Occ. Hygiene and Env. Health

Environmental health programs focus on preventative health issues such as prevention of silicosis, noise-induced-hearing loss and radiation exposure where uranium-bearing ore is encountered. Hygiene management programs are in place at all operations to ensure compliance with the MHSA.

FIU supports the DME’s objective to eradicate new cases of silicosis after December 2013. Using present diagnostic techniques, the goal is to ensure no new cases of silicosis occur among previously unexposed individuals. Previously unexposed individuals are defined as individuals unexposed prior to 2008, and are equivalent to those entering the industry for the first time in 2008.

In the fight to eliminate noise-induced hearing loss, the DME has decreed that after December 2008, the hearing conservation program implemented by the industry must ensure that there is no deterioration in hearing greater than 10% amongst occupationally exposed individuals.

By December 2013, the total noise emitted by all equipment installed in any workplace must not exceed a sound pressure level of 110 dB(A). Steps to comply with this directive include the muffling of rock drills, the silencing of underground fans as well as an employee-awareness program on the importance of hearing conservation.

Radiation exposure should be as low as reasonably achievable and is reported on in line with the requirements from the Certificate of Registration (CoR) and the associated standard procedures approved by the NNR.

Radiation protection programs are in place at MWS and the EMC to ensure compliance with CoR regulations around workforce exposure to radiation.

During 2009/10, extensive monitoring and surveillance of the workforce was conducted. The maximum total effective dose limit for occupationally exposed persons is 100 mSv over a period of five years, but may not exceed 50 mSv in any given year. These limits were not exceeded at any of the operations in the year under review. At MWS, the average annual effective dose was 0,8 mSv and the highest effective dose 4,7 mSv which accrued to a worker on the MWS Buffels Dam 4 reclamation site.

At the EMC a radiation protection task team was established to ensure the implementation of the requirements of the CoR and to determine radiation exposure rates at the mine.

One of the team’s first tasks will be to complete an air quality index survey as per the requirements of the MHSA with special attention on ventilation systems. The sealing of historical ventilating air leakage on the Upper and Middle Elsburg sections resulted in a more air being available at the working places. There is however a major sealing program initiated in the shaft pillar area to ensure the air reaches the working areas.

A simulation of the underground ventilation circuit is being completed currently. The installation of booster fans in the Middle Elsburg section will ensure sufficient air being supplied to the Northern extremities of the Middle Elsburg section – expected completion by the end of June 2010.

Exposure to the public

MWS has completed a radiological worker safety assessment as well as a public safety assessment for the proposed new Tailings Storage Facility (TSF). The assessment included external gamma, exposure to long-lived alpha emitting radionuclides (dust) and short-lived alpha emitting radionuclides (radon and daughter isotopes), as well as the potential ingestion pathway. The reports were submitted to the NNR in March 2010 and NNR approval is awaited. Ezulwini Mine’s public radiation hazard assessment report is expected to be complete in September 2010, to allow for testing in the dry and wet seasons.

EMC’s public radiation hazard assessment report is expected to be complete in September 2010, to allow for testing in the dry and wet seasons.

Both operations have implemented policies specifically designed to protect woman in their reproductive phase, pregnant and breast-feeding women from undue exposure to radiation.

MWS has implemented a policy in collaboration with Fraser Alexander Tailings not to allow women of childbearing age to work in the areas where elevated radioactivity concentrations are evident as at the reclamation sites.

Occupational hygiene measurements

Monthly reports monitoring employees’ exposure to noise and airborne pollutants, in particular silica dust, are generated by the appointed occupational hygienist and in instances of where regulatory limits are exceeded, immediate remedial action is taken.

At MWS, occupational hygiene measurements to date, including gravimetric dust sampling results, indicate that the operation is compliant with the requirements of the MHSA. Occupational hygiene audits were conducted by external consultants and with few exceptions the MWS plant was found to be within the limits for dust, noise, illumination, management of confined space, gases and temperature levels.

Where non-conformances were encountered and noted, immediate rectification action was taken as reflected in the follow up audits and quarterly reports to the DMR.

The EMC is in the process of completing an Air Quality Index analysis to determine the toxins present in the underground ventilating air. Currently gravimetric sampling at these operations only looks at the total respirable mass of airborne particles and is analyzed for silica dust only.

Occupational Medical Surveillance

An occupational medical surveillance program is in place at all operations as required by the MHSA and the NNR.

At MWS, this service is currently being rendered by Duff Scott Hospital, a private hospital which is wholly-owned by Simmer and Jack Mines, Limited, and includes:

Entrance medicals for all new employees to determine baseline health conditions and as required by the MWS Minimum Standard of Fitness Code of Practice;
Exit medicals for any and all employees leaving the service of the company;
Annual medicals; and
Occupational medical surveillance of registered radiation workers (occupationally exposed persons) as required in terms of Section 2.4.1 of MWS Certificate of Registration CoR 30.

At the EMC, a new medical centre was commissioned during the period of review to provide these services.

Going forward, the appointed medical practitioners will be required to report on rates of occupational lung disease including TB, and provides statistics on HIV-AIDS related illnesses, including those employees who are on anti-retrovirals and those who have taken advantage of Voluntary Counselling and Testing, which will be offered as part of the Employee Wellness programs that are expected to be introduced at each operation in F2010. These initiatives form part of the development of a worker well-being index and will include the introduction of exit medical examinations for contractors and a program to link occupational hygiene exposure to medical surveillance records.

Natural Environment

The necessary environmental policies are in place for all operations and are reviewed annually.

The necessary persons have been appointed to oversee and implement the policies and a financial base has been established to effectively manage the system as it relates to SHE issues at all operations. The radiation protection function at both FIU’s operations is run in accordance with the requirements of ISO 9001 and this is being extended to incorporate environmental, health and safety aspects.

A Safety, Health, Environmental and Quality Control (SHEQ) management manual has been prepared and has been expanded and implemented to ensure effective quality management within the SHEQ sphere. Full ISO 9000 and ISO 14000 accreditation is expected to take a minimum of 24 months although formal certification for MWS is not envisaged at this stage.

External Environmental audits are conducted at all operations as per the Environmental Management Program (EMP) relevant to the specific operation. At the MWS operation Environmental Audits are conducted annually, compliant with MPRDA Regulation 55. The next audit is scheduled for August 2010.

The EMC annual environmental performance assessment has been completed and the following graph has the results to the overall performance.

Environment Effects Register (EER)

The impact of each operation on the natural environment is monitored in terms of the respective Environmental Impact Assessments (EIA). These impacts are regularly monitored as part of each operation’s risk management program and each operation is expected to generate a separate EER during F2010, in compliance with the principles of ISO 14001.

No material incidents as they pertained to the environment were recorded at the MWS the operations in 2010.

Environmental Permitting

The mining right application for MWS was granted by the DMR on 15 July 2009. The final date for the execution of the right has not yet been determined. The right will be executed and the commensurate Environmental Management Programme approved as soon as MWS has satisfied the requirements of the DMR insofar as the Quantum of Financial Provision for the final closure of the operation is concerned. The requirements pertaining to financial provision are linked to the Simmer and Jack Buffelsfontein Gold Mine operation (insofar as liability for the Buffels/Harties slimes dams are concerned) and is expected to be finalized concurrent with the conversion of the Buffelsfontein Old Order Mining Right.

An Environmental Authorization for the MWS operation was issued by the NW Department of Agriculture, Conservation, Environment and Rural Development (NWDACERD) on 21 July 2009. Appeals against the issuing of the authorization were lodged by a number of parties and following a suspension of the authorization, pending the appeal process, the authorization was officially withdrawn in November of 2009. Having satisfied all of the concerns raised by the respective appellants, and following a protracted engagement process which included legal counsel, the authorization was reinstated in February 2010 for the site originally earmarked for the new Tailings Storage Facility. Construction of the TSF will commence as soon as the requisite water use license has been issued.

The amended Water Use License application to cover the MWS expansion requirements, was completed and submitted to the Department of Water and Environment (DWAE) in January 2009.

The application was subjected to a protracted and extended review process which included the provision of additional information as requested by DWAE. All indications are that the Water Use License will be issued by DWAE National Office by end June of 2010. Notification has been received from the dam safety office of DWAE that they are satisfied with the design of the TSF.

The Certificate of Registration (CoR) application was amended in September of 2009 to include the new TSF and pipeline connection route as well as the Harties/Buffels slimes dams and the Chemwes plant extension.

There are currently no outstanding issues on the CoR but a number of safety assessments will need to be conducted as soon as the uranium plant is commissioned. The required work has been scheduled and will be completed within the timelines agreed to with the NNR.

The Certificate of Registration (CoR) application for the Ezulwini Mining Company was approved by the NNR during August 2008. Ezulwini expects its Water Use Licence to be awarded imminently, having been submitted in 2006.

At EMC, the EMP is being amended to include the Gold and Uranium Metallurgical Process facilities as built, together with the inclusion of the emergency power generating plant. This document is to be lodged at the DMR by end of June 2010.

Water management

FIU is mindful of the need to recycle and reduce water usage wherever possible. New Order Water Use Licences for all operations have been prepared and submitted for all operations.

The principal source of water for the MWS operation is the Margaret Water Company (MWC). MWS is currently utilizing water pumped from underground at Margaret Shaft by the Margaret Water Company as well as water from the local municipal water purification works and water from Buffelsfontein Mine.

The objective of MWC is to ensure that measures are taken to prevent pollution of both ground and surface water resources in the vicinity of the mining activities, as well as to ensure the safe continuation of mining activities in the Klerksdorp, Orkney, Stilfontein and Hartebeesfontein (KOSH) area, and sustainable remediation and closure after such activities have ceased. This also involves overcoming the potentially disastrous effects of decanted deep-level mine water in the KOSH area. The KOSH area is a complex maze of diverse underground water compartments intersected by an assortment of faults, aquifers, dykes and strata conduits. To achieve its objective, MWC currently pumps 17,400 megalitres per annum of water from underground.

At the EMC, physical monitoring continued across the entire Gemsbokfontein East and West dolomitic compartments as part of the State Technical Committee requirements for dewatering of these compartments. Water sampling is done regularly and the old order water permit is being used in setting limits for release of water into the environment. A water management team has been established to revisit the water management infrastructure rehabilitation plan for the underground workings, with specific emphasis on the reduction of sulphate concentration in decant water, by harvesting extraneous water on the upper levels of the Mine.

An Integrated Water and Waste Management Plan is being generated by EMC as part of the WUL application and is due for completion by end June 2010.

Disposal of solid waste

Waste from the Mine Waste Solutions operation is being addressed in terms of the MWS Waste Management Program which is aligned with the National Waste Policy. Hazardous wastes such as hydrocarbons are disposed of via reputable waste recyclers and discrete and homogenous radioactive process wastes are handled in accordance with requirements of the NNR.

Decontamination facilities at the EMC are being put in place to handle surface contaminated equipment for disposal and repair. A plan to design an approved industrial waste disposal facility at EMC is been initiated and it is expected that this facility will be approved by the authorities by the end of 2010.

Residue deposits

No slime spills have been reported on the slurry feed (from Buffelsfontein dams) and residue pipelines (to MWS No.5 dam) since May 2008. Daily patrols are conducted on residue and slurry feed pipeline routes and the findings recorded in a logbook. This system has virtually eliminated the risk of slimes spills on the residue and slurry feedlines. However a total of six (6) slime spills occurred at the 1A and 1B reclamation pump stations during the year. All of the spills have been cleaned up and additional paddocks and paddock walls have been established at the pump station and along the eastern perimeter of the Buffels complex to mitigate the impact of spills.

At the EMC, the tailings dam is being commissioned in sectors to accept the full deposition volumes.

Ground water and ground stability

In 2009, heavy summer rainfall caused around 28 sinkholes to occur in the Buffelsfontein mine complex and around the MWS plant extension area. These sinkholes were associated with the malfunction of the penstock decant system and were backfilled using waste rock with a mix of fine and coarse material, with natural soil and clay material employed for final contouring and shaping. The backfilling was completed and final contouring undertaken by May 2009. As a result of this intervention, sinkholes were reduced to a total of only three that occurred in January 2010 following heavy rains in the area.

MWS has assumed statutory liability for the Buffels/Harties slimes dams, following the deed of sale between BGM, Simmers and Chemwes (Pty) Limited. A detailed evaluation of the condition and status of all the dams was prepared in 2009 with a view to improving pollution control facilities, including the construction of a system of paddock and cross walls to effectively manage significant rainfall events by retaining water on top of the dam instead of allowing decant via the current flawed penstock system. This has been completed for the Buffels No 5 dam and work is currently underway at the Harties complex.

EMC has been monitoring ground stability since the deed of sale came into effect in 2006/7, no sink holes have been detected by the footpatrols.

Emergency preparedness and disaster management

Emergency procedures are in place at all operations for major risks in accordance with the National and International Disaster Management Act.

Specific issues include disaster management plans around the pumping of some 65 megalitres of water per day at the EMC in order to keep the workings dry as well as ammonia storage for both the MWS and Ezulweni operations . Emergency storage compartments are in place to store water in the event of a power failure.

Air pollution

At MWS the only current discharge to atmosphere is associated with the smoke stack at the current plant smelt house. A program to monitor all stack emissions has been implemented as soon as the new plant is commissioned.

A detailed dust monitoring program incorporating the Buffels / Harties dams was implemented post year end in April 2009. It comprises the installation of 26 single and four directional dust buckets interspaced over the entire area, from Ellaton in the West to the extremity of the Buffels complex in the East as well as south of the Vaal River. Additionally, the design and construction of the berms and cross walls on top of the dams as well as ridge ploughing and selective vegetation has had a positive effect on dust control.

The rehabilitation of the tailings dam (to make it operational) at EMC is largely complete, with all slopes having being grassed. The slimes from the plants are being discharged on top of the dam which helps to control dust.

Fauna and Flora

Alien Plant Control

Removal of alien vegetation is a legal requirement in terms of Sections 72 – 74 of the Biodiversity Act, 2004. At MWS, the five-year program to eradicate alien plants and address propagation and re-growth is currently confined to the areas north and south of the N12 covering an extent of some 2 400 hectares.

At EMC, a program to control and eradicate alien vegetation is in the process of being instituted.

Closure

At MWS, the focus has been on the backfilling of the borrow pits to the north and west of the gold plant extension in an environmentally-responsible manner. This is now largely complete with the exception of a small area to the northwest adjacent to the N12, where topsoil and compaction material is currently still being sourced.

The rehabilitation of the footprint area of the MWS No. 2 dam will be completed as soon as the new tailings facility is completed and commissioned. A detailed assessment of all outstanding work on the footprint has been conducted and a commensurate scope of work prepared. The proposed rehabilitation progamme will also include the cleanup of the spillage control area to the east of the reclamation pump station at MWS No. 2 dam.

EMC has identified 3 areas that will be rehabilitated during the operational phase of the mine and partial closure applications will be lodged after completion of the rehabilitation. The time frame for this action is planned to start in September 2010 for completion by February 2011.

Financial liability and provision

As per Regulation 54(2) of the MPRDA, the rehabilitation and closure liability for all operations was re-assessed in the period under review.

At MWS in 2008, the rehabilitation and closure liability was assessed (in 2008 Rand terms) at R318.4 million as per the DMR Guideline. This includes rehabilitation and closure liabilities associated with the Buffelsfontein tailings dams, the proposed new deposition site as well as the upgraded and extended metallurgical plant. The detailed quantum estimate was incorporated into the EMP document submitted to the DMR on November 14, 2008, which has since been accepted by the DMR.

However, the DMR, in November of 2009, requested MWS to re-assess the environmental liability and to exclude the Buffels/Harties assets. The Quantum Assessment was adjusted accordingly and submitted to the DMR for approval on 11 December 2009. It was approved by the DMR in February 2010. As soon as the Buffelsfontein Old Order Mining Right is converted, and the Buffels/Harties slimes dams ceded to MWS, the Quantum Assessment will be re-adjusted to reflect this liability transfer to MWS.

At the EMC, the total environmental liability is R 61,089,111 as at March 2010. The value of the principle sum in the approved Environmental Trust is R 34,002,224 therefore the deficit between the liability and the principle sum in the Trust is covered by a bank guarantee (R 27,086,887).

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