11.   ENVIRONMENTAL MANAGEMENT

11.19.1  

Compliance

Components of environmental legislation in Namibia are fragmented into different Acts and there is a lack of overarching legislation. In addition, several of the South African laws in practice at the time of Namibia’s independence in 1990, remain in force by virtue of Article 14 of the Constitution of Namibia however these are often outdated and not necessarily enforced. Much of Namibian legislation is in draft form and there is uncertainty if and when several of the draft Acts will be promulgated. The Environmental Management Bill is due to be promulgated in 2005 and will legislate the requirements of Namibia’s Environmental Assessment Policy. Uncertainty exists with authorities requirements and how the current legislation is administrated. As the legislation is fragmented and not formalised, compliance is difficult to assess. However, Rosh Pinah has begun to develop an environmental management plan. As part of this process, the mine has undertaken an “environmental audit of current and past mining practice to determine impact with the objective to design an environmental management plan”.

11.19.2  

Environmental issues

Waste rock dumps stability: Waste rock is disposed on two dumps. These dumps have been constructed by end tipping, resulting in slopes at the natural angle of repose, which are inherently unstable, leading to slumping in various areas. The low rainfall conditions have resulted in a lack of a rehabilitation strategy for the waste rock dumps, as vegetation growth is limited. SRK is of the opinion, that the dumps are a safety hazard and as a minimum will have to be cut back to reduce the slope angle with a liability of about ZAR10 – 20m.

Potential for acid rock drainage: No information is available on the geochemistry of the waste rock dumps, however, considering that the ore that is mined is sulfidic there is a high probability that some sulfides are present in the waste rock. This could potentially lead to the production of acid rock drainage but the potential is probably minimal given the low rainfall in the area. Furthermore, no signs of acid seep were observed at the base of the dumps. SRK, therefore, does not consider ARD a significant risk.

Water contamination at the tailings dam: A single tailings dam, divided into a number of compartments, is present at the mine. Testing has not yet been undertaken to determine sulfide concentrations in the tails, however, relatively low concentrations would be expected as the bulk of the sulfides would be removed during mineral processing. Acidity is therefore not expected to be a significant problem at the tailings dam. Salinity is unlikely to be a significant problem at the tailings dam, as background water quality is poor. Geochemical testing did indicate that the dam is enriched with the heavy metals mercury, zinc, cobalt, barium, lead, selenium and cobalt. Initial groundwater monitoring has indicated the presence of a heavy metal plume below the tailings dam, moving in a southerly direction, however the lack of receptors below the dam would imply that exposure to this contamination is minimal. Therefore, the risk associated with this plume is also considered minimal and SRK is of the opinion that at closure it is unlikely that any groundwater remediation measures would be required around the tailings dam.

Informal settlement sewage: A seep below the toilet facilities of the informal settlement was observed. It is suspected that this is generated by sewage effluent from the toilet facilities daylighting on surface. While the informal settlement is not strictly the mine’s responsibility, the mine constructed the toilets on mine property. Therefore, the mine may be required to implement some form of remedial measures once the informal settlement is removed. To cover this, SRK proposes a sensitivity contingency of ZAR1 – 1.5m.

Hazardous material handling: Historically, hydrocarbon housekeeping management has been poor, resulting in soil contamination around the workshops over an area of approximately 1Ha. It is reported that hydrocarbons have not been detected in the groundwater. It is SRK’s opinion that this lack of hydrocarbons in the groundwater is an artefact of the lack of appropriately placed boreholes, rather than an indicator that the groundwater has not been contaminated. However, the lack of receptors downgradient minimises the risk. Asbestos has been used extensively as a construction material on the mine with offices, shops and the school constructed from asbestos. The pipeline from the Orange River to the mine (300 mm OD) is also constructed from asbestos. At closure, disposal could represent a significant cost. The mine believes that all PCB contaminated oils have been removed however, they are still awaiting receipt of the final clearance certificate. Used oil is collected for recycling.

Waste disposal: All other waste from the mine, including grease, oil filters, redundant plastic and rubber components from the plant and vehicles and domestic rubbish generated by the mine, is transported to the mines waste site on the waste rock dump where it is burned on a daily basis. Closure of this dump represents a liability as it is expected that the mine will be required to ensure that seepage from the area is minimised. It is SRK’s opinion that this could cost in the region of ZAR1 – 4m.

Saline water management: Given the low rainfall of the region, storm water management is not an issue, however, discharge from the aquifers results in an accumulation of water underground. Underground water is stored in an underground sump and recycled back into the mining process. More recently and prior to the construction of the underground sump, the underground water was pumped to the tailings dam where it was allowed to evaporate. In addition, water within the plant that has becomes too saline from recycling is bled to the thickener for disposal on the tailings dam. Historically, underground water and excess plant water was discharged from the mine into the veld or it was used for irrigation of the golf course. This may have led to soil contamination due to the naturally high groundwater salinity and the salinity arising from the plant, however no monitoring has been undertaken to assess the situation. SRK are of the opinion that an investigation into potential contamination is required (estimated cost of ZAR0.25m)

Land degradation: Land degradation has primarily been caused by the construction of the waste rock dumps and the tailings dam. The construction of a small open pit at the foot of the mountain has also resulted in some land degradation. As there is little natural vegetation in the area, the presence of un-vegetated waste rock dumps does not have a significant visual impact, as the waste rock blends into the surrounding landscape.

Air emissions: The tailings dam is a significant source of dust and has resulted in numerous complaints from the local community. Limited remediation is possible with vegetation establishment difficult. SRK is therefore of the opinion that the practicable closure strategy will be to rock clad the dump. Operationally, the mine has applied Dust-a-Cide to the northern slope, adjacent to the village as a means of dust control. The mine also attempts to operate the tailings dam so that the horizontal surfaces are kept wet. It is reported that although some dust is generated from the waste rock dumps, the volumes generated are insignificant. The mine undertakes regular dust monitoring.

Community relationships: The “Sand Hotel” is a safety risk, as it encroaches on the waste rock dump. Furthermore, the presence of the community is reportedly unsettling the residents of the hostel, as the noise from the community is excessive. Rosh Pinah and Skorpion have apparently come to an agreement with the community that each mine will provide a ZAR1m to relocate the settlement to a flat area to the west of the Rosh Pinah town. It is reported by the mine that the community are eager to move.

Social issues: Should the mine close in five years’ time, the implication is that the work force will be made redundant. This will impact on the mine workers and their dependants as there is little employment opportunity in the region. It is expected that at closure, there will be a significant departure of people from the town. This would impact significantly on the town’s economy. The mine is however, of the opinion that the area could be developed for tourism and are investigating, on an ad hoc basis, potential tourism opportunities. Lack of planned and appropriate management of these social issues could result in a significant risk to Exxaro’s reputation. The modified focus exploration strategy aims to increase mine life to beyond ten years to ensure the sustainability of Rosh Pinah mine’s workforce and that of the region.

Closure planning and costing: There is currently no closure plan in place but it is understood that a closure risk assessment is to be undertaken shortly. It is assumed this will be followed by the development of a closure plan. The mine has estimated its liability for immediate closure to be ZAR45m. Of this ZAR45m, ZAR7m is allocated to demolition costs and ZAR38m is allocated to restoration costs. It is SRK’s opinion that this estimate is insufficient to cover potential remediation at closure, particularly if the slimes dams require rock cladding and the asbestos on site requires disposal as hazardous material. It is estimated that the shortfall is some ZAR45m. It must also be noted that the incorporation of the mine into a national park may result in stringent closure requirements being applied to the mine. At this stage it is not possible to quantify this risk, as the requirements of the Park has not been defined. As there have been no legislative requirements in Namibia requiring the mine to establish a closure fund, no closure capital is available. There is however, a provision of ZAR35m in Mine budget to address closure.