Closure Plan For The Closure Of The Driekop 253 Kt (Driekop Area A .

CLOSURE PLAN FOR THE CLOSURE OF THEDRIEKOP 253 KT (DRIEKOP AREA A)PROSPECTING RIGHTDriekop 253KTJANUARY 2020SUBMITTED FOR APPLICATION FOR A CLOSURE CERTIFICATE IN TERMS OF SECTION43 OF THE MPRDAName of applicant: Marula Platinum (Pty) LtdTel no: (013) 214-6040Fax no: (013) 214-6022Postal address: PO Box 1496, Steelpoort, 1133Physical address: Winnarshoek Stand No. 118, Driekop 1129File reference number DMR: LP30/5/1/1/2/293PRSLR Project No.: 710.09002.00016Report No.: 1Revision No.: DMR SubmissionJanuary 2020

Marula Platinum (Pty) LtdClosure Plan for Driekop 253KT (Driekop Area A) PR Closure710.09002.00016January 2020DOCUMENT INFORMATIONTitleClosure Plan for the Closure of the Driekop 253 KT (Driekop Area A) Prospecting RightApplicantMarula Platinum (Pty) LtdProject ManagerCaitlin HirdProject Manager e-mailchird@slrconsulting.comAuthority Reference NoLP30/5/1/1/2/293PRSLR Project No710.09002.00016KeywordsDriekop 253KT, Driekop Area A, Marula, Prospecting, Closure, LimpopoReport DateJanuary 2020Report StatusFor DMR SubmissionREPORT COMPILATIONREPORT COMPILED BY: Caitlin Hird Caitlin HirdEnvironmental Assessment PractitionerREPORT REVIEWED BY: Alex Pheiffer Alex PheifferReviewer (PrSciNat)BASIS OF REPORTThis document has been prepared by an SLR Group company with reasonable skill, care and diligence, and taking account of the manpower, timescalesand resources devoted to it by agreement with Marula Platinum (Pty) Ltd for part or all of the services it has been appointed to carry out. It is subject tothe terms and conditions of that appointment.SLR shall not be liable for the use of or reliance on any information, advice, recommendations and opinions in this document for any purpose by anyperson other than Marula Platinum (Pty) Ltd. Reliance may be granted to a third party only in the event that SLR and the third party have executed areliance agreement or collateral warranty.Information reported herein may be based on the interpretation of public domain data collected by SLR, and/or information supplied by Marula Platinum(Pty) Ltd and/or its other advisors and associates. These data have been accepted in good faith as being accurate and valid.SLR disclaims any responsibility to Marula Platinum (Pty) Ltd and others in respect of any matters outside the agreed scope of the work.The copyright and intellectual property in all drawings, reports, specifications, bills of quantities, calculations and other information set out in this reportremain vested in SLR unless the terms of appointment state otherwise.This document may contain information of a specialised and/or highly technical nature and readers are advised to seek clarification on any elementswhich may be unclear to it. Information, advice, recommendations and opinions in this document should only be relied upon in the context of the wholedocument and any documents referenced explicitly herein and should then only be used within the context of the appointment.i

Marula Platinum (Pty) LtdClosure Plan for Driekop 253KT (Driekop Area A) PR Closure710.09002.00016January 2020CLOSURE PLAN FOR THE CLOSURE OF THE DRIEKOP 253 KT (DRIEKOP AREAA) PROSPECTING RIGHTEXECUTIVE SUMMARYPROJECT BACKGROUNDMarula Platinum (Pty) Ltd (Marula) owns and operates a platinum mine approximately 35 km north west ofBurgersfort in the Greater Tubatse Local Municipality and Sekhukhune District Municipality in the Limpopo Province.Marula holds a Prospecting Right under DMR Ref No: LP30/5/1/1/2/293 PR for platinum group metals (PGMs), silverore, gold ore, nickel ore, cobalt, sulphur (in pyrite), copper ore, and chrome ore in the UG2 reef on a portion of thefarm Driekop 253KT (Driekop Area A) located to the south of the operational mine. A copy of this prospecting right isincluded in Appendix A. This prospecting right was formerly held by Rustenburg Platinum Mines (RPM) and wasceded and transferred to Marula in July 2014. At the same time as RPM’s prospecting right was transferred toMarula, Marula’s converted mining right (which was limited to the Merensky Reef) was amended to include the UG2reef. This prospecting right area falls within the area over which Marula holds a converted mining right (number42/2008) under DMR Ref No: LP30/5/2/2/1/61 MR for PGMs located in the Merensky Reef. The regional and localsettings are illustrated in Figure 1 and Figure 2 respectively.Since Marula’s converted mining right covers PGMs within both the UG2 and Merensky reefs, the prospecting rightfor the UG2 reef is no longer required. Marula is now applying to close the prospecting right (DMR Ref No:LP30/5/1/1/2/293 PR).SLR Consulting (Africa) (Pty) Ltd (SLR), an independent firm of environmental assessment practitioners (EAP), hasbeen appointed by Marula to manage the environmental authorisation processes associated with the closure of theDriekop Area A prospecting right.SUMMARY OF AUTHORISATION REQUIREMENTSPrior to the closure of the prospecting right, a Closure Certificate from the DMR in terms of Section 43(4) of theMineral and Petroleum Resources Development Act, 2002 (Act No. 28 of 2002) is required.STAKEHOLDER ENGAGEMENTAs part of this process, interested and affected parties (IAPs) were given the opportunity to have input into theclosure application process. Further information regarding the stakeholder engagement undertaken is included inSection 15.2 and Appendix C. It should be noted that no comments relating to the closure of the prospecting rightwere received.IMPACTS AND MANAGEMENT ACTIONSThis section provides a summary of the assessment of the potential impacts. The potential impacts/risks have beenassessed against the prospecting right closure objective which is to return any areas disturbed by prospectingactivities to the pre-project state. Given that decommissioning and rehabilitation of each drill site was undertakenonce drilling of each site was completed, this assessment focusses on potential residual impacts/risks as a result ofthe rehabilitation phase only. The assessment of the unmitigated scenario takes into account that decommissioningand rehabilitation activities have already been implemented in line with the management measures outlined in theapproved prospecting EMPr, therefore the assessment of the mitigated scenario is where additional mitigationmeasures are deemed necessary. The table below provides a summary of the potential impacts in no particularorder of importance.i

Marula Platinum (Pty) LtdClosure Plan for Driekop 253KT (Driekop Area A) PR Closure710.09002.00016January 2020AspectPotential impactReference to mitigationmeasuresFlora andFaunaLoss of flora and fauna throughlack of or poor rehabilitationLoss of pre-prospecting landuses through lack of or poorrehabilitationChange in the visual landscapeof the areaNo additional mitigationrequired.No additional mitigationrequired.No additional mitigationrequired.InsignificantNegative and positive socioeconomic impactsNo additional mitigationrequired.Very LowLand-useVisualSocioeconomicSignificance (Unmitigated)(takes into account measuresimplemented as per approved EMPr)Very LowVery LowENVIRONMENTAL STATEMENTThe assessment of the project indicates that the potential for negative residual impacts/risks is very low toinsignificant. It follows that no additional active mitigation is required. When the DMR undertakes its site visit, it isrecommended that a site inspection of the seven drill sites (which could not be located at the time of the finalperformance assessment) is undertaken to ground-truth the expected rehabilitation status.ii

Marula Platinum (Pty) LtdClosure Plan for Driekop 253KT (Driekop Area A) PR Closure710.09002.00016January 2020CONTENTSEXECUTIVE SUMMARY .IPROJECT BACKGROUND . ISUMMARY OF AUTHORISATION REQUIREMENTS . ISTAKEHOLDER ENGAGEMENT . IIMPACTS AND MANAGEMENT ACTIONS. IENVIRONMENTAL STATEMENT. II11.11.21.31.4INTRODUCTION . 1PROJECT OVERVIEW . 1PURPOSE OF THIS REPORT . 1SUMMARY OF AUTHORISATION REQUIREMENTS . 1TERMS OF REFERENCE . 1STAKEHOLDER ENGAGEMENT . 2233.13.23.3LOCATION OF APPLICATION AREA . 2DETAILS OF THE APPLICANT AND THE EAP . 6APPLICANT DETAILS. 6DETAILS OF THE EAP WHO PREPARED THE REPORT . 6EXPERTISE OF THE EAP . 6456MOTIVATION FOR THE CLOSURE OF THE PROSPECTING RIGHT . 7CLOSURE OBJECTIVES . 7PLAN OF AREA UNDER CLOSURE . 877.17.2REGULATORY REQUIREMENTS AND CONDITIONS FOR CLOSURE . 10LEGISLATIVE CONSIDERATION IN THE PREPARATION OF THE REPORT . 10LEGISLATIVE CLOSURE REPORT CONTENT REQUIREMENTS . 1188.18.291010.110.2111212.112.21314ENVIRONMENTAL RISK ASSESSMENT AND IDENTIFIED RESIDUAL AND LATENT IMPACTS . 13BASELINE ENVIRONMENT AFFECTED BY THE PROPOSED ACTIVITY . 13ENVIRONMENTAL IMPACTS AND RISKS . 17PROGRESSIVE REHABILITATION UNDERTAKEN . 25METHODS TO DECOMMISSION PROSPECTING COMPONENTS AND STRATEGIES TO AVOID, MINIMISE ANDMANAGE RESIDUAL OR LATENT IMPACTS . 26DECOMMISSIONING AND REHABILITATION OF DISTURBED AREAS . 26STRATEGIES TO AVOID, MINIMISE AND MANAGE RESIDUAL OR LATENT IMPACTS. 27LONG TERM MAINTENANCE AND MANAGEMENT . 28PROPOSED CLOSURE COST AND FINANCIAL PROVISION . 29CALCULATE AND STATE THE QUANTUM OF THE FINANCIAL PROVISION . 29CONFIRMATION THAT THE FINANCIAL PROVISION WILL BE PROVIDED . 30FINAL AND FUTURE LAND USE . 31ASSUMPTIONS, UNCERTAINTIES, LIMITATIONS AND GAPS IN KNOWLEDGE . 321515.115.215.316171819CONSULTATION RECORD . 33DETAILS OF THE PUBLIC PARTICIPATION PROCESS FOLLOWED . 33PUBLIC PARTICIPATION PROCESS UNDERTAKEN TO DATE . 33REVIEW OF THE CLOSURE PLAN. 33TECHNICAL APPENDICES . 34CONCLUSIONS AND RECOMMENDATIONS . 35UNDERTAKING . 36REFERENCES . 37iii

Marula Platinum (Pty) LtdClosure Plan for Driekop 253KT (Driekop Area A) PR Closure710.09002.00016January 2020APPENDICESAPPENDIX A: EXISTING AUTHORISATION (PROSPECTING RIGHT) AND LETTER OF ABANDONMENT SUBMITTED JULY2015 .AAPPENDIX B: EAP CURRICULUM VITAE AND REGISTRATION . BAPPENDIX C: STAKEHOLDER ENGAGEMENT . CAPPENDIX D: RISK ASSESSMENT CRITERIA . DAPPENDIX E: DETAILED FINAL AUDIT PROCEDURE AND EMP COMMITMENTS . EAPPENDIX F: CLOSURE FORM P (SUBMITTED 15 JULY 2015). FLIST OF TABLESTABLE 1: DESCRIPTION OF THE PROPERTY . 2TABLE 2: APPLICANT DETAILS . 6TABLE 3: DETAILS OF THE PROJECT TEAM . 6TABLE 4: LEGAL FRAMEWORK . 10TABLE 5: REQUIREMENTS FOR APPLICATION FOR CLOSURE CERTIFICATE. 11TABLE 6: GUIDELINE AND POLICY FRAMEWORK . 11TABLE 7: CONTENTS OF THE CLOSURE PLAN . 11TABLE 8: LAND OWNERSHIP WITHIN AND IMMEDIATELY ADJACENT THE DRIEKOP AREA A PROSPECTING RIGHT AREA16TABLE 9: CURRENT CLOSURE AND REHABILIATATION COSTS . 29TABLE 10: PUBLIC PARTICIPATION PROCESS UNDERTAKEN AS PART OF THE CLOSURE PLAN REPORT . 33LIST OF FIGURESFIGURE 1: REGIONAL SETTING . 3FIGURE 2: LOCAL SETTING . 4FIGURE 3: LAYOUT OF DECOMMISSIONED PROSPECTING DRILL SITES . 5FIGURE 4: AREA UNDER CLOSURE (INCLUDING FINAL AND FUTURE LAND USE) . 9FIGURE 5: PHOTOGRAPHS OF DECOMMISSIONED DRILL SITES (DRILLED BETWEEN 2000 AND 2012) . 14iv

Marula Platinum (Pty) LtdClosure Plan for Driekop 253KT (Driekop Area A) PR Closure710.09002.00016January 2020ACRONYMS AND ABBREVIATIONSAcronym / AbbreviationDefinitionBEEBlack Economic EmpowermentBICBushveld Igneous ComplexBIDBackground Information DocumentDWSDepartment of Water and SanitationEAPEnvironmental Assessment PractitionerEIAEnvironmental Impact AssessmentEMPrEnvironmental Management ProgrammeGDARDGauteng Department of Agriculture & Rural DevelopmentGNRGovernment Notice RegulationI&APsInterested and Affected PartiesIBAsImportant Bird and Biodiversity AreasMPRDAMineral and Petroleum Resources Development ActNEMANational Environmental Management ActNWANational Water ActPGMsPlatinum Group MetalsRLSRustenburg Layered SuiteSACNASPSouth African Council for Natural Scientific ProfessionsSLRSLR Consulting (Africa) (Pty) Ltdv