed Health Impact Assessment (HIA) dated November 2017. Career development planning and employee training document dated May 2018.

The requirements of employees and social transition criteria aligned with the final land-uses have been assumed and only a rapid Health Impact Assessment (HIA) has been carried out at project commencement (see the Examples document – Example 10). Only an initial profile of the operation’s employees has been generated.

The needs of employees have been assumed and appropriate social transition criteria developed and costed.

A current HIA is in place and is updated as required, with ongoing occupational HRA conducted.

The needs of employees have been assessed and appropriate social transition criteria developed and costed (mostly operational expenditure and possibly some closure liabilities).

The previously identified socio-economic needs, including an in-depth HIA, as well as the closure vision are well recognised. These aspects have been discussed with employees and updated accordingly. A future forum consisting of management, representative employees, union representatives and community members is in place. The operation’s employees’ capabilities and career aspirations are known and there is alignment with the operations’ business plan.

The needs of employees have been reassessed and appropriate social transition criteria developed and costed (mostly operational expenditure and possibly some closure liabilities).

The confirmed social transition requirements and final land-use objectives have been identified in more detail through social transition planning and re-confirmed by means of employee involvement. A comprehensive, portable skills plan (development and redeployment), taking into account the requirements of the remainder of the business plan, as well as employees’ individual and community members’ social needs, are in place.

The needs of employees are known and appropriate social transition criteria developed and costed (mostly operational expenditure and possibly some closure liabilities).

Closure execution planning, scheduling and costing have been done to a PFS-B level, as per the AA IDM requirements with the key social transition deliverables being (but not limited to):

• Detailed Human Resources (HR) ramp down profile aligned with the decision on contractor vs. owner execution.

• Detailed reskilling and training programme.

• Detailed health plan, covering exit medicals and post closure health care plans.

• A review of the health components as conducted by an independent agency.


The closure and post closure component to address employee impacts, as well as the associated plans have been approved and executed.


Post closure budget is available for monitoring and maintenance phase, and progress is measured and reported long-term residual and latent Impacts are known and are being monitored.


No consultation specific to mine closure planning is required at this stage, as there is typically not a sufficiently detailed closure plan around which to consult. Discussion around mine closure with employees is focused on high level key messages.

Employees have been engaged at the appropriate level of influence related to the mine closure plan by providing them with balanced and objective information to improve their understanding of the issues, alternatives and/or solutions and to enable them to raise issues and concerns.

Employees have been given the opportunity to review the revised mine closure plan and be part of the closure plan development, by means of ongoing engagement with the operation. Feedback from stakeholders on issues, alternatives and/or decisions has been considered and incorporated into the closure plan, where appropriate.

Employees are directly engaged at the appropriate level of influence throughout the process, to ensure that issues and concerns are consistently understood andconsidered, and offered the opportunity to make substantive changes to the closure plan and its criteria, where appropriate.

The employees have been engaged at the appropriate level of influence in each aspect of the decision-making process, through which majority agreement with the mine closure plan and its final post-closure goals has been obtained.

SEP is in place to manage expectations and mitigate impacts during the decommissioning phase.

SEP is in place to manage expectations and mitigate impacts during the monitoring and maintenance phase.

Interested and Affected parties (I&APs):Neighbouring farmers, contractors, suppliers, local and tribal authorities, local schools as well as a few NGOs form part of the I&AP database.

Reference:Closure gap meeting held on 5 June 2019. SEP and I&AP database dated March 2018.

The requirements of I&APs and the social transition criteria and final land-use have been assumed and no community HIA has been completed (see the Examples document – Example 10). The needs of I&APs have been assumed and appropriate social transition criteria developed and costed.

GAP:1) Current level of confidence related to I&AP impacts and needs are not aligned with that required for a mine with between 15-10 years LoA.

Information on community health is obtained from appropriate sources (see AASW Section 4C: Community Health and Safety Management). The needs of I&APs have been assessed through a Social Impact Assessment (SIA). Appropriate social transition criteria (e.g. economic diversification and reduced long-term dependency on mining being a focus area) have been developed and costed (mostly operational expenditure and possibly some closure liabilities). (see AASW Section 4A: Socio-economic Development (SED) Planning.)

The previously identified socio-economic needs, health needs and the closure vision are well recognised. These aspects have been discussed with I&APs and updated accordingly. The operational budgets are geared towards addressing the social transition mitigation measures (e.g. economic diversification), by using current vehicles such as the AASW. The intention is to address all social transition requirements through operational management and not have any closure liabilities. Social transition criteria have been updated and costed (mostly operational expenditure).

The confirmed social transition requirements and final land-use objectives have been identified in more detail and re-confirmed by means of I&APs involvement. Impacts on community health and well-being are managed (mitigated and/or enhanced) in partnership with key stakeholders. The social transition process is managed through the AASW and success is tracked and measured to ensure an acceptable residual social risk profile post closure.

Execution planning, scheduling and costing have been done to a PFS-B level, as per the AA IDM requirements with the key social transition deliverables being (but not limited to):

• A review of the community health components by an independent agency (see Section 4C: Community Health and Safety Management).

• The operational management of the social transition can be demonstrated (e.g. economic diversification, reduced dependency on mining) and residual post closure social risk and costs have been identified.

The detailed execution planning, scheduling and costing have been done and all execution documentation have been completed by improving the PFS-B study to that of a FS level, as per the AA IDM requirements.

The residual closure components to address the social transition, as well as the associated plans have been approved an executed.


Post closure budget is available for monitoring and maintenance phase, and progress is measured and reported Long-term residual and latent Impacts are known and are being monitored.










Employees and their dependants:The mine currently employs 1000 permanent staff and 500 contract staff. The employees dependants have been estimated at a 1 to 4 ratio.

Reference:Presentation by mine – 5 June 2019. HR strategy and detailed 5 year plan dated December 2018.Detailed Health Impact Assessment (HIA) dated November 2017. Career development planning and employee training document dated May 2018.

The requirements of employees and social transition criteria aligned with the final land-uses have been assumed and only a rapid Health Impact Assessment (HIA) has been carried out at project commencement (see the Examples document – Example 10). Only an initial profile of the operation’s employees has been generated.

The needs of employees have been assumed and appropriate social transition criteria developed and costed.

A current HIA is in place and is updated as required, with ongoing occupational HRA conducted.

The needs of employees have been assessed and appropriate social transition criteria developed and costed (mostly operational expenditure and possibly some closure liabilities).

The previously identified socio-economic needs, including an in-depth HIA, as well as the closure vision are well recognised. These aspects have been discussed with employees and updated accordingly. A future forum consisting of management, representative employees, union representatives and community members is in place. The operation’s employees’ capabilities and career aspirations are known and there is alignment with the operations’ business plan.

The needs of employees have been reassessed and appropriate social transition criteria developed and costed (mostly operational expenditure and possibly some closure liabilities).

The confirmed social transition requirements and final land-use objectives have been identified in more detail through social transition planning and re-confirmed by means of employee involvement. A comprehensive, portable skills plan (development and redeployment), taking into account the requirements of the remainder of the business plan, as well as employees’ individual and community members’ social needs, are in place.

The needs of employees are known and appropriate social transition criteria developed and costed (mostly operational expenditure and possibly some closure liabilities).

Closure execution planning, scheduling and costing have been done to a PFS-B level, as per the AA IDM requirements with the key social transition deliverables being (but not limited to):

• Detailed Human Resources (HR) ramp down profile aligned with the decision on contractor vs. owner execution.

• Detailed reskilling and training programme.

• Detailed health plan, covering exit medicals and post closure health care plans.

• A review of the health components as conducted by an independent agency.


The closure and post closure component to address employee impacts, as well as the associated plans have been approved and executed.


Post closure budget is available for monitoring and maintenance phase, and progress is measured and reported long-term residual and latent Impacts are known and are being monitored.


No consultation specific to mine closure planning is required at this stage, as there is typically not a sufficiently detailed closure plan around which to consult. Discussion around mine closure with employees is focused on high level key messages.

Employees have been engaged at the appropriate level of influence related to the mine closure plan by providing them with balanced and objective information to improve their understanding of the issues, alternatives and/or solutions and to enable them to raise issues and concerns.

Employees have been given the opportunity to review the revised mine closure plan and be part of the closure plan development, by means of ongoing engagement with the operation. Feedback from stakeholders on issues, alternatives and/or decisions has been considered and incorporated into the closure plan, where appropriate.

Employees are directly engaged at the appropriate level of influence throughout the process, to ensure that issues and concerns are consistently understood andconsidered, and offered the opportunity to make substantive changes to the closure plan and its criteria, where appropriate.

The employees have been engaged at the appropriate level of influence in each aspect of the decision-making process, through which majority agreement with the mine closure plan and its final post-closure goals has been obtained.



Interested and Affected parties (I&APs):Neighbouring farmers, contractors, suppliers, local and tribal authorities, local schools as well as a few NGOs form part of the I&AP database.


The requirements of I&APs and the social transition criteria and final land-use have been assumed and no community HIA has been completed (see the Examples document – Example 10). The needs of I&APs have been assumed and appropriate social transition criteria developed and costed.

GAP:1) Current level of confidence related to I&AP impacts and needs are not aligned with that required for a mine with between 15-10 years LoA.

Information on community health is obtained from appropriate sources (see AASW Section 4C: Community Health and Safety Management). The needs of I&APs have been assessed through a Social Impact Assessment (SIA). Appropriate social transition criteria (e.g. economic diversification and reduced long-term dependency on mining being a focus area) have been developed and costed (mostly operational expenditure and possibly some closure liabilities). (see AASW Section 4A: Socio-economic Development (SED) Planning.)

The previously identified socio-economic needs, health needs and the closure vision are well recognised. These aspects have been discussed with I&APs and updated accordingly. The operational budgets are geared towards addressing the social transition mitigation measures (e.g. economic diversification), by using current vehicles such as the AASW. The intention is to address all social transition requirements through operational management and not have any closure liabilities. Social transition criteria have been updated and costed (mostly operational expenditure).

The confirmed social transition requirements and final land-use objectives have been identified in more detail and re-confirmed by means of I&APs involvement. Impacts on community health and well-being are managed (mitigated and/or enhanced) in partnership with key stakeholders. The social transition process is managed through the AASW and success is tracked and measured to ensure an acceptable residual social risk profile post closure.

Execution planning, scheduling and costing have been done to a PFS-B level, as per the AA IDM requirements with the key social transition deliverables being (but not limited to):

• A review of the community health components by an independent agency (see Section 4C: Community Health and Safety Management).

• The operational management of the social transition can be demonstrated (e.g. economic diversification, reduced dependency on mining) and residual post closure social risk and costs have been identified.

The detailed execution planning, scheduling and costing have been done and all execution documentation have been completed by improving the PFS-B study to that of a FS level, as per the AA IDM requirements.

The residual closure components to address the social transition, as well as the associated plans have been approved an executed.


Post closure budget is available for monitoring and maintenance phase, and progress is measured and reported Long-term residual and latent Impacts are known and are being monitored.










No consultation specific to mine closure planning is required at this stage, as typically there is not a sufficiently detailed closure plan around which to engage at the appropriate level of influence. If an appropriate plan does exist, engagement at the appropriate level of influence should be from cradle to cradle. High level key messages related to closure should be developed.

GAPS:1) Current level of confidence related to I&AP consultation is not aligned with that required for a mine with between 15-10 years LoA.

I&APs have been engaged at the appropriate level of influence related to the mine closure plan by providing them with balanced and objective information to improve their understanding of the issues, alternatives and/or solutions and to enable them to submit their issues and concerns.

I&APs have been given the opportunity to review the revised mine closure plan and be part of the closure plan development, by means of ongoing engagement with the operation at the appropriate level of influence. Feedback from stakeholders on issues, alternatives and/or decisions has been considered and incorporated into the closure plan, where appropriate.

I&APs are directly engaged at the appropriate level of Influence throughout the process, to ensure that issues and concerns are consistently understood and considered, and offered the opportunity to make substantive changes to the closure plan and its criteria, where appropriate.

The I&APs have been engaged at the appropriate level of influence in each aspect of the decision-making process, through which majority agreement with the mine closure plan and its final social transition and post-closure goals has been obtained.



Authorities:Regional and national (health and safety and environment and mineral regulations), Department of Water Affairs, Department of Environmental and Tourism Affairs, Department of Agriculture, Department of Labour, local authorities, Receiver of Revenue.

Reference:Closure gap meeting held on 5 June 2019. SEP and I&AP database dated March 2018. Authority engagement system – Closure module.

The requirements of authorities are known from the various legal processes, but the social transition criteria and final land-use have been assumed. The needs of the authorities have been assumed to align with the current legal commitments and no additional closure criteria have been developed. A basic legal risk register is in place covering the operational and closure phases.

Additional environmental and social studies have been conducted to improve the confidence in the closure plan, and the potential changes in closure impacts and associated closure criteria. Information on community health is available from public sources. The baseline environmental conditions are known, and the wider strategic socio-economic opportunities and constraints have been identified. A closure vision with underlying principles has been reviewed and improved. A legal risk register to ensure legal compliance during the operational, closure and post closure periods is in place including management plans and tracking tools.

The previously identified environmental mitigation requirements and socio-economic needs, including health, and the closure vision are well recognised. These aspects have been discussed with authorities and updated accordingly.

The legal risk register is maintained and continuously updated (live system).

The confirmed social transition/closure requirements and final land-use objectives have been identified in more detail through closure planning and re-confirmed by means of authority involvement. Impacts on community health and well-being are managed (mitigated and/or enhanced) in partnership with key stakeholders. The legal risk register is maintained and continuously updated (live system).

Closure execution planning, scheduling and costing have been done to a PFS-B level, as per the AA IDM requirements with the key regulatory deliverables being (but not limited to):

• An updated legal risk register including a management plan to ensure legal compliance during the closure and post closure periods (e.g. any new legal requirements due to changes in final closure plan).

• Master project execution schedule that outlines the regulatory process and key deliverable and milestones to achieve asset relinquishment.


The closure and post closure components to address the regulatory requirements, as well as the associated plans have been approved an executed.


Post closure budget is available for monitoring and maintenance phase to track and ensure legal compliance and asset relinquishment.


Authorities have been engaged through the various legal processes and the associated regulatory closure commitments made in this regard.

Authorities have been engaged at the appropriate level of influence and given the opportunity to develop and review the revised mine closure plan (where appropriate), by means of ongoing engagement with the operation.

Authorities have been engaged at the appropriate level of Influence and given the opportunity to develop and review the revised mine closure plan (where appropriate), by means of ongoing engagement with the operation. Feedback from stakeholders on issues, alternatives and/or decisions has been considered and incorporated into the closure plan, where appropriate.

Authorities are directly involved throughout the process, to ensure that issues and concerns are consistently understood and considered, and offered the opportunity to make substantive changes to the closure plan and its criteria, where appropriate.

The authorities have been engaged at the appropriate level of influence in each aspect of the decision-making process, through which majority agreement with the mine closure plan and its final post-closure goals has been obtained.

SEP is in place to also manage regulatory engagements during the decommissioning phase.

SEP is in place to also manage regulatory engagements during the monitoring and maintenance phase.







No consultation specific to mine closure planning is required at this stage, as typically there is not a sufficiently detailed closure plan around which to engage at the appropriate level of influence. If an appropriate plan does exist, engagement at the appropriate level of influence should be from cradle to cradle. High level key messages related to closure should be developed.


I&APs have been engaged at the appropriate level of influence related to the mine closure plan by providing them with balanced and objective information to improve their understanding of the issues, alternatives and/or solutions and to enable them to submit their issues and concerns.

I&APs have been given the opportunity to review the revised mine closure plan and be part of the closure plan development, by means of ongoing engagement with the operation at the appropriate level of influence. Feedback from stakeholders on issues, alternatives and/or decisions has been considered and incorporated into the closure plan, where appropriate.

I&APs are directly engaged at the appropriate level of Influence throughout the process, to ensure that issues and concerns are consistently understood and considered, and offered the opportunity to make substantive changes to the closure plan and its criteria, where appropriate.

The I&APs have been engaged at the appropriate level of influence in each aspect of the decision-making process, through which majority agreement with the mine closure plan and its final social transition and post-closure goals has been obtained.



Authorities:Regional and national (health and safety and environment and mineral regulations), Department of Water Affairs, Department of Environmental and Tourism Affairs, Department of Agriculture, Department of Labour, local authorities, Receiver of Revenue.

Reference:Closure gap meeting held on 5 June 2019. SEP and I&AP database dated March 2018. Authority engagement system – Closure module.

The requirements of authorities are known from the various legal processes, but the social transition criteria and final land-use have been assumed. The needs of the authorities have been assumed to align with the current legal commitments and no additional closure criteria have been developed. A basic legal risk register is in place covering the operational and closure phases.

Additional environmental and social studies have been conducted to improve the confidence in the closure plan, and the potential changes in closure impacts and associated closure criteria. Information on community health is available from public sources. The baseline environmental conditions are known, and the wider strategic socio-economic opportunities and constraints have been identified. A closure vision with underlying principles has been reviewed and improved. A legal risk register to ensure legal compliance during the operational, closure and post closure periods is in place including management plans and tracking tools.

The previously identified environmental mitigation requirements and socio-economic needs, including health, and the closure vision are well recognised. These aspects have been discussed with authorities and updated accordingly.

The legal risk register is maintained and continuously updated (live system).

The confirmed social transition/closure requirements and final land-use objectives have been identified in more detail through closure planning and re-confirmed by means of authority involvement. Impacts on community health and well-being are managed (mitigated and/or enhanced) in partnership with key stakeholders. The legal risk register is maintained and continuously updated (live system).

Closure execution planning, scheduling and costing have been done to a PFS-B level, as per the AA IDM requirements with the key regulatory deliverables being (but not limited to):

• An updated legal risk register including a management plan to ensure legal compliance during the closure and post closure periods (e.g. any new legal requirements due to changes in final closure plan).

• Master project execution schedule that outlines the regulatory process and key deliverable and milestones to achieve asset relinquishment.


The closure and post closure components to address the regulatory requirements, as well as the associated plans have been approved an executed.


Post closure budget is available for monitoring and maintenance phase to track and ensure legal compliance and asset relinquishment.


Authorities have been engaged through the various legal processes and the associated regulatory closure commitments made in this regard.

Authorities have been engaged at the appropriate level of influence and given the opportunity to develop and review the revised mine closure plan (where appropriate), by means of ongoing engagement with the operation.

Authorities have been engaged at the appropriate level of Influence and given the opportunity to develop and review the revised mine closure plan (where appropriate), by means of ongoing engagement with the operation. Feedback from stakeholders on issues, alternatives and/or decisions has been considered and incorporated into the closure plan, where appropriate.

Authorities are directly involved throughout the process, to ensure that issues and concerns are consistently understood and considered, and offered the opportunity to make substantive changes to the closure plan and its criteria, where appropriate.

The authorities have been engaged at the appropriate level of influence in each aspect of the decision-making process, through which majority agreement with the mine closure plan and its final post-closure goals has been obtained.

SEP is in place to also manage regulatory engagements during the decommissioning phase.

SEP is in place to also manage regulatory engagements during the monitoring and maintenance phase.









Stakeholder engagement:Current SEP focus mainly on the regulators and employees, with limited to no engagement with external I&APs.


The operation’s SEP must be in place and must include key concepts of closure planning, such as the closure vision, land-use plan, residual risk profile post closure the management of dependencies, and expectations including the requirement for socio-economic diversification. No detailed engagement on a closure plan is expected at this stage, as typically there is not a sufficiently detailed closure plan around which to engaged (except for operations with a very long LoA – more than 25 years). If an appropriate plan does exist, engagement at the appropriate level of influence should be from cradle to cradle.

The operation’s SEP must be updated to cover the current closure plan as a whole, focusing on getting general I&AP acceptance of the closure plan and associated closure criteria with the intent of delivering a set of acceptable “success criteria” linked to an acceptable closure vision and land-use plan. This will be achieved through ongoing engagement with I&APs and authorities at the appropriate level of influence and might also include capacity building around some technical subjects (e.g. AMD, landform design).


The operation’s SEP will focus on the updated closure plan, including the closure execution components, aiming to transfer ownership of the closure plan from the operation to the I&APs that will remain in the area post closure by getting approval for the “success criteria” linked to an agreed closure vision and land-use plan.

This will be achieved through engagement with I&APs at the appropriate level of nfluence and by directly involving authorities throughout the process, to ensure that issues and concerns are consistently understood and considered and offered the opportunity to make substantive changes to the closure plan and its closure and success criteria, where appropriate.

The current operational SEP have been updated to a PFS-B and subsequent FS level, as per the AA IDM requirements to focus on the closure and post closure phases, covering (but not limited to):

• A detailed communication strategy and plan, including key messaging, single lines of communication and clear understanding of the success criteria.

• Authorities and I&APs have been engaged at the appropriate level of influence in each aspect of the decision-making process, through which majority agreement with the mine closure plan and its final post-closure goals has been obtained.

The SEP is in place to manage to manage regulatory and I&AP engagements during the decommissioning phase.

The SEP is in place to manage to manage regulatory and I&AP engagements during the monitoring and maintenance phase.

Social liability estimate

Social transition liability estimate:All social transition costs are estimated and included in the operational budgets as part of the social performance strategy and execution plan.

Reference:Closure gap meeting held on 5 June 2019. SEP and I&AP database dated March 2018. Preliminary Closure Plan and cost estimate for the mine – March 2019.

Class 5 estimate.

L: -30% to -50%.

H: +50% to +100%.



L: -20% to -50%.

H: +30% to +100%.


GAPS:1) Current level of confidence in the cost estimate is not aligned with that required for a mine with between 15-10 years LoA.

Class 4 estimate.

L: -15% to -30%.

H: +20% to +50%.


Class 4 estimate.

L: -15% to -30%.

H: +20% to +50%.


Class 3 estimate.

L: -10% to -20%.

H: +10% to +30%.


Class 2 estimate.

L: -5% to -15%.

H: +5% to +20%.


Class 1 estimate.

L: -3% to -10%.

H: +3% to +15%.


Class 1 estimate.

L: -3% to -10%.

H: +3% to +15%.








Stakeholder engagement:Current SEP focus mainly on the regulators and employees, with limited to no engagement with external I&APs.


The operation’s SEP must be in place and must include key concepts of closure planning, such as the closure vision, land-use plan, residual risk profile post closure the management of dependencies, and expectations including the requirement for socio-economic diversification. No detailed engagement on a closure plan is expected at this stage, as typically there is not a sufficiently detailed closure plan around which to engaged (except for operations with a very long LoA – more than 25 years). If an appropriate plan does exist, engagement at the appropriate level of influence should be from cradle to cradle.

The operation’s SEP must be updated to cover the current closure plan as a whole, focusing on getting general I&AP acceptance of the closure plan and associated closure criteria with the intent of delivering a set of acceptable “success criteria” linked to an acceptable closure vision and land-use plan. This will be achieved through ongoing engagement with I&APs and authorities at the appropriate level of influence and might also include capacity building around some technical subjects (e.g. AMD, landform design).


The operation’s SEP will focus on the updated closure plan, including the closure execution components, aiming to transfer ownership of the closure plan from the operation to the I&APs that will remain in the area post closure by getting approval for the “success criteria” linked to an agreed closure vision and land-use plan.

This will be achieved through engagement with I&APs at the appropriate level of nfluence and by directly involving authorities throughout the process, to ensure that issues and concerns are consistently understood and considered and offered the opportunity to make substantive changes to the closure plan and its closure and success criteria, where appropriate.

The current operational SEP have been updated to a PFS-B and subsequent FS level, as per the AA IDM requirements to focus on the closure and post closure phases, covering (but not limited to):

• A detailed communication strategy and plan, including key messaging, single lines of communication and clear understanding of the success criteria.

• Authorities and I&APs have been engaged at the appropriate level of influence in each aspect of the decision-making process, through which majority agreement with the mine closure plan and its final post-closure goals has been obtained.

The SEP is in place to manage to manage regulatory and I&AP engagements during the decommissioning phase.

The SEP is in place to manage to manage regulatory and I&AP engagements during the monitoring and maintenance phase.

Social liability estimate

Social transition liability estimate:All social transition costs are estimated and included in the operational budgets as part of the social performance strategy and execution plan.

Reference:Closure gap meeting held on 5 June 2019. SEP and I&AP database dated March 2018. Preliminary Closure Plan and cost estimate for the mine – March 2019.

Class 5 estimate.

L: -30% to -50%.

H: +50% to +100%.



L: -20% to -50%.

H: +30% to +100%.


GAPS:1) Current level of confidence in the cost estimate is not aligned with that required for a mine with between 15-10 years LoA.

Class 4 estimate.

L: -15% to -30%.

H: +20% to +50%.


Class 4 estimate.

L: -15% to -30%.

H: +20% to +50%.


Class 3 estimate.

L: -10% to -20%.

H: +10% to +30%.


Class 2 estimate.

L: -5% to -15%.

H: +5% to +20%.


Class 1 estimate.

L: -3% to -10%.

H: +3% to +15%.


Class 1 estimate.

L: -3% to -10%.

H: +3% to +15%.







Other

Success criteria (physical, bio-physical, social and financial):Even though the operations have detailed closure criteria, a set of success criteria has not been developed to ensure there is alignment with the land-use plan and closure vision. No engagement related to acceptable success criteria has take place with the regulators.

Reference:Closure gap meeting held on 5 June 2019.

Indicative success criteria, covering the physical, bio-physical, social and financial components of closure planning have been developed (internal process only). The success criteria reflect the legal requirements, closure vision, the post-mining land-use, closure objectives and criteria, with an initial monitoring programme.

GAP:1) Current level of confidence related to the required success criteria is not aligned with that required for a mine with between 15-10 years LoA.

Success criteria have been improved to not only reflect the legal requirements, closure vision, post-mining land-use, closure objectives and criteria, but also include parameters for measuring the level of success through a monitoring programme that has been communicated to the authorities.

Updated success criteria have been established to reflect any changes to the post-mining land-use and include monitoring parameters including SMART targets to a defined level of success, and has been approved by authorities, with guidelines for acceptable standards and corrective actions.

Updated success criteria have been established to reflect any changes to the post-mining land-use and include monitoring parameters including SMART targets to a defined level of success, and have been approved by authorities, with guidelines for acceptable standards and corrective actions.

Progress against achieving the approved success criteria are being monitored and tracked by the operation and authorities, and corrective actions (e.g. maintenance) undertaken as required.

The achievement of the targets (success criteria) are being signed-off by the authorities, to enable the relinquishment of the leases.

Risk Assessment:Detailed risk assessment was completed in Q1 2019.

ReferenceUpdated closure risk assessment dated February 2019.

A mine closure and post closure risk assessment was undertaken (see the Examples document – Example 3 and Tool 1) covering the pre and post closure criteria ratings. Unknown risks have been identified and an action plan developed to close the gaps.

The closure and post closure risk assessment has been updated and previous gaps closed, so that most risks can be classified as either significant or insignificant and limited unknown risks remain. Significant and high residual risks have been identified and additional or alternative closure criteria or actions investigated and/or included to reduce the unacceptable residual risks to an acceptable level.

GAPS: The current risk assessment excludes the impacts from I&APs and long-term risks associated with surface and groundwater.

The closure and post closure risk assessment has been updated and all previous unknown risks have been re-classified as either significant or insignificant. Remaining significant and high residual risks have been identifying and additional or alternative closure criteria or actions investigated and/or included to reduce the unacceptable residual risks to an acceptable level.

The closure and post closure risk assessment has been updated and improved by including I&APs and authority inputs. The effectiveness of the controls (i.e. closure criteria) are measured (see the Examples document – Example 13).

The detailed closure and post closure risk assessment has been done to a PFS-B level, as per the AA IDM.

The detailed closure and post closure risk assessment is completed by improving the PFS-B study to that of a FS level, as per the AA IDM requirements.

The decommissioning plan includes all the risk controls associated with effective project execution and tracking in place.


The monitoring and maintenance plan include all the risk controls associated with effective project execution and tracking in place.





Other

Success criteria (physical, bio-physical, social and financial):Even though the operations have detailed closure criteria, a set of success criteria has not been developed to ensure there is alignment with the land-use plan and closure vision. No engagement related to acceptable success criteria has take place with the regulators.

Reference:Closure gap meeting held on 5 June 2019.

Indicative success criteria, covering the physical, bio-physical, social and financial components of closure planning have been developed (internal process only). The success criteria reflect the legal requirements, closure vision, the post-mining land-use, closure objectives and criteria, with an initial monitoring programme.

GAP:1) Current level of confidence related to the required success criteria is not aligned with that required for a mine with between 15-10 years LoA.

Success criteria have been improved to not only reflect the legal requirements, closure vision, post-mining land-use, closure objectives and criteria, but also include parameters for measuring the level of success through a monitoring programme that has been communicated to the authorities.

Updated success criteria have been established to reflect any changes to the post-mining land-use and include monitoring parameters including SMART targets to a defined level of success, and has been approved by authorities, with guidelines for acceptable standards and corrective actions.

Updated success criteria have been established to reflect any changes to the post-mining land-use and include monitoring parameters including SMART targets to a defined level of success, and have been approved by authorities, with guidelines for acceptable standards and corrective actions.

Progress against achieving the approved success criteria are being monitored and tracked by the operation and authorities, and corrective actions (e.g. maintenance) undertaken as required.

The achievement of the targets (success criteria) are being signed-off by the authorities, to enable the relinquishment of the leases.

Risk Assessment:Detailed risk assessment was completed in Q1 2019.

ReferenceUpdated closure risk assessment dated February 2019.

A mine closure and post closure risk assessment was undertaken (see the Examples document – Example 3 and Tool 1) covering the pre and post closure criteria ratings. Unknown risks have been identified and an action plan developed to close the gaps.

The closure and post closure risk assessment has been updated and previous gaps closed, so that most risks can be classified as either significant or insignificant and limited unknown risks remain. Significant and high residual risks have been identified and additional or alternative closure criteria or actions investigated and/or included to reduce the unacceptable residual risks to an acceptable level.

GAPS: The current risk assessment excludes the impacts from I&APs and long-term risks associated with surface and groundwater.

The closure and post closure risk assessment has been updated and all previous unknown risks have been re-classified as either significant or insignificant. Remaining significant and high residual risks have been identifying and additional or alternative closure criteria or actions investigated and/or included to reduce the unacceptable residual risks to an acceptable level.

The closure and post closure risk assessment has been updated and improved by including I&APs and authority inputs. The effectiveness of the controls (i.e. closure criteria) are measured (see the Examples document – Example 13).

The detailed closure and post closure risk assessment has been done to a PFS-B level, as per the AA IDM.

The detailed closure and post closure risk assessment is completed by improving the PFS-B study to that of a FS level, as per the AA IDM requirements.

The decommissioning plan includes all the risk controls associated with effective project execution and tracking in place.


The monitoring and maintenance plan include all the risk controls associated with effective project execution and tracking in place.








Other

Monitoring programme:A detailed monitoring and data management programme that covers all potential impact and risk areas identified in the closure plan is in place and is being funded through annual budgets.

Reference:Updated monitoring and data management programme dated December 2018.

An initial monitoring programme has been developed that covers all potential impact and risk areas identified in closure plan, but may not have been linked to success criteria. A high-level operational maintenance and management plan is in place to address potential issues (e.g. erosion, invasive species).

A detailed monitoring and data management programme has been developed that covers all potential impact and risk areas identified in the closure plan, is implemented, regularly reviewed and linked to success criteria as communicated to the authorities. A detailed operational maintenance and management plan is in place to address issues (e.g. erosion, invasive species, bare areas) with identified mitigation measures.

A detailed monitoring and data management programme that covers all potential impact and risk areas identified in the closure plan, is implemented, regularly reviewed, adapted according to current mine status and linked to the success criteria, as approved by the authorities. A detailed operational maintenance and management plan is in place to address issues (e.g. erosion, invasive species, bare areas), with identified adaptive measures to improve on the success of concurrent rehabilitation and to develop an optimal solution (sustainable in the long-term, executable and at acceptable costs). Actual costs of concurrent closure activities are tracked and reported in the operations financials.

GAP: Success criteria have not been developed to the appropriate level of confidence and not yet approved by the authorities.


A detailed monitoring and data management programme that covers all potential impact and risk areas identified in the closure plan, is implemented, and success tracked and reported to the authorities.

The achievement of the success criteria is monitored via the data management programme and reported to the authorities, to enable the relinquishment of the asset.

Financial requirements and risk assessment

Overall Cost Estimate (Accuracy vs. Maturity level):Initial estimate was completed, and this was updated by site staff.

Note: More assumptions made as part of identifying the closure criteria leads to lower levels of confidence in the estimate and not the methodology that is used for calculation.

Reference:Preliminary Closure Plan and cost estimate for the mine – March 2019; Updated mine closure estimate.

Class 5 estimate.

L: -30% to -50%.

H: +50% to +100%.



L: -20% to -50%.

H: +30% to +100%.

Contingency (P50) of 25%-40


Class 4 estimate.

L: -15% to -30%.

H: +20% to +50%.


Class 4 estimate.

L: -15% to -30%.

H: +20% to +50%.


Class 3 estimate.

L: -10% to -20%.

H: +10% to +30%.


Class 2 estimate.

L: -5% to -15%.

H: +5% to +20%.


Class 1 estimate.

L: -3% to -10%.

H: +3% to +15%.


Class 1 estimate.

L: -3% to -10%.

H: +3% to +15%.






Other

Monitoring programme:A detailed monitoring and data management programme that covers all potential impact and risk areas identified in the closure plan is in place and is being funded through annual budgets.

Reference:Updated monitoring and data management programme dated December 2018.

An initial monitoring programme has been developed that covers all potential impact and risk areas identified in closure plan, but may not have been linked to success criteria. A high-level operational maintenance and management plan is in place to address potential issues (e.g. erosion, invasive species).

A detailed monitoring and data management programme has been developed that covers all potential impact and risk areas identified in the closure plan, is implemented, regularly reviewed and linked to success criteria as communicated to the authorities. A detailed operational maintenance and management plan is in place to address issues (e.g. erosion, invasive species, bare areas) with identified mitigation measures.


GAP: Success criteria have not been developed to the appropriate level of confidence and not yet approved by the authorities.


A detailed monitoring and data management programme that covers all potential impact and risk areas identified in the closure plan, is implemented, and success tracked and reported to the authorities.

The achievement of the success criteria is monitored via the data management programme and reported to the authorities, to enable the relinquishment of the asset.


Overall Cost Estimate (Accuracy vs. Maturity level):Initial estimate was completed, and this was updated by site staff.

Note: More assumptions made as part of identifying the closure criteria leads to lower levels of confidence in the estimate and not the methodology that is used for calculation.

Reference:Preliminary Closure Plan and cost estimate for the mine – March 2019; Updated mine closure estimate.

Class 5 estimate.

L: -30% to -50%.

H: +50% to +100%.



L: -20% to -50%.

H: +30% to +100%.

Contingency (P50) of 25%-40


Class 4 estimate.

L: -15% to -30%.

H: +20% to +50%.


Class 4 estimate.

L: -15% to -30%.

H: +20% to +50%.


Class 3 estimate.

L: -10% to -20%.

H: +10% to +30%.


Class 2 estimate.

L: -5% to -15%.

H: +5% to +20%.


Class 1 estimate.

L: -3% to -10%.

H: +3% to +15%.


Class 1 estimate.

L: -3% to -10%.

H: +3% to +15%.









Estimate is based mainly on assumed closure criteria:

1) Low level of confidence in closure plan with 50% or more assumptions related to the closure criteria in the basis of the estimate.

GAP:1) Current level of confidence in the closure plan Is not aligned with that required for a mine with between 15-10 years LoA, as there are too many assumptions.

Estimate is based on reviewed closure criteria:

1) Medium level of confidence in closure plan with between 30% - 40% assumptions related to the closure criteria in the basis of the estimate.

Estimate is based on tested closure criteria:

1) High level of confidence in closure plan with between 20%-30% assumptions related to the closure criteria in the basis of the estimate.



Estimate is based on proven closure criteria:

1) High level of confidence in closure plan with between 10%- 15% assumptions related to the closure criteria in the basis of the estimate.


1) High level of confidence in closure plan with less than 10% assumptions related to the closure criteria in the basis of the estimate.

Estimate is based on actual historical onsite execution costs:




Overall closure schedule: Current level 2 mine schedule.

Reference:Mine closure programme and detailed level 2 schedule dated March 2019.

Level 1 Schedule, top down planning using high level milestones and key project events.

Level 2 Schedule, top downplanning using high levelmilestones and key project events.

Level 2 Schedule, top downplanning using high-level milestones and key project events. Semi-Detailed.


AA IDM requirements with the key scheduling deliverables being (but not limited to):• Level 4 Schedule, top down planning using key project events. Detailed with focus on identifying and verifying the critical path, key milestones and critical dependencies, long lead items and planning of early works.

Level 4 Schedule, top down planning using key project events. The detailed execution planning, scheduling and costing have been done and all execution documentation have been completed by improving the PFS-B study to that of a FS level, as per the AA IDM requirements.

Level 4 execution schedule, bottom up planning. Detailed, focused on accurately managing and verifying the critical path, near critical path(s), long lead items and planning of ongoing works.

Target Schedule Accuracy of ±50%.




Target Schedule Accuracy of ±20%. Target Schedule Accuracy of ±15%.



Overall financial model and cash flow:Detailed cash flow linked to the closure schedule is available.

Reference:Cashflow dated March 2019.

The initial cashflow is linked to the closure schedule. Detailed cash flow linked to the closure schedule. Final cash flow linked to the closure schedule.

Final cash flow linked to the closure schedule.

Final cash flow linked to execution schedule.

Final cash flow linked to monitoring and maintenance schedule.

(Class 5). (Class 4). (Class 3). (Class 2). (Class 1). (Class 1).

Financial provision:Insurance policy and some guarantees are currently in place.


Select funding method. Financial provision (Class 5).


Financial provision (Class 4). Financial provision (Class 3).

Financial provision (Class 2).

Financial provision/Budget (Class 1).


Mine closure plan (Based on overall confidence):Preliminary Closure Plan and cost estimate for the mine – March 2019.


Preliminary mine closure plan.

GAP:1) For the closure plan to be a “Draft closure plan”, all the gaps as identified in this assessment needs to be addressed (No highlighted columns to the left of the “15-10 year”column).

Draft mine closure plan. Detailed mine closure plan. Final mine closure plan and associated closure execution plan (PFS-B Level).

Final mine closure plan and associated closure execution plan (FS Level).

Closure execution plan, with detailed annual plans, budgets and schedules.

Detailed closure monitoring and maintenance execution plan with detailed annual plans, budgets and schedules.






Estimate is based mainly on assumed closure criteria:

1) Low level of confidence in closure plan with 50% or more assumptions related to the closure criteria in the basis of the estimate.

GAP:1) Current level of confidence in the closure plan Is not aligned with that required for a mine with between 15-10 years LoA, as there are too many assumptions.

Estimate is based on reviewed closure criteria:

1) Medium level of confidence in closure plan with between 30% - 40% assumptions related to the closure criteria in the basis of the estimate.






1) High level of confidence in closure plan with between 10%- 15% assumptions related to the closure criteria in the basis of the estimate.







Overall closure schedule: Current level 2 mine schedule.

Reference:Mine closure programme and detailed level 2 schedule dated March 2019.

Level 1 Schedule, top down planning using high level milestones and key project events.

Level 2 Schedule, top downplanning using high levelmilestones and key project events.



AA IDM requirements with the key scheduling deliverables being (but not limited to):• Level 4 Schedule, top down planning using key project events. Detailed with focus on identifying and verifying the critical path, key milestones and critical dependencies, long lead items and planning of early works.

Level 4 Schedule, top down planning using key project events. The detailed execution planning, scheduling and costing have been done and all execution documentation have been completed by improving the PFS-B study to that of a FS level, as per the AA IDM requirements.

Level 4 execution schedule, bottom up planning. Detailed, focused on accurately managing and verifying the critical path, near critical path(s), long lead items and planning of ongoing works.





Target Schedule Accuracy of ±20%. Target Schedule Accuracy of ±15%.



Overall financial model and cash flow:Detailed cash flow linked to the closure schedule is available.

Reference:Cashflow dated March 2019.

The initial cashflow is linked to the closure schedule. Detailed cash flow linked to the closure schedule. Final cash flow linked to the closure schedule.

Final cash flow linked to the closure schedule.

Final cash flow linked to execution schedule.

Final cash flow linked to monitoring and maintenance schedule.

(Class 5). (Class 4). (Class 3). (Class 2). (Class 1). (Class 1).

Financial provision:Insurance policy and some guarantees are currently in place.


Select funding method. Financial provision (Class 5).


Financial provision (Class 4). Financial provision (Class 3).

Financial provision (Class 2).



Mine closure plan (Based on overall confidence):Preliminary Closure Plan and cost estimate for the mine – March 2019.


Preliminary mine closure plan.

GAP:1) For the closure plan to be a “Draft closure plan”, all the gaps as identified in this assessment needs to be addressed (No highlighted columns to the left of the “15-10 year”column).

Draft mine closure plan. Detailed mine closure plan. Final mine closure plan and associated closure execution plan (PFS-B Level).

Final mine closure plan and associated closure execution plan (FS Level).

Closure execution plan, with detailed annual plans, budgets and schedules.

Detailed closure monitoring and maintenance execution plan with detailed annual plans, budgets and schedules.


APPENDIX B: COMPLETED MASTER ACTION PLAN

RACI

ID number Source Main Task Name Sub Task Name Duration Start Finish Responsible Accountable Consult Inform % Complete

1 MCT V3 – Gap Analysis (5 June 2019).

Update physical closure criteria for infrastructure (on and off-site).

Define demolition waste disposal and recycling requirements and volumes in sufficient detail.

20 days Tue 19/05/28 Mon 19/06/24

Engineering. Head of Engineering.

Environmental; Survey; Legal; Closure.

Security. 0%



Include closure related engagement sessions into the current SEP to confirm the acceptability of the closure criteria, especially related to social infrastructure (e.g. on-site housing).

20 days Tue 19/05/28 Mon 19/06/24

Social Performance. Head of Social Performance.

Community Liaison; Legal; Environmental; Closure.

Exco team. 0%


Update physical closure criteria for mineral waste landforms.

Complete additional kinetic testing and update the landform designs as required.

100 days Tue 19/05/28 Mon 19/10/14

Closure. Head of SSD. Mining; Engineering; Safety; Environmental.

Security. 0%



Review the effectiveness and long-term sustainability of water management structures and measures are improved as required.

10 days Tue 19/05/28 Mon 19/06/10


Environmental; Survey; Legal; Social Performance; Closure.

Security. 0%



Develop an maintain a live system to track the detailed balance for hostile and non-hostile material to ensure no shortfall in materials to execute the closure plan.

40 days Tue 19/05/28 Mon 19/07/22 Information and systems management.

Head of IT. Environmental; Engineering; Processing.

Social Performace; Legal.

0%



Demonstrate the executability of the closure criteria and the cost effectiveness of the designs by on-site execution and rehabilitation.

240 days Tue 19/05/28 Mon 20/04/27

Closure. Head of SSD. Mining; Engineering; Processing; Safety; Environmental.

Security; Social Performance.

0%



Tracking the effectiveness of management measures and closure criteria to improve long-term stability and reduce costs.

240 days Tue 19/05/28 Mon 20/04/27



0%



Update the monitoring programme to track and measure successful on-site containment and remediation.

20 days Tue 20/04/28 Mon 20/05/25

Environmental. Head of SSD. Mining; Engineering; Processing; Safety; Closure.


0%



Review and update the LoA plans to ensure it allows for sufficient available areas to undertake landform closure execution (shaping and rehabilitation).

60 days Tue 20/05/26 Mon 20/08/17

Mining. Head of Mining. Environmental; Engineering; Processing; Safety; Closure.


0%


Update physical closure criteria for non-mineral waste.

Develop a set of success criteria to make sure there is alignment with the closure criteria and the final land-use plan and closure vision.

40 days Tue 20/05/26 Mon 20/07/20 Closure. Head of SSD. Mining; Engineering; Processing; Safety; Social Performance; Legal; Environmental.

Security. 0%


Update physical closure criteria rerated to the mining area.

Review previous closure criteria and updated by doing a site-specific investigation into the closure methodology as well as focused benchmarking.

60 days Tue 19/05/28 Mon 19/08/19

Closure. Head of SSD. Mining; Engineering; Processing; Safety; Social Performance; Legal; Environmental; Security.

Exco team. 0%



Improve the granularity of the criteria (BoE) by including decommissioning, closure and long-term monitoring and maintenance requirements, and costs for the mining area.

20 days Tue 19/09/10 Mon 19/10/07


Exco team. 0%



Develop and include the detailed geotechnical and geochemical stability design requirements into a predictive model to quantify and manage the associated risks (e.g. pit break back zones identification, subsurface support deterioration and subsequent surface settlement, long-term metal leaching due to AMD).

90 days Tue 19/05/28 Mon 19/09/30

Environmental. Head of SSD. Mining; Processing; Safety; Social Performance; Legal; Closure.

Engineering. 0%



Develop detailed operation and closure designs to identify and maintain long-term ZoI (failure zones), covering people and the environment, needs to be in place .

60 days Tue 19/05/28 Mon 19/08/19


Exco team. 0%



Develop detailed security plans to not only address operational risks but also the projected future closure and post closure risk components such as long-term access control and others safety and security risks.

40 days Tue 19/05/28 Mon 19/07/22 Security. Head of Security. Mining; Engineering; Processing; Safety; Social Performance; Legal; Environmental; Closure.

Exco team. 0%



Complete detailed studies to address long-term impacts on surface and underground water resources (e.g. pit water quality, future decant, interconnectivity of groundwater between mines, health impacts on people).

90 days Tue 19/05/28 Mon 19/09/30


Engineering. 0%


RACI




Define demolition waste disposal and recycling requirements and volumes in sufficient detail.

20 days Tue 19/05/28 Mon 19/06/24


Environmental; Survey; Legal; Closure.

Security. 0%



Include closure related engagement sessions into the current SEP to confirm the acceptability of the closure criteria, especially related to social infrastructure (e.g. on-site housing).

20 days Tue 19/05/28 Mon 19/06/24



Exco team. 0%



Complete additional kinetic testing and update the landform designs as required.

100 days Tue 19/05/28 Mon 19/10/14

Closure. Head of SSD. Mining; Engineering; Safety; Environmental.

Security. 0%



Review the effectiveness and long-term sustainability of water management structures and measures are improved as required.

10 days Tue 19/05/28 Mon 19/06/10


Environmental; Survey; Legal; Social Performance; Closure.

Security. 0%



Develop an maintain a live system to track the detailed balance for hostile and non-hostile material to ensure no shortfall in materials to execute the closure plan.

40 days Tue 19/05/28 Mon 19/07/22 Information and systems management.

Head of IT. Environmental; Engineering; Processing.


0%



Demonstrate the executability of the closure criteria and the cost effectiveness of the designs by on-site execution and rehabilitation.

240 days Tue 19/05/28 Mon 20/04/27



0%



Tracking the effectiveness of management measures and closure criteria to improve long-term stability and reduce costs.

240 days Tue 19/05/28 Mon 20/04/27



0%



Update the monitoring programme to track and measure successful on-site containment and remediation.

20 days Tue 20/04/28 Mon 20/05/25

Environmental. Head of SSD. Mining; Engineering; Processing; Safety; Closure.


0%



Review and update the LoA plans to ensure it allows for sufficient available areas to undertake landform closure execution (shaping and rehabilitation).

60 days Tue 20/05/26 Mon 20/08/17

Mining. Head of Mining. Environmental; Engineering; Processing; Safety; Closure.


0%


Update physical closure criteria for non-mineral waste.

Develop a set of success criteria to make sure there is alignment with the closure criteria and the final land-use plan and closure vision.

40 days Tue 20/05/26 Mon 20/07/20 Closure. Head of SSD. Mining; Engineering; Processing; Safety; Social Performance; Legal; Environmental.

Security. 0%



Review previous closure criteria and updated by doing a site-specific investigation into the closure methodology as well as focused benchmarking.

60 days Tue 19/05/28 Mon 19/08/19


Exco team. 0%



Improve the granularity of the criteria (BoE) by including decommissioning, closure and long-term monitoring and maintenance requirements, and costs for the mining area.

20 days Tue 19/09/10 Mon 19/10/07


Exco team. 0%



Develop and include the detailed geotechnical and geochemical stability design requirements into a predictive model to quantify and manage the associated risks (e.g. pit break back zones identification, subsurface support deterioration and subsequent surface settlement, long-term metal leaching due to AMD).

90 days Tue 19/05/28 Mon 19/09/30


Engineering. 0%



Develop detailed operation and closure designs to identify and maintain long-term ZoI (failure zones), covering people and the environment, needs to be in place .

60 days Tue 19/05/28 Mon 19/08/19


Exco team. 0%



Develop detailed security plans to not only address operational risks but also the projected future closure and post closure risk components such as long-term access control and others safety and security risks.

40 days Tue 19/05/28 Mon 19/07/22 Security. Head of Security. Mining; Engineering; Processing; Safety; Social Performance; Legal; Environmental; Closure.

Exco team. 0%



Complete detailed studies to address long-term impacts on surface and underground water resources (e.g. pit water quality, future decant, interconnectivity of groundwater between mines, health impacts on people).

90 days Tue 19/05/28 Mon 19/09/30


Engineering. 0%


RACI




Review the updated closure criteria as defined and costed for the mining areas (final voids, shafts, adits) to ensure alignment with the final closure vision and land-use plan.

10 days Tue 19/10/08 Mon 19/10/21


Exco team. 0%


Update physical closure cost estimate. Develop a Class 4 estimate (L: -15% to -30% with H: +20% to +50% and contingency (P50) of 20% -30%), as required for a mine with a LoA of 15-10 years.

20 days Tue 20/08/18 Mon 20/09/14

Finance. Head of Finance. Mining; Engineering; Processing; Safety; Social Performance; Legal; Environmental; Security.

Exco team. 0%


Update Biophysical closure and rehabilitation criteria related to land-use and land capability.

Include appropriate engagement sessions with I&AP in the current SEP to get focused inputs and subsequent broadly external acceptance of the land-use and land capability plan.

40 days Tue 20/04/28 Mon 20/06/22



Exco team. 0%



Develop and conduct a research programmes to understand seed dormancies.

240 days Tue 19/05/28 Mon 20/04/27

Environmental. Head of SSD. Social Performance; Closure.

Legal. 0%


Update Biophysical closure and rehabilitation criteria related to surface and groundwater.

Do a detailed closure and post-closure impact assessment to cover the surface and groundwater impacts, including additional specialist studies.

80 days Tue 19/05/28 Mon 19/09/16

Closure. Head of SSD. Mining; Engineering; Processing; Social Performance; Legal; Environmental.

Safety; Finance.

0%



Update the closure risk assessment and communicate the significant and insignificant risks to I&APs for comment.

40 days Tue 19/05/28 Mon 19/07/22 Closure. Head of SSD. Mining; Engineering; Processing; Social Performance; Legal; Environmental; Safety; Security.

Exco team. 0%



Develop a detailed solute transfer mode; with a integrated surface and groundwater numerical; and geochemical model; and associated storm water management structures and systems, that are costed in the closure liability are in place.

100 days Tue 19/05/28 Mon 19/10/14

Environmental. Head of SSD. Mining; Processing; Safety; Social Performance; Legal; Closure; Engineering; Finance.

Exco team. 0%



Develop detailed closure criteria using updated and detailed site wide water and solute balance and water management plan for LoA, including all inflows and outflows.

20 days Tue 20/06/23 Mon 20/07/20 Closure. Head of SSD. Mining; Engineering; Processing; Safety; Social Performance; Legal; Environmental; Security.

Exco team. 0%


Update Biophysical closure and rehabilitation criteria related to visual impacts/requirements.

Conduct additional specialist studies, including landscape studies to ensure that all unknown risks and gaps have been closed and the appropriate mitigation identified.

120 days Tue 19/05/28 Mon 19/11/11


Exco team. 0%



Update operational management measures and implement trials to demonstrate the effectiveness of the mitigation measures.

60 days Tue 19/11/12 Mon 20/02/03


Engineering. 0%


Update Biophysical closure cost estimate. Develop a Class 4 estimate (L: -15% to -30% with H: +20% to +50% and contingency (P50) of 20% -30%), as required for a mine with a LoA of 15-10 years.

20 days Tue 20/07/21 Mon 20/08/17


Exco team. 0%


Update Social transition requirements /criteria related to I&APs.

Assess the needs of I&APs through an SIA. 60 days Tue 19/05/28 Mon 19/08/19



Exco team. 0%



Develop appropriate social transition criteria (e.g. economic diversification and reduced long-term dependency on mining being a focus area) and associated costs (mostly operational expenditure and possibly some closure liabilities).

90 days Tue 19/08/20 Mon 19/12/23



Exco team. 0%



Ensure that the operational budgets are geared towards addressing the social transition mitigation measures (e.g. economic diversification), by using current vehicles such as the Anglo Social Way.

20 days Tue 19/12/24 Mon 20/01/20



Exco team. 0%

APPENDIX B: COMPLETED MASTER ACTION PLAN (completed)


RACI




Review the updated closure criteria as defined and costed for the mining areas (final voids, shafts, adits) to ensure alignment with the final closure vision and land-use plan.

10 days Tue 19/10/08 Mon 19/10/21


Exco team. 0%


Update physical closure cost estimate. Develop a Class 4 estimate (L: -15% to -30% with H: +20% to +50% and contingency (P50) of 20% -30%), as required for a mine with a LoA of 15-10 years.

20 days Tue 20/08/18 Mon 20/09/14


Exco team. 0%



Include appropriate engagement sessions with I&AP in the current SEP to get focused inputs and subsequent broadly external acceptance of the land-use and land capability plan.

40 days Tue 20/04/28 Mon 20/06/22



Exco team. 0%



Develop and conduct a research programmes to understand seed dormancies.

240 days Tue 19/05/28 Mon 20/04/27

Environmental. Head of SSD. Social Performance; Closure.

Legal. 0%



Do a detailed closure and post-closure impact assessment to cover the surface and groundwater impacts, including additional specialist studies.

80 days Tue 19/05/28 Mon 19/09/16

Closure. Head of SSD. Mining; Engineering; Processing; Social Performance; Legal; Environmental.

Safety; Finance.

0%



Update the closure risk assessment and communicate the significant and insignificant risks to I&APs for comment.

40 days Tue 19/05/28 Mon 19/07/22 Closure. Head of SSD. Mining; Engineering; Processing; Social Performance; Legal; Environmental; Safety; Security.

Exco team. 0%



Develop a detailed solute transfer mode; with a integrated surface and groundwater numerical; and geochemical model; and associated storm water management structures and systems, that are costed in the closure liability are in place.

100 days Tue 19/05/28 Mon 19/10/14

Environmental. Head of SSD. Mining; Processing; Safety; Social Performance; Legal; Closure; Engineering; Finance.

Exco team. 0%



Develop detailed closure criteria using updated and detailed site wide water and solute balance and water management plan for LoA, including all inflows and outflows.


Exco team. 0%



Conduct additional specialist studies, including landscape studies to ensure that all unknown risks and gaps have been closed and the appropriate mitigation identified.

120 days Tue 19/05/28 Mon 19/11/11


Exco team. 0%



Update operational management measures and implement trials to demonstrate the effectiveness of the mitigation measures.

60 days Tue 19/11/12 Mon 20/02/03


Engineering. 0%


Update Biophysical closure cost estimate. Develop a Class 4 estimate (L: -15% to -30% with H: +20% to +50% and contingency (P50) of 20% -30%), as required for a mine with a LoA of 15-10 years.

20 days Tue 20/07/21 Mon 20/08/17


Exco team. 0%



Assess the needs of I&APs through an SIA. 60 days Tue 19/05/28 Mon 19/08/19



Exco team. 0%



Develop appropriate social transition criteria (e.g. economic diversification and reduced long-term dependency on mining being a focus area) and associated costs (mostly operational expenditure and possibly some closure liabilities).

90 days Tue 19/08/20 Mon 19/12/23



Exco team. 0%



Ensure that the operational budgets are geared towards addressing the social transition mitigation measures (e.g. economic diversification), by using current vehicles such as the Anglo Social Way.

20 days Tue 19/12/24 Mon 20/01/20



Exco team. 0%


RACI



Update social transition requirements /criteria related to I&APs.

Give I&APs the opportunity to review the revised mine closure plan and be part of the closure plan development, by means of ongoing engagement with the operation at the appropriate level of influence.

20 days Tue 19/05/28 Mon 19/06/24


Exco team. 0%



Consider feedback from stakeholders on issues, alternatives and/or decisions and incorporated into the closure plan, where appropriate.


Exco team. 0%


Update social transition requirements related to SEP.

Update the operation’s SEP to focus on the updated closure plan, including the closure execution components, aiming to transfer ownership of the closure plan from the operation to the I&APs that will remain in the area post closure.

10 days Tue 20/12/15 Mon 20/12/28



Exco team. 0%



Engage with I&APs at the appropriate level of Influence to ensure that issues and concerns are consistently understood and considered and offered the opportunity to make substantive changes to the closure plan and its closure and success criteria, where appropriate.

240 days Tue 19/05/28 Mon 20/04/27


Exco team. 0%


Update social transition cost estimate. Develop a Class 4 estimate (L: -15% to -30% with H: +20% to +50% and contingency (P50) of 20%-30%), as required for a mine with a LoA of 15-10 years.

20 days Tue 20/01/21 Mon 20/02/17


Exco team. 0%


Update success criteria and monitoring programme.

Develop updated success criteria to reflect any changes to the post-mining land-use and include monitoring parameters including SMART targets to a defined level of success.

90 days Tue 20/05/19 Mon 20/09/21


Exco team. 0%



Get the success criteria approved by authorities, with guidelines for acceptable standards and corrective actions.

60 days Tue 20/09/22 Mon 20/12/14


Exco team. 0%


Update the current risk assessment. Identify any remaining significant and high residual risks and include additional or alternative closure criteria or actions to reduce the unacceptable residual risks to an acceptable level.

10 days Tue 20/09/22 Mon 20/10/05


Exco team. 0%


Improve the overall cost estimate accuracy and confidence.

Develop a Class 4 estimate (L: -15% to -30% with H: +20% to +50% and contingency (P50) of 20%-30%), as required for a mine with a LoA of 15-10 years.

20 days Tue 20/10/06 Mon 20/11/02


Exco team. 0%



Improve the level of confidence in closure plan by reducing the assumptions related to the closure criteria in the basis of the estimate to between 20%-30%.

10 days Tue 20/10/06 Mon 20/10/19


Exco team. 0%


Update the overall financial provision. Update the financial provision to align with a level 4 estimate.

10 days Tue 20/11/03 Mon 20/11/16


Exco team. 0%


Update the overall mine closure plan. Update the overall mine closure plan to a “Draft” mine closure plan.

20 days Tue 20/11/17 Mon 20/12/14


Exco team. 0%

APPENDIX B: COMPLETED MASTER ACTION PLAN (completed)


RACI




Give I&APs the opportunity to review the revised mine closure plan and be part of the closure plan development, by means of ongoing engagement with the operation at the appropriate level of influence.

20 days Tue 19/05/28 Mon 19/06/24


Exco team. 0%



Consider feedback from stakeholders on issues, alternatives and/or decisions and incorporated into the closure plan, where appropriate.


Exco team. 0%



Update the operation’s SEP to focus on the updated closure plan, including the closure execution components, aiming to transfer ownership of the closure plan from the operation to the I&APs that will remain in the area post closure.

10 days Tue 20/12/15 Mon 20/12/28



Exco team. 0%



Engage with I&APs at the appropriate level of Influence to ensure that issues and concerns are consistently understood and considered and offered the opportunity to make substantive changes to the closure plan and its closure and success criteria, where appropriate.

240 days Tue 19/05/28 Mon 20/04/27


Exco team. 0%


Update social transition cost estimate. Develop a Class 4 estimate (L: -15% to -30% with H: +20% to +50% and contingency (P50) of 20%-30%), as required for a mine with a LoA of 15-10 years.

20 days Tue 20/01/21 Mon 20/02/17


Exco team. 0%



Develop updated success criteria to reflect any changes to the post-mining land-use and include monitoring parameters including SMART targets to a defined level of success.

90 days Tue 20/05/19 Mon 20/09/21


Exco team. 0%



Get the success criteria approved by authorities, with guidelines for acceptable standards and corrective actions.

60 days Tue 20/09/22 Mon 20/12/14


Exco team. 0%


Update the current risk assessment. Identify any remaining significant and high residual risks and include additional or alternative closure criteria or actions to reduce the unacceptable residual risks to an acceptable level.

10 days Tue 20/09/22 Mon 20/10/05


Exco team. 0%



Develop a Class 4 estimate (L: -15% to -30% with H: +20% to +50% and contingency (P50) of 20%-30%), as required for a mine with a LoA of 15-10 years.

20 days Tue 20/10/06 Mon 20/11/02


Exco team. 0%



Improve the level of confidence in closure plan by reducing the assumptions related to the closure criteria in the basis of the estimate to between 20%-30%.

10 days Tue 20/10/06 Mon 20/10/19


Exco team. 0%


Update the overall financial provision. Update the financial provision to align with a level 4 estimate.

10 days Tue 20/11/03 Mon 20/11/16


Exco team. 0%


Update the overall mine closure plan. Update the overall mine closure plan to a “Draft” mine closure plan.

20 days Tue 20/11/17 Mon 20/12/14


Exco team. 0%


APPENDIX C: COMPLETED MASTER ACTION PLAN SCHEDULE

ID Task Mode Task Name Duration Start Finish

1 Draft Mine Closure Plan Development 415 days Tue 19/05/28 Mon 20/12/282 Physical Closure 340 days Tue 19/05/28 Mon 20/09/143 Update physical closure criteria for infrastructure (on and off‐site) 20 days Tue 19/05/28 Mon 19/06/244 Define demolition waste disposal and recycling requirements and volumes. 20 days Tue 19/05/28 Mon 19/06/245 Include closure related engagement sessions into the current SEP. 20 days Tue 19/05/28 Mon 19/06/246 Update physical closure criteria for mineral waste landforms 320 days Tue 19/05/28 Mon 20/08/177 Complete additional kinetic testing & update the landform designs. 100 days Tue 19/05/28 Mon 19/10/148 Review the effectiveness & sustainability of water management structures. 10 days Tue 19/05/28 Mon 19/06/109 Develop a live system to track the material balance for hostile and non‐hostile material. 40 days Tue 19/05/28 Mon 19/07/2210 Demonstrate the executability of the closure criteria & cost effectiveness. 240 days Tue 19/05/28 Mon 20/04/2711 Tracking management measures and closure criteria to improve stability and reduce costs. 240 days Tue 19/05/28 Mon 20/04/2712 Update the monitoring program. 20 days Tue 20/04/28 Mon 20/05/2513 Review and update the LoM plans to include landform closure execution. 60 days Tue 20/05/26 Mon 20/08/1714 Update physical closure criteria for non‐mineral waste 40 days Tue 20/05/26 Mon 20/07/2015 Develop success criteria aligned with the closure criteria; final land use & closure vision. 40 days Tue 20/05/26 Mon 20/07/2016 Update physical closure criteria related to the mining area 105 days Tue 19/05/28 Mon 19/10/2117 Review previous closure criteria and do focused benchmarking. 60 days Tue 19/05/28 Mon 19/08/1918 Improve the granularity of the criteria (Basis of Estimate). 20 days Tue 19/09/10 Mon 19/10/0719 Include geotechnical & geochemical stability design requirements into a predictive model. 90 days Tue 19/05/28 Mon 19/09/3020 Develop detailed operation and closure designs. 60 days Tue 19/05/28 Mon 19/08/1921 Develop detailed security plans. 40 days Tue 19/05/28 Mon 19/07/2222 Complete detail studies on long‐term impacts on surface and underground water resources. 90 days Tue 19/05/28 Mon 19/09/3023 Review the updated closure criteria a to align with the final closure vision & land use plan. 10 days Tue 19/10/08 Mon 19/10/2124 Update physical closure cost estimate 20 days Tue 20/08/18 Mon 20/09/1425 Develop a Class 4 estimate. 20 days Tue 20/08/18 Mon 20/09/1426 Biophysical closure 320 days Tue 19/05/28 Mon 20/08/1727 Update Biophysical closure and rehabilitation criteria related to land use and land capability. 280 days Tue 19/05/28 Mon 20/06/2228 Include appropriate engagement sessions with I&AP on land‐use and land capability plan. 40 days Tue 20/04/28 Mon 20/06/2229 Research programs to understand seed dormancies. 240 days Tue 19/05/28 Mon 20/04/2730 Update Biophysical closure and rehabilitation criteria related to surface and groundwater. 300 days Tue 19/05/28 Mon 20/07/2031 Do a detailed closure & post‐closure impact assessment and additional specialist studies. 80 days Tue 19/05/28 Mon 19/09/1632 Update the closure risk assessment and communicate risks to I&APs for comment. 40 days Tue 19/05/28 Mon 19/07/2233 Develop a detailed solute transfer model that are costed & liability is in place. 100 days Tue 19/05/28 Mon 19/10/1434 Develop detailed closure criteria. 20 days Tue 20/06/23 Mon 20/07/2035 Update Biophysical closure and rehabilitation criteria related to visual impacts / requirements. 180 days Tue 19/05/28 Mon 20/02/0336 Conduct additional specialist studies, including landscape studies. 120 days Tue 19/05/28 Mon 19/11/1137 Update operational management measures and implement trials. 60 days Tue 19/11/12 Mon 20/02/0338 Update Biophysical closure cost estimate. 20 days Tue 20/07/21 Mon 20/08/1739 Develop a Class 4 estimate. 20 days Tue 20/07/21 Mon 20/08/1740 Social Transition 415 days Tue 19/05/28 Mon 20/12/2841 Update Social transition requirements / criteria related to I&APs 170 days Tue 19/05/28 Mon 20/01/2042 Assess the needs of I&APs through a Social Impact Assessment (SIA). 60 days Tue 19/05/28 Mon 19/08/19

AprMayJun JulAugSepOctNovDecJanFebMarAprMayJun JulAugSepOctNovDecJanF2nd Quart 3rd Quarte4th Quarte1st Quarte2nd Quart 3rd Quarte4th Quarte1st

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Project: Master Action Plan ExaDate: Wed 19/07/03




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43 Develop appropriate social transition criteria (e.g. economic diversification). 90 days Tue 19/08/20 Mon 19/12/2344 Ensure that the operational budgets are geared towards social transition. 20 days Tue 19/12/24 Mon 20/01/2045 Give I&Aps the opportunity to review the revised mine closure plan. 20 days Tue 19/05/28 Mon 19/06/2446 Consider feedback from stakeholders on issues, alternatives and/or decisions. 20 days Tue 19/06/25 Mon 19/07/2247 Update Social transition requirements related to Stakeholder engagement planning (SEP) 415 days Tue 19/05/28 Mon 20/12/2848 Update the operation's SEP to focus on the updated closure plan. 10 days Tue 20/12/15 Mon 20/12/2849 Engage with I&Aps at the appropriate level of Influence (Ongoing) 240 days Tue 19/05/28 Mon 20/04/2750 Update Social transition cost estimate 20 days Tue 20/01/21 Mon 20/02/1751 Develop a Class 4 estimate. 20 days Tue 20/01/21 Mon 20/02/1752 Success Criteria & Monitoring Program 150 days Tue 20/05/19 Mon 20/12/1453 Update success criteria & monitoring program 150 days Tue 20/05/19 Mon 20/12/1454 Develop success criteria including SMART targets to a defined level of success. 90 days Tue 20/05/19 Mon 20/09/2155 Get the success criteria to be approved by authorities. 60 days Tue 20/09/22 Mon 20/12/1456 Financial Requirements and Risk Assessment 60 days Tue 20/09/22 Mon 20/12/1457 Update the current risk assessment 10 days Tue 20/09/22 Mon 20/10/0558 Identify any remaining significant and high residual risks and reduce the unacceptable residual risks to an 10 days Tue 20/09/22 Mon 20/10/0559 Improve the overall cost estimate accuracy and confidence 20 days Tue 20/10/06 Mon 20/11/0260 Develop a Class 4 estimate. 20 days Tue 20/10/06 Mon 20/11/0261 Improve the overall cost estimate accuracy and confidence 10 days Tue 20/10/06 Mon 20/10/1962 Improve the level of confidence in closure plan by reducing the assumptions. 10 days Tue 20/10/06 Mon 20/10/1963 Update the overall financial provision 10 days Tue 20/11/03 Mon 20/11/1664 Update the financial provision to align with a level 4 estimate. 10 days Tue 20/11/03 Mon 20/11/1665 Update the overall mine closure plan. 20 days Tue 20/11/17 Mon 20/12/1466 Update the overall mine closure plan to a "Draft" mine closure plan. 20 days Tue 20/11/17 Mon 20/12/14


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APPENDIX C: COMPLETED MASTER ACTION PLAN SCHEDULE (continued)




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INTRODUCTION

AA has developed a Group Rehabilitation Strategy (the ‘Strategy’) that commits AA to ensuring all rehabilitation areas are safe, stable, non-polluting and sustainable. The Group Rehabilitation Strategy provides a standard for integrating rehabilitation in business planning process and setting targets to eliminate the rehabilitation backlog (defined as lease hold area deemed not economically viable for future mining). The Group Rehabilitation Strategy is applicable to open cut operations and forms the basis for developing a Business Unit (BU) or operation specific Strategy.

A Rehabilitation Strategy emphasises the senior leader’s commitment to optimise rehabilitation through ensuring the backlog is managed, and to facilitate integration into the business planning processes (i.e. LoAP). Successful concurrent rehabilitation programmes occur when activities are fully integrated into the various operational planning functions. The Rehabilitation Strategy should outline the rehabilitation vision and objectives for the operation, which align to the closure vision and post-mining land-use plan.

The AA Mine Closure Standard requires the development of Five-Year Rehabilitation Plans, which should outline the:• Process to integrate rehabilitation into the business plan. • Rehabilitation targets set on a rolling five-year period.• Detailed rehabilitation prescriptions and trials to be

implemented. • Rehabilitation monitoring programme that is linked to

the success criteria. • Suggested management and maintenance activities.

The proposed methodology to develop a rehabilitation strategy (Figure 1) and a five-year rehabilitation plan is outlined below.

METHODOLOGY

The Strategy should be developed in a workshop with the presence of key internal stakeholders (e.g. General Manager, Technical Services Manager, Safety Health and Environment (SHE) Manager) to ensure Senior Leadership direction and acceptance. The Strategy should set the high-level rehabilitation objectives for the site (safe, stable, self-sustaining and non-polluting) as well as domain-specific objectives. This means that a site can have multiple rehabilitation objectives that are linked to each agreed post-mining land-use. An example of a specific rehabilitation objective for native vegetation is:

‘To rehabilitate defined areas to a low-maintenance native vegetation with composition, structure and function based on a relevant reference ecosystem (or agreed representative site) with a stable landform and self-sustaining vegetation cover’.

EXAMPLE 7: REHABILITATION STRATEGY AND FIVE-YEAR REHABILITATION PLANS

The next step is to develop a commitment to concurrent (also known as progressive) rehabilitation and to reduce the rehabilitation backlog (land available for rehabilitation) over the remaining life of the asset. The targets should be integrated into the business plan to ensure resources and budgets are allocated. Older operations with a significant backlog, due to poor historical integration into the business plan, should be reducing it over the remaining life of the mine. Newer mines with limited backlog should be committing to concurrent rehabilitation opportunities through strategic waste deposition three-years after the initial disturbance. All rehabilitation targets need to consider the budgeted LoA clearing rate (excluding clearing for permanent infrastructure) to ensure backlog is managed appropriately.

The Strategy should also set out the process to develop sustainable rehabilitation prescriptions, success criteria and monitoring, and maintenance and management programmes to facilitate the relinquishment process. These items will then be expanded in the five-year rehabilitation plan. The Strategy should ultimately be signed off by the Business Unit Chief Executive Officer (BU CEO) to ensure strategic alignment.

A five-year rehabilitation plan (‘Rehabilitation Plan’) must be developed and updated on an annual basis as per the AA Mine Closure Standard. A Rehabilitation Plan will build on the commitments made by the BU and operation to investigate rehabilitation opportunities and undertake research trials towards closing knowledge gaps and driving relinquishment. It should be integrated into the LoAP and the medium term mine plan and must include the following:• High-level summary of the baseline environmental and

legal requirements for the site.• Summary of disturbance and rehabilitation profile (in

hectares) for each domain on-site, including areas available for rehabilitation.

• Annual rehabilitation targets for the five-year period.• Rehabilitation prescriptions (i.e. landform design, growth

medium, erosion control measures, seeding/planting specifications, fertiliser rates) to be applied to each rehabilitation area.

• Estimated budget to rehabilitate according to the five-year plan.

• Review of the rehabilitation programme implemented in the previous year including expenditure.

• Rehabilitation monitoring programme to be implemented over the five-year period.

• Rehabilitation maintenance and management action plan and budget to ensure areas are being managed to relinquishment.

Once drafted, the Rehabilitation Plan should be endorsed by the relevant site leadership team (General Manager, Finance Manager, Technical Services Manager, SHE Manager) to ensure the plan is resourced and budgeted appropriately. The Plan should be developed in line with the site’s budgeting cycle and updated on an annual basis to reflect changes in the mine plan.



METALLURGICAL COAL REHABILITATION STRATEGY

AA Metallurgical Coal (Met Coal) has a disturbed ground footprint of greater than 24 000 ha. A five-point Rehabilitation Strategy has been developed to focus rehabilitation efforts at Met Coal.

REHABILITATION OBJECTIVES AND TARGETS

✔ Rehabilitation areas will be safe, stable, non-polluting, sustainable and mee the agreed post-mining land-use through innovation.

✔ Site-specific rehabilitation objectives will meet applicable stakeholdeer identified land-uses.

✔ Rehabilitation targets are reconciled, audited and included in CEO, Executive Head of Open cut and Executive Head of Underground and site General Manager (GM) metrics to promote accountability and tracked monthly and quarterly.

ÈREHABILITATION PLANNING

✔ Operational and closure planning is integrated through collaboration to develop the best overall rehabilitation plan, including consideration of the impact of business decisions.

✔ Annual rehabilitation target hectares are based on eliminating outstanding disturbance liability and maintaining ratio of rehabilitation hectares to the area disturbed each year.

✔ Annual Rehabilitation Target = Annual clearing Rate (ha) + [Rehabilitation Backlog (ha)/No. of Years Until Last Coal].

✔ Rolling five-year rehabilitation plans will be in line with Regulator and Internal Requirements.

ÈREHABILITATION PRESCRIPTIONS

✔ A guideline, outlining the key considerations for developing site-specific five-year rehabilitation plans, will be developed for Met Coal open cut and underground operations.

✔ Selective placement of problematic spill (e.g. acidic, dispersive, vulnerable to spontaneous combustion) will be standard practice.

✔ Topsoil, growth medium and capping materials (i.e. rock for dispersive, clays for TFS75s) will be selectively stripped and conserved for use in the rehabilitation process.

✔ Seed procurement processes will be auditable.

River pylons to be considered to reduce subsidence in waterways.

Site-specific and auditable rehabilitation standard operating procedures (i.e. landform design, surface water and erosion control, subsidence management, seed lits, weed/ invasive species, monitoring protocol) will exist.

ÈCOMPLETION CRITERIA

✔ Site-specific rehabilitation completion criteria, with input from applicable stakeholders, will be developed.

✔ Progressive certification of rehabilitated areas against defined completion criterial (also known as success criteria) will be obtained to demonstrate commitent to our stakeholders.

ÈMONITORING AND MAINTENANCE

✔ Monitoring and maintenance programmes will be developed to ensure the safety of our surrounding communities and to facilitate the process of achieving sign-off on completion criteria.

✔ Records related to rehabilitation design, construction, implementation and monitoring shall be maintained.

Figure 1: Met Coal Rehabilitation Strategy.



INTRODUCTION

Success criteria (also known as completion criteria) are the agreed standards that must be met to facilitate lease relinquishment. They include physical, biophysical and socio-economic parameters and are generally defined through engagement with regulators and other external stakeholders. Success criteria must complement and fully align with the closure vision, objectives and closure criteria (Figure 1). They should be SMART. Success criteria should be developed in the early stages of the development of an operation and should become more quantitative over time as concurrent rehabilitation is undertaken and success criteria are tested. During engagement with regulators, it should be made clear that success criteria will change over time as they are tested, but this should not be used as an excuse to not attempt to develop them early in an operations life. It is important that an appropriate monitoring programme is developed (if possible, in collaboration with the regulators) to ensure that the right data are being collected to determine whether success criteria are being met. If the success criteria are not being met, a maintenance programme should be developed. The proposed methodology for developing success criteria is explained below and an example excel spreadsheet template is also provided.

METHODOLOGY

Operations should develop high level principles that they are trying to achieve with the success criteria. An example of success criteria principles would be:• Meet rehabilitation objectives.

• Landforms are integrated into the surrounding landscape and are non-polluting.

• Rehabilitation exhibits sustained growth and is resilient.• Management of rehabilitation can be integrated with

surrounding areas and requires no additional ongoing resources.

• Social transition has left a positive legacy and sustainable post-mining livelihoods.

Each success criteria principle should be assessed at multiple time categories. An example of success criteria time categories would be:• Development and mining.• Rehabilitation process.• Early development (0-5 year old rehabilitation). • Established rehabilitation and relinquishment (> 5 year

old rehabilitation).

This step entails the use of the condition and commitments register as developed in Tool 1. These should ideally be contained within a register that is updated regularly with tracking of required actions (Table 1).

Success criteria should then be developed for each time category and cross-referenced with the principle. The criteria and intent stated as a question, the relevant domains, guidelines for acceptance, the accepted standard and potential corrective actions should then be developed (Table 2), using the conditions and commitments as a starting point.

EXAMPLE 8: SUCCESS CRITERIA


Barro Alto Mine in Brasil as seen by drone.


Table 1: Example of a conditions and commitments register.

RELEVANT DOCUMENT

REFERENCE/LICENCE NUMBER

REFERENCE IN

DOCUMENT COMMITMENTENVIRONMENTAL

ASPECTRESPONSIBLE DEPARTMENT COMPLIANCE

Pit and dump extention and Environmental Management Programme (EMPr) consolidation.

NC 30/5/1/2/2/ (10056) MR.

Section 12. Implement the Closure Toolbox and AA way as per the Closure Plan.

Topography. Land management.

Pit and dump extention and EMPr consolidation.

NC 30/5/1/2/2/ (10056) MR.

Section 12. Comply to the Mine residue classification and characterisation in compliance with GNR 635 of August 2013, “National Norms and Standards for the Assessment of waste for landfill disposal” and GNR 636 of August 2013, “National Norms and Standards for disposal of waste to landfill”, in terms of NEMWA, 2008.

Topography. Env management.


NC 30/5/1/2/2/ (10056) MR.

Section 12. Comply to the SIOM Code of Practice (COP) on mine residue deposits.

Topography. Mining.


NC 30/5/1/2/2/ (10056) MR.

Section 12. Implement a topsoil management plan. Soils. Land management.


NC 30/5/1/2/2/ (10056) MR.

Section 12. Implement a rehabilitation programme. Land-use and land capability.

Land management.


NC 30/5/1/2/2/ (10056) MR.

Section 12. Develop and Implement System and Operational Procedures and training programme in compliance with ISO14001.

Soils. Env management.


NC 30/5/1/2/2/ (10056) MR.

Section 12. Comply with the National Norms and Standards for the Remediation of Contaminated Land and Soil Quality (GNR.331 of 2014), thereunder.

Land-use and land capability.

Env management.


NC 30/5/1/2/2/ (10056) MR.


Soils. Land management.


NC 30/5/1/2/2/ (10056) MR.




NC 30/5/1/2/2/ (10056) MR.

Section 12. Reasonable precaution will be taken to prevent spillage and in case there is spillage, cleaning procedures to be undertaken in order to comply with the principles of pollution prevention and duty of care (NEMA, 1998).



NC 30/5/1/2/2/ (10056) MR.

Section 12. Manage general and/or hazardous waste in a manner as to comply with NEM: WA, 2008.



NC 30/5/1/2/2/ (10056) MR.

Section 12. Implement Water management measures in compliance with NWA, 1998 and GN 704, 1999.



NC 30/5/1/2/2/ (10056) MR.

Section 12. Comply with the National Norms and Standards for the Remediation of Contaminated Land and Soil Quality (GNR.331 of 2014), thereunder.



Figure 1: Relationship between closure vision, PMLs, objectives, closure criteria, success criteria and the monitoring programme to facilitate progressive sign-off and relinquishment.


Table 2: Example of the proposed structure of success criteria for one time category.

PRINCIPLE CRITERIA AND INTENT DOMAINGUIDELINES FOR ACCEPTANCE ACCEPTED STANDARD

POTENTIAL CORRECTIVE ACTIONS

Rehabilitation objective.

Have clear land-use objectives been developed for the site?

All – although objectives may vary in different areas.

Land-use objectives should be developed with input from relevant stakeholders.

Land-use objectives have been approved by the relevant government agency.

Feedback from agencies and stakeholders to be incorporated into the land-use objectives.


Has a clear rehabilitation objective been developed?

All The rehabilitation objective should align with the rehabilitation strategy and closure plan, and any AA guidelines. The rehabilitation objective should allow site to meet the land-use objectives.

The site specific rehabilitation objective has been endorsed by the relevant government agencies following stakeholder input.

Feedback from agencies and stakeholders to be incorporated into the rehabilitation objective.


Has a clear rehabilitation plan been developed, covering rehabilitation for each year?

All Rehabilitation plan should align with the Closure plan, LoA plan and short/medium term mine plan.

Annual rehabilitation plans have been developed and agreed by all relevant internal stakeholders.

Plan is implemented as agreed.

Sufficient resources are available to complete progressive rehabilitation.

Review areas available and adjust plan accordingly.

Integrated, non-polluting landforms.

Are the rehabilitation designs appropriate?

All Rehabilitation designs should be developed to comply with the commitments in the Environmental Management Programme (EMP).

The designs are consistent with the conditions and include appropriate aspects such as slope angles, slope lengths, drainage lines, and stormwater management structures.

Redesign as required and include suitable structures.


Are the rehabilitation procedures documented?

All The rehabilitation techniques should be documented, including technical designs, moonscaping techniques, topsoil placement and seeding.

Agreed rehabilitation procedures have been developed and have been described in the Environmental Management System (EMS) and Rehabilitation Strategy.

Develop and agree on rehabilitation procedures and document in the EMS and Rehabilitation Strategy.


Is adequate cover material available?

All A supply of cover material should be sourced and its quality and characteristics recorded.

There is appropriate topsoil, spoil and other non vegetative cover available.

Source the cover material and ensure its availability.

RELEVANT DOCUMENT

REFERENCE/LICENCE NUMBER

REFERENCE IN

DOCUMENT COMMITMENTENVIRONMENTAL

ASPECTRESPONSIBLE DEPARTMENT COMPLIANCE


NC 30/5/1/2/2/ (10056) MR.


Surface water. Env management.


NC 30/5/1/2/2/ (10056) MR.

Section 12. Comply with DWS’s Best Practice Guideline Series in terms of integrated water and waste management and monitoring.



NC 30/5/1/2/2/ (10056) MR.

Section 12. Implement a Surface water monitoring programme.



NC 30/5/1/2/2/ (10056) MR.




NC 30/5/1/2/2/ (10056) MR.

Section 12. Reasonable precaution will be taken to prevent spillage and in case there is spillage, cleaning procedures to be undertaken in order to comply with the principles of pollution prevention and duty of care (NEMA, 1998).



NC 30/5/1/2/2/ (10056) MR.

Section 12. Manage general and/or hazardous waste in a manner as to comply with NEM: WA, 2008.



NC 30/5/1/2/2/ (10056) MR.

Section 12. Comply to the Mine residue classification and characterisation in compliance with GNR 635 of August 2013, “National Norms and Standards for the Assessment of waste for landfill disposal” and GNR 636 of August 2013, “National Norms and Standards for disposal of waste to landfill”, in terms of NEMWA, 2008.



NC 30/5/1/2/2/ (10056) MR.


Surface water Land management.


NC 30/5/1/2/2/ (10056) MR.

Section 12. Comply to the SIOM Code of practice (COP) on mine residue deposits.

Surface water. Mining.


NC 30/5/1/2/2/ (10056) MR.


Groundwater. Env management.


NC 30/5/1/2/2/ (10056) MR.

Section 12. Comply with DWS’s Best Practice Guideline Series in terms of integrated water and waste management and monitoring.



NC 30/5/1/2/2/ (10056) MR.

Section 12. Implement a Groundwater monitoring programme.



NC 30/5/1/2/2/ (10056) MR.

Section 12. Conduct Site survey for red data and protected plants and animals (on greenfield areas).

Natural flora and fauna.

Env management.


EXAMPLE 9: SOCIAL TRANSITION RISK ASSESSMENT AND CASH FLOW


INTRODUCTION

A social transition plan is developed using the risk based MCT approach that aims to achieve a plan that is practically and financially executable with an acceptable residual risk profile. The aim of the social transition plan is to ensure that the reputation of the company will be protected, resulting in long-term shareholder and stakeholder value and a future license to operate. The basis of the social transition costs, are directly linked to the mitigation of risks and the optimisation of opportunities and hence will change as the risk profile changes (lower cost vs. higher residual risk). The example

of the social transition risk assessment and cash flow, demonstrates the relationship between residual risk and the associated costs.

Social transition should not be a standalone component but integrated with the physical, bio-physical and financial components of LoAP. The risk assessment, with social transition criteria and the subsequent basis of estimate documents should be used as live document going forward. These documents should be used to change the current operational activities and improve the overall confidence in the social transition plan components and reduce the funds required during the post closure phase.

View of the Mototolo Concentrator, South Africa.


SOCIAL TRANSITION RISK ASSESSMENT, CRITERIA AND LIABILITY ESTIMATE

DIRECT IMPACTS ON SOCIO-ECONOMIC ASPECTS AT

CLOSURE

RISK ISSUES FOR SOCIO-ECONOMIC ASPECTS AT

CLOSURE

PRE-MITIGATION

RISK RANKING MITIGATION/CLOSURE CRITERIA

OPERATING COSTS WHILE STILL IN

PRODUCTION PHASE

(CURRENT AND ADDITIONAL)

SOCIAL LIABILITY DURING

DECOMMIS-SIONING PHASE

(0 TO 5 ACTIVE YEARS POST PRODUCTION

PERIOD)


MONITORING PHASE

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MAINTENANCE PERIOD, POST DECOMMIS-

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ADDITIONAL ACTIONS

REQUIRED POST RISK

ASSESSMENT

ADDITIONAL CLOSURE

COST POST-MITIGATION

FinancialLegal and Regulatory

Reputation/Social/

Community/Health and

Safety

Current Mitigating Actions

Current

Operating costs

(2019)

(Annual cost in $m)

Operating costs in the last 5 years

(total cost for 5 years

in $m)

Estimated Decommis-

sioning Liability Estimate

(total cost for 5 years in $m)

Estimated Monitoring and Maintenance

Liability Estimate



Reputation/Social/


Safety

Additional Actions

Required

Current Operating

costs (Annual cost

in $m)

Operating costs in

the last 5 years


in $m)

Estimated Decommis-

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$m)

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and Maintenance

Liability Estimate


$m)


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1. Employees and dependants

1.1 Loss of security of income.

The loss of salary and benefits for the mine employees, such as medical aid, housing, water and electricity allowances, which could relate to a situation where employees might not be able to obtain alternative employments leaving them unemployed (reputation).

4 4 21 Utilise the existing stakeholder forms (engagement forums) to:

1. Maintain relationships between the mine and unions.

2. Identify possible portable skills to build capacity with employees.

3. Implement training opportunities to transfer these identified skills.

4. Identifying infrastructure with a beneficial post-mining re-use for possible handover, and plan and cost the required modifications, if any.

5. Develop and agree on the downscaling and retrenchment plan with union and jointly agree on redeployment strategies within the company.

6. Promote a culture of self-employment and self-maintenance or none dependence on the mine (town transformation).

7. Develop a skills development programme to maximise job opportunities and alternative livelihoods.

8. All retrenchments will be done as per Labour Act and collective agreements.

9. System to be put in place to track ex employees’ re-employment status post mine closure.

10. Current medical contributions by the company is 50% for medical aid, and will be increased to 75% for VSP candidates.

11. The cost of repatriation is included in current HR budget for relevant staff (approx. 60% of people).

1. $0,5m

2. $0,2m

3. Included

4. Included

5. Included

6. Included

7. Included

8. None

9. Included

10. Included

11. Included

Total: $0,7m

1. $2,5m

2. $1,0m

3. $0,5m

4. Included

5. Included

6. $3,0m

7. Included

8. $10,5m

9. Included

10. (Included in 2022 only)

11. Included

Total: $17,5m

1. $2,5m

2. None

3. None

4. None

5. None

6. None

7. None

8. $5,2m

9. None

10. Included

11. Included

Total: $7,7m

1. None

2. None

3. None

4. None

5. None

6. None

7. None

8. N$2,2m

9. None

10. None

11. None

Total: $2.2m

4 3 18 12. Need clear strategy on selling of company assets – including covering employee properties.

13. Clear town transformation strategy and budget and communication plan.

14. Housing strategy must be clear.

15.Investor/ employee confidence to be establish.

16. Town transformation is looking at the sustainability of the education and other services – linking with government and combining with other mines, etc.

12. None

13. None

14. None

15. None

16. None

Total: $0

12. (Antici-pated sales not included)13. None14. None15. None

16. None

Total: $0

12. None

13. None

14. None

15. None

16. None

Total: $0

12. None

13. None

14. None

15. None

16. None

Total: $0

4 3 18

Risk that current home owners might experience a reduction in property value and battle to pay the mortgage having to work somewhere ells. Can’t sell the house and need accommodation somewhere else.

2 3 8 2 2 5 2 2 5

The risk of production stoppages/disruption due to employees reaction to downscaling and mine closure.

4 3 18 4 3 18 4 2 14

1.2 Reluctance of employees to buy property in local town due to short LoA.

Risk of employees not taking up the offer to buy property in local town, and rather stick to current housing conditions (free water, etc.).

4 4 21 1. Need additional mitigation. 1. None

Total: $0

1. None

Total: $0

1. None

Total: $0

1. None

Total: $0

4 4 21 2. Clear town transformation strategy and budget and communication plan.


4. Investor/employee confidence to be establish.

2. Included

3. Included

4. Included

Total: $0

2. Included

3. Included

4. Included

Total: $0

2. Included

3. Included

4. Included

Total: $0

2. Included

3. Included

4. Included

Total: $0

4 3 18

1.3 Illegal mining. Risk of illegal mining by employees and wider community, resulting in safety and security risks. (reputation and safety).

3 4 17 4 3 18 5 3 22 1. Keep security in place and relook at future requirements related to town opening, and security risks associated with possible increased in unemployment.

2. The current rehabilitation plan covers some risks associate with voids and large structures being made safe.

1. $4,1m

2. Included

Total: $4,1m

1. $22m

2. Included

Total: $22m

1. $31,8m

2. Included

Total: $31,8m

1. $3,4m

2. Included

Total: $3,4m

3 3 13 3 3 13 4 3 18 3. Increase police and government support.

4. National park security to play a role going forward.

3. None

4. None

Total: $0

3. None

4. None

Total: $0

3. None

4. None

Total: $0

3. None

4. None

Total: $0

3 3 13 3 3 13 4 2 14



CLOSURE


CLOSURE

PRE-MITIGATION



PRODUCTION PHASE





PERIOD)


MONITORING PHASE

(10 YEAR CARE AND



ADDITIONAL ACTIONS

REQUIRED POST RISK

ASSESSMENT

ADDITIONAL CLOSURE



Reputation/Social/


Safety


Current

Operating costs

(2019)

(Annual cost in $m)



in $m)

Estimated Decommis-




Liability Estimate



Reputation/Social/


Safety

Additional Actions

Required

Current Operating

costs (Annual cost

in $m)

Operating costs in

the last 5 years


in $m)

Estimated Decommis-

sioning Liability

Estimate


$m)


and Maintenance

Liability Estimate


$m)


Reputation/Social/


Safety

Con

sequ

ence

Pro

babi

lity

Rat

ing

Con

sequ

ence

Pro

babi

lity

Rat

ing

Con

sequ

ence

Pro

babi

lity

Rat

ing

Con

sequ

ence

Pro

babi

lity

Rat

ing

Con

sequ

ence

Pro

babi

lity

Rat

ing

Con

sequ

ence

Pro

babi

lity

Rat

ing

Con

sequ

ence

Pro

babi

lity

Rat

ing

Con

sequ

ence

Pro

babi

lity

Rat

ing

Con

sequ

ence

Pro

babi

lity

Rat

ing

1. Employees and dependants

1.1 Loss of security of income.

The loss of salary and benefits for the mine employees, such as medical aid, housing, water and electricity allowances, which could relate to a situation where employees might not be able to obtain alternative employments leaving them unemployed (reputation).

4 4 21 Utilise the existing stakeholder forms (engagement forums) to:

1. Maintain relationships between the mine and unions.

2. Identify possible portable skills to build capacity with employees.

3. Implement training opportunities to transfer these identified skills.

4. Identifying infrastructure with a beneficial post-mining re-use for possible handover, and plan and cost the required modifications, if any.

5. Develop and agree on the downscaling and retrenchment plan with union and jointly agree on redeployment strategies within the company.

6. Promote a culture of self-employment and self-maintenance or none dependence on the mine (town transformation).

7. Develop a skills development programme to maximise job opportunities and alternative livelihoods.

8. All retrenchments will be done as per Labour Act and collective agreements.

9. System to be put in place to track ex employees’ re-employment status post mine closure.

10. Current medical contributions by the company is 50% for medical aid, and will be increased to 75% for VSP candidates.

11. The cost of repatriation is included in current HR budget for relevant staff (approx. 60% of people).

1. $0,5m

2. $0,2m

3. Included

4. Included

5. Included

6. Included

7. Included

8. None

9. Included

10. Included

11. Included

Total: $0,7m

1. $2,5m

2. $1,0m

3. $0,5m

4. Included

5. Included

6. $3,0m

7. Included

8. $10,5m

9. Included

10. (Included in 2022 only)

11. Included

Total: $17,5m

1. $2,5m

2. None

3. None

4. None

5. None

6. None

7. None

8. $5,2m

9. None

10. Included

11. Included

Total: $7,7m

1. None

2. None

3. None

4. None

5. None

6. None

7. None

8. N$2,2m

9. None

10. None

11. None

Total: $2.2m

4 3 18 12. Need clear strategy on selling of company assets – including covering employee properties.

13. Clear town transformation strategy and budget and communication plan.


15.Investor/ employee confidence to be establish.

16. Town transformation is looking at the sustainability of the education and other services – linking with government and combining with other mines, etc.

12. None

13. None

14. None

15. None

16. None

Total: $0

12. (Antici-pated sales not included)13. None14. None15. None

16. None

Total: $0

12. None

13. None

14. None

15. None

16. None

Total: $0

12. None

13. None

14. None

15. None

16. None

Total: $0

4 3 18

Risk that current home owners might experience a reduction in property value and battle to pay the mortgage having to work somewhere ells. Can’t sell the house and need accommodation somewhere else.

2 3 8 2 2 5 2 2 5

The risk of production stoppages/disruption due to employees reaction to downscaling and mine closure.

4 3 18 4 3 18 4 2 14

1.2 Reluctance of employees to buy property in local town due to short LoA.

Risk of employees not taking up the offer to buy property in local town, and rather stick to current housing conditions (free water, etc.).

4 4 21 1. Need additional mitigation. 1. None

Total: $0

1. None

Total: $0

1. None

Total: $0

1. None

Total: $0

4 4 21 2. Clear town transformation strategy and budget and communication plan.


4. Investor/employee confidence to be establish.

2. Included

3. Included

4. Included

Total: $0

2. Included

3. Included

4. Included

Total: $0

2. Included

3. Included

4. Included

Total: $0

2. Included

3. Included

4. Included

Total: $0

4 3 18

1.3 Illegal mining. Risk of illegal mining by employees and wider community, resulting in safety and security risks. (reputation and safety).

3 4 17 4 3 18 5 3 22 1. Keep security in place and relook at future requirements related to town opening, and security risks associated with possible increased in unemployment.

2. The current rehabilitation plan covers some risks associate with voids and large structures being made safe.

1. $4,1m

2. Included

Total: $4,1m

1. $22m

2. Included

Total: $22m

1. $31,8m

2. Included

Total: $31,8m

1. $3,4m

2. Included

Total: $3,4m

3 3 13 3 3 13 4 3 18 3. Increase police and government support.

4. National park security to play a role going forward.

3. None

4. None

Total: $0

3. None

4. None

Total: $0

3. None

4. None

Total: $0

3. None

4. None

Total: $0

3 3 13 3 3 13 4 2 14



CLOSURE


CLOSURE

PRE-MITIGATION



PRODUCTION PHASE





PERIOD)


MONITORING PHASE

(10 YEAR CARE AND



ADDITIONAL ACTIONS

REQUIRED POST RISK

ASSESSMENT

ADDITIONAL CLOSURE



Reputation/Social/


Safety


Current

Operating costs

(2019)

(Annual cost in $m)



in $m)

Estimated Decommis-




Liability Estimate



Reputation/Social/


Safety

Additional Actions

Required

Current Operating

costs (Annual cost

in $m)

Operating costs in

the last 5 years


in $m)

Estimated Decommis-

sioning Liability

Estimate


$m)


and Maintenance

Liability Estimate


$m)


Reputation/Social/


Safety

Con

sequ

ence

Pro

babi

lity

Rat

ing

Con

sequ

ence

Pro

babi

lity

Rat

ing

Con

sequ

ence

Pro

babi

lity

Rat

ing

Con

sequ

ence

Pro

babi

lity

Rat

ing

Con

sequ

ence

Pro

babi

lity

Rat

ing

Con

sequ

ence

Pro

babi

lity

Rat

ing

Con

sequ

ence

Pro

babi

lity

Rat

ing

Con

sequ

ence

Pro

babi

lity

Rat

ing

Con

sequ

ence

Pro

babi

lity

Rat

ing

1.4 Loss in critical skills.

There is a risk that the schooling might not be sustained in its current form post mining, resulting in people moving out of the area, or incurring more cost for schooling and claim from the company.

2 3 8 1. Town transformation is looking at the sustainability of the schooling and other services – linking with government and combining with other mines, etc.

1. Included

Total:$0

1. Included

Total:$0

1. Included

Total:$0

1. Included

Total:$0

2 2 5 None required. 2 2 5

1.5 Loss in income from businesses.

Employees that are also business owners might claim compensation from the company for the business that will not be viable post mining (short LoA and unreality expectations on sustainability of their business).

2 3 8 1. Town transformation process.

2. Current SEP that communicates the current and possible future state.

1. Included

2. Included

Total: $0

1. Included

2. Included

Total: $0

1. Included

2. Included

Total: $0

1. Included

2. Included

Total: $0


1.6 Inability to pay mortgage.

Risk that employees that do buy there houses in in the local town might not be able to pay the mortgage.

4 4 21 1. If bought through the provident fund, the house would be paid at closure if needed.

2. Communication on the risk of buying a house is in place.

3. Insurance from banks that bond will be paid on retrenchment.

1. Included

2. Included

3. Included

Total: $0

1. Included

2. Included

3. Included

Total: $0

1. Included

2. Included

3. Included

Total: $0

1. Included

2. Included

3. Included

Total: $0


1.7 Loss in property value.

Risk that employees that do buy there houses in in the local town might not be able to re-sell the property in future (loss in property value).



1. Included

2. Included

Total: $0

1. Included

2. Included

Total: $0

1. Included

2. Included

Total: $0

1. Included

2. Included

Total: $0

4 3 18 None. 4 3 18

1.8 Data and intellectual capital loss/theft.

Risk of company data and information being taken from the company and benefit other entities.

4 3 18 1. Non disclosure is included in employment conditions of employment.

2. The safe keeping (legal requirement) and management of information (IM systems and servers).

3. Historic servers and software needs to be maintained post mining (medical contributions).

1. Included

2. $2m

3. Included

Total: $2m

1. Included

2. $8m

3. Included

Total: $8m

1. Included

2. $4m

3. Included

Total: $4m

1. Included

2. $2m

3. Included

Total: $2m

4 2 14 4. Alternative additional methods to be investigated (cloud, etc.).

4. Included

Total: $0

4. Included

Total: $0

4. Included

Total: $0

4. Included

Total: $0

4 2 14

1.9 Increase in social ills.

Risk of increase in crime and cost of increase insecurity, claimed by employees.

4 4 21 1. Access control will be in place, as it’s a national park. 1. Included

Total: $0

1. Included

Total: $0

1. Included

Total: $0

1. Included

Total: $0

3 4 17 2. Risk to be assessed and security improved.

2. None

Total: $0

2. None

Total: $0

2. None

Total: $0

2. None

Total: $0

3 3 13

1.10 Vandalism. The risk of employee and or other parties vandalism company property (including animals) post opening of town and with the closing of the mine.

3 3 13 3 3 13 1. Existing security and local police will assist. 1. Included

Total: $0

1. $1m

Total: $1m

1. Included

Total: $0

1. Included

Total:$0

3 3 13 3 2 9 2. Capacity of local police and services/infrastructure to be investigated.

2. Included

Total: $0

2. Included

Total:$0

2. Included

Total: $0

2. Included

Total: $0

3 2 9 3 2 9

SOCIAL TRANSITION RISK ASSESSMENT, CRITERIA AND LIABILITY ESTIMATE (continued)



CLOSURE


CLOSURE

PRE-MITIGATION



PRODUCTION PHASE





PERIOD)


MONITORING PHASE

(10 YEAR CARE AND



ADDITIONAL ACTIONS

REQUIRED POST RISK

ASSESSMENT

ADDITIONAL CLOSURE



Reputation/Social/


Safety


Current

Operating costs

(2019)

(Annual cost in $m)



in $m)

Estimated Decommis-




Liability Estimate



Reputation/Social/


Safety

Additional Actions

Required

Current Operating

costs (Annual cost

in $m)

Operating costs in

the last 5 years


in $m)

Estimated Decommis-

sioning Liability

Estimate


$m)


and Maintenance

Liability Estimate


$m)


Reputation/Social/


Safety

Con

sequ

ence

Pro

babi

lity

Rat

ing

Con

sequ

ence

Pro

babi

lity

Rat

ing

Con

sequ

ence

Pro

babi

lity

Rat

ing

Con

sequ

ence

Pro

babi

lity

Rat

ing

Con

sequ

ence

Pro

babi

lity

Rat

ing

Con

sequ

ence

Pro

babi

lity

Rat

ing

Con

sequ

ence

Pro

babi

lity

Rat

ing

Con

sequ

ence

Pro

babi

lity

Rat

ing

Con

sequ

ence

Pro

babi

lity

Rat

ing

1.4 Loss in critical skills.

There is a risk that the schooling might not be sustained in its current form post mining, resulting in people moving out of the area, or incurring more cost for schooling and claim from the company.

2 3 8 1. Town transformation is looking at the sustainability of the schooling and other services – linking with government and combining with other mines, etc.

1. Included

Total:$0

1. Included

Total:$0

1. Included

Total:$0

1. Included

Total:$0


1.5 Loss in income from businesses.

Employees that are also business owners might claim compensation from the company for the business that will not be viable post mining (short LoA and unreality expectations on sustainability of their business).



1. Included

2. Included

Total: $0

1. Included

2. Included

Total: $0

1. Included

2. Included

Total: $0

1. Included

2. Included

Total: $0


1.6 Inability to pay mortgage.

Risk that employees that do buy there houses in in the local town might not be able to pay the mortgage.

4 4 21 1. If bought through the provident fund, the house would be paid at closure if needed.

2. Communication on the risk of buying a house is in place.

3. Insurance from banks that bond will be paid on retrenchment.

1. Included

2. Included

3. Included

Total: $0

1. Included

2. Included

3. Included

Total: $0

1. Included

2. Included

3. Included

Total: $0

1. Included

2. Included

3. Included

Total: $0


1.7 Loss in property value.

Risk that employees that do buy there houses in in the local town might not be able to re-sell the property in future (loss in property value).



1. Included

2. Included

Total: $0

1. Included

2. Included

Total: $0

1. Included

2. Included

Total: $0

1. Included

2. Included

Total: $0

4 3 18 None. 4 3 18

1.8 Data and intellectual capital loss/theft.

Risk of company data and information being taken from the company and benefit other entities.

4 3 18 1. Non disclosure is included in employment conditions of employment.

2. The safe keeping (legal requirement) and management of information (IM systems and servers).

3. Historic servers and software needs to be maintained post mining (medical contributions).

1. Included

2. $2m

3. Included

Total: $2m

1. Included

2. $8m

3. Included

Total: $8m

1. Included

2. $4m

3. Included

Total: $4m

1. Included

2. $2m

3. Included

Total: $2m

4 2 14 4. Alternative additional methods to be investigated (cloud, etc.).

4. Included

Total: $0

4. Included

Total: $0

4. Included

Total: $0

4. Included

Total: $0

4 2 14

1.9 Increase in social ills.

Risk of increase in crime and cost of increase insecurity, claimed by employees.

4 4 21 1. Access control will be in place, as it’s a national park. 1. Included

Total: $0

1. Included

Total: $0

1. Included

Total: $0

1. Included

Total: $0

3 4 17 2. Risk to be assessed and security improved.

2. None

Total: $0

2. None

Total: $0

2. None

Total: $0

2. None

Total: $0

3 3 13

1.10 Vandalism. The risk of employee and or other parties vandalism company property (including animals) post opening of town and with the closing of the mine.

3 3 13 3 3 13 1. Existing security and local police will assist. 1. Included

Total: $0

1. $1m

Total: $1m

1. Included

Total: $0

1. Included

Total:$0

3 3 13 3 2 9 2. Capacity of local police and services/infrastructure to be investigated.

2. Included

Total: $0

2. Included

Total:$0

2. Included

Total: $0

2. Included

Total: $0

3 2 9 3 2 9



CLOSURE


CLOSURE

PRE-MITIGATION



PRODUCTION PHASE





PERIOD)


MONITORING PHASE

(10 YEAR CARE AND



ADDITIONAL ACTIONS

REQUIRED POST RISK

ASSESSMENT

ADDITIONAL CLOSURE



Reputation/Social/


Safety


Current

Operating costs

(2019)

(Annual cost in $m)



in $m)

Estimated Decommis-




Liability Estimate



Reputation/Social/


Safety

Additional Actions

Required

Current Operating

costs (Annual cost

in $m)

Operating costs in

the last 5 years


in $m)

Estimated Decommis-

sioning Liability

Estimate


$m)


and Maintenance

Liability Estimate


$m)


Reputation/Social/


Safety

Con

sequ

ence

Pro

babi

lity

Rat

ing

Con

sequ

ence

Pro

babi

lity

Rat

ing

Con

sequ

ence

Pro

babi

lity

Rat

ing

Con

sequ

ence

Pro

babi

lity

Rat

ing

Con

sequ

ence

Pro

babi

lity

Rat

ing

Con

sequ

ence

Pro

babi

lity

Rat

ing

Con

sequ

ence

Pro

babi

lity

Rat

ing

Con

sequ

ence

Pro

babi

lity

Rat

ing

Con

sequ

ence

Pro

babi

lity

Rat

ing

1.11 Retaining employees with specific skills during closure phase.

There is a risk that employees with specific skills required during closure may leave prior to closure, requiring recruitment of additional employees (adding costs).

4 4 21 1. A retention strategy/plan to be developed for the final 5 years to address this risk (strategy to include all critical skills and not only production critical skills). (Include redeployment, retention bonuses, etc. in plan).

1. $0

Total: $0

1. $3.6

Total: $3.6

1. $0

Total: $0

1. $0

Total: $0


1.12 Deterioration of town services.

There is a risk of recruiting the appropriate skills during this phase, considering deteriorating services such as schooling, hospital, etc.

3 3 13 Review and generate competitive packages to stay competitive and flexible packages first in and first out (FIFO, etc.).

1. Included

Total: $0

1. Included

Total: $0

1. Included

Total: $0

1. Included

Total: $0


1.13 Main contracting companies treatment of employees at mine closure.

If the main contracting companies do not follow due process when retrenching or redeploying their personnel when the mine closes there could be reputational consequences for the company.

3 3 13 1. Confirmed with key contracting companies regarding their downscaling and retrenchment plans. Ongoing engagement and monitoring with contractors regarding downscaling of operations and closure. (Main contracts contain clause on retrenchment process).

2. The SEP must includes the message related to contractor company responsibilities and contractor to also comply with the labour act.

1. Included

2. Included

Total: $0

1. Included

2. Included

Total: $0

1. Included

2. Included

Total: $0

1. Included

2. Included

Total: $0


1.14 Contractor claims for early contract termination.

Risk of additional cost due toe early terminations – short notice.

4 4 21 1. Continuous communication with contractors

2. Future communications on short notice, etc.

3. Possible re-negotiations for those contracts that extend beyond LoA.

1. Included

2. Included

3. Included

Total: $0

1. Included

2. Included

3. Included

Total: $0

1. Included

2. Included

3. Included

Total: $0

1. Included

2. Included

3. Included

Total: $0


1.15 Employee HRA.

If HRA indicates that many employees may require post-closure health management due to occupational and chronic diseases, a post-closure health management plan may need to be developed (financial, reputational, social).

2 2 5 1. Conduct surveillance programmes and identify any additional actions and costs.

2. Mandatory entry and exit medicals is in place.

3. Historical and current statistics need to be collated, analysed and tracked.

4. VCT and Wellness Programmes (HIV/TB) to continue and be tracked through medical aid system.

5. Disability payments will continue via disability insurance.

1. None

2. None

3. Included

4. None

5. $0,8m

Total: $0,8m

1. $0,5m

2. $1,2m

3. Included

4. None

5. $4m

Total: $5,7m

1. $1m

2. $0,2m

3. Included

4. None

5. $4m

Total: $5,2m

1. $0,4m

2. $0m

3. Included

4. None

5. $1,4m

Total: $1,8m





CLOSURE


CLOSURE

PRE-MITIGATION



PRODUCTION PHASE





PERIOD)


MONITORING PHASE

(10 YEAR CARE AND



ADDITIONAL ACTIONS

REQUIRED POST RISK

ASSESSMENT

ADDITIONAL CLOSURE



Reputation/Social/


Safety


Current

Operating costs

(2019)

(Annual cost in $m)



in $m)

Estimated Decommis-




Liability Estimate



Reputation/Social/


Safety

Additional Actions

Required

Current Operating

costs (Annual cost

in $m)

Operating costs in

the last 5 years


in $m)

Estimated Decommis-

sioning Liability

Estimate


$m)


and Maintenance

Liability Estimate


$m)


Reputation/Social/


Safety

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1.11 Retaining employees with specific skills during closure phase.

There is a risk that employees with specific skills required during closure may leave prior to closure, requiring recruitment of additional employees (adding costs).

4 4 21 1. A retention strategy/plan to be developed for the final 5 years to address this risk (strategy to include all critical skills and not only production critical skills). (Include redeployment, retention bonuses, etc. in plan).

1. $0

Total: $0

1. $3.6

Total: $3.6

1. $0

Total: $0

1. $0

Total: $0


1.12 Deterioration of town services.

There is a risk of recruiting the appropriate skills during this phase, considering deteriorating services such as schooling, hospital, etc.

3 3 13 Review and generate competitive packages to stay competitive and flexible packages first in and first out (FIFO, etc.).

1. Included

Total: $0

1. Included

Total: $0

1. Included

Total: $0

1. Included

Total: $0


1.13 Main contracting companies treatment of employees at mine closure.

If the main contracting companies do not follow due process when retrenching or redeploying their personnel when the mine closes there could be reputational consequences for the company.

3 3 13 1. Confirmed with key contracting companies regarding their downscaling and retrenchment plans. Ongoing engagement and monitoring with contractors regarding downscaling of operations and closure. (Main contracts contain clause on retrenchment process).

2. The SEP must includes the message related to contractor company responsibilities and contractor to also comply with the labour act.

1. Included

2. Included

Total: $0

1. Included

2. Included

Total: $0

1. Included

2. Included

Total: $0

1. Included

2. Included

Total: $0


1.14 Contractor claims for early contract termination.

Risk of additional cost due toe early terminations – short notice.

4 4 21 1. Continuous communication with contractors

2. Future communications on short notice, etc.

3. Possible re-negotiations for those contracts that extend beyond LoA.

1. Included

2. Included

3. Included

Total: $0

1. Included

2. Included

3. Included

Total: $0

1. Included

2. Included

3. Included

Total: $0

1. Included

2. Included

3. Included

Total: $0


1.15 Employee HRA.

If HRA indicates that many employees may require post-closure health management due to occupational and chronic diseases, a post-closure health management plan may need to be developed (financial, reputational, social).

2 2 5 1. Conduct surveillance programmes and identify any additional actions and costs.

2. Mandatory entry and exit medicals is in place.

3. Historical and current statistics need to be collated, analysed and tracked.

4. VCT and Wellness Programmes (HIV/TB) to continue and be tracked through medical aid system.

5. Disability payments will continue via disability insurance.

1. None

2. None

3. Included

4. None

5. $0,8m

Total: $0,8m

1. $0,5m

2. $1,2m

3. Included

4. None

5. $4m

Total: $5,7m

1. $1m

2. $0,2m

3. Included

4. None

5. $4m

Total: $5,2m

1. $0,4m

2. $0m

3. Included

4. None

5. $1,4m

Total: $1,8m




CLOSURE


CLOSURE

PRE-MITIGATION



PRODUCTION PHASE





PERIOD)


MONITORING PHASE

(10 YEAR CARE AND



ADDITIONAL ACTIONS

REQUIRED POST RISK

ASSESSMENT

ADDITIONAL CLOSURE



Reputation/Social/


Safety


Current

Operating costs

(2019)

(Annual cost in $m)



in $m)

Estimated Decommis-




Liability Estimate



Reputation/Social/


Safety

Additional Actions

Required

Current Operating

costs (Annual cost

in $m)

Operating costs in

the last 5 years


in $m)

Estimated Decommis-

sioning Liability

Estimate


$m)


and Maintenance

Liability Estimate


$m)


Reputation/Social/


Safety

Con

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ence

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1.16 Impact on public health system in labour sending areas and local areas if ex-employees all have to access public health facilities post-closure.

Risk that labour sending areas public health system will not be able to cope with influx of ex-employees and dependants returning (requiring funding/support from company).

2 2 5 1. No additional mitigation anticipated (To be confirmed with current study).

1. None

Total: $0

1. None

Total: $0

1. None

Total: $0

1. None

Total: $0

2 2 5 None required 2 2 5

OVERALL Totals (Excluding additional actions). $7,6m $57,8m $48,7m $9,4m OVERALL Totals (additional actions only).

$0 $0 $0 $0

OVERALL Totals (including additional actions).

$7,6m $57,8m $48,7m $9,4m

2. Interested and Affected parties

2.1 Socio-psychological impact:

• Increased community negativity.

• Increase in community isolation.

• Possible collapse of social organisa-tions initiated by the mine.

• Decline in general quality of life.

An increase in the nature and extent to which people experience a sense of loss of community identity and cohesion, which could lead to a need for increased counselling and psychological support for ex-employees. This could result in a situation whereby local business, churches, etc. might expect the company to support them after mine closure.

4 4 21 1. Maintain operational broad-based stakeholder engagement meetings:

1.1 Determine and develop key messaging for mine closure issues.

1.2 At stakeholder engagement sessions include these key messages on closure issues.

2. Inform stakeholders on current and future mine planning through appropriate communication platforms.

2.1 Determine and develop key closure messaging (go from broad/general issues to more specific issues over time).


2.3 Inform stakeholders on current and future mine planning through appropriate communication platforms.

3. Counselling for employees and psycho-social support.

4. Financial literacy, business acumen support to employees.

1. $1m

2. Included

3. $0,5m

4. None

Total: $1,5m

1. $4m

2. Included

3. $3m

4. $1m

Total: $8m

1. $4m

2. Included

3. $0,1m

4. None

Total: $4,1m

1. $2m

2. Included

3. $0m

4. None

Total: $2m

4 3 18 None. 4 3 18

2.2 Economic impact:

• Down-scaling of mine-related and mine-dependent businesses.

Dependency of businesses on the mine resulting in a high risk of closing down these businesses and therefore having a negative impact on the economic sector of the local area (these also include small and micro scale businesses dependent on the mine).

2 4 12 3 3 13 Note: If other mines should close/downscale at the same time the risk may be higher.

1. Identify and invest only in those social economic development (SED), Corporate Social Investment (CSI), etc, projects that will not require ongoing financial input by the mine:

1.1 Review existing identified projects and update process flow to identify projects to ensure closure components are addressed.

1.2 Review new SED strategy to ensure alignment. Also identify gaps and actions.

2. Identify service providers who are principally reliant on the mine for their business survival and determine if the mine could support them in the interim. Identify required actions and costs.

2.1 Determine who the key providers of services are (through Supply Chain) and develop a register.

2.2 Consultants to investigate small scale service providers (include in register).

2.3 Track service providers(large and small scale) with the intention to reduce dependency over time.

2.4 Assistance to be given to the most vulnerable businesses to diversify their businesses.

1. $1,7m

2. None

Total: $1,7m

1. $2,8m

2. None

Total: $2,8m

1. $2,5m

2. None

Total: $2,5m

1. None

2. None

Total: N$0

2 3 8 3 3 13 None required. 2 3 8 3 3 13




CLOSURE


CLOSURE

PRE-MITIGATION



PRODUCTION PHASE





PERIOD)


MONITORING PHASE

(10 YEAR CARE AND



ADDITIONAL ACTIONS

REQUIRED POST RISK

ASSESSMENT

ADDITIONAL CLOSURE



Reputation/Social/


Safety


Current

Operating costs

(2019)

(Annual cost in $m)



in $m)

Estimated Decommis-




Liability Estimate



Reputation/Social/


Safety

Additional Actions

Required

Current Operating

costs (Annual cost

in $m)

Operating costs in

the last 5 years


in $m)

Estimated Decommis-

sioning Liability

Estimate


$m)


and Maintenance

Liability Estimate


$m)


Reputation/Social/


Safety

Con

sequ

ence

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lity

Rat

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1.16 Impact on public health system in labour sending areas and local areas if ex-employees all have to access public health facilities post-closure.

Risk that labour sending areas public health system will not be able to cope with influx of ex-employees and dependants returning (requiring funding/support from company).

2 2 5 1. No additional mitigation anticipated (To be confirmed with current study).

1. None

Total: $0

1. None

Total: $0

1. None

Total: $0

1. None

Total: $0


OVERALL Totals (Excluding additional actions). $7,6m $57,8m $48,7m $9,4m OVERALL Totals (additional actions only).

$0 $0 $0 $0


$7,6m $57,8m $48,7m $9,4m

2. Interested and Affected parties

2.1 Socio-psychological impact:

• Increased community negativity.

• Increase in community isolation.

• Possible collapse of social organisa-tions initiated by the mine.

• Decline in general quality of life.

An increase in the nature and extent to which people experience a sense of loss of community identity and cohesion, which could lead to a need for increased counselling and psychological support for ex-employees. This could result in a situation whereby local business, churches, etc. might expect the company to support them after mine closure.

4 4 21 1. Maintain operational broad-based stakeholder engagement meetings:

1.1 Determine and develop key messaging for mine closure issues.


2. Inform stakeholders on current and future mine planning through appropriate communication platforms.

2.1 Determine and develop key closure messaging (go from broad/general issues to more specific issues over time).


2.3 Inform stakeholders on current and future mine planning through appropriate communication platforms.

3. Counselling for employees and psycho-social support.

4. Financial literacy, business acumen support to employees.

1. $1m

2. Included

3. $0,5m

4. None

Total: $1,5m

1. $4m

2. Included

3. $3m

4. $1m

Total: $8m

1. $4m

2. Included

3. $0,1m

4. None

Total: $4,1m

1. $2m

2. Included

3. $0m

4. None

Total: $2m

4 3 18 None. 4 3 18

2.2 Economic impact:

• Down-scaling of mine-related and mine-dependent businesses.

Dependency of businesses on the mine resulting in a high risk of closing down these businesses and therefore having a negative impact on the economic sector of the local area (these also include small and micro scale businesses dependent on the mine).

2 4 12 3 3 13 Note: If other mines should close/downscale at the same time the risk may be higher.

1. Identify and invest only in those social economic development (SED), Corporate Social Investment (CSI), etc, projects that will not require ongoing financial input by the mine:


1.2 Review new SED strategy to ensure alignment. Also identify gaps and actions.

2. Identify service providers who are principally reliant on the mine for their business survival and determine if the mine could support them in the interim. Identify required actions and costs.

2.1 Determine who the key providers of services are (through Supply Chain) and develop a register.

2.2 Consultants to investigate small scale service providers (include in register).

2.3 Track service providers(large and small scale) with the intention to reduce dependency over time.

2.4 Assistance to be given to the most vulnerable businesses to diversify their businesses.

1. $1,7m

2. None

Total: $1,7m

1. $2,8m

2. None

Total: $2,8m

1. $2,5m

2. None

Total: $2,5m

1. None

2. None

Total: N$0

2 3 8 3 3 13 None required. 2 3 8 3 3 13



CLOSURE


CLOSURE

PRE-MITIGATION



PRODUCTION PHASE





PERIOD)


MONITORING PHASE

(10 YEAR CARE AND



ADDITIONAL ACTIONS

REQUIRED POST RISK

ASSESSMENT

ADDITIONAL CLOSURE



Reputation/Social/


Safety


Current

Operating costs

(2019)

(Annual cost in $m)



in $m)

Estimated Decommis-




Liability Estimate



Reputation/Social/


Safety

Additional Actions

Required

Current Operating

costs (Annual cost

in $m)

Operating costs in

the last 5 years


in $m)

Estimated Decommis-

sioning Liability

Estimate


$m)


and Maintenance

Liability Estimate


$m)


Reputation/Social/


Safety

Con

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ence

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2.3 Lack of alternative socio-economic opportunities/projects to offset the economic impact of mine closure.

There is a risk that there will be a loss of revenue (rates and taxes) to the municipality (risk to municipality) due to the lack of alternative socio-economic projects that will create employment.

There is a risk that the future home owners will not be able to afford the required rates and taxes to sustain the municipality resulting in the company having to pay the shortfall on rates and taxes to the municipality.

There is also a risk of failure to attract credible investors to sustain/support town.

5 4 24 4 4 21 1. LED/SED strategy to be implemented.

2. Investor conference to beheld to improve confidence for investment.

2.1 Possible holiday housing and/or retirement opportunities to be investigated.

2.2 Higher learning entities.

2.3 Council providing serviced plots for development and selling.

2.4 Investigate options for government housing schemes.

3. Memorandum of Agreement (MoA) with town council.

4. Overarching town transformation strategy and timeline is critical beyond current LoA .

5. SPV projects (agriculture, tourism and renewable energy) would be critical. Timeous job creations will be a challenge (takes 15 plus years to create sustainable projects). Not currently in place.

6. Accommodation Strategy is critical.

7. Community Based Investment initiatives.

8. SEP (Focus is on creating awareness around the importance of paying rates and taxes).

1. Included

2. Included

3. Included

4. $5,7m

5. $1,5m

6. Included

7. Included

8. Included

Total: $7,2m

1. Included

2. Included

3. Included

4. $23,5m

5. $4,2m

6. Included

7. Included

8. Included

Total: $27,7m

1. Included

2. Included

3. Included

4. $13m

5. Included

6. Included

7. Included

8. Included

Total: $13m

1. Included

2. Included

3. Included

4. Included

5. Included

6. Included

7. Included

8. Included

Total: $0

5 4 24 4 4 21 9. Investor conference to beheld to improve confidence for investment (post production period).

10. Re-focus and alignment of Group commitment to stay committed to Town Transformation (Financial) until sustainability (15 years post production).

11. Timeous execution of initiatives under SED/LED and SPV funding.

12. The period that these initiatives will take for the SPV initiatives to materialise will take 5-15 years.

13. Original SPV objectives were planned for Job creation within a long life of asset but now the focused moved to closure mitigation.

14. Framework Agreement partnership between Government and the company needs long-term commitment.

9. None

10. None

11. None

12. Included

13. Included

14. Included

Total: $0

9. None

10. None

11. None

12. Included

13. Included

14. Included

Total: $0

9. None

10. $20m

11. $45m

12. Included

13. Included

14. Included

Total: $65m

9. None

10. $25m

11. None

12. Included

13. Included

14. Included

Total: $25m

3 3 13 4 2 14




CLOSURE


CLOSURE

PRE-MITIGATION



PRODUCTION PHASE





PERIOD)


MONITORING PHASE

(10 YEAR CARE AND



ADDITIONAL ACTIONS

REQUIRED POST RISK

ASSESSMENT

ADDITIONAL CLOSURE



Reputation/Social/


Safety


Current

Operating costs

(2019)

(Annual cost in $m)



in $m)

Estimated Decommis-




Liability Estimate



Reputation/Social/


Safety

Additional Actions

Required

Current Operating

costs (Annual cost

in $m)

Operating costs in

the last 5 years


in $m)

Estimated Decommis-

sioning Liability

Estimate


$m)


and Maintenance

Liability Estimate


$m)


Reputation/Social/


Safety

Con

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ence

Pro

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2.3 Lack of alternative socio-economic opportunities/projects to offset the economic impact of mine closure.

There is a risk that there will be a loss of revenue (rates and taxes) to the municipality (risk to municipality) due to the lack of alternative socio-economic projects that will create employment.

There is a risk that the future home owners will not be able to afford the required rates and taxes to sustain the municipality resulting in the company having to pay the shortfall on rates and taxes to the municipality.

There is also a risk of failure to attract credible investors to sustain/support town.

5 4 24 4 4 21 1. LED/SED strategy to be implemented.

2. Investor conference to beheld to improve confidence for investment.

2.1 Possible holiday housing and/or retirement opportunities to be investigated.

2.2 Higher learning entities.

2.3 Council providing serviced plots for development and selling.

2.4 Investigate options for government housing schemes.

3. Memorandum of Agreement (MoA) with town council.

4. Overarching town transformation strategy and timeline is critical beyond current LoA .

5. SPV projects (agriculture, tourism and renewable energy) would be critical. Timeous job creations will be a challenge (takes 15 plus years to create sustainable projects). Not currently in place.

6. Accommodation Strategy is critical.

7. Community Based Investment initiatives.

8. SEP (Focus is on creating awareness around the importance of paying rates and taxes).

1. Included

2. Included

3. Included

4. $5,7m

5. $1,5m

6. Included

7. Included

8. Included

Total: $7,2m

1. Included

2. Included

3. Included

4. $23,5m

5. $4,2m

6. Included

7. Included

8. Included

Total: $27,7m

1. Included

2. Included

3. Included

4. $13m

5. Included

6. Included

7. Included

8. Included

Total: $13m

1. Included

2. Included

3. Included

4. Included

5. Included

6. Included

7. Included

8. Included

Total: $0

5 4 24 4 4 21 9. Investor conference to beheld to improve confidence for investment (post production period).

10. Re-focus and alignment of Group commitment to stay committed to Town Transformation (Financial) until sustainability (15 years post production).

11. Timeous execution of initiatives under SED/LED and SPV funding.

12. The period that these initiatives will take for the SPV initiatives to materialise will take 5-15 years.

13. Original SPV objectives were planned for Job creation within a long life of asset but now the focused moved to closure mitigation.

14. Framework Agreement partnership between Government and the company needs long-term commitment.

9. None

10. None

11. None

12. Included

13. Included

14. Included

Total: $0

9. None

10. None

11. None

12. Included

13. Included

14. Included

Total: $0

9. None

10. $20m

11. $45m

12. Included

13. Included

14. Included

Total: $65m

9. None

10. $25m

11. None

12. Included

13. Included

14. Included

Total: $25m

3 3 13 4 2 14



CLOSURE


CLOSURE

PRE-MITIGATION



PRODUCTION PHASE





PERIOD)


MONITORING PHASE

(10 YEAR CARE AND



ADDITIONAL ACTIONS

REQUIRED POST RISK

ASSESSMENT

ADDITIONAL CLOSURE



Reputation/Social/


Safety


Current

Operating costs

(2019)

(Annual cost in $m)



in $m)

Estimated Decommis-




Liability Estimate



Reputation/Social/


Safety

Additional Actions

Required

Current Operating

costs (Annual cost

in $m)

Operating costs in

the last 5 years


in $m)

Estimated Decommis-

sioning Liability

Estimate


$m)


and Maintenance

Liability Estimate


$m)


Reputation/Social/


Safety

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2.4 Government’s lack of capacity to take over community services associated with health and education.

The mine contributes to social development in around the communities and towns. The risk is that when the mine closes these contributions will dwindle and fall-away over time leaving the municipality/region to pick-up on these services.

There is a also a risk that current funding and support related to education might not be sustained post mining (schools might have to close), resulting in community dissatisfaction and reputational risks.

4 3 18 1. Government/Municipal capacity building programme initiative to be identified and costed.

2. Possible Trust option for protection and management of infrastructure (Government will lease from a Trust).

3. Agreement with government to take over all services.

4. Primary-Private School to be funded by the company, the High School will be a Model C School (Part government and part company funded).

5. Review and establish the additional capacity requirements associate with the hospital and security (police) services and infrastructure (additional beds required and police cells, etc.).

6. Investigate options for a 3rd party to take over for funding for the Private primary school and the Model C High School post closure.

7. Investigate alternative housing options.

8. Company to match government’s investment in the local area.

1. $0,1m

2. Included

3. Included

4. Included

5. Included

6. Included

7. Included

8. Included

Total: $0,1m

1. $0,4m

2. Included

3. Included

4. Included

5. Included

6. Included

7. Included

8. Included

Total: $0,4m

1. None

2. Included

3. Included

4. Included

5. Included

6. Included

7. Included

8. Included

Total: $0

1. None

2. Included

3. Included

4. Included

5. Included

6. Included

7. Included

8. Included

Total: $0


2.5 Consultation with affected parties.

If consultation does not follow correct legal and other procedures uncertainties in communities and other affected parties in regards to closure issues may lead to financial, legal and/or reputational risks.

4 5 23 1. Stakeholder Engagement Plan (detailed, focused, timeous) must be updated/adapted to include closure issues and criteria. It is critical that there is ongoing stakeholder engagement. It is important that there is sufficient capacity and skills to implement the stakeholder engagement plan – post closure. (Note: Only one SEP required to ensure consistency of message.)

1.1. Develop a separate SEP for closure and then integrate into broader SEP.

1. Included

Total: $0

1. Included

Total: $0

1. Included

Total: $0

1. Included

Total: $0


2.6 Community health/safety impact post closure.

There is a risk that there may be health/safety impacts on surrounding communities and tourists post closure (asbestos, old buildings, voids, long term health impacts etc.).

4 4 21 4 4 21 1. Community health risk assessment prior to closure to establish baseline.

2. Post-closure data management and integrity will be maintained (Occupational hygienist will remain employed till post decommissioning).

3. Management of land tenure post-closure (prior to closure certificate) will be maintained.

4. Emergency response planning during closure and post-closure phase to be maintained.

4.1 MoU in place with council for current services.

4.2 Cost reflected only includes current operational expenditure and not replacement of equipment.

5. Closure specific requirements in the bio-physical closure plan (Will address the related social risks (shaping of dumps, management of voids and ponds etc.).

6. Review current Rehabilitation Plan of 2019.

7. All contractors handling asbestos related infrastructure go through asbestos handling training prior executing the job.

1. None

2. $0,2m

3. Included

4. $1,2m

5.Included

6. Included

7. Included

Total: $1,4m

1. None

2. $1m

3. Included

4. $2,8m

5.Included

6. Included

7. Included

Total: $3,8m

1. $0,2m

2. $2m

3. Included

4. $3m

5.Included

6. Included

7. Included

Total: $5,2m

1. None

2. None

3. Included

4. $1m

5.Included

6. Included

7. Included

Total: $1m

4 2 14 4 2 14 None 4 3 18 4 3 18




CLOSURE


CLOSURE

PRE-MITIGATION



PRODUCTION PHASE





PERIOD)


MONITORING PHASE

(10 YEAR CARE AND



ADDITIONAL ACTIONS

REQUIRED POST RISK

ASSESSMENT

ADDITIONAL CLOSURE



Reputation/Social/


Safety


Current

Operating costs

(2019)

(Annual cost in $m)



in $m)

Estimated Decommis-




Liability Estimate



Reputation/Social/


Safety

Additional Actions

Required

Current Operating

costs (Annual cost

in $m)

Operating costs in

the last 5 years


in $m)

Estimated Decommis-

sioning Liability

Estimate


$m)


and Maintenance

Liability Estimate


$m)


Reputation/Social/


Safety

Con

sequ

ence

Pro

babi

lity

Rat

ing

Con

sequ

ence

Pro

babi

lity

Rat

ing

Con

sequ

ence

Pro

babi

lity

Rat

ing

Con

sequ

ence

Pro

babi

lity

Rat

ing

Con

sequ

ence

Pro

babi

lity

Rat

ing

Con

sequ

ence

Pro

babi

lity

Rat

ing

Con

sequ

ence

Pro

babi

lity

Rat

ing

Con

sequ

ence

Pro

babi

lity

Rat

ing

Con

sequ

ence

Pro

babi

lity

Rat

ing

2.4 Government’s lack of capacity to take over community services associated with health and education.

The mine contributes to social development in around the communities and towns. The risk is that when the mine closes these contributions will dwindle and fall-away over time leaving the municipality/region to pick-up on these services.

There is a also a risk that current funding and support related to education might not be sustained post mining (schools might have to close), resulting in community dissatisfaction and reputational risks.

4 3 18 1. Government/Municipal capacity building programme initiative to be identified and costed.

2. Possible Trust option for protection and management of infrastructure (Government will lease from a Trust).

3. Agreement with government to take over all services.

4. Primary-Private School to be funded by the company, the High School will be a Model C School (Part government and part company funded).

5. Review and establish the additional capacity requirements associate with the hospital and security (police) services and infrastructure (additional beds required and police cells, etc.).

6. Investigate options for a 3rd party to take over for funding for the Private primary school and the Model C High School post closure.

7. Investigate alternative housing options.

8. Company to match government’s investment in the local area.

1. $0,1m

2. Included

3. Included

4. Included

5. Included

6. Included

7. Included

8. Included

Total: $0,1m

1. $0,4m

2. Included

3. Included

4. Included

5. Included

6. Included

7. Included

8. Included

Total: $0,4m

1. None

2. Included

3. Included

4. Included

5. Included

6. Included

7. Included

8. Included

Total: $0

1. None

2. Included

3. Included

4. Included

5. Included

6. Included

7. Included

8. Included

Total: $0


2.5 Consultation with affected parties.

If consultation does not follow correct legal and other procedures uncertainties in communities and other affected parties in regards to closure issues may lead to financial, legal and/or reputational risks.

4 5 23 1. Stakeholder Engagement Plan (detailed, focused, timeous) must be updated/adapted to include closure issues and criteria. It is critical that there is ongoing stakeholder engagement. It is important that there is sufficient capacity and skills to implement the stakeholder engagement plan – post closure. (Note: Only one SEP required to ensure consistency of message.)

1.1. Develop a separate SEP for closure and then integrate into broader SEP.

1. Included

Total: $0

1. Included

Total: $0

1. Included

Total: $0

1. Included

Total: $0


2.6 Community health/safety impact post closure.

There is a risk that there may be health/safety impacts on surrounding communities and tourists post closure (asbestos, old buildings, voids, long term health impacts etc.).

4 4 21 4 4 21 1. Community health risk assessment prior to closure to establish baseline.

2. Post-closure data management and integrity will be maintained (Occupational hygienist will remain employed till post decommissioning).

3. Management of land tenure post-closure (prior to closure certificate) will be maintained.

4. Emergency response planning during closure and post-closure phase to be maintained.

4.1 MoU in place with council for current services.

4.2 Cost reflected only includes current operational expenditure and not replacement of equipment.

5. Closure specific requirements in the bio-physical closure plan (Will address the related social risks (shaping of dumps, management of voids and ponds etc.).

6. Review current Rehabilitation Plan of 2019.

7. All contractors handling asbestos related infrastructure go through asbestos handling training prior executing the job.

1. None

2. $0,2m

3. Included

4. $1,2m

5.Included

6. Included

7. Included

Total: $1,4m

1. None

2. $1m

3. Included

4. $2,8m

5.Included

6. Included

7. Included

Total: $3,8m

1. $0,2m

2. $2m

3. Included

4. $3m

5.Included

6. Included

7. Included

Total: $5,2m

1. None

2. None

3. Included

4. $1m

5.Included

6. Included

7. Included

Total: $1m

4 2 14 4 2 14 None 4 3 18 4 3 18



CLOSURE


CLOSURE

PRE-MITIGATION



PRODUCTION PHASE





PERIOD)


MONITORING PHASE

(10 YEAR CARE AND



ADDITIONAL ACTIONS

REQUIRED POST RISK

ASSESSMENT

ADDITIONAL CLOSURE



Reputation/Social/


Safety


Current

Operating costs

(2019)

(Annual cost in $m)



in $m)

Estimated Decommis-




Liability Estimate



Reputation/Social/


Safety

Additional Actions

Required

Current Operating

costs (Annual cost

in $m)

Operating costs in

the last 5 years


in $m)

Estimated Decommis-

sioning Liability

Estimate


$m)


and Maintenance

Liability Estimate


$m)


Reputation/Social/


Safety

Con

sequ

ence

Pro

babi

lity

Rat

ing

Con

sequ

ence

Pro

babi

lity

Rat

ing

Con

sequ

ence

Pro

babi

lity

Rat

ing

Con

sequ

ence

Pro

babi

lity

Rat

ing

Con

sequ

ence

Pro

babi

lity

Rat

ing

Con

sequ

ence

Pro

babi

lity

Rat

ing

Con

sequ

ence

Pro

babi

lity

Rat

ing

Con

sequ

ence

Pro

babi

lity

Rat

ing

Con

sequ

ence

Pro

babi

lity

Rat

ing

2.7 Media (includes social media).

The risk of increased negative publicity based on non-factual sensualisation.

5 3 22 4 4 21 1. Unpack current concerns and expectations and either address as part of the SEP process and or as part of the current operational risk management plan and I&AP issues log.

2. Targeted Media intervention.

3. Pro active business update and factual data supply to Employees, government and other key stakeholders.

1. Included

2. Included

3. Included

Total: $0

1. Included

2. Included

3. Included

Total: $0

1. Included

2. Included

3. Included

Total: $0

1. Included

2. Included

3. Included

Total: $0

4 3 18 4 3 18 None required 4 3 18 4 3 18

2.8 Increase in social ills in town.

There is a risk that social ills will increase significantly, also considering the lack of employment post mining. This will be exacerbated as a result of mine closure and increase in unemployment.

4 4 21 1. Appropriate programmes which address social ills, drug and alcohol abuse, violence, teenage pregnancies etc.

2. Improve home-owner security.

3. Security forces require collaboration.

4. Review and improve existing capacity.

5. Clarification of roles and responsibilities for the handling of social ills incidents.

6. Collaboration and engage with government for public health services.

1. $0,5m

2. None

3. Included

4. None

5. Included

6. Included

Total: $0,5m

1. $2m

2. None

3. Included

4. None

5. Included

6. Included

Total: $2m

1. $2m

2. None

3. Included

4. None

5. Included

6. Included

Total: $2m

1. None

2. None

3. Included

4. None

5. Included

6. Included

Total: $0

4 3 18 None 4 3 18

2.9 Closure vision/land-use plan may not be aligned with expectations of the communities.

There is a risk that the current vision and land-use plan is not acceptable to affected parties and any change to the vision and land-use plan will result in a change in the closure liability estimate. Stakeholder conflicts in terms of the desired post-mining land-use/s may result in delayed site relinquishment and/or attaining mine closure.

3 3 13 1. To be dealt with in the SEP (especially in terms of closure vision and post closure land-use).

2. Studies are done to prove land capability and viability of land for various uses post-closure.

Note: What can and cannot be achieved at closure should drive engagement with I&APs.

1. Included

2. Included

Total: $0

1. Included

2. Included

Total: $0

1. Included

2. Included

Total: $0

1. Included

2. Included

Total: $0





CLOSURE


CLOSURE

PRE-MITIGATION



PRODUCTION PHASE





PERIOD)


MONITORING PHASE

(10 YEAR CARE AND



ADDITIONAL ACTIONS

REQUIRED POST RISK

ASSESSMENT

ADDITIONAL CLOSURE



Reputation/Social/


Safety


Current

Operating costs

(2019)

(Annual cost in $m)



in $m)

Estimated Decommis-




Liability Estimate



Reputation/Social/


Safety

Additional Actions

Required

Current Operating

costs (Annual cost

in $m)

Operating costs in

the last 5 years


in $m)

Estimated Decommis-

sioning Liability

Estimate


$m)


and Maintenance

Liability Estimate


$m)


Reputation/Social/


Safety

Con

sequ

ence

Pro

babi

lity

Rat

ing

Con

sequ

ence

Pro

babi

lity

Rat

ing

Con

sequ

ence

Pro

babi

lity

Rat

ing

Con

sequ

ence

Pro

babi

lity

Rat

ing

Con

sequ

ence

Pro

babi

lity

Rat

ing

Con

sequ

ence

Pro

babi

lity

Rat

ing

Con

sequ

ence

Pro

babi

lity

Rat

ing

Con

sequ

ence

Pro

babi

lity

Rat

ing

Con

sequ

ence

Pro

babi

lity

Rat

ing

2.7 Media (includes social media).

The risk of increased negative publicity based on non-factual sensualisation.


2. Targeted Media intervention.

3. Pro active business update and factual data supply to Employees, government and other key stakeholders.

1. Included

2. Included

3. Included

Total: $0

1. Included

2. Included

3. Included

Total: $0

1. Included

2. Included

3. Included

Total: $0

1. Included

2. Included

3. Included

Total: $0

4 3 18 4 3 18 None required 4 3 18 4 3 18

2.8 Increase in social ills in town.

There is a risk that social ills will increase significantly, also considering the lack of employment post mining. This will be exacerbated as a result of mine closure and increase in unemployment.

4 4 21 1. Appropriate programmes which address social ills, drug and alcohol abuse, violence, teenage pregnancies etc.

2. Improve home-owner security.

3. Security forces require collaboration.

4. Review and improve existing capacity.

5. Clarification of roles and responsibilities for the handling of social ills incidents.

6. Collaboration and engage with government for public health services.

1. $0,5m

2. None

3. Included

4. None

5. Included

6. Included

Total: $0,5m

1. $2m

2. None

3. Included

4. None

5. Included

6. Included

Total: $2m

1. $2m

2. None

3. Included

4. None

5. Included

6. Included

Total: $2m

1. None

2. None

3. Included

4. None

5. Included

6. Included

Total: $0

4 3 18 None 4 3 18

2.9 Closure vision/land-use plan may not be aligned with expectations of the communities.

There is a risk that the current vision and land-use plan is not acceptable to affected parties and any change to the vision and land-use plan will result in a change in the closure liability estimate. Stakeholder conflicts in terms of the desired post-mining land-use/s may result in delayed site relinquishment and/or attaining mine closure.

3 3 13 1. To be dealt with in the SEP (especially in terms of closure vision and post closure land-use).

2. Studies are done to prove land capability and viability of land for various uses post-closure.

Note: What can and cannot be achieved at closure should drive engagement with I&APs.

1. Included

2. Included

Total: $0

1. Included

2. Included

Total: $0

1. Included

2. Included

Total: $0

1. Included

2. Included

Total: $0




CLOSURE


CLOSURE

PRE-MITIGATION



PRODUCTION PHASE





PERIOD)


MONITORING PHASE

(10 YEAR CARE AND



ADDITIONAL ACTIONS

REQUIRED POST RISK

ASSESSMENT

ADDITIONAL CLOSURE



Reputation/Social/


Safety


Current

Operating costs

(2019)

(Annual cost in $m)



in $m)

Estimated Decommis-




Liability Estimate



Reputation/Social/


Safety

Additional Actions

Required

Current Operating

costs (Annual cost

in $m)

Operating costs in

the last 5 years


in $m)

Estimated Decommis-

sioning Liability

Estimate


$m)


and Maintenance

Liability Estimate


$m)


Reputation/Social/


Safety

Con

sequ

ence

Pro

babi

lity

Rat

ing

Con

sequ

ence

Pro

babi

lity

Rat

ing

Con

sequ

ence

Pro

babi

lity

Rat

ing

Con

sequ

ence

Pro

babi

lity

Rat

ing

Con

sequ

ence

Pro

babi

lity

Rat

ing

Con

sequ

ence

Pro

babi

lity

Rat

ing

Con

sequ

ence

Pro

babi

lity

Rat

ing

Con

sequ

ence

Pro

babi

lity

Rat

ing

Con

sequ

ence

Pro

babi

lity

Rat

ing

2.10 Unsustain-ability of the local town (Town Transfor-mation, Social Way).

Risk of failure to implement long-term objectives/projects in support of town sustainability.

Risk of failure to implement accommodation/housing strategy that will impact on town sustainability.

Loss of support for town transformation from key stakeholders.

Risk that banks will not provide finance for bonds and other business opportunities, due to the current/perceived risk.

5 3 22 5 4 24 1. Identify and invest only in those social economic development (SED, CSI, etc.) projects that will not require ongoing financial input by the mine:


2. Review new SED strategy to ensure alignment. Also identify gaps and actions.

3. LED strategy to be executed.

4. Investor conference to be held.

5. MoA with town council.

6. Town conditioning report.

7. Overarching town transformation strategy and timeline.

8. Decision making framework with monetary and authority levels.

9. Town infrastructure master plan.

10. Asset register and conditioning assessment report.

11. SPV (Agriculture/Tourism/Alternative Energy).

12. Accommodation Strategy.

13. Higher learning entities.

14. SEP to include wider collaboration with other businesses and wider region.

15. Housing strategy which includes selling of houses to both employees, government employees and private enterprises.

16. Council providing serviced plots for development and selling.

17. Investigate options for government housing schemes.

18. Review and revise housing and employment conditions strategy.

19. Steercom (Regional Councilor, Mayor, the Attorney General as the Patriot).

(See recommended and additional actions as listed for Action 2.3).

1. Included

2. Included

3. Included

4. Included

5. Included

6. Included

7. Included

8. Included

9. Included

10. Included

11. Included

12. Included

13. Included

14. Included

15. Included

16. Included

17. Included

18. Included

19. Included

Total: N$0

1. Included

2. Included

3. Included

4. Included

5. Included

6. Included

7. Included

8. Included

9. Included

10. Included

11. Included

12. Included

13. Included

14. Included

15. Included

16. Included

17. Included

18. Included

19. Included

Total: N$0

1. Included

2. Included

3. Included

4. Included

5. Included

6. Included

7. Included

8. Included

9. Included

10. Included

11. Included

12. Included

13. Included

14. Included

15. Included

16. Included

17. Included

18. Included

19. Included

Total: N$0

1. Included

2. Included

3. Included

4. Included

5. Included

6. Included

7. Included

8. Included

9. Included

10. Included

11. Included

12. Included

13. Included

14. Included

15. Included

16. Included

17. Included

18. Included

19. Included

Total: N$0

5 3 22 5 3 22 (See recommended and additional actions as listed for Action 2.3).

1. Included

2. Included

3. Included

4. Included

5. Included

6. Included

7. Included

8. Included

9. Included

10. Included

11. Included

12. Included

13. Included

14. Included

15. Included

16. Included

17. Included

18. Included

19. Included

Total: N$0

1. Included

2. Included

3. Included

4. Included

5. Included

6. Included

7. Included

8. Included

9. Included

10. Included

11. Included

12. Included

13. Included

14. Included

15. Included

16. Included

17. Included

18. Included

19. Included

Total: N$0

1. Included

2. Included

3. Included

4. Included

5. Included

6. Included

7. Included

8. Included

9. Included

10. Included

11. Included

12. Included

13. Included

14. Included

15. Included

16. Included

17. Included

18. Included

19. Included

Total: N$0

1. Included

2. Included

3. Included

4. Included

5. Included

6. Included

7. Included

8. Included

9. Included

10. Included

11. Included

12. Included

13. Included

14. Included

15. Included

16. Included

17. Included

18. Included

19. Included

Total: N$0

3 3 13 4 2 14

2.11 Expectations and concerns raised in NGO/CBO reports.

If expectations and concerns raised by NGOs are not addressed prior to and during closure there may be further negative publicity in this regard striking community unhappiness and potential for increasing costs during closure.

5 4 24

1. Unpack current concerns and expectations and either address as part of the SEP process and or as part of the current operational risk management plan and I&AP issues log.

1. Included

Total: $0

1. Included

Total: $0

1. Included

Total: $0

1. Included

Total: $0

5 1 15 None 5 1 15

2.12 Significant health and safety implications due to illegal mining post production/closure.

There is a risk of significant health and safety implications due to illegal mining post production/closure. (Fatalities).

5 3 22 1. Bio-physical rehabilitation criteria will be implemented, as per the rehabilitation plan. (Note: The cost associated with bio-physical closure is already included in the overall mine closure plan liability estimate).

2. Security controls will be in place.

1. None

2. Included

Total: $0

1. None

2. Included

Total: $0

1. None

2. Included

Total: $0

1. None

2. Included

Total: $0

5 2 19 None 5 2 19




CLOSURE


CLOSURE

PRE-MITIGATION



PRODUCTION PHASE





PERIOD)


MONITORING PHASE

(10 YEAR CARE AND



ADDITIONAL ACTIONS

REQUIRED POST RISK

ASSESSMENT

ADDITIONAL CLOSURE



Reputation/Social/


Safety


Current

Operating costs

(2019)

(Annual cost in $m)



in $m)

Estimated Decommis-




Liability Estimate



Reputation/Social/


Safety

Additional Actions

Required

Current Operating

costs (Annual cost

in $m)

Operating costs in

the last 5 years


in $m)

Estimated Decommis-

sioning Liability

Estimate


$m)


and Maintenance

Liability Estimate


$m)


Reputation/Social/


Safety

Con

sequ

ence

Pro

babi

lity

Rat

ing

Con

sequ

ence

Pro

babi

lity

Rat

ing

Con

sequ

ence

Pro

babi

lity

Rat

ing

Con

sequ

ence

Pro

babi

lity

Rat

ing

Con

sequ

ence

Pro

babi

lity

Rat

ing

Con

sequ

ence

Pro

babi

lity

Rat

ing

Con

sequ

ence

Pro

babi

lity

Rat

ing

Con

sequ

ence

Pro

babi

lity

Rat

ing

Con

sequ

ence

Pro

babi

lity

Rat

ing

2.10 Unsustain-ability of the local town (Town Transfor-mation, Social Way).

Risk of failure to implement long-term objectives/projects in support of town sustainability.

Risk of failure to implement accommodation/housing strategy that will impact on town sustainability.

Loss of support for town transformation from key stakeholders.

Risk that banks will not provide finance for bonds and other business opportunities, due to the current/perceived risk.

5 3 22 5 4 24 1. Identify and invest only in those social economic development (SED, CSI, etc.) projects that will not require ongoing financial input by the mine:


2. Review new SED strategy to ensure alignment. Also identify gaps and actions.

3. LED strategy to be executed.

4. Investor conference to be held.

5. MoA with town council.

6. Town conditioning report.

7. Overarching town transformation strategy and timeline.

8. Decision making framework with monetary and authority levels.

9. Town infrastructure master plan.

10. Asset register and conditioning assessment report.

11. SPV (Agriculture/Tourism/Alternative Energy).

12. Accommodation Strategy.

13. Higher learning entities.

14. SEP to include wider collaboration with other businesses and wider region.

15. Housing strategy which includes selling of houses to both employees, government employees and private enterprises.

16. Council providing serviced plots for development and selling.

17. Investigate options for government housing schemes.

18. Review and revise housing and employment conditions strategy.

19. Steercom (Regional Councilor, Mayor, the Attorney General as the Patriot).

(See recommended and additional actions as listed for Action 2.3).

1. Included

2. Included

3. Included

4. Included

5. Included

6. Included

7. Included

8. Included

9. Included

10. Included

11. Included

12. Included

13. Included

14. Included

15. Included

16. Included

17. Included

18. Included

19. Included

Total: N$0

1. Included

2. Included

3. Included

4. Included

5. Included

6. Included

7. Included

8. Included

9. Included

10. Included

11. Included

12. Included

13. Included

14. Included

15. Included

16. Included

17. Included

18. Included

19. Included

Total: N$0

1. Included

2. Included

3. Included

4. Included

5. Included

6. Included

7. Included

8. Included

9. Included

10. Included

11. Included

12. Included

13. Included

14. Included

15. Included

16. Included

17. Included

18. Included

19. Included

Total: N$0

1. Included

2. Included

3. Included

4. Included

5. Included

6. Included

7. Included

8. Included

9. Included

10. Included

11. Included

12. Included

13. Included

14. Included

15. Included

16. Included

17. Included

18. Included

19. Included

Total: N$0

5 3 22 5 3 22 (See recommended and additional actions as listed for Action 2.3).

1. Included

2. Included

3. Included

4. Included

5. Included

6. Included

7. Included

8. Included

9. Included

10. Included

11. Included

12. Included

13. Included

14. Included

15. Included

16. Included

17. Included

18. Included

19. Included

Total: N$0

1. Included

2. Included

3. Included

4. Included

5. Included

6. Included

7. Included

8. Included

9. Included

10. Included

11. Included

12. Included

13. Included

14. Included

15. Included

16. Included

17. Included

18. Included

19. Included

Total: N$0

1. Included

2. Included

3. Included

4. Included

5. Included

6. Included

7. Included

8. Included

9. Included

10. Included

11. Included

12. Included

13. Included

14. Included

15. Included

16. Included

17. Included

18. Included

19. Included

Total: N$0

1. Included

2. Included

3. Included

4. Included

5. Included

6. Included

7. Included

8. Included

9. Included

10. Included

11. Included

12. Included

13. Included

14. Included

15. Included

16. Included

17. Included

18. Included

19. Included

Total: N$0

3 3 13 4 2 14

2.11 Expectations and concerns raised in NGO/CBO reports.

If expectations and concerns raised by NGOs are not addressed prior to and during closure there may be further negative publicity in this regard striking community unhappiness and potential for increasing costs during closure.

5 4 24

1. Unpack current concerns and expectations and either address as part of the SEP process and or as part of the current operational risk management plan and I&AP issues log.

1. Included

Total: $0

1. Included

Total: $0

1. Included

Total: $0

1. Included

Total: $0

5 1 15 None 5 1 15

2.12 Significant health and safety implications due to illegal mining post production/closure.

There is a risk of significant health and safety implications due to illegal mining post production/closure. (Fatalities).

5 3 22 1. Bio-physical rehabilitation criteria will be implemented, as per the rehabilitation plan. (Note: The cost associated with bio-physical closure is already included in the overall mine closure plan liability estimate).

2. Security controls will be in place.

1. None

2. Included

Total: $0

1. None

2. Included

Total: $0

1. None

2. Included

Total: $0

1. None

2. Included

Total: $0

5 2 19 None 5 2 19



CLOSURE


CLOSURE

PRE-MITIGATION



PRODUCTION PHASE





PERIOD)


MONITORING PHASE

(10 YEAR CARE AND



ADDITIONAL ACTIONS

REQUIRED POST RISK

ASSESSMENT

ADDITIONAL CLOSURE



Reputation/Social/


Safety


Current

Operating costs

(2019)

(Annual cost in $m)



in $m)

Estimated Decommis-




Liability Estimate



Reputation/Social/


Safety

Additional Actions

Required

Current Operating

costs (Annual cost

in $m)

Operating costs in

the last 5 years


in $m)

Estimated Decommis-

sioning Liability

Estimate


$m)


and Maintenance

Liability Estimate


$m)


Reputation/Social/


Safety

Con

sequ

ence

Pro

babi

lity

Rat

ing

Con

sequ

ence

Pro

babi

lity

Rat

ing

Con

sequ

ence

Pro

babi

lity

Rat

ing

Con

sequ

ence

Pro

babi

lity

Rat

ing

Con

sequ

ence

Pro

babi

lity

Rat

ing

Con

sequ

ence

Pro

babi

lity

Rat

ing

Con

sequ

ence

Pro

babi

lity

Rat

ing

Con

sequ

ence

Pro

babi

lity

Rat

ing

Con

sequ

ence

Pro

babi

lity

Rat

ing

2.13 Human rights and heritage impacts.

Risk of human rights and heritage impacts at closure.

4 2 14 1. Conduct a human rights and heritage impact due diligence for closure – can be included in human rights and heritage risk assessment.

2. Operate according to company policy and standards and within the legal frameworks.

3. Human Rights Due Diligence Training for employees.

1. None

2. Included

3. Included

Total: $0

1. None

2. Included

3. Included

Total: $0

1. $1m

2. Included

3. Included

Total: $1m

1. None

2. Included

3. Included

Total: $0


2.14 Informal settlements.

Influx of people into the town putting pressure on infrastructure and increase of social ills.

3 4 17 1. Town Plan has formal areas dedicated to Informal settlements.

1. None

Total: $0

1. None

Total: $0

1. None

Total: $0

1. None

Total: $0

3 4 17 None 3 4 17

2.15 Less funding for NGOs which the mine support as the mine funds will no longer be available.

CBO unhappiness with mine closure.

Such NGOs may demand on-going support.

Some CBOs may be unhappy with mine closure and seek media attention to place company in bad light.


2. Investigate possibility of third party to take over financial responsibilities.

1. Included

2. Included

Total: N$0

1. Included

2. Included

Total: N$0

1. Included

2. Included

Total: N$0

1. Included

2. Included

Total: $0

1 2 2 3 3 13 None required 1 2 2 3 3 13

OVERALL Totals (Excluding additional actions). $12,4m $44,7m $27,8m $3m OVERALL Totals (Additional actions only).

$0 $0 $65m $25m


$12,4m $44,7m $92,8m $28m

3. Authorities

3.1 Consultation with authorities.

There is a risk that social transition needs and requirements of relevant authorities have not been agreed through collaborative consultation, resulting in inappropriate social transition criteria. Closure success criteria not agreed with government.

3 3 13 3 3 13 Same as above – SEP (Key stakeholders/sectors). Included

Total: $0

Included

Total: $0

Included

Total: $0

Included

Total: $0

3 3 13 3 2 9 None required 3 3 13 3 2 9




CLOSURE


CLOSURE

PRE-MITIGATION



PRODUCTION PHASE





PERIOD)


MONITORING PHASE

(10 YEAR CARE AND



ADDITIONAL ACTIONS

REQUIRED POST RISK

ASSESSMENT

ADDITIONAL CLOSURE



Reputation/Social/


Safety


Current

Operating costs

(2019)

(Annual cost in $m)



in $m)

Estimated Decommis-




Liability Estimate



Reputation/Social/


Safety

Additional Actions

Required

Current Operating

costs (Annual cost

in $m)

Operating costs in

the last 5 years


in $m)

Estimated Decommis-

sioning Liability

Estimate


$m)


and Maintenance

Liability Estimate


$m)


Reputation/Social/


Safety

Con

sequ

ence

Pro

babi

lity

Rat

ing

Con

sequ

ence

Pro

babi

lity

Rat

ing

Con

sequ

ence

Pro

babi

lity

Rat

ing

Con

sequ

ence

Pro

babi

lity

Rat

ing

Con

sequ

ence

Pro

babi

lity

Rat

ing

Con

sequ

ence

Pro

babi

lity

Rat

ing

Con

sequ

ence

Pro

babi

lity

Rat

ing

Con

sequ

ence

Pro

babi

lity

Rat

ing

Con

sequ

ence

Pro

babi

lity

Rat

ing

2.13 Human rights and heritage impacts.

Risk of human rights and heritage impacts at closure.

4 2 14 1. Conduct a human rights and heritage impact due diligence for closure – can be included in human rights and heritage risk assessment.

2. Operate according to company policy and standards and within the legal frameworks.

3. Human Rights Due Diligence Training for employees.

1. None

2. Included

3. Included

Total: $0

1. None

2. Included

3. Included

Total: $0

1. $1m

2. Included

3. Included

Total: $1m

1. None

2. Included

3. Included

Total: $0


2.14 Informal settlements.

Influx of people into the town putting pressure on infrastructure and increase of social ills.

3 4 17 1. Town Plan has formal areas dedicated to Informal settlements.

1. None

Total: $0

1. None

Total: $0

1. None

Total: $0

1. None

Total: $0

3 4 17 None 3 4 17

2.15 Less funding for NGOs which the mine support as the mine funds will no longer be available.

CBO unhappiness with mine closure.

Such NGOs may demand on-going support.

Some CBOs may be unhappy with mine closure and seek media attention to place company in bad light.


2. Investigate possibility of third party to take over financial responsibilities.

1. Included

2. Included

Total: N$0

1. Included

2. Included

Total: N$0

1. Included

2. Included

Total: N$0

1. Included

2. Included

Total: $0

1 2 2 3 3 13 None required 1 2 2 3 3 13

OVERALL Totals (Excluding additional actions). $12,4m $44,7m $27,8m $3m OVERALL Totals (Additional actions only).

$0 $0 $65m $25m


$12,4m $44,7m $92,8m $28m

3. Authorities

3.1 Consultation with authorities.

There is a risk that social transition needs and requirements of relevant authorities have not been agreed through collaborative consultation, resulting in inappropriate social transition criteria. Closure success criteria not agreed with government.

3 3 13 3 3 13 Same as above – SEP (Key stakeholders/sectors). Included

Total: $0

Included

Total: $0

Included

Total: $0

Included

Total: $0

3 3 13 3 2 9 None required 3 3 13 3 2 9



CLOSURE


CLOSURE

PRE-MITIGATION



PRODUCTION PHASE





PERIOD)


MONITORING PHASE

(10 YEAR CARE AND



ADDITIONAL ACTIONS

REQUIRED POST RISK

ASSESSMENT

ADDITIONAL CLOSURE



Reputation/Social/


Safety


Current

Operating costs

(2019)

(Annual cost in $m)



in $m)

Estimated Decommis-




Liability Estimate



Reputation/Social/


Safety

Additional Actions

Required

Current Operating

costs (Annual cost

in $m)

Operating costs in

the last 5 years


in $m)

Estimated Decommis-

sioning Liability

Estimate


$m)


and Maintenance

Liability Estimate


$m)


Reputation/Social/


Safety

Con

sequ

ence

Pro

babi

lity

Rat

ing

Con

sequ

ence

Pro

babi

lity

Rat

ing

Con

sequ

ence

Pro

babi

lity

Rat

ing

Con

sequ

ence

Pro

babi

lity

Rat

ing

Con

sequ

ence

Pro

babi

lity

Rat

ing

Con

sequ

ence

Pro

babi

lity

Rat

ing

Con

sequ

ence

Pro

babi

lity

Rat

ing

Con

sequ

ence

Pro

babi

lity

Rat

ing

Con

sequ

ence

Pro

babi

lity

Rat

ing

3.2 Legal obligations with regulators.

1. If legal obligations with regulators are not implemented it may impact the closure period and final relinquishment of the site (cost implications).

2. Uncertainty related to the Legal requirements associated to relinquish assets/land.

3. The risk that newly defined end-land-use requirements based on current International Union for Conservation of Nature (IUCN) for category 6 could have new requirements which could financially and reputationally impact the company.

3 3 13 3 3 13 5 2 19 1. SEP

2. Identify and agree on closure success criteria as well as legal process to be followed.

3. Legal view of the potential requirements with regard to IUCN category 6.

1. Included

2. $1m

3. None

Total: $1m

1. Included

2. $3m

3. $1m

Total: $4m

1. Included

2. $1m

3. None

Total: $1m

1. Included

2. None

3. None

Total: $0

3 3 13 3 2 9 5 1 15 None required 3 3 13 3 2 9 5 1 15

3.3 Permits requirements for final land-use.

1. There is a risk that future requirements for water abstraction permits might not be approved or timeously issued for imple-mentation of closure related Socio-Economic opportunities (e.g. Mining VS upstream Agriculture Strategies).

2. License agreements associated with air travel.

3 4 17 1. Legal review of current agreements associated with water supply/licenses.

2. Review of availability and future allocation of water resources.

3. Define way forward, plan and schedule.

1.$0,1m

2. Included

3. None

Total: $0,1m

1.$0,2m

2. Included

3. None

Total: $0,2m

1.$0,3m

2. Included

3. None

Total: $0,3m

1.$0,1m

2. Included

3. None

Total: $0,1m





CLOSURE


CLOSURE

PRE-MITIGATION



PRODUCTION PHASE





PERIOD)


MONITORING PHASE

(10 YEAR CARE AND



ADDITIONAL ACTIONS

REQUIRED POST RISK

ASSESSMENT

ADDITIONAL CLOSURE



Reputation/Social/


Safety


Current

Operating costs

(2019)

(Annual cost in $m)



in $m)

Estimated Decommis-




Liability Estimate



Reputation/Social/


Safety

Additional Actions

Required

Current Operating

costs (Annual cost

in $m)

Operating costs in

the last 5 years


in $m)

Estimated Decommis-

sioning Liability

Estimate


$m)


and Maintenance

Liability Estimate


$m)


Reputation/Social/


Safety

Con

sequ

ence

Pro

babi

lity

Rat

ing

Con

sequ

ence

Pro

babi

lity

Rat

ing

Con

sequ

ence

Pro

babi

lity

Rat

ing

Con

sequ

ence

Pro

babi

lity

Rat

ing

Con

sequ

ence

Pro

babi

lity

Rat

ing

Con

sequ

ence

Pro

babi

lity

Rat

ing

Con

sequ

ence

Pro

babi

lity

Rat

ing

Con

sequ

ence

Pro

babi

lity

Rat

ing

Con

sequ

ence

Pro

babi

lity

Rat

ing

3.2 Legal obligations with regulators.

1. If legal obligations with regulators are not implemented it may impact the closure period and final relinquishment of the site (cost implications).

2. Uncertainty related to the Legal requirements associated to relinquish assets/land.

3. The risk that newly defined end-land-use requirements based on current International Union for Conservation of Nature (IUCN) for category 6 could have new requirements which could financially and reputationally impact the company.

3 3 13 3 3 13 5 2 19 1. SEP

2. Identify and agree on closure success criteria as well as legal process to be followed.

3. Legal view of the potential requirements with regard to IUCN category 6.

1. Included

2. $1m

3. None

Total: $1m

1. Included

2. $3m

3. $1m

Total: $4m

1. Included

2. $1m

3. None

Total: $1m

1. Included

2. None

3. None

Total: $0

3 3 13 3 2 9 5 1 15 None required 3 3 13 3 2 9 5 1 15

3.3 Permits requirements for final land-use.

1. There is a risk that future requirements for water abstraction permits might not be approved or timeously issued for imple-mentation of closure related Socio-Economic opportunities (e.g. Mining VS upstream Agriculture Strategies).

2. License agreements associated with air travel.

3 4 17 1. Legal review of current agreements associated with water supply/licenses.

2. Review of availability and future allocation of water resources.

3. Define way forward, plan and schedule.

1.$0,1m

2. Included

3. None

Total: $0,1m

1.$0,2m

2. Included

3. None

Total: $0,2m

1.$0,3m

2. Included

3. None

Total: $0,3m

1.$0,1m

2. Included

3. None

Total: $0,1m




CLOSURE


CLOSURE

PRE-MITIGATION



PRODUCTION PHASE





PERIOD)


MONITORING PHASE

(10 YEAR CARE AND



ADDITIONAL ACTIONS

REQUIRED POST RISK

ASSESSMENT

ADDITIONAL CLOSURE



Reputation/Social/


Safety


Current

Operating costs

(2019)

(Annual cost in $m)



in $m)

Estimated Decommis-




Liability Estimate



Reputation/Social/


Safety

Additional Actions

Required

Current Operating

costs (Annual cost

in $m)

Operating costs in

the last 5 years


in $m)

Estimated Decommis-

sioning Liability

Estimate


$m)


and Maintenance

Liability Estimate


$m)


Reputation/Social/


Safety

Con

sequ

ence

Pro

babi

lity

Rat

ing

Con

sequ

ence

Pro

babi

lity

Rat

ing

Con

sequ

ence

Pro

babi

lity

Rat

ing

Con

sequ

ence

Pro

babi

lity

Rat

ing

Con

sequ

ence

Pro

babi

lity

Rat

ing

Con

sequ

ence

Pro

babi

lity

Rat

ing

Con

sequ

ence

Pro

babi

lity

Rat

ing

Con

sequ

ence

Pro

babi

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Rat

ing

Con

sequ

ence

Pro

babi

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Rat

ing

Overall totals (excluding additional actions). $1,1 $4,2m $1,3m $0,1m OVERALL Totals (additional actions only).

$0 $0 $0 $0

Owner’s Team (salary and housing). $0 $0 $25m $8m OVERALL Totals (including additional actions).

$1,1 $4,2m $1,3m $0,1m

Grand total (including additional actions). $21,1m $106,7m $167,8m $45,5m

Total including additional actions.

$320M

(Post production cost - $213,3m).

Grand total (excluding additional actions). $21,1m $106,7m $102,8M

($65m excluded for additional mitigation).

$20,5m


Total EXCLUDING ADDITIONAL ACTIONS.

$230M



Probability

Consequences

1 2 3 4 5

5 11 16 20 23 25

4 7 12 17 21 24

3 4 8 13 18 22

2 2 5 9 14 19

1 1 3 6 10 15


Refer to Example 3 Closure Risk Assessment for the details on the AA 5x5 risk matrix.



CLOSURE


CLOSURE

PRE-MITIGATION



PRODUCTION PHASE





PERIOD)


MONITORING PHASE

(10 YEAR CARE AND



ADDITIONAL ACTIONS

REQUIRED POST RISK

ASSESSMENT

ADDITIONAL CLOSURE



Reputation/Social/


Safety


Current

Operating costs

(2019)

(Annual cost in $m)



in $m)

Estimated Decommis-




Liability Estimate



Reputation/Social/


Safety

Additional Actions

Required

Current Operating

costs (Annual cost

in $m)

Operating costs in

the last 5 years


in $m)

Estimated Decommis-

sioning Liability

Estimate


$m)


and Maintenance

Liability Estimate


$m)


Reputation/Social/


Safety

Con

sequ

ence

Pro

babi

lity

Rat

ing

Con

sequ

ence

Pro

babi

lity

Rat

ing

Con

sequ

ence

Pro

babi

lity

Rat

ing

Con

sequ

ence

Pro

babi

lity

Rat

ing

Con

sequ

ence

Pro

babi

lity

Rat

ing

Con

sequ

ence

Pro

babi

lity

Rat

ing

Con

sequ

ence

Pro

babi

lity

Rat

ing

Con

sequ

ence

Pro

babi

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Rat

ing

Con

sequ

ence

Pro

babi

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Rat

ing

Overall totals (excluding additional actions). $1,1 $4,2m $1,3m $0,1m OVERALL Totals (additional actions only).

$0 $0 $0 $0

Owner’s Team (salary and housing). $0 $0 $25m $8m OVERALL Totals (including additional actions).

$1,1 $4,2m $1,3m $0,1m

Grand total (including additional actions). $21,1m $106,7m $167,8m $45,5m

Total including additional actions.

$320M


Grand total (excluding additional actions). $21,1m $106,7m $102,8M


$20,5m


Total EXCLUDING ADDITIONAL ACTIONS.

$230M




SOCIAL TRANSITION CASH FLOW

TABLE NUMBER

MAIN CATEGORY

SUB CATEGORY

OPERATING COSTS

($MILLIONS)(WHILE STILL IN

PRODUCTION PHASE)

LOA COSTS ($MILLIONS)

(LAST 5Y OF PRODUCTION)

DECOMMISSIONING PHASE ($MILLIONS)

(YEARS 0 TO 5)

MONITORING AND MAINTENANCE PHASE ($MILLIONS)

(YEARS 6 TO 15)

LOA AND DECOMMISSIONING

AND MONITORING AND MAINTENANCE

PHASES ($MILLIONS)

(YEARS -5 TO 15)

DECOMMISSIONING AND MONITORING

AND MAINTENANCE PHASES ONLY($MILLIONS)

(YEARS 1 TO 15)

Current (2017)

Year -5 (2019)

Year- 4 (2020)

Year -3 (2021)

Year -2 (2022)

Year -1 (2023)

Total for

phase

Year 1 (2024)

Year 2 (2025)

Year 3 (2026)

Year 4 (2027)

Year 5 (2028)

Total for

phase

Year 6 (2029)

Year 7 (2030)

Year 8 (2031)

Year 9 (2032)

Year 10

(2033)

Year 11

(2034)

Year12 (2035)

Year 13

(2036)

Year 14

(2037)

Year 15

(2038)

Total for

phase

1.1 Employees and dependants.

Managing employee dependency.

$0,7 $1,5 $1,5 $2,7 $3,4 $6,7 $15,8 $3,4 $2,5 $0,5 $0,5 $2,3 $9,2 $0,0 $0,0 $0,0 $0,0 $0,0 $0,0 $0,0 $0,0 $0,0 $0,0 $0,0

1.2 Managing employee and data retention.

$2,0 $1,4 $1,4 $1,4 $1,4 $1,4 $7,0 $0,9 $0,9 $0,9 $0,9 $0,9 $4,5 $0,2 $0,2 $0,2 $0,2 $0,2 $0,2 $0,2 $0,2 $0,2 $0,2 $2,0

1.3 Managing employees health and safety.

$0,8 $4,0 $4,0 $3,2 $5,1 $6,5 $22,8 $0,6 $0,6 $0,6 $0,6 $0,8 $3,2 $0,5 $0,5 $0,4 $0,4 $0,4 $0,4 $0,4 $0,4 $0,4 $0,4 $4,2

1.4 Managing issues related to contractors.

$0,0 $1,2 $1,2 $1,2 $1,2 $1,4 $6,2 $1,4 $1,2 $0,7 $0,5 $0,5 $4,3 $0,0 $0,0 $0,0 $0,0 $0,0 $0,0 $0,0 $0,0 $0,0 $0,0 $0,0

1.5 Managing impacts on public health services and public safety.

$4,1 $1,2 $1,2 $1,2 $1,2 $1,2 $6,0 $6,6 $6,6 $6,6 $4,5 $3,2 $27,5 $0,4 $0,4 $0,3 $0,3 $0,3 $0,3 $0,3 $0,3 $0,3 $0,3 $3,2

Totals (including additional mitigation).

$7,6 $9,3 $9,3 $9,7 $12,3 $17,2 $57,8 $12,9 $11,8 $9,3 $7,0 $7,7 $48,7 $1,1 $1,1 $0,9 $0,9 $0,9 $0,9 $0,9 $0,9 $0,9 $0,9 $9,4 $115,9 $58,1

2.1 I&APs. Managing community expectations and impacts.

$1,5 $1,4 $1,4 $1,4 $1,4 $1,4 $7,0 $1,5 $1,5 $1,4 $1,4 $1,3 $7,1 $0,1 $0,1 $0,1 $0,1 $0,1 $0,1 $0,1 $0,1 $0,1 $0,1 $1,0

2.2 Managing impact on businesses.

$2,7 $2,3 $2,3 $2,3 $2,3 $2,0 $11,2 $2,1 $2,1 $1,1 $0,4 $0,4 $6,1 $0,0 $0,0 $0,0 $0,0 $0,0 $0,0 $0,0 $0,0 $0,0 $0,0 $0,0

2.3 Managing impact on community health and safety.

$1,0 $1,0 $1,0 $1,0 $1,0 $1,0 $5,0 $2,0 $2,0 $1,5 $0,4 $0,0 $5,9 $0,0 $0,0 $0,0 $0,0 $0,0 $0,0 $0,0 $0,0 $0,0 $0,0 $0,0

2.4 Managing impacts on town’s sustainability.

$7,2 $6,1 $5,1 $4,1 $4,1 $2,1 $21,5 $2,0 $1,8 $1,7 $1,7 $1,5 $8,7 $0,2 $0,2 $0,2 $0,2 $0,2 $0,2 $0,2 $0,2 $0,2 $0,2 $2,0


$12,4 $10,8 $9,8 $8,8 $8,8 $6,5 $44,7 $7,6 $7,4 $5,7 $3,9 $3,2 $27,8 $0,3 $0,3 $0,3 $0,3 $0,3 $0,3 $0,3 $0,3 $0,3 $0,3 $3,0 $75,5 $30,8

3.1 Authorities. Managing consultation with authorities.

$0,1 $0,1 $0,1 $0,0 $0,0 $0,2 $0,4 $0,1 $0,1 $0,0 $0,1 $0,1 $0,4 $0,0 $0,0 $0,0 $0,0 $0,0 $0,0 $0,0 $0,0 $0,0 $0,0 $0,1

3.2 Managing legal obligations.

$1,0 $0,9 $0,9 $0,7 $0,7 $0,6 $3,8 $0,2 $0,2 $0,2 $0,2 $0,1 $0,9 $0,0 $0,0 $0,0 $0,0 $0,0 $0,0 $0,0 $0,0 $0,0 $0,0 $0,0


$1,1 $1,0 $1,0 $0,7 $0,7 $0,8 $4,2 $0,3 $0,3 $0,2 $0,3 $0,2 $1,3 $0,0 $0,0 $0,0 $0,0 $0,0 $0,0 $0,0 $0,0 $0,0 $0,0 $0,1 $5,6 $1,4

4.1 Owner’s team.

4) Owner’s team to execute project and sustain investor conference in the town (salaries and housing).

$0,0 $0,0 $0,0 $0,0 $0,0 $0,0 $0,0 $5,5 $5,5 $5,0 $4,5 $4,5 $25,0 $2,0 $1,4 $1,0 $0,8 $0,5 $0,5 $0,5 $0,5 $0,4 $0,4 $8,0 $33,0 $33,0

Phase totals (Including additional mitigation).

$21,1 $21,1 $20,1 $19,2 $21,8 $24,5 $106,7 $26,3 $25,0 $20,2 $15,7 $15,6 $102,8 $3,4 $2,8 $2,2 $2,0 $1,7 $1,7 $1,7 $1,7 $1,6 $1,6 $20,5 $230,0 $123,3

Phase totals (excluding additional mitigation).

$21,1 $21,1 $20,1 $19,2 $21,8 $24,5 $106,7 $39,3 $38,0 $33,2 $28,7 $28,6 $167,8 $5,9 $5,3 $4,7 $4,5 $4,2 $4,2 $4,2 $4,2 $4,1 $4,1 $45,5 $320,0 $213,3


TABLE NUMBER

MAIN CATEGORY

SUB CATEGORY

OPERATING COSTS

($MILLIONS)(WHILE STILL IN

PRODUCTION PHASE)

LOA COSTS ($MILLIONS)

(LAST 5Y OF PRODUCTION)

DECOMMISSIONING PHASE ($MILLIONS)

(YEARS 0 TO 5)

MONITORING AND MAINTENANCE PHASE ($MILLIONS)

(YEARS 6 TO 15)

LOA AND DECOMMISSIONING

AND MONITORING AND MAINTENANCE

PHASES ($MILLIONS)

(YEARS -5 TO 15)

DECOMMISSIONING AND MONITORING

AND MAINTENANCE PHASES ONLY($MILLIONS)

(YEARS 1 TO 15)

Current (2017)

Year -5 (2019)

Year- 4 (2020)

Year -3 (2021)

Year -2 (2022)

Year -1 (2023)

Total for

phase

Year 1 (2024)

Year 2 (2025)

Year 3 (2026)

Year 4 (2027)

Year 5 (2028)

Total for

phase

Year 6 (2029)

Year 7 (2030)

Year 8 (2031)

Year 9 (2032)

Year 10

(2033)

Year 11

(2034)

Year12 (2035)

Year 13

(2036)

Year 14

(2037)

Year 15

(2038)

Total for

phase

1.1 Employees and dependants.

Managing employee dependency.

$0,7 $1,5 $1,5 $2,7 $3,4 $6,7 $15,8 $3,4 $2,5 $0,5 $0,5 $2,3 $9,2 $0,0 $0,0 $0,0 $0,0 $0,0 $0,0 $0,0 $0,0 $0,0 $0,0 $0,0

1.2 Managing employee and data retention.

$2,0 $1,4 $1,4 $1,4 $1,4 $1,4 $7,0 $0,9 $0,9 $0,9 $0,9 $0,9 $4,5 $0,2 $0,2 $0,2 $0,2 $0,2 $0,2 $0,2 $0,2 $0,2 $0,2 $2,0

1.3 Managing employees health and safety.

$0,8 $4,0 $4,0 $3,2 $5,1 $6,5 $22,8 $0,6 $0,6 $0,6 $0,6 $0,8 $3,2 $0,5 $0,5 $0,4 $0,4 $0,4 $0,4 $0,4 $0,4 $0,4 $0,4 $4,2

1.4 Managing issues related to contractors.

$0,0 $1,2 $1,2 $1,2 $1,2 $1,4 $6,2 $1,4 $1,2 $0,7 $0,5 $0,5 $4,3 $0,0 $0,0 $0,0 $0,0 $0,0 $0,0 $0,0 $0,0 $0,0 $0,0 $0,0

1.5 Managing impacts on public health services and public safety.

$4,1 $1,2 $1,2 $1,2 $1,2 $1,2 $6,0 $6,6 $6,6 $6,6 $4,5 $3,2 $27,5 $0,4 $0,4 $0,3 $0,3 $0,3 $0,3 $0,3 $0,3 $0,3 $0,3 $3,2


$7,6 $9,3 $9,3 $9,7 $12,3 $17,2 $57,8 $12,9 $11,8 $9,3 $7,0 $7,7 $48,7 $1,1 $1,1 $0,9 $0,9 $0,9 $0,9 $0,9 $0,9 $0,9 $0,9 $9,4 $115,9 $58,1

2.1 I&APs. Managing community expectations and impacts.

$1,5 $1,4 $1,4 $1,4 $1,4 $1,4 $7,0 $1,5 $1,5 $1,4 $1,4 $1,3 $7,1 $0,1 $0,1 $0,1 $0,1 $0,1 $0,1 $0,1 $0,1 $0,1 $0,1 $1,0

2.2 Managing impact on businesses.

$2,7 $2,3 $2,3 $2,3 $2,3 $2,0 $11,2 $2,1 $2,1 $1,1 $0,4 $0,4 $6,1 $0,0 $0,0 $0,0 $0,0 $0,0 $0,0 $0,0 $0,0 $0,0 $0,0 $0,0

2.3 Managing impact on community health and safety.

$1,0 $1,0 $1,0 $1,0 $1,0 $1,0 $5,0 $2,0 $2,0 $1,5 $0,4 $0,0 $5,9 $0,0 $0,0 $0,0 $0,0 $0,0 $0,0 $0,0 $0,0 $0,0 $0,0 $0,0

2.4 Managing impacts on town’s sustainability.

$7,2 $6,1 $5,1 $4,1 $4,1 $2,1 $21,5 $2,0 $1,8 $1,7 $1,7 $1,5 $8,7 $0,2 $0,2 $0,2 $0,2 $0,2 $0,2 $0,2 $0,2 $0,2 $0,2 $2,0


$12,4 $10,8 $9,8 $8,8 $8,8 $6,5 $44,7 $7,6 $7,4 $5,7 $3,9 $3,2 $27,8 $0,3 $0,3 $0,3 $0,3 $0,3 $0,3 $0,3 $0,3 $0,3 $0,3 $3,0 $75,5 $30,8

3.1 Authorities. Managing consultation with authorities.

$0,1 $0,1 $0,1 $0,0 $0,0 $0,2 $0,4 $0,1 $0,1 $0,0 $0,1 $0,1 $0,4 $0,0 $0,0 $0,0 $0,0 $0,0 $0,0 $0,0 $0,0 $0,0 $0,0 $0,1

3.2 Managing legal obligations.

$1,0 $0,9 $0,9 $0,7 $0,7 $0,6 $3,8 $0,2 $0,2 $0,2 $0,2 $0,1 $0,9 $0,0 $0,0 $0,0 $0,0 $0,0 $0,0 $0,0 $0,0 $0,0 $0,0 $0,0


$1,1 $1,0 $1,0 $0,7 $0,7 $0,8 $4,2 $0,3 $0,3 $0,2 $0,3 $0,2 $1,3 $0,0 $0,0 $0,0 $0,0 $0,0 $0,0 $0,0 $0,0 $0,0 $0,0 $0,1 $5,6 $1,4

4.1 Owner’s team.

4) Owner’s team to execute project and sustain investor conference in the town (salaries and housing).

$0,0 $0,0 $0,0 $0,0 $0,0 $0,0 $0,0 $5,5 $5,5 $5,0 $4,5 $4,5 $25,0 $2,0 $1,4 $1,0 $0,8 $0,5 $0,5 $0,5 $0,5 $0,4 $0,4 $8,0 $33,0 $33,0

Phase totals (Including additional mitigation).

$21,1 $21,1 $20,1 $19,2 $21,8 $24,5 $106,7 $26,3 $25,0 $20,2 $15,7 $15,6 $102,8 $3,4 $2,8 $2,2 $2,0 $1,7 $1,7 $1,7 $1,7 $1,6 $1,6 $20,5 $230,0 $123,3

Phase totals (excluding additional mitigation).

$21,1 $21,1 $20,1 $19,2 $21,8 $24,5 $106,7 $39,3 $38,0 $33,2 $28,7 $28,6 $167,8 $5,9 $5,3 $4,7 $4,5 $4,2 $4,2 $4,2 $4,2 $4,1 $4,1 $45,5 $320,0 $213,3


EXAMPLE 10: HEALTH CONSIDERATIONS IN MINE CLOSURE

INTRODUCTION

At AA we put our people’s health and wellbeing at the heart of our business. Our ambition is to positively influence the optimal health balance between the person and their environment. Zero harm at the work floor and healthy lifestyle enhancement are the focus of AA’s health function.

Health is also at the heart of the community concerns about mining. Mining operations which discharge pollutants into the surrounding environment over the life of asset have the potential to impact on human health if not mitigated. Exposure to the various mining products and raw materials can have negative impacts on human health.

Many of these communities become directly or indirectly dependent on the mining industry for their livelihoods throughout the life of asset. Managing the impact of mine closure on these communities must become an integral part of mine closure planning, with a special focus on mitigating negative impacts, including health, and extending sustainability beyond mine closure.

Sections 1 to 7 provide guidance on the practicalaspects of managing the health impacts on workersinvolved in mine closure tasks and activities and thesurrounding communities. The purpose of the guidance is to:• Prevent sickness resulting from closure related work.• Maintain physical and psychological health and wellness

to maximize productivity and minimise medical costs to both the company and employees.

• Comply with occupational health legislation, Group Health, Wellness and Sustainability policies and Duty of Care.

• Limit any negative impacts on the health and wellbeing of surrounding communities.

• Partnering with government or non-governmental organisations to drive community health initiatives contained in sustainable mining plans.

1. OCCUPATIONAL HEALTH RISK MANAGEMENT

1.1 Introduction

All operational requirements and expected deliverables with regards to health and wellness apply until such time the site is formally closed. Sites undergoing closure are required to develop, implement and maintain an occupational health programme. If properly implemented and complied with, this would protect the health of workers by assessing, monitoring and reducing their exposure to health risks. The AA Group SSD Occupational Hygiene Standard (AA SSD.S.004) will be used as the framework for the development and implementation of such a programme. This programme will have a number of processes which shall cover all components of the closure plan and process.

1.2 Occupational Hygiene

A closing site is required to establish and maintain occupational hygiene processes (including a system of occupational hygiene measurements), in order to understand occupational exposure to health risks.

1.3 Medical Surveillance

A closing site is required to establish and maintain a system of medical surveillance. A closing site must ensure access to the full-time or part-time services of an occupational hygienist and an occupational medical practitioner to assist in the establishment and maintenance of the occupational health processes.

1.4 Occupational Health Record Keeping

Record keeping in occupational health falls into three main areas: occupational hygiene, medical surveillance and human resources. The purpose of record keeping is to provide a record of employees’ work, exposure and medical surveillance history during their time with the company. This information is used to improve the risk


Saldhana Iron Ore stockyard, South Africa.


management process, to assist with compensation where necessary and may be used as evidence in civil claims. The information system should be designed in such a way as to provide a link between occupational hygiene data, medical surveillance data and the record of service kept by the personnel department.

Records should be kept for an appropriate length of time. For occupational health information, this is often determined by legislation and may be as long as 40 years. For the purposes of standardization, AA’s policy is to keep occupational health information for 40 years after exposure ceases or according to legislative requirements, whichever is the longer.

Since the employees work history forms part of the exposure profile, provision should be made to keep that portion of the personnel file, which contains details of job history and movement within the company for the same length of time.

The worker’s medical record should remain confidential and, where this is kept off-site, the responsible occupational medical practitioner should be satisfied that this is in accordance with good medical practice and ethics. It is essential that the links between exposure data, the work history and the medical record be maintained for the full length of time.

2. HEALTH IMPACT ASSESSMENTS

An HIA is a systematic approach to predicting and managing the potential positive and negative health effects of mining operations and projects on local communities and wider society. An HIA should be undertaken as early as possible in the project design (iteratively and in parallel with project planning), with HIA outcomes timed to inform key decisions. It should then be updated as required, during the operation’s life of asset. Through the HIA process, all the significant community health and well-being impacts will be identified, measures will be prioritised to minimise the negative and maximise the positive health impacts, the findings will be reported, and a HMP will be developed to implement the recommendations of the HIA.

The HMP should be based on the impacts identified, their public health significance, and the priority attributed by the affected communities. The HMP should not only address health outcomes, but also health determinants (e.g. income and social status, social support networks, education, employment and working conditions, social environments, physical environments, personal health practices and coping skills, healthy child development, biology and genetic endowment, health services, gender and culture), health equity/inequality and the cumulative impacts of the operation.

Refer to ICMM’s Good Practice Guidance on Heath Impact Assessment 2010, available at www.icmm.com/library/hia. This practice guidance can be used in conjunction with ICMM’s Good Practice Guidance on Occupational Health Risk Assessment - first issued in 2009 and updated in 2016 available at http://www.icmm.com/gpg-occupational-health.

The latter document is intended for mining and metals managers and advisors who are responsible for ensuring the occupational health and well-being of employees and third party contractors. Although the guidance focuses on the occupational health risks to employees and contractors in a mining and metals operation, it is important to note that these risks can also affect the wider community living around that operation.

3. HEALTH RISK ASSESSMENTS

An HRA is the structured and systematic identification and analysis of workplace hazards to assess their potential risks to health and determine appropriate control measures to protect the health and well-being of workers. The HRA process is a partnership between occupational health advisors, occupational hygiene advisors, managers and operational staff who use their knowledge, experience and skills to support the HRA process. The initial HIA will be based on what will be required to make the community sustainable post-closure and should draw on information obtained from the HRA of employees and contractors of the operation, because the same risks can also affect the wider community living adjacent to the operation. The data from the HRA need to be incorporated into



the environmental health assessments. Operations are required to identify and understand the health issues and health service delivery issues in communities where mining operations exist, through appropriate baseline data. Opportunities to address community health issues should be identified and evaluated.

Refer also to ICMM’s Good Practice Guidance on Occupational Health Risk Assessment - first issued in 2009 and updated in 2016 available at http://www.icmm.com/gpg-occupational-health.

4. INTEGRATED ENVIRONMENTAL, SOCIAL AND HEALTH IMPACT ASSESSMENTS

As the operational plan is developed in more detail, a more formal, in-depth HIA is discussed with I&APs. The in-depth HIA should be completed with the assistance of relevant specialists, either as a standalone assessment or as part of an integrated ESHIA. There are important overlaps between health, environmental and social issues, because many health determinants are also recognised components of EIA and SIA. Advantages of an integrated ESHIA include the assurance that the scope of the HIA is fit-for-purpose, the provision of a more robust assessment of the health impacts, a reduction in duplication of fieldwork and community consultations, and the identification of more comprehensive risk-based health management measures. More recently, HIAs have seen a transformation with an increased focus on the potential impacts of projects or operations on overall community health and well-being, with an equal emphasis on disease epidemiology and prevention. This transformation has increased the overlap and interdependencies between EIA and HIA methodologies.

5. MANAGEMENT OF HEALTH IMPACTS ON COMMUNITIES

Impacts on community health and well-being are managed (mitigated and/or enhanced) in partnership with stakeholders. Local stakeholders include community representatives, government officials, health service/public health officials, and community health and development workers. Health care providers are well recognised as important contributors to health status and play an important role in influencing the health of communities. To obtain a holistic view of how mining affects community health, it is important to include perspectives from community residents who have experience with social determinants of health (e.g. gender, age, income, education). Community health monitoring (surveillance) is

an important component of the implementation of the HMP or the integrated ESHMP.

6. DEVELOPMENT OF SUSTAINABLE COMMUNITY HEALTH

An evaluation of the operation and its potential impacts on local communities’ health and well-being should be undertaken at regular intervals (e.g. every 3 years), by an independent agency as part of an adaptive operational management process. Three aspects of an operation can be evaluated: its process, its impact (short term impacts) and its outcomes (long term impacts). This will inform the refinement of the in-depth HIA to be part of the final closure plan.

A formal and documented mechanism must be established for following people considered to be “at risk”, into the future, post-closure. This will involve specific follow-up for particular exposure groups, and general follow-up for the remainder of the affected parties. Social issues such as housing, living conditions, water and sanitation services, local infrastructure development, local workforce development and training, and local institution capacity development all have effects on the health of communities in mining regions.

Refer also to ICMM’s Community Development Toolkit, London, 2010, available at www.icmm.com/community-development-toolkit. The toolkit provides practical guidance for all stages of the community development process – from exploration through construction, operations, and eventually decommissioning and closure, including the post-closure environment.

7. EMERGENCY MEDICAL CARE

Each closing site shall have a designated person in charge of emergency medical response and a detailed medical emergency response plan for the handling of medical emergencies. This must be done at site level, not regionally, and will detail the response from first aid through to evacuation with clearly defined responsibilities. Contracting companies should ideally be catered for in the existing AA arrangements for the evacuation of their employees from operational sites. This must be covered in the contract between AA and the contracting company. If alternative arrangements are made, these must be to the same standard as those for AA employees at operational sites.


Landau Collieries – Kromdraai, South Africa.


INTRODUCTION

The Kepner Tregoe (KT) decision analysis tool, often used in mining project evaluation, has been adapted to prioritize integrated planning opportunities related to closure to increase the likelihood of realizing the potential value. The methodology is explained below and an example excel spreadsheet template is also provided.

METHODOLOGY

The KT analysis is undertaken as a one or two-day workshop with representation from all relevant internal stakeholders including mine planning, engineering,

operations, environment, social (including community and HR), legal, financial, safety and health. The first step in the process is to clearly state the decision that is going to be made. For example, the decision identified for a diamond mine was to “Prioritize the top few integrated planning opportunities that leads to sustainable outcomes and meets stakeholder expectations, which realize the maximum value leading to positive reputational outcomes”. The potential integrated planning opportunities are then brainstormed, with existing options taken from closure plans provided as a starting point (Table 1). The next step is to identify the objectives that an opportunity should meet. These are split into ‘Musts’ (mandatory requirements) and ‘Wants’ (desired requirements – Figure 1).

Table 1: Example of brainstormed integrated planning opportunities and their prioritisation through group voting.

Opportunities Votes

1 1. Plant old waste rock deposits (WRDs) rehabilitation with trees instead of reshaping them. 1

2 Characterise the material to be mined so that it can be selectively placed. 2

3 Investigate tailings material or compost as potential growth medium. 5

4 Investigate alternative productive land-uses (e.g. solar/wind/hydro power, biofuels, agriculture on tailings dams, mining museum, university training).

9

5 Use pit water as resource in closure. 4

6 Investigate option of joining NE WRD’s into a mega dump. 2

7 Rehabilitate only outer slopes and offset cost of inner slopes to improve surrounding land productivity. 7

8 Use slimes dams surfaces for agricultural purpose due to availability of water. 2

9 Investigate alternative landform designs (e.g. moonscaping) to conserve topsoil. 8

10 Create waste disposal facilities on-site. 1

11 Irrigation of surrounding land to increase carrying capacity. 1

12 Optimise in-pit dumping opportunities in the short term. 10

13 Collaborate with neighbouring mines for regional closure planning. 2

EXAMPLE 11: KEPNER TREGOE OPPORTUNITIES ANALYSIS


View of the mine and beneficiation plant of the Minas Rio Project, Brasil.


Wants are then rated individually against each other as being of higher importance, similar importance or lower importance to obtain a weighting (Figure 2). The brainstormed opportunities are then assessed against the ‘Musts’ and any opportunities that do not meet all of them are eliminated. The remaining opportunities are then rated against the ‘Wants’ on a scale of 1-10 (Figure 3). This score is multiplied by the weighting to get a total score for each opportunity (Figure 4). A high-level risk assessment exercise is then undertaken, listing only on the top 3 risks associated with each opportunity, focusing on identifying any potential fatal flaws. Depending on the stated decision at the start of the process, the most highly scored few

opportunities are chosen and detailed implementation plans including an action plan with RACI and high-level schedule are developed to assess whether the opportunity should be progressed further (Figure 5). Responsibility, Accountability, Consult, Inform (RACI) involves identifying Responsibility (who is responsible for doing the task), Accountability (who is accountable for making sure the task is done), Consult (who should be consulted when the task is undertaken) and Inform (who should be informed when the task is being undertaken and completed. The action plan and project implementation plan are then tracked over the following 6-12 months and realised value was estimated where relevant.

Project name:

ICPS WORKSHOPDevelop objectives and classify into MUSTS and WANTS

Objectives (selection criteria)MUSTReduce the closure liability or prevent it from increasing.Improve integration of closure into mine plan.Integrated planning opportunities need to be able to be implement from LoA through medium- to short-term planning.Operationa cost impact neutral (-2%) or positive.Implementation can be undertaken in a sustainble way meeting she requirements.

WANTS Classify objectives into MUSTS and WANTS.

Is this objective mandatory?Is this objective measurable?Is this objective realistic?

Works can be implemented now (realise value within two years).

No negative impact to mine production rates.

No additional resources (e.g. Equipment, capital) to implement unless funded by the opportunity.

Meets reasonable community expectations and assist with social licence to operate.

Potential to increase LoA.

Potential to fund closure activities by generating cash flow at end of LoA.

Risk to mining schedule and production must be low to moderate.

Reduce haul distance.

Optimise progressive rehabilitation.

Minimise footprint.

Maximise backfill.

All other objectives are WANTS.Which MUST objectives are reflected in the WANTS?

}Yes to all 3 – MUST

Figure 1 : Example of definitions of MUSTS and WANTS.



How important is the ROW compared to the COLUMN?

Much more important More important

Equally important Less important

Much less important

1 2 3 4 5 6 7 8 9 10 11

Wor

k ca

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5 Potential to increase LoA

6Potential to fund closure acivities by generating cash flow at end of LoA

7 Risk to mining schedule and production must be low to moderate

8 Reduce haul distance

9 Optimise progressive rehabilitation

10 Minimise footprint

11 Maximise backfill

Figure 2: Example of weighting wants against each other.

Figure 3: Example of scoring opportunities against the Wants (note that only scores of 0, 3, 5, 7 and 10 are allowed).

Alternative

Pit backfilling options at

Grant

Pit backfilling options at

Botha

Optimise topsoil

management

Optimise progressive

rehabilitation

Optimise scheduling

of low grade material

1 Works can be implemented now (realise value within two years

10 7 10 10 5

2 No negative impact to mine production rates

7 7 10 10 10

3 No additional resources (e.g. equipment, capital) to implement unless funded by the opportunity

10 3 10 5 5

4 Meets reasonable community expectations and assist with social licence to operate

10 10 10 10 0

5 Potential to increase LoA 3 3 0 0 0

6 Potential to fund closure activities by generating cash flow at end of LoA

0 5 3 3 0

7 Risk to mining schedule and production must be low to moderate

5 3 10 10 7

8 Reduce haul distance distance 10 5 0 0 0

9 Optimise progressive rehabilitation 7 7 10 10 7

10 Minimise footprint 10 10 5 5 7


R = Responsible

A = Accountable

C = Consulted

I = Informed Min

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M

Act

ing

Man

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Te

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Env

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Long

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1. Pit backfilling options. Time (days)

Project Management. 5 A C I R C C

Project Scope. 2 A C I R C C

Project Schedule. 1 A C I R C C

Run mine schedule to optimise waste movement for phase 5-8 with access road into backfill area. 2 A C I R C C

Run mine schedule to opimise waste movement for phase8-6 with backfill. 2 A C I R C C

Make decision on option to move forward. 0 A R

Redesign pit and roads/ramps to match new designed backfilling option. 20 A R

Re-run the mine schedule. 10 A R

Re-run HME requirements. 3 A

High level geotechnical review. 5 A C

Estimate Capex, Opex and mine closure liability. R A

Compare to base case and make decision to proceed or not. 1 A R

Presentation to Mine leadership team. 1 A R

Make decision to proceed or not. 0 A R C

Undertake more detailed LoA, medium and short term planning. R

Figure 4: Example of final scoring for opportunities and associated highest risk.

Figure 5: Example of detailed implementation plan and associated RACI chart.

1 Grant Pit backfilling options2 Botha Pit backfilling options3 Optimising topsoil management4 Optimise progressive rehabilitation activities5 Optimise scheduling of low grade material in WRD

Decision and Risk Matrix Results

Alternatives

Tota

l Sco

re

600,0

500,0

400,0

300,o

200,0

100,0

0,01

18 (S) 18 (S) 20 (S) 16 (S)

2 3

Alternatives

Risk:

4 5

278

382411

459

548


Gahcho Kué Mine, Canada.


EXAMPLE 12: DEVELOPING CLOSURE OBJECTIVES AND KPI’S FOR SENIOR LEADERSINTRODUCTION

The following objectives and Key Performance Indicators (KPI’s) related to Mine Closure Planning have been drafted to assist Senior Leaders at AA operations in developing commitments as part of the performance management process. The objectives are higher level targets that would be included in Key Result Areas for relevant staff, with the KPI’s being the measurable outputs of meeting these defined objectives. Not all of the objectives and KPI’s will be relevant to all operations, but should be seen as a starting point to developing breakthrough outcomes in closure planning and concurrent rehabilitation.

OBJECTIVES

• Provide the necessary resources to update closure plans aligned with the MCT every three years (Environmental Manager).

• Provide the necessary resources to implement the Master Action Plan developed from the Gap Analysis, Risk Assessment and Opportunities Analysis conducted as part of the ICPS (Environmental Manager).

• Calculate LoA and premature closure liabilities at least once a year (end of financial and end of calendar year) according to agreed Group Principles and communicate outputs to Group Finance and Mine Closure Planning Department (Finance Manager).

• Liaise with Group Finance to obtain bank guarantees or bonds (Finance Manager).

• Develop and implement five-year plans that optimise temporary progressive rehabilitation (Environmental Manager/SSD Manager).

• Work with Technical & Sustainability staff to proactively identify and explore opportunities to reduce closure liabilities and risks (Environmental Manager/Technical Manager).

• Develop a Stakeholder Engagement Plan specifically for closure (Social Performance and Government Relations Manager).

KPI’S

• Reduce closure liability or operational expenditure by $x M (GM/Finance Manager/Environmental Manager).

• Improve confidence level in closure liability estimate by x% (Environmental Manager).

• Meet Temporary progressive rehabilitation target of x ha (Environmental Manager/SSD Manager).

• Number of mine planning opportunities that decrease closure liability or create value that are realised (Environmental Manager/Technical Manager).

• Closure plan updated on time and meeting all MCT requirements (Environmental Manager/Head of SSD).

• Reduce three significant or high rated closure risks to moderate or low (post-mitigation – Environmental Manager).

• Number of closure plan actions completed (Environmental Manager).



EXAMPLE 13: CLOSURE CRITERIA EFFECTIVENESS REVIEW


INTRODUCTION

The closure risk assessment ratings assume that all closure criteria are 100% effective. We know this is rarely the case. While not all closure related criteria can be tested for effectiveness during operations (e.g. demolition, decommissioning), some can, particularly those related to concurrent rehabilitation. A closure criteria effectiveness review should be carried out between successive updates of closure plans. For closure criteria that are not fully effective, actions plans should be developed to address the identified issues.

METHODOLOGY

Critical closure criteria are those that have a post mitigation residual risk rating of significant or high (Anglo 5x5 – 13

or higher rating). These should first be listed in a table and those that can be assessed for effectiveness based on the remaining LoA identified (Table 1).

The identified closure criteria to address the significant or high residual risk should be identified along with the process to verify effectiveness (Table 2). The following should be assessed for each risk and classified as fully effective, partially effective or ineffective:

• Formal procedure and/or standard.• Management system in place.• Evidence of Planning.• Required budget in place.• Evidence of reporting.• RACI in place and active.

Barro Alto scenic viewpoint, Brasil.



RISK CONTROL CLOSURE CRITERIA REVIEW PROCESSSignificant/High Residual RiskDam overflow. Monitoring and Trigger Action Response Plan

(TARP).Review existing monitoring programme and TARP and inspect in the field.

Inadequate dam maintenance. Inspection and maintenance schedule. Review schedule and audit in the field.Inability to cap ES void. Dewater, consolidate and cap. Not relevant as plan is to challenge capping requirement.Spon Com from coal seams in high or low wall. Sustainable high wall rehabilitation and capping

of low wall.Review sustainable high wall technique and capping procedures and inspect trial areas in the field.

Blasting on high walls moves less material than design.

Dozer push at higher cost. Financial risk only so suggest CCE not value adding.

Failure of sustainable high wall technique leads to erosion.

Sustainable high wall rehabilitation. Covered in the previous risk.

Table 1: Example of critical closure criteria with significant or high residual risks.

Actions should be developed for any partially effective closure criteria and urgent action should be taken for any identified ineffective controls. These actions should be added

to the Master Action Plan (MAP) and tracked for completion between successive updates of the closure plan.


Table 2: Finalised site critical control specification summary.

Critical Control Number

Critical Control Title

Critical Control Owner

Critical Control Routine Monitoring

Critical Control Subject to Higher Level Assurance

Critical Control Effectiveness Monitoring and Reporting

Critical Control Specification - Criteria for Effective Control By Who Frequency

Requirements to verify Effectiveness Owner Frequency

Formal Procedure & Standard

Management System in Place

Evidence of Planning

Required Budget in Place

Evidence of Reporting

RACI in Place, and Active

CCE Status

CC#1 Spontaneous combustion

Mine Manager 1. Implement sustainable high wall treatment. 2. Capping of high risk low wall material with inerts based on risk. 3. Coverage of high risk material with pit water. 4. Visual inspections and other monitoring.

Contract Supervisor

Monthly No 1. Verify correct implementation of the sustainable highwall rehabilitation methdology. 2. In field inspection of capping thickness in WRD’s. 3. Monitoring of rehabilitation success. 4. Maintenance requirements identified and implemented.

Carl Grant Monthly Partial Partial Yes Partial Partial Yes Action Required

CC#2 WRD rehabilitation

Mine Manager 1. Reshaping of WRD batters to 18 degrees. 2. Topsoil to be applied to a minimum depth of 100 mm. 3. Planting and seeding of endemic species. Fertiliser addition. 4. Monitoring of rehabilitation and maintenance. 5. Implementation of post-closure monitoring programme.

Contract Supervisor

Monthly No 1. Verify reshaping of WRD batters to 18 degrees. 2. Verify topsoil or OGM being applied at correct depth or rate. 3. Verify planting and seeding of correct endemic species and appropriate fertiliser addition. 4. Monitoring of rehabilitation and identification of required maintenance. 5.Verify implementation of required maintenence using agreed procedures, with follow-up monitoring.

Carl Grant Monthly Partial Partial Yes Yes Partial Yes Action Required

CC#3 Void water quality Mine Manager 1. Capping of tailings (2 m thick). 2. Groundwater monitoring. 3. Groundwater modelling. 4. Geochemical testing of tailings.

Carl Grant Quarterly No 1. Investigate justification for not capping tailings. 2. Review geochemical analysis of void water monitoring results from an ecotoxicology perspective. 3. Review void modelling and update with new data (evaporation). 4. Review geochemical testing results for tailings and overburden.

Carl Grant Quarterly Partial Partial Partial Yes Partial Yes Action Required

CC#4 Offset quality Mine Manager 1. Follow restoration plan including appropriate capping of landform. 2. Maintain compliance with Rehabilitation and Offset Management Plan. 3. Implementation of post-closure monitoring programme.

Carl Grant Annual No 1. Follow restoration plan including appropriate capping of landform. 2. Maintain compliance with Rehabilitation and Offset Management Plan. 3. Implementation of post-closure monitoring program.

Carl Grant Annual Yes Partial Partial Partial Yes Yes Action Required

CC#5 Closure liability Mine Manager 1. Conduct regular review of the template and closure costings. 2. Continue Annual Review process with DP&E and DRE.

Rudolph Botha Biannually Yes ( ) 1. Conduct regular review of the template and closure costings. 2. Continue Annual Review process with DP&E and DRE.

Rudolph Botha

Biannually Yes Yes Partial Yes Yes Yes Action Required


Table 2: Finalised site critical control specification summary.

Critical Control Number

Critical Control Title

Critical Control Owner

Critical Control Routine Monitoring

Critical Control Subject to Higher Level Assurance

Critical Control Effectiveness Monitoring and Reporting

Critical Control Specification - Criteria for Effective Control By Who Frequency

Requirements to verify Effectiveness Owner Frequency

Formal Procedure & Standard

Management System in Place

Evidence of Planning

Required Budget in Place

Evidence of Reporting

RACI in Place, and Active

CCE Status

CC#1 Spontaneous combustion

Mine Manager 1. Implement sustainable high wall treatment. 2. Capping of high risk low wall material with inerts based on risk. 3. Coverage of high risk material with pit water. 4. Visual inspections and other monitoring.

Contract Supervisor

Monthly No 1. Verify correct implementation of the sustainable highwall rehabilitation methdology. 2. In field inspection of capping thickness in WRD’s. 3. Monitoring of rehabilitation success. 4. Maintenance requirements identified and implemented.

Carl Grant Monthly Partial Partial Yes Partial Partial Yes Action Required

CC#2 WRD rehabilitation

Mine Manager 1. Reshaping of WRD batters to 18 degrees. 2. Topsoil to be applied to a minimum depth of 100 mm. 3. Planting and seeding of endemic species. Fertiliser addition. 4. Monitoring of rehabilitation and maintenance. 5. Implementation of post-closure monitoring programme.

Contract Supervisor

Monthly No 1. Verify reshaping of WRD batters to 18 degrees. 2. Verify topsoil or OGM being applied at correct depth or rate. 3. Verify planting and seeding of correct endemic species and appropriate fertiliser addition. 4. Monitoring of rehabilitation and identification of required maintenance. 5.Verify implementation of required maintenence using agreed procedures, with follow-up monitoring.

Carl Grant Monthly Partial Partial Yes Yes Partial Yes Action Required

CC#3 Void water quality Mine Manager 1. Capping of tailings (2 m thick). 2. Groundwater monitoring. 3. Groundwater modelling. 4. Geochemical testing of tailings.

Carl Grant Quarterly No 1. Investigate justification for not capping tailings. 2. Review geochemical analysis of void water monitoring results from an ecotoxicology perspective. 3. Review void modelling and update with new data (evaporation). 4. Review geochemical testing results for tailings and overburden.

Carl Grant Quarterly Partial Partial Partial Yes Partial Yes Action Required

CC#4 Offset quality Mine Manager 1. Follow restoration plan including appropriate capping of landform. 2. Maintain compliance with Rehabilitation and Offset Management Plan. 3. Implementation of post-closure monitoring programme.

Carl Grant Annual No 1. Follow restoration plan including appropriate capping of landform. 2. Maintain compliance with Rehabilitation and Offset Management Plan. 3. Implementation of post-closure monitoring program.

Carl Grant Annual Yes Partial Partial Partial Yes Yes Action Required

CC#5 Closure liability Mine Manager 1. Conduct regular review of the template and closure costings. 2. Continue Annual Review process with DP&E and DRE.

Rudolph Botha Biannually Yes ( ) 1. Conduct regular review of the template and closure costings. 2. Continue Annual Review process with DP&E and DRE.

Rudolph Botha

Biannually Yes Yes Partial Yes Yes Yes Action Required


EXAMPLE 14: PROJECT MANAGEMENT FRAMEWORK (PMF) – STUDY AND PROJECT EXECUTION PLAN TEMPLATE


Amandelbult’s Tumela 1 Shaft, South Africa.


INTRODUCTION

This Project Execution Plan Template defines the minimum criteria that must be delivered by the Investment Team at the end of the Opportunity, Concept, Pre-Feasibility A, Pre-Feasibility B and Feasibility Stages. The Project Execution Plan template is intended to be tailored to the appropriate level to suite the effort/scope of the study effort. The intent of the document is to have one consolidated Project/Study Execution Plan for the owner’s scope and any key contractors associated with the delivery of the Investment.

The Investment Charter Sections 1 through 5 content shall be addressed per the major section headings with appropriate detail to match the study level as per the guidance provided in the Investment Charter template. The Planning Basis Sections 6 through 27 shall be tailored to be applicable to the project/study effort requirements. Each section represents typical content and it is at the Investment Teams discretion to determine applicable content for their project.

INVESTMENT CHARTER

1. BUSINESS GOALS AND OBJECTIVES

This section should summarize the business case and include the business objectives. It should describe how the investment fits into the corporate portfolio and strategy. Describe the investment history and background with key reasons for developing this investment. The investment purpose and mission need to be clearly stated and explained. It is important that the team has a good understanding of the body of work that has been conducted prior to this point in time. Summarize the issues faced and resolved in the previous study work and residual issues and risk that need to be addressed in the next stage.

The section should list both the highest ranked opportunities and risks associated with the investment along with a brief description of the path forward on the opportunities or the mitigation plan on the risk including exit strategies as appropriate.

1.1. BACKGROUND AND INVESTMENT HISTORY [BRIEF STAGE BY STAGE LOOK BACK]

1.2. BUSINESS CASE

1.3. BUSINESS OBJECTIVES

1.4. INVESTMENT CRITICAL ISSUES RISKS AND OPPORTUNITIES

2. PROJECT OBJECTIVES

This section should summarize the Stage specific Project Objectives and how they will achieve the goals of the Business Objectives This section should list the opportunities and risks associated with this stage of work to allow for the Development of the investment along with a brief description of the path forward on the opportunities or the mitigation plan on the risk including exit strategies as appropriate.

Set out the objectives from the perspective of all

stakeholders and state the investment vision.

The Investment Team also identifies the key objectives for which the key performance indicators (KPIs) can be defined: usually related to safety, capital cost, schedule (project completion and /or first production) and capacity.

As a guide, the Project Objectives consider the following items when being developed (notwithstanding being covered elsewhere with a greater level of detail):• Business objective requirements.• Stakeholder requirements.• Any special requirements for working within an existing

operation.• Any special environmental considerations and

requirements.• Any local content requirements.• The use of safety factors in equipment sizing to mitigate

production risks.• Sparing philosophy for the investment.

2.1. PROJECT BACKGROUND AND HISTORY

2.2. PROJECT/STAGE OBJECTIVES

2.3. CLIENT (OPERATIONS) USER REQUIREMENTS

2.4. KEY AND CRITICAL SUCCESS FACTORS

2.5. PROJECT OBJECTIVE CRITICAL ISSUES, RISKS AND OPPORTUNITIES (SWOT)

3. SCOPE OF INVESTMENT

3.1. BACKGROUND AND LOCATION

3.2. DESCRIPTION OF FACILITIES

3.3. EXECUTION DESCRIPTION

3.4. PROJECT DELIVERABLES [STAGE DELIVERABLES]

3.5. BATTERY LIMITS AND EXCLUSIONS

3.6. CRITICAL SCOPE ISSUES, RISKS AND OPPORTUNITIES [INCLUDED ITEMS SUCH AS NEW TECHNOLOGIES OR POTENTIALLY RISK LOCATIONS]

4. EXECUTION APPROACH AND WORK PLAN

This section should describe the Execution Approach and Work Plan for the Stage specific work. The work should be consistent with the Project Objective, Business Objectives and IDM Guidance.



4.1. BACKGROUND 4.2. MANAGEMENT PLAN APPROACH

4.2.1. GOVERNANCE STRUCTURE

4.2.2. PROJECT SPONSOR

4.2.3. STEERING COMMITTEE

4.2.4. PROJECT TEAM COMPOSITION OWNER/CONTRACTORS [INCLUDE ORG STRUCTURE AND NARRATIVE OF EXECUTION APPROACH (E.G. OWNER MANAGED, EPCM, ETC.)]

4.3. PROJECT KEY MILESTONE CHART/SCHEDULE [INCLUDE STAGE AND OVERALL PROJECT MILESTONES]

4.4. EXECUTION APPROACH RISK AND OPPORTUNITIES [INCLUDE ANY NON-TRADITIONAL EXECUTION APPROACHES OR AREAS OF PARTICULAR RISK TO APPROACH]

4.5. BUDGET SUMMARY [INCLUDE SUMMARY OF BUDGET REQUEST FOR THE STAGE BY MAJOR WBS CATEGORY, HIGHLIGHT ANY EARLY CAPITAL SPENDS, LIST SUNK COST BY STAGE]

4.6. CRITICAL ISSUES

5. SUSTAINABILITY APPROACH

This section should describe the Strategy for the sustainability of the Investment and identify critical commitments (future and current) for the success of the business case. It will need to identify any critical activities/negotiations that will need to occur during this stage.

5.1. BACKGROUND AND COMMITMENT STRATEGY

5.2. EXTERNAL STAKEHOLDERS LIST

5.3. COMMUNICATIONS and ENGAGEMENT STRATEGY [INCLUDE LOCAL AND REGIONAL COMMUNITIES, GOVERNMENT AGENCIES, NGO’S, MEDIA, ETC.]

5.4. COMMITMENT COST REGISTER AND ASSOCIATED SCHEDULE

5.5. CRITICAL ISSUES, RISKS AND OPPORTUNITIES

6. RISK MANAGEMENT PLAN

6.1. BACKGROUND AND OBJECTIVES

6.2. RISK MANAGEMENT PROCESS/DEFINITION OF RISK

6.3. RISK IDENTIFICATION AND MITIGATION AND ESTIMATE THE RELATED IMPACTS ON SCHEDULE AND COSTS ROLES AND RESPONSIBILITIES

7. ORGANISationAL PLAN


7.2. ORGANISATIONAL STRATEGY

7.3. ORGANISATION CHART

7.4. ROLES RESPONSIBILITIES AND RESOURCES (RACI)


8. FUNDING AND FINANCING PLAN


8.2. INSURANCE PHILOSOPHY

8.3. FUNDING STRATEGY

8.4. FINANCING STRATEGY/HEDGING

8.5. TAXES AND EXEMPTIONS REQUIREMENTS

8.6. ROLES, RESPONSIBILITIES AND RESOURCES


9. REGULATORY, ENVIRONMENTAL AND PERMITTING MANAGEMENT PLAN


9.2. EIS

9.3. REGULATORY APPROVALS

9.4. PERMITTING REQUIREMENTS

9.5. PERMITS CONDITIONS INCLUDING OFFSET STRATEGY

9.6. MONITORING AND CONTROL METHODS



10. PRIME CONTRACTING PLAN


10.2. CONTRACTING STRATEGY

10.3. CONTRACT SEGMENTS

10.4. CONTRACTOR SELECTION PROCESS


11. ENGINEERING MANAGEMENT PLAN (E/EP/EPCM/EPC/SELF EXECUTE)


11.2. DESIGN MANAGEMENT PHILOSOPHY


11.2.1. BIM

11.2.2. MODULARISATION STRATEGY

11.3. STANDARDS AND SPECIFICATIONS

11.4. DESIGN MANAGEMENT TOOLS AND TECHNIQUES

11.5. ENGINEERING QA/QC MANAGEMENT

11.6. DRAWING AND DOCUMENT CONTROL REQUIREMENTS

11.7. ENGINEERING AND TECHNICAL FUNCTION INTEGRATION

11.8. VALUE IMPROVEMENT PRACTICES

11.9. ROLES, RESPONSIBILITIES


12. OWNER SCOPE DESIGN MANAGEMENT PLAN


12.2. INTEGRATION PLAN OWNERS/CONTRACTORS (EPCM, ETC.)

12.3. GEOSCIENCE PLAN

12.4. MINE PLAN

12.5. METALLURGICAL AND PROCESS PLAN

12.6. INVESTMENT ASSURANCE PLAN

12.7. OTHERS AS REQUIRED

12.8. ROLES AND RESPONSIBILITIES


13. CONSTRUCTABILITY PLAN


13.2. CONSTRUCTABILITY PROCESS



14. LOGISTICS PLAN


14.2. TRAFFIC AND TRANSPORTATION MANAGEMENT

14.3. CUSTOMS REQUIREMENTS MANAGEMENT



15. PROCUREMENT AND MATERIALS MANAGEMENT PLAN


15.2. PROCUREMENT AND MATERIAL MANAGEMENT STRATEGY

15.3. PROCEDURES, PROTOCOLS, PROCEDURES TOLLS

15.4. LONG LEAD PROCUREMENT

15.5. MATERIAL PROCUREMENT

15.6. FIRST FILL AND SPARE PARTS PROCUREMENT

15.7. EXPEDITING, DILIGENCE AND INSPECTION

15.8. LAY-DOWN/MARSHALLING YARD AREAS

15.9. EQUIPMENT AND MATERIAL PRESERVATION, WAREHOUSING AND STORAGE



16. CONSTRUCTION MANAGEMENT PLAN


16.2. CONSTRUCTION MANAGEMENT STRATEGY

16.3. CONSTRUCTION SAFETY INCLUDING LOCK-OUT PROCEDURES (FOR BROWNFIELD PROJECTS) TEMPORARY CONSTRUCTION FACILITIES/SERVICES

16.4. CONSTRUCTION EQUIPMENT

16.5. EQUIPMENT/MATERIAL LOGISTICS

16.6. CONSTRUCTION QA/QC

16.7. PUNCH LIST PROCESS

16.8. CRISES MANAGEMENT APPROACH

16.9. ROLES RESPONSIBILITIES AND RESOURCES


17. HUMAN RESOURCES/LABOR RELATIONS PLAN


17.2. SITE STRATEGY

17.3. PROJECT STRATEGY

17.4. WORK FORCE REQUIREMENTS



18. PRE COMMISSIONING PLAN (C0)


18.2. PRE-COMMISSIONING MANAGEMENT STRATEGY

18.3. PRE-COMMISSIONING CONSIDERATIONS

18.4. PRE-COMMISSIONING SEQUENCE

18.5. SAFETY REVIEW, INCLUDING LOCK-OUT PROCEDURES AND TRAINING

18.6. SYSTEM HANDOVER REQUIREMENTS

18.7. ACCEPTANCE CRITERIA




19. COMMISSIONING AND START-UP MANAGEMENT PLAN (C1-C4)


19.2. COMMISSIONING AND STARTUP MANAGEMENT STRATEGY

19.3. COMMISSIONING AND STARTUP CONSIDERATIONS

19.4. COMMISSIONING AND STARTUP SEQUENCE

19.5. SAFETY REVIEW, INCLUDING LOCK-OUT PROCEDURES AND TRAINING

19.6. SYSTEM HANDOVER REQUIREMENTS




20. COST MANAGEMENT PLAN


20.2. WBS INCLUDING CBS, WORK PACKAGES, CODE OF ACCOUNTS, ETC.

20.3. ESTIMATE AND BUDGET BASIS AND ASSUMPTIONS

20.4. COST CONTROL APPROACH

20.5. CHANGE AND TREND MANAGEMENT APPROACH

20.6. SYSTEMS DESCRIPTION

20.7. PROJECT PROGRESS REPORTING

20.8. RISK AND CONTINGENCY MANAGEMENT APPROACH



21. SCHEDULE MANAGEMENT PLAN


21.2. SCHEDULE BASIS AND ASSUMPTIONS

21.3. SCHEDULING STRATEGY

21.4. SCHEDULE CONTROL

21.5. SCHEDULE HIERARCHY

21.6. SCHEDULE RISK ANALYSIS AND OUTCOME

21.7. PROGRESS AND PERFORMANCE CONTROL

21.8. SYSTEM DESCRIPTION



22. QUALITY ASSURANCE/QUALITY CONTROL MANAGEMENT PLAN


22.2. QA/QC METHODS AND TOOLS, TECHNIQUES

22.3. DOCUMENT CONTROL/RECORD KEEPING

22.4. QA/QC CLOSEOUT/HANDOVER REPORT



23. SAFETY MANAGEMENT PLAN


23.2. SAFETY MANAGEMENT STRATEGY

23.3. SAFETY RULES AND REGULATIONS

23.4. PERSONNEL SAFETY

23.5. TRAINING



24. HEALTH MANAGEMENT PLAN


24.2. HEALTH MANAGEMENT STRATEGY

24.3. HEALTH RULES AND REGULATIONS



25. INFORMATION MANAGEMENT PLAN


25.2. SCOPE

25.3. ORGANISATION

25.4. COMMUNICATION MANAGEMENT

25.5. INFORMATION REPOSITORIES/EXCHANGE

25.6. BUSINESS SYSTEMS

25.7. IT INFRASTRUCTURE

25.8. ROLES AND RESPONSIBILITIES AND RESOURCES

26. OPERATIONAL READINESS PLAN


26.2. INITIAL AND SUSTAINED OPERATIONS CONSIDERATIONS

26.3. OR MANAGEMENT STRATEGY

26.4. TRAINING PLAN

26.5. OPERATIONS HANDOVER REQUIREMENTS





27. MARKETING PLAN


27.2. MARKET CRITERIA

27.3. SUPPLY AGREEMENTS AND PENALTIES



Sishen Mine, South Africa – Inspection being done on locomotive and rail.


EXAMPLE 15: QUANTITATIVE RISK SIMULATION AND ANALYSIS


A distant view of the Dishaba Mine, South Africa.




INTRODUCTION

The accuracy of the closure cost estimate might not be at the required level from an investment review point of view based on the inherent nature of a closure plan (scope not always finalised and not always agreed with the regulator until late in the LoA). It is therefore important that an accurate contingency estimated process is followed. A Quantitative Risk Analysis (QRA) consists of the establishment of a quantitative model and applying probabilistic parameters (e.g. Monte Carlo analysis), that will give an accurate contingency liked to the accuracy of the estimate (P50 vs P80 vs P90). This example contains extracts from a QRA, to demonstrate the benefits of this approach.

TYPICAL QRA OUTPUTS

Figure 1 below illustrates a typical example of the % confidence of the base estimate and the additional contingency required to obtain a 90% confidence level with a legend on how it must be interpreted:

Base estimate confidence level

Contigency required

Required confidence level

Acceptable risk

Value

Itera

tions

Figure 1: Illustration of confidence level related to contingency

The Monte Carlo simulations provided the following results:

Figure 2 is a waterfall chart that illustrates exclusions, reductions and additions in values on the original study phase 1 capex budget that was applied to determine a base capital estimate for 2012 on which a Monte Carlo analysis could be performed. The original budget of $US205 M was reduced to $US105.4 M.

Original to Base Estimate Capex Waterfall ($’000 000)Original Study Total Project Phase 1 Capex Budget (based on 2011 figures)

Exclude initial capitalised operating cost estimate

Exclude initial contingency estimate

Reduced consultants, study and execution cost

Outsourcing mining earth moving equipment

Reduced plant construction, packaging, shipping, erection and commissioning

Reduced bulk earthworks, roads and civils

Outsourcing generator sets and electrical/mechanical reduction

Reduced building costs

Reduce equipment, LDVs, IT, labs, worshop and services, trucks – to Franceville

Reduced upgrade of roads to Franceville

Reduced IT infrastructure

Excluded railway station

Additional locomotive and wagons cost

Additional plant modifications and EFL

Additional site establishment and infrastructure design work

Additional SHE permits and mining rights (including $11.2m packaged plant cost

New 2012 baseline estimate with 8% escalation

$205.9

$18.8

$23.6

$11.1

$6.5

$20

$20.9

$8.4

$5.2

$7.7

$2.7

$1.9

$2.0

$3.9

$1.2

$0.8

$22.4

$105.4

$0 $50.0 $100.0 $150.0 $200.0 $250.0

Figure 2: Typical base estimate capex waterfall, to be used in a Monte Carlo analysis


Uncertainty associated with the project’s capital estimate is represented by the risk profile below (histogram and cumulative distribution curve graph, as illustrated in Figure 3 below).

The top capital sensitivity drivers to the estimate cost are shown in the tornado graph below (the cost sensitivity of an item is a measure of the correlation between the cost of the item and the cost of the project).Capex Monte Carlo distribution.

CAPEX – Project Team Procurement

CAPEX – Locomotives and wagons

CAPEX – Road upgrade (external 18 km – from production

CAPEX – Plant erection and commissioning

CAPEX – Mining rights

CAPEX – Buildings and infrastructure

CAPEX – Part 1 – ROAD AND BULK EARTHWORKS

CAPEX – Consultant cost

CAPEX – Part 2 – WATER MANAGEMENT

CAPEX – Modifications to the original plant

CAPEX – Part 3 – SLURRY AND RETURN WATER

CAPEX – Project team cost

CAPEX – Eath moving equipment

CAPEX – SHE permits

CAPEX – Electrical reticulation

CAPEX – Part 4 – SEWAGE TREATMENT PLANT

Regression coeffients

-0.0

5

0.0

0

0.0

5

0.1

0

0.1

5

0.2

0

0.2

5

0.3

0

0.3

5

0.0

00

.40

0.4

5

0.5

0

Coefficient value

0.49

0.48

0.42

0.27

0.26

0.25

0.25

0.13

0.10

0.09

0.07

0.07

0.03

0.03

0.03

Figure 4: Typical tornado graph, reflecting cost sensitivities.

Uncertainty associated with the project’s operational expenditure estimate over five years is represented by the risk profile as reflected in Figure 5 on the next page (histogram and cumulative distribution curve graph).

5.0%

9080

8

7

6

5

4

3

2

1

0

100.0%

87.5%

75.0%

62.5%

50.0%

37.5%

25.0%

12.5%

0.0%%85 95 100 105 110 115 120 125

5.0%90.0%

109.8191.64

TOTAL (excl tax)/Monte Carlo Capital Cost

Minimum $80 826 550.89Maximum $123 601 922.15Mean $100 827 868.43Std Dev %5 508 004.58Values 5 000

Capex Monte Carlo distribution.

10%

= $

93

70

0 1

05

.15

90

% =

$10

7 9

19 3

12.7

9

Bas

e es

timat

e =

10

541

85

08

Values in Millions ($)

Figure 3: Typical risk profile demonstrated by a histogram and cumulative distribution curve, using Monte Carlo Analysis for Capex cost.


Values in millions ($)

Grand total/total Opex cost

Minimum $196 411 087.08

Maximum $225 398 673.05

Mean $210 290 699.84

Std Dev $4 668 579.92

Values 5 000

5.0% 90.0% 5.0%

195 200 205 210 215 220 225 230

202.64 218.04

Opex Monte Carlo distribution

9

8

7

6

5

4

3

2

1

0

100.0%

88.9%

77.8%

66.7%

55.6%

44.4%

33.3%

22.2%

11.1%

0.0%

10%

= $

20

4 1

55

05

6.9

6

90

% =

$21

6 2

81 7

59

.57

Bas

e es

timat

e =

213

23

99

83

8

The same principle as with the capital estimate distribution applies where the range between the lowest cost and the most likely cost is on average much higher than the range between the most likely cost and the highest cost. The base operational expenditure estimate of $US213.24 M over five years therefore has a very high confidence level of 75%.

Figure 5: Typical risk profile demonstrated by a histogram and cumulative distribution curve, using Monte Carlo Analysis for Opex cost.


General view of Amandelbult’s Tumela 1 Shaft, South Africa.


INTRODUCTION

This example contains an illustration of the requirements and deliverables associated with execution planning and scheduling. Key components such as resource availability, assumptions related to production and non-production time, as well as describing the key activities, key dependencies, equipment availability and utilisation (see Table 1 below), etc. are required as part of the planning process.

Examples of key planning inputs

Resources:• 2 x Bulldozers – CAT D9.• 2 x Excavators Large – Liebherr 984.• 1 x Excavator Small – Liebherr 944.• 1 x Team of six workers (Need two teams to achieve

planting target).• 1 x Road Grader.• 1 x Bio-Physical Contractor (Building of concrete wall).• 1 x Bio-Physical Long Slopes (Probably helicopter).• 4 x Physical Contractors.• 4 x Transition Contractors.

Production and non-production time:• All rehabilitation team work 5 days per week.• The rehabilitation team work from Mondays to Fridays.• The rehabilitation team work from 07H00 to 16H00

(nine hours) on work days.• The rehabilitation team work 45 hours per week.• The rehabilitation team don’t work on public holidays.• The plan allows for planting only in January, February

and March and also constrains the small excavator from other activities.

• The plan allows wetting only in January, February, March and April.

BioPhysical – Shaping – Large excavator. m²/hr 180

BioPhysical – Shaping – Bulldozer. m²/hr 227

BioPhysical – Moonscaping – Bulldozer. m²/hr 2 065

BioPhysical – Stormwater Drain – Small Excavator.

m²/hr 1 079

BioPhysical – Roads – Small excavator. m²/hr 1 079

BioPhysical – Roads – Grader. m²/hr 58 606

BioPhysical – Planting – Small excavator. m²/hr 975

BioPhysical – Planting Dump – Farm workers.

m²/hr 487

BioPhysical – Wetting W1 – Watertanker + 4x4 light vehicle.

m²/hr 1 301


m²/hr 1 301


m²/hr 1 301


m²/hr 1 301

BioPhysical – Ripping – Bulldozer. m²/hr 1 061

Moonscapes/ha. 200 ea/ha

Excavator travel speed normal. 2.7 km/hr

Travel time between moonscapes. 0.22 min

Travel time between moonscapes/rows. 0.11 min

Loads per moonscape. 2 ea

Time to create moonscape – cycle. 1.20 min/moonscape

Time to create moonscape/ha. 4.0 hrs/ha

Moonscaping excavator. 2 493 m2/hr

Moonscaping excavator. 1 589 m2/hr effective

Moonscapes/ha. 200 ea/ha

Excavator travel speed normal. 2.7 km/hr

Travel time between moonscapes. 0.22 min

Travel time between moonscapes/rows. 0.11 min

Loads per moonscape. 2 ea

Time to create moonscape – cycle. 1.01 min/moonscape

Time to create moonscape/ha. 6.5 hrs/ha

Time to plant and close. 0.9 min/moonscape

Planting small excavator. 1 529 m2/hr

Planting small excavator. 975 m2/hr effective

EXAMPLES OF KEY ACTIVITIES

Bio-Physical Activities

Step 1: Prepare Dump Shaping – Large excavatorShaping – BulldozerMoonscaping – BulldozerStormwater drain – Small excavatorRoads – Small excavatorRoads – Grader

Step 2: Plant DumpPlanting – Small excavatorPlanting dump – Local workersWetting W1 – Watertanker + light vehicleWetting W2 – Watertanker + light vehicleWetting W3 – Watertanker + light vehicleWetting W4 – Watertanker + light vehicle

Physical Activities

Step 1: Demolish infrastructureRemove – Workshop Cranes – ContractorRemove – Light steel – ContractorRemove – Medium Steel – ContractorRemove – Heavy Steel – ContractorRemove – Double brick wall single story – ContractorRemove – Double brick wall multi-level – ContractorRemove – Reinforced concrete floor 250 mm – ContractorRemove – Reinforced concrete floor 400 mm – ContractorRemove – Reinforced concrete floor 800 mm – ContractorRemove – Concrete slab 340 mm – Contractor

EXAMPLE 16: EXECUTION PLANNING AND SCHEDULING



Excavating foundations – ContractorRemove – Railway – ContractorRemove – Weighbridge – ContractorRemove – Conveyor System – Contractor

Other transition activitiesGame Farm Management

Water managementAir Quality ManagementHeritage or Infrastructure ManagementRehabilitation monitoringSlope Stability ManagementLegal AssessmentMine residue deposits Management


Original EXCEL base outcome60.00

50.00

40.00

30.00

20.00

10.00

0.00

2015

ZA

R M

illio

ns

2017

2019

20212023

20252027

20292031

20332035

pre 2

015

– Physical EXCEL base – BioPhysical EXCEL base

– Transition EXCEL base

New XPAC base outcome60.00

50.00

40.00

30.00

20.00

10.00

0.00

2015

ZA

R M

illio

ns201

7201

92021

20232025

20272029

20312033

2035

pre 2

015

– Physical EXCEL base – BioPhysical EXCEL base

– Transition EXCEL base

Figure 1: Reflecting a typical analysis comparing the results from 2 different scheduling systems (EXCEL and XPAC).

As part of execution planning and scheduling it is important to evaluate the accuracy and the overall confidence in the models used. Figure 1 above is a typical result where an old and a more advance new planning system was used, and the results compared in an attempt to measure the confidence in the new system/model.

Table 2: Typical cash flow linked to the execution plan

Developing an operational cash flow (see Table 2) once the scheduling has been completed is part of optimising the execution plan. This often involves the leveling out the opex costs over the scheduled execution period and in doing so improving the net present cost of the project. Having a linked cash flow to the work breakdown structure and execution schedule improves the confidence in the execution plan. The execution schedule and cash flow can also be used to de-risk the project by rescheduling activities as appropriate (e.g. deferring the demolition of the plant because there could be a potential future buyer and hence early demolition could destroy future value).

Code Data Field Name

01/Jan/2015 01/Jan/2016

01/Jan/2016 01/Jan/2017

01/Jan/2017 01/Jan/2018

01/Jan/2018 01/Jan/2019

01/Jan/2019 01/Jan/2020

01/Jan/2020 01/Jan/2021

01/Jan/2021 01/Jan/2022

01/Jan/2022 01/Jan/2023

01/Jan/2023 01/Jan/2024

01/Jan/2024 01/Jan/2025

01/Jan/2025 01/Jan/2026

01/Jan/2026 01/Jan/2027

bud Budget bio Bio-Physical

fix Fixed R 5 289 869.86 5 337 899.61 17 736 654.25 9 445 679.68 15 918 186.32 17 777 711.47 19 584 065.22 20 525 376.67 32 294 086.13 10 284 734.18 15 377 428.70 13 073 321.78

bas Baseline R 0.00 8 127 222.25 6 399 703.58 12 698 059.88 6 949 840.00 3 093 193.36 10 593 027.13 18 128 052.51 3 563 444.00 11 057 194.07 4 090 765.98 5 744 241.00

kio KIO R 0.00 2 872 445.88 798 649.28 0.00 838 829.90 0.00 0.00 4 920 520.78 1 953 410.26 0.00 465 728.36 0.00

tot Total Bio-Physical R 5 289 869.86 16 337 567.74 24 935 007.10 22 143 739.56 23 706 856.21 20 870 904.83 30 177 092.35 43 573 949.96 37 810 940.40 21 341 928.25 19 933 923.05 18 817 562.78

sp1

phy Physical

fix Fixed R 0.00 1 405 023.24 22 961 203.52 9 141 676.53 10 269 846.24 11 158 579.66 0.00 0.00 0.00 0.00 0.00 0.00

bas Baseline R 0.00 81 851.06 211 890.37 20 087.25 365 460.42 0.00 146 824.07 0.00 0.00 292 162.28 0.00 0.00

kio KIO R 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

tot Total Physical R 0.00 1 486 874.30 23 173 093.89 9 161 763.78 10 635 306.66 11 158 579.66 146 824.07 0.00 0.00 292 162.28 0.00 0.00

sp2

tra Transition

fix Fixed R 6 203 948.25 37 642 656.18 56 517 844.73 21 189 887.00 24 745 501.26 12 654 664.25 8 134 659.27 10 445 038.16 10 445 038.16 10 445 038.16 10 777 352.36 9 629 158.16

bas Baseline R 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

kio KIO R 829 759.67 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

tot Total Transition R 7 033 707.92 37 642 656.18 56 517 844.73 21 189 887.00 24 745 501.26 12 654 664.25 8 134 659.27 10 445 038.16 10 445 038.16 10 445 038.16 10 777 352.36 9 629 158.16

sp3

tot Total Costs All R 12 323 577.78 55 467 098.21 104 625 945.72 52 495 390.34 59 087 664.13 44 684 148.74 38 458 575.70 54 018 988.12 48 255 978.56 32 079 128.69 30 711 275.41 28 446 720.94

Comp

Comp

Comp

Comp

Comp

Comp


EXAMPLE 17: WORK BREAKDOWN STRUCTURE


The Oaks rehabilitation in South Africa.


INTRODUCTION

Developing a detailed Work Breakdown Structure (WBS) using the execution schedule to at least level 3 (work package level) is a key component of any project execution plan. An example of a typical WBS layout is provided (Figure 1), with a more detailed breakdown of the WBS components to 3 levels, that links to the various work packages and the associated project budget items also provided (Table 1, every WBS item is linked to a cost number, to track and manage the budget).



MCMine Closure Plan

MC 0Milestones

MC.11000. Mining

MC.22000. Site Development

MC.33000. Process Facility

MC.1.41400.Fixed Mining Equipment

MC.2.12100. General Site Development and Layout

MC.3.43400. Recovery Plant (Portion of Building 80)

MC.1.51500. Electrical Power Supply and Distribution

MC.2.22200. Access Roads

MC.3.73700. Paste Fill Plant/Bulk Sample Plant (Building 24)

MC.1.61600. Surface Facilitites

MC.2.32300 Air Strip

MC.3.93900 Process Building (Building 80)

Figure 1: Typical mine closure plan WBS layout


MC.44000. Utilities

MC.55000. Ancillary Buildings

MC.66000. WMP and Water Waste MGM

MC.99000. Indirect

MC.4.14100. Power Plant and Distribution (Utilities Complex Building 66)

MC.4.24200. Fuel Storage and Distribution

MC.4.2.1Fuel Storage Area 1




MC.4.2.5Distribution

MC.4.2.6Other Fuel Storage Tanks

MC.4.34300. Glycol System

MC.4.74700. Services Complex (Building No. 73) and Utilidor (Building No. 68)

MC.5.55500. Ancillary Buildings

MC.5.65600. Cold Storage (Inc Cement Storage)

MC.5.85800. Plant Mobile and Utility Equipment

MC.6.16100. North Pile

MC.6.36300. Water Management and Treatment – Overland Pipeline Removals

MC.6.56500. Off-site Hazardous Waste Disposal

MC.9.19100. EPCM

MC.9.39300. Temporary Construction Facilities and Equipment

MC.9.49400. Construction Camp and Catering

MC.9.59500. Transportation during Demolition Activities

MC.9.89800. Mobilisation and Demobilisation by Winter Road


Table 1: Detailed mine closure – WBS

Level Code Description

1 1.0.00.00 Mine Closure.

2 1.1.00.00 Decommissioning of Structures.

3 1.1.01.00 Permitting.

4 1.1.01.01 Permitting for 2019 Season.



3 1.1.02.00 General Conditions.

4 1.1.02.01 Construction and Project Management – 2019 Season.

4 1.1.02.02 Pre-Mobilisation Planning – 2019 Season.

4 1.1.02.03 Procurement/Contracting – 2019 Season.

4 1.1.02.04 Mobilisation and Site Preparation – 2019 Season.

4 1.1.02.05 Utility Isolation – 2019 Season.

4 1.1.02.06 Site Accommodation and Services – 2019 Season.




4 1.1.02.14 Demobilisation – 2020 Season.

4 1.1.02.15 Close-out Report – 2020 Season.


4 1.1.02.22 Pre-Mobilisation Planning – 2023 Season.

4 1.1.02.23 Procurement/Contracting – 2023 Season.

4 1.1.02.24 Mobilisation and Site Preparation – 2023 Season.



4 1.1.02.27 Demobilisation – 2023 Season.

4 1.1.02.28 Close-out Report – 2023 Season.

3 1.1.03.00 Demolition – 2019 Season

4 1.1.03.01 Primary Crusher.

4 1.1.03.02 Primary Crusher Product Conveyor to Splice House.

4 1.1.03.03 Splice House.

4 1.1.03.04 Primary Crusher Product Conveyor to Transfer House.

4 1.1.03.05 Radial Stacker Feed Conveyor and Reclaim Area.

4 1.1.03.06 Primary and Secondary Scrubber Feed Conveyors.

4 1.1.03.07 Feed Conveyors Take up Building.

4 1.1.03.08 Back Feed Conveyor from HPRC to Transition House.

4 1.1.03.09 Back Feed Conveyor from Transition House to Transfer House.

4 1.1.03.10 Transition House.

4 1.1.03.11 Transfer House.

4 1.1.03.12 Conveyor to Processed Kimberlite.

4 1.1.03.13 Processed Kimberlite Tower.

4 1.1.03.14 Process Plant.

4 1.1.03.15 Workshop/Warehouse.

4 1.1.03.16 Security/Admin Building.

4 1.1.03.17 Fuel Tank Farm and Fuel Dispensing Stations.

4 1.1.03.18 Construction Camp.

4 1.1.03.19 TAJ/Exploration/Environmental Storage.

4 1.1.03.20 Miscellaneous Storage Tanks.

4 1.1.03.21 Exploration Tango Office.



4 1.1.03.22 Managers Offices.

4 1.1.03.23 Heated Storage/ERT Building.

4 1.1.03.24 Environmental Lab Building.

4 1.1.03.25 Dewatering Infrastructure (except wells).

4 1.1.03.26 Open Pit.

3 1.1.04.00 Disposal – 2019 Season

4 1.1.04.01 Primary Crusher.

4 1.1.04.02 Primary Crusher Product Conveyor to Splice House.

4 1.1.04.03 Splice House.

4 1.1.04.04 Primary Crusher Product Conveyor to Transfer House.

4 1.1.04.05 Radial Stacker Feed Conveyor and Reclaim Area.

4 1.1.04.06 Primary and Secondary Scrubber Feed Conveyors.

4 1.1.04.07 Feed Conveyors take up building.

4 1.1.04.08 Back Feed Conveyor from HPRC to Transition House.

4 1.1.04.09 Back Feed Conveyor from Transition House to Transfer House.

4 1.1.04.10 Transition House.

4 1.1.04.11 Transfer House.

4 1.1.04.12 Conveyor to Processed Kimberlite.

4 1.1.04.13 Processed Kimberlite Tower.

4 1.1.04.14 Process Plant.

4 1.1.04.15 Workshop/Warehouse.

4 1.1.04.16 Security/Admin Building.

4 1.1.04.17 Fuel Tank Farm and Fuel Dispensing Stations.

4 1.1.04.18 Construction Camp.

4 1.1.04.19 TAJ/Exploration/Environmental Storage.

4 1.1.04.20 Miscellaneous Storage Tanks.

4 1.1.04.21 Exploration Tango Office.

4 1.1.04.22 Managers Offices.

4 1.1.04.23 Heated Storage/ERT Building.

4 1.1.04.24 Environmental Lab Building.

4 1.1.04.25 Dewatering Infrastructure (except wells).

4 1.1.04.26 Open Pit.

3 1.1.05.00 Demolition – 2020 Season

4 1.1.05.01 Water Treatment Plant and Outside Office.

4 1.1.05.02 Sewage treatment Plant.

4 1.1.05.03 Incinerator Plant.

4 1.1.05.04 Boiler No. 1 (Accommodation Complex).

4 1.1.05.05 Boiler No. 2 (Processing Plant).

4 1.1.05.06 On-Site Piping.

4 1.1.05.07 Off-Site Piping – Fine Processed Kimberlite Slurry.

4 1.1.05.08 13.8 KV Site Overhead Lines and 115 KV Transmission Lines at Victor Site.

4 1.1.05.09 Quarry Pump House.

4 1.1.05.10 Environmental Lab.

4 1.1.05.11 SHR and E Office.

4 1.1.05.12 Mining Office.

4 1.1.05.13 Accommodation Complex and Administration Office.

4 1.1.05.14 Remainder of 115 KV Transmission Lines to Attawapiskat.



3 1.1.06.00 Disposal – 2019 Season.

4 1.1.06.01 Water Treatment Plant and Outside Office.

4 1.1.06.02 Sewage treatment Plant.

4 1.1.06.03 Incinerator Plant.

4 1.1.06.04 Boiler No. 1 (Accommodation Complex).

4 1.1.06.05 Boiler No. 2 (Processing Plant).

4 1.1.06.06 On-Site Piping.

4 1.1.06.07 Off-Site Piping – Fine Processed Kimberlite Slurry.

4 1.1.06.08 13.8 KV Site Overhead Lines and 115 KV Transmission Lines at Victor Site.

4 1.1.06.09 Quarry Pump House.

4 1.1.06.10 Environmental Lab.

4 1.1.06.11 Safety, Human Resources and Environmental Office.

4 1.1.06.12 Mining Office.

4 1.1.06.13 Accommodation Complex and Administration Office.

4 1.1.06.14 Remainder of 115 KV Transmission Lines to Attawapiskat.

3 1.1.07.00 Demolition – 2023 Season.

4 1.1.07.01 13.8 KV Site Overhead Lines.

4 1.1.07.02 Off-Site Piping.

4 1.1.07.03 River Pump House.

4 1.1.07.04 Emergency/Backup Generators.

4 1.1.07.05 Electrical Switchyard/Substation.

4 1.1.07.06 KDR and Other Temporary Facilities.

1.1.07.07 Underground Power Lines.

3 1.1.08.00 Disposal – 2023 Season.

4 1.1.08.01 13.8 KV Site Overhead Lines.

4 1.1.08.02 Off-Site Piping.

4 1.1.08.03 River Pump House.

4 1.1.08.04 Emergency/Backup Generators.

4 1.1.08.05 Electrical Switchyard/Substation.

4 1.1.08.06 KDR and Other Temporary Facilities.

1.1.08.07 Underground Power Lines.

3 1.1.09.00 Dewatering and Monitoring Wells

4 1.1.09.01 Dewatering Wells

4 1.1.09.02 Monitoring Wells

2 1.2.00.00 Site Characterisation and Soil Remediation.

3 1.2.01.00 Remediation.

3 1.2.02.00 Post Closure Phase 2 ESA.

2 1.3.00.00 Stabilisation Works.

3 1.3.01.00 Stabilisation Works.

4 1.3.01.01 Pit Perimeter Placement of Berm Barricade, Warning Signs.

4 1.3.01.02 Barricade Pit Ramp.

4 1.3.01.03 Emergency Pit Overflow Channel (estimated @ $541,926.00).

4 1.3.01.04 Central Quarry Pond Backfill/Bank Sloping/Reclamation Cover.

4 1.3.01.05 Central Quarry Channel Restoration and Connection to NGC (fish habitat).

4 1.3.01.06 East Overburden Pond Connection to NGC (fish habitat).

4 1.3.01.07 South Quarry Connection to SGC (fish habitat).

4 1.3.01.08 Fine Processed Kimberlite Cell #1 Toe Drain.

4 1.3.01.09 Victor Pit Beach Rock Armoring (estimated @ $6,831,231.00).

4 1.3.01.10 Ground Water Remediation (Sulphate Management) – Slurry Cutoff Ditch.

4 1.3.01.11 Demolition Landfill.

Mine Closure – Work Breakdown Structure (WBS) (continued)



2 1.4.00.00 Land Reclamation.

3 1.4.01.00 Permitting.

3 1.4.02.00 General Conditions.

4 1.4.02.01 Overall Mobilisation and Demobilisation.

3 1.4.03.00 Site Preparation and Reclamation.

4 1.4.03.01 Project 1: East Overburden Stockpile (EOVB) – Site Preparation and Reclamation.

4 1.4.03.02 Project 2: South Quarry (SQ) – Site Preparation, Resloping and Reclamation.

4 1.4.03.03 Project 3: Waste Rock Stockpile (WRS) – Site Preparation and Reclamation.

4 1.4.03.04 Project 4: Demolition Landfill.

4 1.4.03.05 Project 5: Low Grade Stockpile (LGS) – Site Preparation and Reclamation.

4 1.4.03.06 Project 6: Fine Processed Kimberlite Cell #1 and PFK Cell #2 – Site Preparation and Reclamation.

4 1.4.03.07 Project 7: Polishing Pond (PP) Pond Perimeter – Reclamation.

4 1.4.03.08 Project 9: Process Plant and Main Camp – Site Preparation and Reclamation.

4 1.4.03.09 Project 10: Transportation Corridors – Site Preparation and Reclamation.

4 1.4.03.10 Project 12: Bio-Remediation Cell – Site Preparation and Reclamation.

4 1.4.03.11 Project 13: Demolition, Site Clean-up and Disposal of Solid Waste and Salvageable Material.

4 1.4.03.12 Airstrip.

4 1.4.03.13 CQ Discharge Channel.

4 1.4.03.14 Airport Road.

4 1.4.03.15 Pit Slopes.

4 1.4.03.16 Main Haul Road.

4 1.4.03.17 Water Intake Road.

4 1.4.03.18 Water Intake.

4 1.4.03.19 End Pit Lake.

4 1.4.03.20 Polishing Pond.

4 1.4.03.21 SQ Discharge Channel.

3 1.4.04.00 Seeding.






4 1.4.04.06 Project 6: Fine Processed Kimberlite Cell #1 and PFK Cell #2 – Site Preparation and Reclamation.






4 1.4.04.12 Airstrip.



4 1.4.04.15 Pit Slopes.

4 1.4.04.16 Main Haul Road.






3 1.4.05.00 Planting.








4 1.4.05.06 Project 6: FPK Cell #1 and Fine Processed Kimberlite Cell #2 – Site Preparation and Reclamation.






4 1.4.05.12 Airstrip.



4 1.4.05.15 Pit Slopes.

4 1.4.05.16 Main Haul Road..






2 1.5.00.00 Post-Closure Monitoring Programme 2014-2024.

3 1.5.01.00 Post Closure Bio-physical Monitoring and Inspection Programme (2018-2024).

4 1.5.01.01 Geotechnical Inspections (Year 2019-2024).

3 1.5.02.00 Aquatics Programmes (2019-2022).

4 1.5.02.01 Attawapiskat River Well Field Discharge Receiving Water Study.

4 1.5.02.02 Fine Processed Kimberlite Discharge Receiving Water Study.

4 1.5.02.03 Adaptive Management Strategy Aquatic Biological Monitoring – Naysh.

4 1.5.02.04 Mercury Monitoring Programme – Small bodied Fish (assumes 2, 3-year cycles – 2019 and 2022).

4 1.5.02.05 Mercury Monitoring Programme – Large/Small Bodied Fish.

4 1.5.02.06 General Site Effects – SGC EEM.

4 1.5.02.07 Metals Bioaccumulation (Landfill) NGC.

3 1.5.03.00 Water Quality Monitoring (2019-2029).

4 1.5.03.01 LF-3, 4A, 5, 6, 7 and Demolition Landfill Discharge.

4 1.5.03.02 Central Quarry.

4 1.5.03.03 WWTP/WTP.

4 1.5.03.04 Confluence/Winter Road Crossing 04FC011/04FC010.

4 1.5.03.05 Phase 1 Ditch.

4 1.5.03.06 Monument Channel.

4 1.5.03.07 Attawapiskat River Samples.

4 1.5.03.08 Northeast Fen.

4 1.5.03.09 North Granny Creek.

4 1.5.03.10 South Granny Creek.

4 1.5.03.11 Main Rivers.

4 1.5.03.12 Summer Groundwater Programme.

4 1.5.03.13 Biosolids.

3 1.5.04.00 Laboratory Costs.

3 1.5.05.00 Wildlife Monitoring.

4 1.5.05.01 Monitoring – caribou @ year 10.

4 1.5.05.02 Monitoring – birds @ year 10.

Mine Closure – Work Breakdown Structure (WBS) (continued)



4 1.5.05.03 Monitoring – small mammals @ year 10.

3 1.5.06.00 Noise Monitoring (2019 – 2021).

3 1.5.07.00 Air Quality Monitoring (2019-2022).

2 1.6.00.00 Operations and Maintenance – Post Closure 2019-2022.

3 1.6.01.00 Equipment mobilisation/demobilisation.

3 1.6.02.00 Construction of Reclamation Camp.

3 1.6.03.00 Maintenance of Reclamation Camp and associated facilities.

3 1.6.04.00 Winter Road Construction and Maintenance.

3 1.6.05.00 Operate flow supplementation for 2.5 year.

3 1.6.07.00 Reclamation Camp Dismantling and Disposal.

2 1.7.00.00 Non Distributable Overhead Costs.

3 1.7.01.00 Salaries and Benefits.

3 1.7.02.00 Accommodations and Travel.

3 1.7.03.00 External Consulting.

2 1.8.00.00 Owner’s Management Cost.

3 1.8.01.00 Owner’s Project Management.

3 1.8.02.00 Owner’s Support Centre.

3 1.8.03.00 Mine Closure General and Administration.

3 1.8.04.00 Owner Permitting.

2 1.9.00.00 Indirect Cost.

3 1.9.01.00 Draw Down of ARO Liability Account.

3 1.9.02.00 Re-trenching and re-training programme.

3 1.9.03.00 Social Investment.

3 1.9.04.00 Engineering and Consultants.

3 1.9.05.00 Temporary Facilities.

3 1.9.06.00 Power Supply.

3 1.9.07.00 Power Plant Operating.

3 1.9.08.00 Bulk Fuel.

4 1.9.08.01 Bulk Diesel.

4 1.9.08.02 Bulk Gas.

4 1.9.08.03 Northec Fuel Consumption.

3 1.9.09.00 Closure Mine Camp Catering.

3 1.9.10.00 General Contractor Expenses.

3 1.9.11.00 Shipping and Handling Indirect.

3 1.9.12.00 Spare Parts.

3 1.9.13.00 Freight.

4 1.9.13.01 Passenger Airfare.

4 1.9.13.02 Road Freight.

4 1.9.13.03 Helicopter Support.

3 1.9.14.00 Other Support Contracts.

3 1.9.98.00 Contingency.

3 1.9.99.00 Escalation.


EXAMPLE 18: DEMOLITION PLAN


Kolomela Mine, South Africa. Intern Robin Bhola and Izak Gous (Environmental Tech) check on the progress of a sap flow study on these sheperd trees on the mine property. The study is being conducted to better understand the tree and how it will respond when used in rehabilitation of the mine.


INTRODUCTION

These two examples reflect a typical “Table of Contents” to give some indication as to the scope of a demolition plan that is influenced by the size of the operations. Table 1 relates to a very small demolition project, that typically will take place during the operational phase of a mine and be executed by the owner’s team with some specialist support from a demolition contractor. Table 2 on the other hand is an example of a final demolition plan for a large mining operation that typically will be executed and managed by an external contractor with sub contractors.

Table 1: Example of a simplified Table of Contents for a demolition plan.

TABLE OF CONTENTS

1 Project

1.1 Purpose of this document 1

1.1.1 Project background 1

1.2 Scope definition and management summary 2

1.2.1 Demolition strategies 2

1.2.2 Scope of work 2

1.2.3 Work, plant, equipment and services etc. excluded 3

1.2.4 Work, plant, equipment and services etc. included 3

1.3 Methodology 3

1.4 Stakeholders 4

1.5 High level overview of risk assessment 4

2 Organisation and Staffing 4

3 Health and Safety 4

3.1 Asbestos 5

3.2 Safety 7

4 Completion 7

5 Supporting Plans 7

5.1 Operational readiness plan 7



Table 2: Example of a detailed Table of Contents for a complex demolition project.

TABLE OF CONTENTS

Executive summary i

Document control ii

Abbreviations and acronyms iii

1. Introduction 1

1.1 Mine closure objectives 1

1.2 Scope of work for DEP 2

1.3 Integration with other closure work packages 3

2 Analysis of steady state closure and overall strategy for demolition execution 6

3 Demolition execution plan scope 8

3.1 Logistics management plan 9

3.2 Support management plan and contractor’s temporary facilities 11

3.3 Asset removals and salvage plan 13

3.4 Waste management plan 17

3.4.1 Off-site management of hazardous waste 17

3.4.2 On-site management of inert demolition waste and detritus 19

3.5 Demolition plan 21

3.5.1 Removal of major structures 21

3.5.2 Removal of minor structures 23

3.5.3 Removal of other items 24

3.6 Site restoration plan 25

3.6.1 Seal of mine openings 25

3.6.2 Soil cover and surface grading/scarification 26

3.6.3 Facilities for long term monitoring and revegetation maintenance 26

3.7 Engineering, procurement and construction management plan 27

3.7.1 Engineering 27

3.7.2 Procurement 28

3.7.3 Construction management 28

3.9 Excluded scope elements 32

4. Schedule management plan 33

4.1 Critical path construction schedule 33

4.2 Resource requirements 34

4.3 Dependencies related to excluded work areas and scope 35

5. Cost management plan 36

5.1 Basis of estimate 36

5.2 Cost estimate for DEP implementation 37

5.3 Risk management plan 38

5.3.1 Cost uncertainty 38

5.3.2 Allowances 41

5.3.3 Risk contingency 42

6. Stakeholder management plan 43

7. Environmental, health and safety stewardship monitoring plan 44

8. Conclusion 45


Kolomela Mine, South Africa.


INTRODUCTION

A Closure Maintenance and Management Plan (CMMP) is important to understand the management activities to ensure the rehabilitation areas are sustainable into the future. They must be aligned to the recreated post-mining land capabilities and identified land-uses. The will form an important part of the transfer agreement between the mine and the post-mining land-user facilitating lease relinquishment. This will ensure the land is adequately managed and reduces the risk of exposing the company to long-term management costs.

METHODOLOGY

The objective of rehabilitation management is for the area to be self-sustaining and resilient and to require no more management effort than surrounding areas with the same land-use. The most common rehabilitation management

issues are fire, weeds, feral animals, erosion, plant diseases, overgrazing and nutrient cycling. It is important these are addressed to ensure the overall rehabilitation objectives of safe, stable, non-polluting and self-sustaining rehabilitation are met.

Rehabilitation areas should be monitored at an early stage and results compared to success criteria. Areas that do not meet the defined success criteria should have maintenance activities completed to facilitate achievement of the success criteria. Areas requiring maintenance should be addressed as soon as possible and re-monitored until success criteria are met.

A CMMP should clearly detail the known residual risks, limitations to land-use capability and the potential for latent environmental risks. The CMMP should explain the risk causes, already implemented actions, proposed preventative actions as well as future corrective actions

EXAMPLE 19: CLOSURE MAINTENANCE AND MANAGEMENT PLAN



should the residual risk event occur. The proposed methodology for developing a CMMP is outlined below and an example is provided. The CMMP should:• Highlight sensitive areas that require specific activities

excluded (i.e. no grazing on tailings or waste dumps with hostile materials encapsulated).

• Weed/invasive/alien species control programmes to be implemented along with a species map.

• Mitigating erosion and managing sedimentation of waterways or drains.

• Introduction of stock (domestic or game) and stocking rates.

• Fertiliser rates, type and timing to optimize pasture productivity.

• Fencing and stock water points maintenance requirements.• Re-seeding or re-planting.• Feral animal control requirements.• Fire regimes (if appropriate) to be implemented to

integrate into the surrounding landscape.

• An indication of where infrastructure can and cannot be constructed (such as over unconsolidated spoils).

• Alleviating compaction where vegetation establishment and growth is limited.

• Identification of areas where groundwater contamination from the rehabilitated mine site may be present as well as any modelling of plume movement and exclusion points for new groundwater abstraction points.

• Any specific and agreed commitments to other stakeholders that the new land-user will need to maintain (i.e. potable water supply, access to monitoring points).

The approach should be to demonstrate, through identification of success criteria and associated monitoring, that rehabilitated areas with the desired composition and structure are self-sustaining non-polluting and resilient. Maintenance and management work must be budgeted and implemented with planned versus actual works tracked and reported.


Helena Tailings Dam facility in South Africa, showing reinforcement work being done.


EXAMPLE 20: SUGGESTED STRUCTURE FOR ANGLO AMERICAN CLOSURE PLANS


Kolomela Mine Process plant, South Africa.


INTRODUCTION

The ‘Table of Contents’ structure for closure plans is an expansion from the structure proposed in the MCT (Version 2, 2013) to reflect the additional work that was undertaken as part of the ICPS process as well as to accommodate existing and anticipated future regulatory requirements.

PROPOSED STRUCTURE

The overall closure plan itself should be short and to the point (Main report of between 50 and 80 pages) and only contain the outcomes (summary) of the detailed closure planning steps and deliverables. The rest of the supporting documentation that were developed as part of the process, should form part of an appendix.

The main closure plan report should contain the following:

EXECUTIVE SUMMARY

The executive summary must be short (< 5 pages) and describe the closure plan by focusing on the following five key topics namely the closure vision, final land-use plan (map), summary of the closure liability, residual risk profile, key gaps and associated action plan to close the gaps.

1.0 Introduction Include a high-level description of the mine, current

situation and requirements linked to the development of the closure plan.

2.0 Baseline: 2.1 Physical and biophysical context. 2.2 Social and economic context. 2.3 Closure conditions and commitments (including

legal and regulatory requirements).3.0 Influencing Factors: 3.1 Benchmark and outline closure options (based

on residual risk). 3.2 Identification of the final land-use plan . 3.3 Closure vision, policies and KPI’s.4.0 Closure Planning: 4.1 Overview of the LoAP. 4.2 Identified integrated planning opportunities. 4.3 Concurrent rehabilitation strategy and ongoing

implementation. 4.4 Closure objectives. 4.5 Closure criteria. 4.6 Success criteria. 4.7 Proposed monitoring programme.5.0 Closure risk assessment (with and without closure

criteria). Only include the profile of the “unacceptable” residual

risks (full risk assessment to be included as an appendix).

6.0 Closure gap analysis:



Only include a summary of the key gaps (full gap analysis will be included as an appendix).

7.0 MAP Only include a summary of the key actions from the

various sources (e.g. gap analysis, risk assessment, opportunities), RACI and key milestones (full master action plan with RACI and schedule will be included as an appendix).

8.0 I&AP consultation (Closure Stakeholder Engagement Plan).

Only include the most significant stakeholder issues/concerns and anticipated needs based on current and historical engagements, including anticipated future needs based on social trending.

9.0 Closure Costs:

9.1 Closure cost estimate (drawings, assumptions – Basis of Estimate).

Only include the a description of the key assumptions, the main categories of the basis of estimate and the summary sheets of the estimate (the full cost estimate, with all the drawings and detailed basis of estimate will be included as an appendix).

9.2 Closure cash flow and schedule: Only include the high level cashflow and level 1

schedule with key milestones (the detailed cashflow and level 3 schedule will be included as an appendix).

10.0 Closure maintenance and management plans Include the summary of the plan in this section with

the full plan as an appendix.11.0 Proposed closure organisational structure

General view of the Barro Alto laboratory, Brasil.


Include the organisational structure in this section, describing the decision philosophy related to for example, owner execution vs. contractor execution of some or all of the closure plan activities.

12.0 Audit and reporting: Describe the process that will be followed to ensure

the identified gaps are closed and the closure plan is improved to the required level of confidence. Also

describe the governance and reporting process that will be followed.

13.0 Review process: Describe the ongoing review and continuous

improvement process that will be followed as well as any requirements for additional resources and or budget.

APPENDICES

All the detailed reports and analysis that were used in developing the closure plan (e.g. detailed drawings and cost estimate, gap analysis spreadsheet, risk register, RACI, MAP) should be included as appendices.


Kolomela Mine Leeufontein pit operations in South Africa.


ACRONYMSAA Anglo American

AMD Acid Mine Drainage

ARD Acid Residue Deposit

BoE Basis of Estimate

BU Business Unit

BU CEO Business Unit Chief Executive Officer

CBO Community Based Organisation

CEO Chief Executive Officer

CEP Community Engagement Plan

CMMP Closure Maintenance and Management Plan

COP Code of Practice

CRD Coard Residue Deposit

CSI Corporate Social Investment

DAFF Department of Agriculture, Forestry and Fisheries

DENC Department of Environment and Nature Conservation

DWS Department of Water and Sanitation

DWS WUL DWS water use licence

EAP Employment Assessment Process

EIA Environmental Impact Assessment

EMP Environmental Management Programme

EMPr Environmental Management Programme Report

EMS Environmental Management System

ESHIA Environmental, Social and Health Impact

ESHMP Environmental, Social and Health Management Plan

FIFO Fly In and Fly Out or First In is First Out

FOS Factor of Safety

FRD Fine Residue Deposit

FS Feasibility Study

GIS Geographic Information System

GM General Manager

HIA Health Impact Assessment

HMP Health Management Plan

HRA Health Risk Assessment

HR Human Resources

I&APs Interested and Affected Parties

ICMM International Council on Mining and Metals

ICPS Integrated Closure Planning System

ID Investment Development or Identifications

IDM Investment Development Model

IDP Individual Development Plan

IT Information Technology

IUCN International Union for Conservation of Nature

KPI Key Performance Indicator

KT Kepner Tregoe

LED Local Economic Development

LGA Land Grid Array

LoA Life of Asset

LoAP Life of Asset Planning

MAP Master Action Plan

MCP Mine Closure Planning

MCT Mine Closure Toolbox

Met Coal Metallurgical Coal

MoA Memorandum of Agreement

MPRDA Mineral, Petroleum and Resources Development Act

MRA Mineral Resources Act

NEMA National Environmental Management Act

NEMBA National Environmental Management Biodiversity Act

NGO Non-Governmental Organisation

OEL Occupational Exposure Limit

P&G Primary and General

PEF Public Engagement Forum

PEP Project Execution Plan

PFM Project Management Framework

PFS Pre-Feasibility Study

PMF Project Management Framework

PMLs Post-mining Land-uses

QRA Quantitative Risk Assessment

RACI Responsible, Accountable, Consulted and Informed

SEAT Social Economic Assessment Toolbox

SED Socio-Economic Development

SEP Stakeholder Engagement Plan

SHE Safety Health and Environment

SHIRA Social and Human Rights Impact and Risk Analysis

SHR Safety and Human Resources

SIA Social Impact Assessment

SIOM Sishen Iron Ore Mine

SLP Social and Labour Plan

SMART Specific, Measurable, Attributable, Realistic and Time-framed

SMP Social Management Plan

SPON COM Spontaneous Combustion

SPV Special Purpose Vehicle

SoW Scope of Work

SWOT Strengths, Weaknesses, Opportunities and Threats

TSF Tailing Storage Facility

WBS Work Breakdown Schedule

WRD Waste Rock Deposit

ZoI Zone of Influence



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Helena Tailings Dam facility, South Africa.


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MINE CLOSURE TOOLBOX/media/Files/A/... · achieve its burning ambition and purpose, the closure team must deliver value through integrated, risk and opportunities based closure planning