Managing environmental impacts and opportunities
The nature of our business – mining and processing PGMs – creates an environmental impact. Our strategic commitment to operational excellence and ethical business practices require us to minimise the environmental footprint of our operations and, where necessary, mitigate or remediate our impacts. This is achieved by improving the efficiency with which we use input resources such as energy and water.
While the resource-intensive nature of the primary production of PGMs remains a challenge for the platinum industry, these metals play an important role in reducing pollutants through technologies including catalytic converters and fuel cells.
Access to sufficient potable water and a stable supply of electricity remain key challenges in South Africa. Lonmin continues to identify ways to reduce our reliance on Rand Water Board supplies and to optimise the efficient use of internal water sources. This is accomplished through the re-use of process water, abstraction of water from the Buffelspoort water scheme, treatment of effluent and implementation of water savings projects. The Company also transfers water from areas of surplus to areas of deficit, and follows a maintenance programme to ensure that pipelines are regularly inspected for leaks and repaired.
The administrative and financial burden of compliance with the rapidly evolving environmental regulatory framework is particularly challenging in the current cost-constrained industry environment.
Civil society increasingly focuses on holding companies to account regarding their impact on surrounding communities and the natural environment. Lonmin’s environmental strategy entrenches a proactive approach to managing our long-term impact that goes beyond the need to safeguard our licence to operate by ensuring compliance with relevant legislation. The social licence to operate is becoming an increasingly important matter for potential and existing investors, customers and other stakeholders. Regular engagements are critical to establish clear communication channels with stakeholders regarding our approach to monitoring and mitigating our environmental impacts.
Building strong partnerships with local government is crucial to effectively address the challenges faced in the communities in which we operate, including service delivery, supply of potable water, electricity and waste management.
Our strategic environmental pillars are aligned with our operational environmental pillars to meet the environmental management objectives at operational level:
- Maintaining our licence to operate – compliance with legal requirements
- Resource management and use – Integration of ISO 14001 systems across Lonmin
- Stakeholder relations
- Minimising environmental footprint and impact for sustainable closure – Implement projects to reduce our impact on the environment
This chapter provides an overview of our most important environmental risks and opportunities, how these are managed, monitored and, where possible, mitigated. Performance is reported under the environmental areas of water management, energy security and efficiency, waste management, air quality, climate change and biodiversity and land management. Most of the programmes discussed relate to our operations in the North West Province near Marikana, where the majority of our operations are located.
Engaging with stakeholders
A comprehensive database of interested and affected parties in and around Lonmin’s operations has been compiled and we regularly engage with local communities, including before significant projects are started, as required by various regulations. Environmental Impact Assessment (EIA) regulatory processes provide for community and public participation.
Concerns regarding environmental matters can be raised through formal environmental grievance mechanisms that are in place. A dedicated phone number (014 571 2088) at the Marikana operations is routed to the emergency and disaster management call centre, where complaints and concerns are captured into the complaints register and a community complaint form. The environmental register tracks actions to be taken in response to the complaint and provides for feedback on progress with an official response generated. At the Precious Metal Refinery (PMR) in Brakpan, an intercom box allows community members to register complaints where a similar process is followed.
Lonmin’s operations and communities share environmental resources, and engagements are held regularly to communicate with community members and understand their concerns. Environmental complaints are captured on the Lonmin ISO 14001 environmental management system, investigated and responded to according to the Lonmin system procedural requirements. Environmental open days were held in Marikana and at the PMR during the year, with a focus on sharing knowledge on environmental management. Community members were encouraged to discuss their views on Lonmin’s environmental performance and the challenges they face in their respective areas. These open days were attended by employees and a range of external stakeholders including government, communities, interested parties and NGOs.
Government and regulators
Government sets environmental regulatory standards; compliance is monitored to achieve equitable access to natural resources and the responsible management of the mining industry’s direct and indirect environmental impacts. Mining and other activities in South Africa are regulated by the Department of Mineral Resources (DMR), Department of Water and Sanitation (DWS) and Department of Environmental Affairs (DEA) which oversee the industry and the extraction of the country’s mineral and natural resources. Regular formal engagements with regulators align expectations and outcomes, and create an enabling environment for sharing of best practices and enabling the “co-factor” (co-operation, collaboration) to be realised.
Industry bodies and associations
The Company works closely with industry bodies and business associations, including the South African Chamber of Mines and the National Business Institute (NBI) so that our position on environmental matters is represented.
We participate in numerous water forums and associations, including those forums held with Rustenburg Local Municipality and Magalies Water on all water-related matters. Discussion points included water demand management initiatives by the mines and municipalities, and solutions to water supply in the short and medium term.
Risks and opportunities
The sustainability risks and opportunities related to the environment are identified below, with references to information regarding their management and mitigation. The risk management approach is discussed here of this report and in the Annual Report and Accounts 2016.
Utilities – Access to secure energy and water as well as the optimal use of the input resources are critical for mining operations
The higher than inflation tariff-based increases in electricity and the Company’s inability to reduce this cost any further, have impacted the operating costs of Company operations. A stable electricity environment, in terms of pricing, is critical in ensuring our long-term sustainability. Water utilisation has also been challenging, both from an infrastructure point of view as well as availability. Capacity deterioration within local municipalities is also adding to this challenge. The establishment of informal settlements resulted in communities requesting water and electricity supply as a basic need and keeps adding to the burden of local municipalities and industries for service delivery.
Supply constraints in respect of energy or water could impact upon our ability to operate effectively and meet our production targets. Furthermore, cost increases in respect of these utilities impact our margins. Water availability is becoming a critical component for any business to survive and still remains a basic human need.
Opportunities and mitigation
Ongoing implementation of the electricity conservation programme as well as water optimisation through demand management. An integrated water management plan for Lonmin has been developed with the goal to reduce reliance on Rand Water as far as possible, within the operations, and to maximise the recovery and re-use of all other sources of water. Longer-term plans to treat some streams of these alternative sources to potable level to make the business more independent of Rand Water. Explore further opportunity to supply communities out of such streams. As part of ensuring optimal electricity usage, Lonmin is a member of the Eskom Energy Intensive User Group (EIUG), and conducts monthly and daily electricity consumption and reporting. Additional initiatives to ensure optimal usage is the electricity conservation programme and loadshedding contractual agreements to manage supply side constraints. As part of ensuring appropriate continuity during an outage, the Company has implemented risk-based scenario planning based on available Eskom capacity.
From a water optimisation perspective, the Company has implemented water conservation and demand management initiatives. The process as to how water is being monitored and managed is aligned with how power is being managed in the business.
Increasing environmental regulatory requirements, legislation and amendments1
Increasing environmental legislation for mining and processing requires careful understanding and management to ensure compliance and avoid unnecessary costs. Various regulatory requirements must be complied with, and it is critical that these are understood and that appropriate measures are implemented to ensure compliance.
Opportunities and mitigation
Proactive management of our environmental obligations demonstrates our corporate citizenship agenda, builds our relationships with communities and regulators, and helps us to retain our legal and social licences to operate.
|1||This risk is not part of Lonmin’s principal risks, but is important in the context of our environment management.|
Accountability and governance
The Board is ultimately accountable for the Company’s environmental performance through the Safety, Health and Environment (SHE) Committee, and the Executive Committee (Exco), supported by senior management at corporate and operational levels. The Exco has established a SHE sub-committee, which reviews SHE performance quarterly to identify critical concerns and opportunities, and to monitor operational safety, health and environmental performance.
Our environmental department is responsible for strategic direction in terms of environmental management and compliance, and monitors environmental performance. Line management is accountable for operational environmental compliance, supported by the environmental department. We take a precautionary approach to environmental management, aiming for compliance and continual improvement. Risks relating to sustainability, including environmental impacts, are incorporated into the Company’s corporate risk registers. Reviews of these risks and their associated management plans are conducted by the relevant operational and management teams, and the results of these reviews are presented to the SHE and Risk Committees of the Board.
Lonmin’s Safety and Sustainable Development Policy and the ISO 14001 system procedures define the Company’s approach to environmental stewardship.
Our ISO 14001 environmental management system (EMS) is well managed and we maintained our certification through annual third-party verification. The ISO 14001 EMS is a self-regulatory tool that promotes the minimisation and management of potential environmental impacts. A range of internal and external audits are conducted to monitor and verify the integrity of the EMS and the Company’s overall environmental performance. These include, among others, quarterly internal key performance indicator (KPI) audits, external EMP performance assessments, water use licence audits, Mining Charter audits, internal and external ISO 14001 audits, and environmental legal compliance audits.
As part of continuous improvement, an additional external audit was conducted to verify the internal rating system of environmental incidents against the Lonmin ISO 14001 system procedures, as well as benchmarking with other industries. All actual level 3 and above incident ratings were verified and samples were taken of the lower-level incidents that were audited against the Lonmin procedures.
A range of internal environmental indicators and targets are reported against every month to track performance on environmental matters. Reports are provided monthly to the operations, Exco and the Board, and to the Board SHE Committees, which meets quarterly to review the Company’s performance on SHE matters.
Our focus on proactive engagements with important stakeholder groups including communities, regulators and internal stakeholders has strengthened relationships, emphasised the critical importance of environmental compliance and improved the Company’s ability to secure approvals timeously.
External policies, frameworks and regulations
The primary acts that regulate Lonmin’s environmental footprint/activities are the Mineral and Petroleum Resources Development Act, No 28 of 2002 (MPRDA), the National Environmental Management Act, No 107 of 1998 (NEMA), and the National Water Act, No 36 of 1998 (NWA), with numerous other relevant legislation and associated regulations. The requirements of our various mining rights include an EMP approved by the DMR.
Lonmin’s approach to environmental responsibility is underpinned by:
- the International Council on Mining and Metals’ (ICMM) 10 Principles of sustainable development (Principle 6: Seek continual improvement of environmental performance and Principle 7: Contribute to biodiversity and integrated approaches to land use planning) and aligned to the mandatory requirements of the ICMM position statements for climate change and protective areas; and
- the UNGC (Principle 7: Businesses should support a precautionary approach to environmental challenges; Principle 8: Undertake initiatives to promote greater environmental responsibility; and Principle 9: Encourage the development and diffusion of environmentally friendly technologies).
We submitted our 10th consecutive CDP (formerly the Carbon Disclosure Project) report and our third CDP water disclosure report – the second water disclosure report for public disclosure.
We had zero environmental incidents above a level 3 and five level 3 environmental incidents during 2016. Level 3 environmental incidents are those incidents that have a moderate impact on the environment, but are reversible within the lifetime of the operations. All of these incidents were related to water and reported to the regulating authorities.
Authority inspections were undertaken on our atmospheric emission licence (AEL) at the PMR and the water use licence for the Marikana operations. The review of the AEL was undertaken by the Ekurhuleni metropolitan municipality and the inspection of the Marikana water use licence was conducted by the DWS.
Approach and performance
The following section discusses the specific approach and the 2016 performance for each material environmental area at Lonmin. These include:
- Water management
- Energy security and efficiency
- Waste management
- Air quality
- Climate change
- Biodiversity and land management
South Africa is a water scarce country from a resource availability perspective. This is exacerbated by various challenges impacting the availability of this important and critical resource including climate change, ageing and poorly maintained infrastructure, illegal water connections, and the current drought conditions.
The drought conditions in South Africa necessitated water restrictions across the country. We support the South African government in its call for preserving and using this resource efficiently. We take a proactive approach to the management and efficient utilisation of water at our operations. Targets to reduce water consumption have been set for all business units and are tracked on a continuous basis. Deviations are investigated immediately and captured within the relevant management systems.
Demand and pressure on bulk water infrastructure in the Greater Lonmin Community (GLC) continues to increase with the growth in neighbouring towns and settlements. Demand for water is forecast to exceed current resources. With only a few remaining large-scale water resource development opportunities available, future delivery and supply of water is likely to be uncertain and costly.
Water-related risks are assessed and mitigated as part of the structured, multi-disciplinary risk assessment process, which covers all operations and some key suppliers, including the Rand Water utility as our primary water supplier. Water risks are also considered by the Audit and Risk Committee of the Board.
We distribute water through a water infrastructure network that covers a distance of approximately 30 kilometres. Water is distributed to and from the Company’s various mining and processing areas. We also act as a water services intermediary by distributing water to surrounding communities.
Our water use licence amendment application for the Marikana operations was issued in June 2016. The amended licence has provided new opportunities for us to access water from additional sources to provide greater flexibility and access to water in respect of seasonal variations. These sources include the abstraction from the anthropogenic aquifers in our backfilled opencast pits. The abstraction from this resource contributes to the improvement of water quality. External audits are conducted on compliance with the water use licences. The Parliamentary Portfolio Committee on Water and Sanitation undertook an oversight visit to the North West Province. As part of the agenda, a site visit was undertaken to the Lonmin operations in addition to Lonmin presenting on Water Conservation and Demand Management Strategy.
Anthropogenic aquifer systems or aquifer storage and recharge (ASR) has a wide range of applications, most commonly the storage of surplus water in the subsurface. Water that would otherwise be lost through evaporation from dams and rivers and/or spillages during high-flow events can be stored and used during times of limited availability. Water filters into the subsurface aquifers through infiltration basins or by injection boreholes, enabling the user to store surplus water.
The South African government recognises ASR as a method to enhance aquifer conditions and developed the Artificial Recharge Strategy to introduce ASR as a water management option and provides guidance on how it can be applied in South African conditions (Department of Water Affairs, 2007).
The Water Conservation and Demand Management Strategy aims to secure access to sufficient water to supply our operations and sustain our life of business plan, optimise freshwater consumption and use process water more efficiently, and minimise contamination of ground and surface water resources around our operations, ultimately to reduce our closure liabilities. Various projects have been identified to meet the objectives with a total implementation budget of around R342 million across the project timeframes to be invested.
Lonmin’s integrated water balance simulates scenarios and risk assessments to inform decisions about our water use, manage the effectiveness of the strategy, and standardise best water practices throughout the business. The integrated water balance assists in determining the best ways to transfer water from water-positive areas to water-deﬁcit areas within the operations, increases understanding of water ﬂows, improves efficiency, investigates opportunities, reduces costs, and decreases potable water consumption.
Water use is regulated by the National Water Act and regulations, the Water Services Act and the National Environmental Management Act and regulations, and through approved water use licences. Our EMS manages and monitors water use and includes groundwater modelling, surface and groundwater monitoring, toxicity testing and bio-monitoring. Due to the nature of the ore and the manner in which it is processed, PGM mining and processing activities do not generate acid mine drainage.
Water use and quality monitoring is conducted on a monthly basis and reported to management. Efficiency targets are assigned to business units in terms of potable water use. Should water consumption or water quality exceedances be identified, the ISO 14001 system procedure is followed in terms of reporting, investigating and developing or reviewing action plans to address these exceedances. With the drought intensifying throughout 2016, a water protocol management code was developed using principles applied in the management of electrical energy.
Consumption of Rand Water Board water is measured across the property, trended and reported daily. Levels at containment facilities are tracked. The tracking system is designed to flag and call for a certain water conservation stage. Stages initiate alternative supply sources established through the Integrated Water Management Plan (IWMP) to balance the system.
- Participating in the CDP water disclosure project for the third year, the second time for public disclosure.
- Strengthened relationships with key stakeholders, including the DWS.
- Developing infrastructure in support of the Water Conservation and Demand Management Strategy.
- Obtained approval for the revised water use licence for the Marikana operations, which authorises alternative sources of water for use. The licence further authorises key water uses required for the planned bulk tailings treatment project.
- Savings of Rand Water realised of up to 600m3/day at certain concentrators.
Lonmin’s fresh water sources include Rand Water and the Buffelspoort Dam for our Marikana operations, in addition to Rand Water for the PMR. Our Limpopo operations draw water from regional well fields.
Our five-year target (to 30 September 2017) is to reduce our aggregate freshwater intake per unit of production by 15% from the 2012 baseline year. In 2016, against the 2012 baseline year, water efficiency improved by 13.0%; less water was used and production ounces delivered were higher, positively impacting our water efficiency.
The Marikana operations consume most of our freshwater profile, making up 93% (7,494,422m3) of our total freshwater consumption (8,043,792m3). Operational initiatives undertaken to reduce our freshwater footprint and improve on our re-use and recycling include the reduction of Rand Water intake at our concentrator processing plants. This was achieved by investing in relevant infrastructure to:
- direct appropriate grey water flows into these areas; and
- to install a filtration plant.
Savings of up to 600m3 of Rand Water per day at the areas of implementation have been realised. The completion of additional projects in 2017 has the opportunity to increase water saving to 1,300m3 per day.
Water recycling and reuse
Water reuse and recycling is optimised by the integrated water balance. The processing plants use a closed loop reticulation system to reduce and minimise water withdrawals. There are seven waste water sewage treatment plants at Lonmin’s Marikana operations from which final effluent is used for operational processes. Through the closed reticulation system, 15.4 million m3 (2015: 13.4 million m3) of water was recycled and reused during 2016.
Groundwater and surface water quality is monitored at numerous boreholes and surface monitoring points, against the water use licence parameters.
Water levels at high-risk containment facilities are monitored and communicated to users through a weekly environmental “robot” alert on a green-orange-red scale. In addition, an internal water demand management procedure was developed with various stages of water restrictions. Critical water levels trigger mitigation measures to eliminate environmental discharges (where water levels are high), and prompt the necessary steps to support stable operations (where water levels are low). Preventive and management procedures are in place for discharges.
Where a water discharge occurs, it is reported to the DWS. Water samples are taken at source and, if the discharge entered a stream, upstream and downstream from a discharge to determine the impacts on water quality. Internally, a flash report is generated and, based on our risk ranking tables, an incident rating is reported based on a combination of volume, quality, impact on the environment and legal requirements. Discharges are investigated and action plans put in place to reduce discharges. The theft of piping, pumps and high-density polyethylene (HDPE) liners on our properties continues to pose a serious challenge to effective water management. Corrective actions that we are implementing to address discharges include the automation of water reticulation circuits, installation of water level indicators, additional security measures and desilting of dams.
Four containment facilities were relined according to required specifications.
Five level three water discharge incidents occurred during 2016 (2015: three). All of these incidents have been
reported to the regulating authorities. According to our sampling, the environmental impact of these discharges, due to the quality of the water, was limited, and none of these discharges had an impact on biodiversity, sensitive or protected water bodies.
Water and the community
Lonmin and the communities access potable water from the same source, and local municipalities use our bulk infrastructure to distribute water to the communities of Segwaelane, Oustad, Wonderkop, Marikana and Mooinooi. The Company acts as an intermediary in this role.
We work closely with local municipalities to find solutions for community water sources, including enabling and aligning local economic development in support of water infrastructure creation. We also support local municipalities and communities through the treatment of five megalitres (Ml) of waste water from communities per day at waste water treatment plants and tanker discharge points. Furthermore, we provide maintenance support to the municipality services and will remove blockages when notified. As part of our environmental management inspections on our infrastructure, we also inspect municipal infrastructure related to waste water treatment.
Water recycling and reuse
|1||Water efficiency is consumption of freshwater per PGMoz produced (m3 per PGMoz).|
|2||To evaluate the reuse and recycling figures, the use of a simulation is undertaken. The dynamic model is frequently updated and refined to align to production, and actual water consumption once it becomes available. The model was refined as part of continuous improvement in 2015.|
Energy security and efficiency
Electricity forms the majority of Lonmin’s energy consumption and is used in many critical applications, including powering surface and underground ventilation fans, dewatering pumps, material handling equipment, processing plants and winder plants. Our current mining operations do not need refrigeration plants.
Given that electricity accounts for approximately 7.5% of our annual expenditure, including capital expenditure, energy efficiency initiatives are important for cost containment and business viability, and to minimise greenhouse gas (GHG) emissions. The expected above-inflation increases in electricity prices and the impact of a likely carbon tax are built into the life of business plan as part of our strategy to improve cost efficiencies.
Lonmin’s energy management strategy is based on South African National Standards (SANS) 50001. While electricity supply stabilised during the year, we continue to communicate regularly with Eskom regarding agreed demand levels, power interruptions and supply constraints. Production disruptions can be minimised where we receive advance warning of electricity supply interruptions through shutting down concentrator streams so that mining production and smelter power can be kept stable.
Electricity consumption targets are established per business area and reported on monthly, with specific energy efficiency projects launched to reduce electricity consumption. During 2016, a project was launched with the objective of reducing electrical consumption by optimising the compressed air reticulation systems through the means of an operational control room. This has, for 2016, realised a saving of 12,400MWh, approximately R10 million and 12,400 tonnes in indirect CO2 emissions. The project will remain in place going into 2017 and we are investigating the expansion thereof to additional areas of consumption.
Energy efficiency projects are centrally managed, tracked and reported and there is a capital budget in place to pursue strategic new technologies and various research and development initiatives.
Energy consumption and efficiency
We report energy efficiency performance in terms of MWh per PGMoz produced and in kWh per tonne mined. Energy consumed decreased to 6,344.2TJ, and from the 2012 baseline we have seen a decrease of 1.3%. The most significant decrease in energy consumption was a 51% reduction in the use of diesel consumption (512.0TJ in 2015 to 249.0TJ in 2016). However, our energy efficiency compared to the 2012 baseline has regressed by 7.6%. The deterioration of energy efficiency was driven by production and energy usage.
- Total energy consumption for the year was 6,344.2TJ (2015: 6,783.0TJ), a decrease of 6.4% year-on-year.
- Energy efficiency improved year-on-year by 5.8% from 4.68GJ/PGMoz to 4.4GJ/PGMoz.
- Indirect energy (electricity) consumption was 1,571,620MWh, or 5,657.0TJ (2015: 5,835.8TJ).
- Electricity efficiency per kWh/tonnes hoisted was 153.0 (2015: 143.7).
- Direct energy: 691TJ (2015: 950TJ).
Our 30 September 2017 target set in 2012, is to improve our aggregate energy consumption per unit of production by 8% from the baseline. Our ability to achieve this target has been affected by the planned shaft closures, which impact economies of scale efficiencies. These targets are being reviewed in light of the change in our production profile and supply constraints.
Energy efficiency projects
During 2016, Lonmin energy efficiency projects included:
- optimising the compressed air reticulation systems through the implementation of a focused energy control room for these systems; and
- tracking the performance of our rollover projects including lighting efficiency roll-out and 45kW energy efficiency underground fans.
We continue to investigate the viability of various innovative energy efficiency projects. The fuel cell project at the Precious Metals Refinery was not viable in its current form, and is being reviewed. Another project investigated was a biomass project that proved unfeasible. While environmental approval has been received, we are still awaiting the necessary approvals to commence construction of the solar plant from the municipality and NERSA.
|1||Conversion: one terajoule = 1,000 Gigajoules; one Megawatt = 0.0036 terajoules (2006 IPCC Guidelines for national Greenhouse Gas Inventories, Volume 2 Energy, Chapter 1 Introduction)|
Lonmin is committed to minimising the waste generated by its operations. Mining, processing and refining of metals generate extensive amounts of general and hazardous waste that must be properly managed to avoid impacts on the natural environment and surrounding communities. Our governance planning and management programmes aim to prevent and reduce waste generation and facilitates alignment to procedures in order to prevent, reduce, and recycle wherever possible.
The Lonmin Waste Management Standard defines our approach to waste management in the business to support compliance and reduce the Company’s impact on the environment. The Standard has been integrated into key performance indicator (KPI) audits and standard operating procedures across all operations.
Waste that is treated and/or disposed of is handled in a responsible way, aligned with the duty of care principle and in accordance with relevant legislation. Wherever possible, we prioritise alternatives to disposal to landfill to reduce our environmental footprint, reduce resource utilisation, minimise costs and adhere to legal requirements. We continue to research clean technology alternatives and reuse, recycling and treatment opportunities relating to our waste streams in alignment with the prohibition of various waste streams to landfill. Apart from the effort to meet compliance, we have targets to track our disposal to landfill, which provide insight at all business levels to consider research and development into promoting this endeavour.
General waste includes domestic waste, packaging, garden waste, building and demolition waste, rubber, scrap metal, wood, food waste, tyres and business waste, which includes industrial plastic. Hazardous waste consists mainly of calcium sulphite (CaSO3) and various liquid waste streams, as well as smaller amounts of other hazardous waste streams, generated by the laboratories and operational sites. Mine residue deposits such as waste rock and tailings dams are now classified through the National Environmental Management: Waste Act, No 59 of 2008 (the Waste Act) GN634 Waste Classification and Management Regulations. These regulations have created, in some instances, unrealistic requirements as the design and management requirements have been conceived for the construction, development and management of general and hazardous waste landfills only. Engagements with the DEA, DWS and DMR through the Chamber of Mines have indicated that the DWS is open to a risk-based approach on a case-by-case basis where alternative mitigation solutions to barrier systems could achieve the same objectives as the prescribed composite liner barrier system. In addition, the DEA is considering excluding waste residue deposits from the definition of waste, and this is under review with the relevant regulatory authorities. Lonmin’s approach to managing this waste stream is discussed in the tailings section that follows.
Our draft IWMP, which is being reviewed, addresses the requirements of the Waste Act, regulations, norms and standards and relevant waste by-laws. The draft IWMP stipulates how waste is generated, handled and transported within the activities of collection, reuse, recycling, treatment and, ﬁnally, disposal. The alignment between the draft IWMP and procedural implementation is managed through the environmental management system, and cost savings are maximised by preventing double handling of waste and by segregating waste streams to maximise separation and recovery through reuse, recycling and refurbishment.
Internal and external audits measure compliance with waste management procedures, legislation and commitments as part of the annual ISO 14001 certification process. External compliance audits are also conducted on-site at permitted and licensed waste facilities. Third-party audits are conducted on external hazardous waste facilities to support compliance, and our adherence to the requirement of duty of care of our hazardous waste from cradle to cradle/grave.
A waste recycling and separation monitoring programme is in place at the processing operations, with quarterly KPI auditing conducted and penalties imposed to drive separation practices on site. A gap assessment on waste separation monitoring was conducted at the mining operations and quarterly auditing will be rolled out to the mining operations in the year ahead. E-waste has been stored and collected separately for a number of years, with the management of final consolidation for external collection being undertaken at the information management department. We are aligning our operations to meet the prohibition of certain waste streams to landfill and are rolling out a waste light bulb storage and collection system across the operations to collect all light bulbs for recycling of 100% of their components, which include mercury, e-waste and arsenic.
All waste stream classifications have been aligned with SANS 10234 and assessment procedures were implemented for waste disposal to landfill, as required by the Waste Classification and Management Regulations and associated norms and standards. Safety data sheets are being developed in terms of the waste classification process to provide information regarding responsible handling and management to transporters and end users. Waste procedures include different waste types, classification status and possible additional/alternative landfill sites should these be required.
Lonmin operates the only permitted general waste landfill in the Mooinooi/Marikana area, which provides strategically important disposal opportunities for communities, businesses and mining. To make sure that we have enough space to continue to use this strategically placed facility, we are undertaking the legal process to obtain a waste licence to extend the Mooinooi landfill facility to develop another 40 years of landfill capacity.
We spent over R157 million on waste management services at all of our operations in 2016. This includes the management and engineering services associated with our tailings and waste rock dumps.
- The Lonmin Waste Management Standard and standard operating procedures provide uniformity across all operations. Monthly inspections and gap assessments of KPI audits are undertaken to ensure adherence to the uniform procedures.
- The community waste swap shop at Wonderkop in the North West continues to be a highlight and received a commendation from the North West Provincial Department of Environment. The viability of a mobile waste swap shop, to reach a number of different community areas, is being investigated.
- The Tedcor waste collection system managed by Lonmin continues to provide a daily waste collection service to 11 communities around the Marikana operations, with disposal of this waste being catered for at the Lonmin Mooinooi Landfill.
General waste is separated at the operations into its component waste streams, which include domestic waste, mixed recyclables, wood, steel and rubber. Separation occurs on-site at plants, shafts, the smelter, refineries and offices. Waste for recycling and reuse is gathered at internal transfer areas such as the salvage yards (Marikana and Limpopo operations) or the waste storage area at the PMR. Independent waste contractors collect the waste from these areas for reuse and recycling, and disposal of the residual domestic waste stream.
General waste from the Marikana operation that cannot be reused, refurbished or recycled is disposed of at the permitted Mooinooi GSB landfill site at the Marikana operation. The other operations use the nearest permitted municipal landfill sites. Waste collection, internal and external waste transportation, and the operation of the Mooinooi landfill site are performed by specialist external waste contractors. Monthly meetings are held with these contractors to support compliance with contracts and legal requirements.
- 17,461 tonnes of general waste generated, an increase of 3% compared to 2015.
- 8,766 tonnes of general waste to landfill in 2016, 2% higher than 2015.
49.8% of general waste recycled or reused during the year:
- 5,620 tonnes recycled
- 2,956 tonnes reused
- 119 tonnes composted
Our 30 September 2017 target is to reduce general waste to landfill by 5%, from the 2012 baseline year. General waste to landfill decreased by 15% in 2016 compared to the 2012 baseline year. We are well under way to meet this target.
Hazardous waste streams from our operations include CaSO3, liquid acid and alkaline waste streams from the PMR. Our goal is to reduce hazardous waste generation through researching and developing cleaner technology mechanisms. This includes generating products rather than a waste stream, extracting water from the liquid waste stream through treatment technologies, or reusing and recycling hazardous waste materials to generate a usable product (for example, ash used to generate bricks).
CaSO3 is the most significant hazardous waste stream at Lonmin’s operations. It is produced as a residue from the capture and treatment of sulphur dioxide (SO2) emissions at the smelter. CaSO3 is disposed of at a licensed waste disposal site. We continue to research cleaner production technologies for the generation of CaSO3 that may lead to a product that can be generated rather than a waste stream from the capture and treatment process.
The specialised tailings dams on site hold an estimated 100,000 tonnes of CaSO3. These dams were temporarily decommissioned and capped in 2012, and a seepage drainage collection system was installed to capture residual seepage to prevent environmental impacts. We are investigating ways to rework and convert the CaSO3 in these dams into gypsum for the production of cement and other building products. Should this not prove technically and economically viable, responsible rehabilitation and closure of the CaSO3 dams will be incorporated into the permanent closure design at a later stage.
Acid and alkaline liquid waste streams are produced at the PMR. These are currently treated off-site and disposed to landfill. Our goal is to run a closed-loop system on these waste streams and we are researching ways to recycle the substantial amount of water in this waste back into the process plants to reduce municipal water use. From 2019, liquid waste to landfill will be prohibited and we are working with our waste contractors so that systems are in place to manage this requirement.
The environmental approval process for the PMR waste incinerator is under way. This is a closed-loop system project aims to ultimately achieve zero waste disposal to landfill. The project supports the application of the waste hierarchy principle promoting reduced disposal to landfill, to manage the loss of PGMs through waste streams going off-site and reduce the theft risk of PGMs.
76,492 tonnes of hazardous waste were generated, 18% less than in 2015, of which:
- 70,603 tonnes were sent to landfill and includes:
- 42,447 tonnes of CaSO3, a decrease of 27% on 2015;
- 26,221 tonnes of PMR waste effluent (liquid waste); and
- 1,941 tonnes of other hazardous waste.
- 5,888 tonnes were recycled and reused.
- 14.94 tonnes of hazardous waste were incinerated.
Our five-year target (to 30 September 2017) is to reduce hazardous waste to landfill by 5% off the 2012 baseline year. Hazardous waste to landfill showed a 10% decrease from the 2012 baseline year. An adequate best practical environmental option for diversion of hazardous waste from landfill is still pending and must be obtained and implemented to enable further reductions. The operation of the desulphurisation plant has improved, in conjunction with the decrease in production, as well as unforeseen plant shutdowns, which has resulted in a decrease in waste generation. Minimising both atmospheric emissions and hazardous waste generation targets will require substantial investment in new technology. This remains a challenge in the context of current financial constraints, and realising our target to reduce hazardous waste to landfill will be challenging.
Underground workings produce waste rock, which is non-ore bearing rock that is disposed of onto surface waste rock stockpiles, also known as mine residue stockpiles. Our opencast operations created overburden waste stockpiles, which are temporary facilities as the waste rock will be returned to the opencast pit during reinstatement and rehabilitation. There are three areas where we currently store opencast overburden waste stockpiles, including the U2 opencast pit, which is under care and maintenance, and the U10a and U10b pits, which are undergoing rehabilitation. There are nine waste rock dumps from underground mining at Lonmin’s Marikana operations and one at the Limpopo operation. We continue to identify viable uses for waste rock and are investigating feasible opportunities at the Marikana operations. Waste rock is also purchased for use in road construction by surrounding municipalities, provincial road agencies, the community for construction, and other private entities. The waste rock at Limpopo is reused by various entities, transported by a community-established transport company and taken to a crusher plant off-site. In this way, 25,475m3 of waste rock was reused, reducing our environmental liability and rehabilitation costs. In total, Lonmin generated 865kt of waste rock during 2016 (2015: 870.3kt), with the change mainly attributable to the orderly closure of some shafts.
Tailings from ore being milled at the concentrators are stored at six operational and five dormant above-ground tailings storage facilities (TSFs), all of which are lined with a thick layer of clay. Specific mandatory Codes of Practice guide how TSFs are managed and these are submitted to the DMR and the DWS’s Dam Safety Office. Codes of Practice for mine residue deposits and waste rock deposits are being updated for submission in 2017.
The TSFs are managed by specialist tailings contractors, who are on-site continuously to monitor TSF integrity, stability and functionality. All sites are grassed on perimeter walls and the dormant tailings dams are grassed on top to reduce dust generation and erosion. Tailings dams have irrigation systems to suppress dust, and chemical dust suppression is undertaken at TSF 6. Specialist engineers conduct quarterly inspections to monitor compliance with regulations.
10,222kt of tailings were generated (2015: 11,636kt) and deposited onto the six functional TSFs.
We continually face challenges with the fencing in of large facilities such as TSFs, as fencing structures are stolen or disassembled almost on a daily basis. This leaves Lonmin exposed to illegal access by people and animals, to the detriment of side slope rehabilitation and stability, theft of piping and equipment, and safety of people and animals. Our security department is investigating sustainable solutions to address this challenge. In June 2016, funding was secured for a bulk tailings treatment project that will add 29,000oz of low-cost platinum to production annually. The Eastern Platinum Tailings Dam will be hydraulically mined and the slurry processed to recover chromite and PGMs. We have applied for the required environmental authorisations to support the project.
An internal land contamination inventory of all areas potentially contaminated has been compiled. The assessment of contaminated areas is done on a phased approach, to determine and confirm whether these meet the requirements set out in Part 8 of the Waste Act. None of the areas assessed have shown contamination levels which require registration on the DEA’s contaminated land inventory.
A basic assessment application was submitted to the DEA in 2012 on the remediation of contaminated land at the PMR. Changes to the Waste Act invalidated the basic assessment submission before approval was finalised, and a remediation order was issued to Lonmin for this application. In response to the remediation order, our groundwater monitoring programme was updated and expanded, including the sinking of additional boreholes. All boreholes undergo the same sampling and analysis as required by the remediation order. A borehole census was undertaken in and around the PMR facility, with no sensitive receptors identified. Annual water quality monitoring reports are submitted to the DEA together with the required risk assessment. We continuously monitor water quality to determine trends and plume movement. To facilitate the requirements of the remediation order, Lonmin has completed detailed designs for the construction of two storm water containment dams, which will act as a barrier/capping system over the contaminated area to prevent any moisture from coming into contact with the source and to reduce the plume movement. The legal authorisation process to license these dams will start in 2017, together with detailed designs for the cut-off trench, which will be constructed to contain and allow for abstraction of seepage from the contaminated area.
Community waste management
We have various waste management initiatives in place to address the lack of service delivery, illegal dumping and littering in local communities. These include various clean-up campaigns and the Tedcor waste collection project, which collects waste from 11 different areas and resulted in 4,137 tonnes of waste being removed from local communities in the past year.
We are collaborating with the Rustenburg local municipality by providing land for the construction of a waste transfer station, which will support the local community through improved municipal service delivery and job creation. The project includes a waste buy-back centre, where the community can exchange valuable waste for cash/tokens for specific recyclables.
Our focus for 2017 will be on:
rolling out the waste bulb removal project;
finalising all material safety data sheets for waste streams;
changing operational systems in line with landfill assessments undertaken;
securing the waste licence for the Mooinooi landfill and developing the first new waste cell;
finalising trials around the PMR liquid waste treatment projects;
getting implementation ready for the remediation of contamination and upgrading of the stormwater management system at the PMR;
starting the Eastern Platinum (Proprietary) Limited (EPL) bulk tailings treatment project; and
preparing a waste rock reuse strategy for the Marikana operations.
Summary of waste streams
General waste materials recycled and re-used
Hazardous waste materials disposed to landfill, recycled and treated
|1||Incorrectly reported in 2015 as 277 tonnes, however, total hazardous waste to landfill was correctly reported.|
|2||In previous reports, metal liners with steel balls and concentrator scats and scraps were presented as separate line items. These amounts are not included in the total ferrous and non-ferrous scrap amount.|
|3||Incorrectly reported in 2015 as 12 tonnes.|
Lonmin acknowledges its responsibility to continuously manage and minimise the impact of emissions from our operations on ambient air quality. The National Environment Management: Air Quality Act, No 39 of 2004 (Air Quality Act) regulates air quality in South Africa through AELs and focuses on both source and impact on the ambient environment. Amendments to the five-year AELs at the smelter, base metals refinery, precious metals refinery and assay laboratory were approved during the year.
Lonmin’s Environmental Management Strategy addresses air quality management, and emissions to the atmosphere are minimised through the use of air pollution control equipment installed at our processing facilities. The EMPRs, incorporated into the ISO 14001 environmental management system, details air quality objectives and requirements including emissions and ambient air quality monitoring. Effective management and compliance are monitored through internal (quarterly KPI audits) and external audits, emissions verification audits, emissions reduction management plans and independent ISO 14001 certification audits.
A reduction of emissions by 2020 is required in terms of the Air Quality Act. This reduction is applicable to certain of the processing activities and the associated emissions. Achieving these standards will require significant capital investment to reduce emissions for the activity and pollutant. We have made good progress in the identification of requirements to enable our relevant processing activities to achieve the required reductions.
A workshop with a specific focus on air quality matters was held with the community in proximity to the PMR operations in Brakpan. This originated from the matters raised at the open day and other engagements. The workshop has set the platform for constructive engagement.
Sulphur dioxide (SO2), particulate matter (PM) and nitrogen dioxide (NOx) are the three pollutants regulated for the activities at our smelter. SO2 emissions are minimised through air pollution control equipment, including the completed fugitive capture system. The chemical process used to remove the SO2 generates CaSO3, which is a hazardous waste stream. We continue to research alternative technology that could generate a by-product rather than a waste stream.
Various chemicals are used in the processes at the PMR that extract and refine PGMs, which result in emission of chlorine gas (CL2), hydrochloric acid (HCl), nitrogen trihydrogen (NH3), PM, NOx and SO2. A series of air pollution control equipment is in place to scrub and control emissions of these gases prior to release to the main stack. Waste effluent generated from the scrubbers is stored in effluent tanks and removed by a service provider to a permitted landfill site. Various research and development projects are in place at the PMR to reduce effluent, beneficiate waste, and recover and recycle water back to the process.
The laboratory is regulated for particulate matter and lead. Scrubbing systems and baghouses are in place to minimise atmospheric emissions.
- SO2 emissions averaged 13.6 tonnes/day, an increase from 2015 due to test work being conducted on the optimisation of lime consumption, to reach AEL limits, as well as lower availability on the regeneration thickener.
- Yearly average SO2 concentration for the Sulphur Fixation Plant stack was 1,424 mg/Nm3 for the smelter operations.
Total suspended particles and emissions management
Total suspended particles (TSPs) arise from wind erosion of tailings dams, stack emissions, general mining activities such as drilling and blasting, materials handling, crushing and screening and from vehicle movement on paved and unpaved roads. Ambient dust levels are monitored in and around our operations. These results are submitted to our relevant authorities and communicated to our communities during the environmental open day held at Marikana.
TSP and dust suppression is managed through a range of measures. These include vegetation growth on the sidewalls of all tailings dams and surfaces of dormant tailings dams; chemical and water suppression on the surfaces of operational tailings dams and unpaved roads (grey water is recycled and reused in the process); sweeping of tarred/surfaced roads; and suppression systems at materials handling and crushing facilities. Theft of components from the irrigation systems on the tailings facilities is an ongoing challenge and a project is underway to look at additional measures to protect infrastructure. Particulate matter emissions at the various processing activities are minimised by the air pollution control equipment in place to reduce atmospheric emissions.
Other emissions, including those classified as ozone-depleting substances (ODS), persistent organic pollutants, volatile organic compounds and hazardous emissions are present at our operations, although to a much lesser extent. Our procurement systems select only new equipment that does not use ODS and a phase out plan has been initiated to remove equipment containing ODS.
The Waterberg-Bojanala Air Quality Plan was promulgated in December 2015, and Lonmin’s Marikana operations fall within this priority area. The Company participated in the multi-stakeholder team that developed the plan and is now participating in its execution. Lonmin also participates in the Highveld Priority Area multi-reference stakeholder group.
2015 was a decisive year in terms of the international climate change negotiations. In December 2015, the 21st Conference of the Parties (COP21) occurred in Paris with the outcome of the Paris Agreement, which takes a significant step towards a lower-carbon world. For the first time, virtually every country is required to reduce its GHG emissions and set out their plans to avert climate change. For the agreement to have legal force, it must be ratified by at least 55 of the 195 countries that adopted it and these countries must represent 55% of all global emissions. As at 4 September 2016, 25 countries including the USA and China had ratified the agreement, representing 40% of global emissions.
Climate change poses a range of risks and opportunities to the mining industry. Physical risks that could have an effect
on our operations include changes in weather patterns (i.e. extreme drought/flood/precipitation/temperature) which in turn may lead to water shortages, water discharges, increased operating costs, negative effects on local communities, impacts on the supply chain and biodiversity loss. The issue of water scarcity is likely to be further exacerbated by climate change and may lead to operational closures and downtime where water is not available in sufficient quantities to sustain the operations.
Regulatory risk from climate change relates to the pending implementation of the national carbon tax scheme in South Africa. Given the current draft policy documentation, Lonmin’s carbon tax projections range from approximately R84 million, increasing at 10% per annum until 2021. Our approach to managing this risk rests on improving our operational energy efficiencies and reviewing the business case behind renewable energy generation.
Lonmin’s business strategy addresses climate change through various mitigation and adaptation initiatives, including energy efficiency and energy security projects, seizing opportunities in PGM marketing, investment in fuel cell technology, feasible renewable energy to reduce emissions and water conservation and demand management. The main aspects of climate change are addressed in the operational excellence strategic pillar through resource management of energy efficiency initiatives that reduce energy requirements and subsequent emissions and water management through our Water Conservation and Demand Management Strategy.
Lonmin’s most signiﬁcant source of GHG emissions relates to the impact of our indirect emissions (scope 2) footprint arising from the use of electricity from a predominately coal‑based power generation system. Our primary GHG reduction initiatives are linked to our energy efficiency projects.
We participate in the CDP for both climate change and water, in which companies voluntarily disclose on the relevant matters. Targets are in place to reduce energy consumption and minimise GHG emissions. Lonmin’s primary product – PGMs – play an important role in managing GHG emissions through technologies such as catalytic converters and fuel cells.
- The carbon footprint for 2016 scope 1 and 2 was 1,660,484tCO2e.
- Emissions arising from electricity consumption comprise 95.9% of the total carbon footprint.
- GHG efficiency for 2016 is 1.146tCO2e/PGMoz.
Lonmin recognises that GHG emission reduction is necessary as part of the transition to a low-carbon economy. However, it is important that the risks arising from this transition are managed and implemented within a sustainable framework. We all agree that business as usual is not an option and that carbon pricing is a way to effect meaningful change.
The carbon tax regime as currently proposed will affect Lonmin both as a direct cost of carbon tax on scope 1 emissions and as a pass-through cost on scope 2 emissions (although National Treasury has stated that the scope 2 pass-through will be avoided in the first phase up to 2020). The Carbon Tax Bill was published in November 2015, and the comment period ended on 15 December 2015. Lonmin provided comment on the Bill through its association with the Chamber of Mines. The process of preparing the Company’s operations for mandatory GHG reporting aligned to South African guidelines is underway. Forecasts of the likely impact of a carbon tax are built into the life of business plan as part of our strategy to improve cost efficiencies.
Developments in carbon regulation
The world is inexorably moving towards GHG emissions reductions and is transitioning to a lower-carbon economy. COP21 in Paris in December 2015 is seen to have been a success and a very significant step towards this lower-carbon world.
In light of the strong agreement at COP21 on the need to reduce emissions, the inadequacy of current global plans to achieve an average 2°C maximum rise, and the realities of the South African economy’s high carbon intensity, it must be assumed that pressure to reduce emissions within South Africa can only increase.
There have been two important developments on emissions reduction in South Africa carbon taxation and carbon budgeting.
Firstly, National Treasury issued a discussion paper on carbon taxation in 2010. National Treasury originally proposed to implement a carbon tax on emissions from January 2015, but has since delayed this until 2017. Several issues are still being discussed with industry, such as the extent of tax-free allowances and the possibility of companies buying carbon offsets from other companies.
Secondly, the Department of Environmental Affairs (DEA), in its capacity as generator and custodian of the National Climate Change Response, has been developing proposals for carbon budgeting since mid-2013. The DEA’s approach is to allocate carbon budgets to individual companies and to require them to submit mitigation plans for future reductions (pollution prevention plans). The DEA will also require companies to report their GHG emissions on an annual basis.
Industry believes that many principles should be used to guide South Africa’s carbon policy. Some of the more important points are: the effectiveness of reduction initiatives – how much emissions will be reduced, with what certainty and at what cost; how costs are distributed across society and the economy as a whole; the impact on trade competitiveness of South African companies in relation to their competitors; and policy certainty.
Meeting reduction targets
Our target is to reduce scope 1 and 2 GHG emissions by 4% by 2017 from a 2012 baseline year. In 2016, absolute GHG tonnes of CO2 increased by 5.9% against the 2012 baseline for scope 1 and 2 emissions. However, GHG efficiency has improved by 5.4% from 1.212tCO2e/PGMoz in 2015 to 1.146tCO2e/PGMoz. In total, Lonmin emitted 1,665ktCO2e (2015: 1,758ktCO2e). The reporting scope of emissions increased this year to include scope 1 emissions from the Mooinooi landfill site and waste water treatment works at the Marikana operations. These sources accounted for 0.5% of the 2016 carbon profile, but are not yet included in the target and performance.
Detail on GHG and climate change assessment can be found in this CDP submission.
|1||Disposal of waste to landfill and waste water treatment works GHG emissions were added to scope 1 during 2016.|
|1||Disposal of waste to landfill and waste water treatment works GHG have been added to scope 1 during 2016.|
The main initiatives in 2017 will centre around preparing the business for mandatory reporting of GHG emissions and assisting communities to address water issues arising from climate change.
Biodiversity and land management
The Marikana Thornveld is listed as a vulnerable ecosystem under the National Environmental Management: Biodiversity Act, No 10 of 2004. While Lonmin’s Marikana operations are located within this ecosystem, none of the operations are located in high biodiversity-sensitive areas, although a number of protected/threatened species are likely to be found at our operations.
The ecosystem vulnerability of the operational area is not only impacted by mining and related activities, but by various other influences such as human settlement, is poor agricultural practices, industry and business. We therefore view biodiversity as a material aspect, because rehabilitation is a key regulatory and financial requirement for the Company. Biodiversity is also linked to annual closure liabilities and biodiversity and ecosystem services integrity is material for sustainability of the natural environment and for our stakeholders.
The updated biodiversity action plan (BAP) for the Marikana operations covers all mining operations and meets the requirements of the relevant legislation, regional and national conservation plans, and the Mining and Biodiversity Guidelines. Our approach to biodiversity management aligns with the ICMM 10 Principles and its position statement on mining and protected areas, as well as with the DMR Biodiversity Guidelines.
Biodiversity impact assessments are performed with any biodiversity risks identified. These risks are incorporated into operational risk registers, with action plans in place to address potential risks. The Lonmin Biodiversity and Land Management Standard sets out our approach to biodiversity management and is supported by standard operating procedures.
Specialised software supports the Marikana BAP by modelling key parameters and a BAP GIS tool allows for rapid evaluation and identification of risks to biodiversity of proposed infrastructure development management and monitoring decisions and compliance risks. This tool helps to identify variables including the potential buffering quality of existing wetlands and associated vegetation, the richness and abundance of faunal habitats, ecological degradation, and the location of red data and protected species observed on-site.
Where protected/threatened flora or fauna such as gladioli, bees and snakes are found at our operations, strategies are in place to transplant and/or relocate them.
We are committed to the development of a plan to achieve no net loss to biodiversity and are investigating how this can be achieved within the plan and operational procedures, which are aligned to our BAP.
- Obtained conservation permits for various projects around the mines for the relocation of protected plants.
- Removed and relocated more than 3,000 protected plant species this year.
- Focused on various communication and awareness initiatives across the mines regarding protected and red data species.
- Clearing of alien invasive species continued in collaboration with the government’s Working for Water project, the Kusuala Green and Biodiversity project and the GLC, creating 50 jobs for local community members.
An overview of biodiversity composition at our operations is available. This includes a register of protected species (Schedule 11 of the Nature Conservation Ordinance of Transvaal, No 1 of 1983), a list of plants and animals on the International Union for Conservation of Nature (IUCN) Red List of Threatened Species sighted at our operations over the past 10 years and expected to be located in this area; and the conservation status of these species.
Over 165 heritage sites have been identified around the Lonmin Marikana operations, including iron age sites, archaeological artefacts, graves and old building structures. Where possible, heritage sites are identified within Lonmin’s mining right area, and where the need arises, we engage with local communities to understand their significance and follow the requirements of the Heritage Act, should these sites be impacted. Newly identified sites, including graves located on our mining right, are added to the heritage inventory. Any sites which are close to our operations or have the potential to be impacted by our operations are demarcated and fenced off. Lonmin respects the cultural heritage of the communities in which we operate and allows families of ancestors buried in and around our operations to hold cleansing and remembrance ceremonies on site.
Lonmin’s mine closure strategy and risk-based closure and rehabilitation assessment have identified risks for closure and considered this in relation to the closure strategies currently under review. The review will culminate in an updated and consolidated closure and rehabilitation strategy, aligned to the new Financial Provision Regulations now regulated through the NEMA. The DEA published draft amendments to the regulations on 9 September 2016, in an attempt to address the major uncertainty brought by these regulations. Lonmin will still adhere to the regulations and the clarification note provided by the DEA in the development of the strategy and various supporting documents to quantify the financial provision. To create a holistic strategy, we will align it with the Rehabilitation Strategy Implementation Plan (RSIP) as is required under our water use licence.
In addition to the Social and Labour Plans (SLPs) that are in place to deliver on various needs identified in surrounding communities, we are also investigating the incorporation of social closure planning into the environmental closure planning for holistic sustainable closure where long-term community economic viability will be a reality. During the operational phase of the mine, progressive rehabilitation and social closure, objectives and projects are set and systematically applied as per our closure strategies, which are reviewed on an ongoing basis.
Our annual closure cost assessments to calculate the liability quantum include a detailed inventory of areas that require decommissioning, remediation or rehabilitation and provide information of how this is quantified. Lonmin’s unscheduled and scheduled closure cost assessments for each mining and prospecting right are undertaken by independent specialists on an annual basis. Reports on these assessments are submitted to the DMR for verification. Any shortfall required in financial provision is made primarily through the issuing of bank guarantees, or transfers to the Lonmin Platinum Pollution and Rehabilitation Trust Fund. In addition, the full costing of unscheduled closure, which includes the environmental liability associated with all our assets, remediation and rehabilitation required, is included in Lonmin’s annual financial statements.
Land management governance
Internal and external audits verify compliance with land management legislation, Environmental Management Plan (EMP) performance assessment commitments and ISO 14001 requirements. Activities during prospecting and exploration are managed through the Environmental Drilling Standard with regard to on-site operational environmental requirements and rehabilitation. Where third parties have access to parts of our operations through their mining rights, they are held to our standards.
Audits of the rehabilitated opencast areas are conducted to quantify where rehabilitation is lacking or only partially undertaken, the success of rehabilitation, and where further repair and maintenance is required on these rehabilitated areas. A rehabilitation, repair and maintenance plan is developed to address the findings. A challenge we are managing is the various opposing land uses in and around our operations. This has led to the encroachment of animals from communities onto our opencast rehabilitated areas. Overgrazing denudes vegetation which can cause erosion, release of unstable sediments onto water courses, and erosion topsoil, exposing overburden waste rock from the opencast operations. As there are no methodical animal grazing practices, certain of these areas are left with very little to no potential for recovery. Lonmin continues to engage with the community regarding this matter, but will be developing an animal management plan to establish a symbiotic relationship to address this matter.
In the year ahead, we will progress our no net loss initiatives, continue rehabilitation and repair on the open pit areas, implement aesthetic improvements at E3 facilities to reduce their visibility to nearby communities, enhance our closure planning, implement a waste rock removal strategy and related contracts. We will also implement the requirements of the new Financial Provision Regulations and establish an animal grazing management plan with animal owners.