NAMAGROEN EMPR Amendment.pdf - DLIST Benguela

ENVIRONMENTAL MANAGEMENT PROGRAMME REPORTFOR MINING OPERATIONS INWEST COAST MARINE DIAMOND MININGCONCESSIONS 8(a) AND 9(a), ANDPROSPECTING OPERATIONS IN CONCESSION 8(b)ADDENDUM FOR DREDGING OPERATIONSPrepared by:Pisces Environmental ServicesOctober 2008Contact Addresses:Namagroen Prospecting & Investments (Pty) Ltd Pisces Environmental Services (Pty) LtdPO Box 6141P.O. Box 312287129 Erinvale EstateTokai 7966Somerset WestSouth AfricaSouth AfricaTel / Fax: +27 21 847 1566 Tel / Fax: +27 21 782 9553E-mail: apulfrich@pisces.co.za

Addendum to EMPR for Concessions 8(a), 9(a) and 8(b)ii• Impacts on the terrestrial environment from stockpiling of marine gravels (Highly probable).Mitigation measures that will bring the impacts to acceptable levels are proposed.Counteracting these potentially negative interactions are the beneficial aspects of:• Infilling of mined-out pits thereby contributing to the rehabilitation of past miningdisturbance in the terrestrial environment.• Stimulation of economic activity within the region, and employment opportunities.• Taxes and revenues that accrue to the State.Part B presents the revised Environmental Management Plan specific to dredging operations, whichwill form the bulk of the legally binding document that stipulates how Namagroen and itscontractors will conduct the environmental monitoring, management and mitigation undertakenregarding the proposed dredging operations in the areas. These commitments will become part ofthe authorisation agreement between Namagroen and the Government of the Republic of SouthAfrica, represented by the Department of Minerals and Energy (DME). The matrix has been dividedinto separate parts dealing with aspects specific to:• System Administration and General company procedures• Safety, Health and Environmental Management• Prospecting and Dredging Operations and Vessels at Sea• Accidents and Emergencies• Onshore Logistical Support and Gravel Processing• Waste Management and Pollution Control• Biological Diversity and Resource Use• Socio-economicsIn each part, the environmental management actions to be taken to minimise environmental impactas well as mitigate or remedy environmental damage are listed. Once authorisation of the EMPRamendment is obtained, this matrix will also form the basis of the annual Performance Reports tothe Department of Minerals and Energy.Also included in Part B is an Environmental Monitoring Plan and a Rehabilitation and Closure Plan.Part C provides a list of references cited in the document, and covers the Statutory and LegalRequirements for the proposed dredging operations.Namagroen Prospecting & Investments October 2008

Addendum to EMPR for Concessions 8(a), 9(a) and 8(b)iiiCONTENTSEXECUTIVE SUMMARY ............................................................................................ iACRONYMS AND ABBREVIATIONS ..............................................................................viPART A:INTRODUCTION................................................................................................... 11. GENERAL INFORMATION .................................................................................... 31.1 Name, address, telephone and fax number of the holder of the mining authorisation..... 31.2 Name, address and telephone number of the operations manager ............................ 31.3 Location of the Project ............................................................................... 31.3.1 Concession area number........................................................................ 31.3.2 Surface area of concessions.................................................................... 31.3.3 Name and location of nearest coastal town(s), city, harbour and airport/field....... 31.3.3.1 Magisterial District ................................................................... 31.3.3.2 Municipality ............................................................................ 31.3.4 Location of onshore logistical facility ........................................................ 31.3.5 Neighbouring Concession Holders ............................................................. 51.4 Description of the proposed project ................................................................ 51.4.1 Target mineral and by-products............................................................... 51.4.2 Estimated Reserves.............................................................................. 51.4.3 Planned production rate - volume of gravel dredged per year........................... 51.4.4 Life expectancy of project ..................................................................... 51.5 Proposed timetable, duration and sequence ...................................................... 51.5.1 Prospecting Projects ............................................................................ 51.5.1.1 Date of Issue of prospecting permit ............................................... 51.5.1.2 Date of submission of EMPR ......................................................... 51.5.1.3 Proposed date of starting, duration and completion of prospecting......... 51.5.2 Mining Projects................................................................................... 61.5.2.1 Date of issuing of mining authorisation ........................................... 61.5.2.2 Date of submission of EMPR ......................................................... 61.5.2.3 Date of starting and duration of construction / setting up period ........... 61.5.2.4 Estimated dates of starting of mining, full production and cessation ofproduction ........................................................................................ 61.5.2.5 Estimated dates of progressive or partial closure applications ............... 61.5.2.6 Estimated dates of decommissioning and aftercare programme.............. 61.5.2.7 Estimated date for final closure application ..................................... 62. MOTIVATION FOR THE PROJECT........................................................................... 62.1 Specific Benefits of the Project ..................................................................... 62.2 Compatibility with policies, plans, strategies etc. ............................................... 72.2.1 Namagroen’s Environmental Policy Statement.............................................. 82.3 Consideration of Project Alternatives .............................................................. 93. DETAILED DESCRIPTION OF THE PROJECT ............................................................... 9Namagroen Prospecting & Investments October 2008

Addendum to EMPR for Concessions 8(a), 9(a) and 8(b)iv3.1 Mining Target Areas.................................................................................... 93.2 Description of the Dredging, Discharge and Processing Operations...........................103.2.1 Trailing Suction Hopper Dredger .............................................................103.2.2 Discharge to Land...............................................................................143.2.3 Final Gravel Processing ........................................................................163.2.4 Production Rates and Extent of Mining Disturbance ......................................163.3 Transportation of Gravel.............................................................................173.4 Waste emissions, discharges, refuse generation, disposal and process materials ..........173.4.1 Emissions and Discharges ......................................................................173.4.2 Process Materials ...............................................................................183.4.3 Refuse Generation and Disposal thereof ....................................................183.5 Utilization of Resources..............................................................................193.5.1 Service water....................................................................................193.5.2 Drinking water...................................................................................193.5.3 Power supply ....................................................................................193.5.4 Fuel supply.......................................................................................193.6 Onshore Logistical Support, Stockpiling and Processing Facility ..............................194 ENVIRONMENTAL IMPACT ASSESSMENT ...................................................................194.1 Introduction............................................................................................194.2 Assessment Procedure and Rating of Significance ...............................................204.3 Assessment of Environmental Impacts.............................................................214.3.1 Marine Habitats and Associated Communities..............................................224.3.2 Chemical Effects of Sediment Resuspension and Deposition ............................314.3.3 Other Impacts Associated with Dredging Operations......................................334.3.4 Onboard Waste and Materials Management ................................................374.3.5 Accidents & Emergencies......................................................................384.3.6 Onshore Gravel Processing ....................................................................404.3.7 Waste Management and Pollution Control on Land........................................434.4 Conclusions of this Assessment .....................................................................454.4.1 Positive Aspects .................................................................................454.4.2 Negative Aspects................................................................................454.5 Assessment of Cumulative Impacts.................................................................474.6 Monitoring Recommendations.......................................................................484.7 Conclusion..............................................................................................48PART B:ENVIRONMENTAL MANAGEMENT PLAN .......................................................................491. Introduction .............................................................................................491.1 Environmental Objectives ...........................................................................491.2 Action Plans and Control Measures.................................................................501.3 Monitoring, EMP Performance Assessment and Submission of Information ..................501.3.1 Monitoring and ongoing assessment of impacts ............................................501.3.2 EMP Performance Assessment ................................................................51Namagroen Prospecting & Investments October 2008

Addendum to EMPR for Concessions 8(a), 9(a) and 8(b)v1.4 Applicable Legal and Other Requirements ........................................................511.5 Financial Provision ....................................................................................511.6 Responsibilities ........................................................................................511.7 Decommissioning and Closure.......................................................................51ENVIRONMENTAL MONITORING PLAN ........................................................................77REHABILITATION AND CLOSURE PLAN .......................................................................80PART C:1. REFERENCES .................................................................................................852. STATUTORY AND OTHER REQUIREMENTS ...............................................................893. CONFIDENTIAL INFORMATION.............................................................................91APPENDIX I.......................................................................................................93Technical Specifications of the Vessels used to mine Concessions 8(a) and 9(a) ..............93Namagroen Prospecting & Investments October 2008

Addendum to EMPR for Concessions 8(a), 9(a) and 8(b)viACRONYMS AND ABBREVIATIONSAUV - Autonomous Underwater VehicleBCLME - Benguela Current Large Marine EcosystemBEE - Black Economic EmpowermentCFC - Chloro-fluorocarboncm - centimetresCO 2 - carbon dioxideDEAT - Department of Environmental Affairs and TourismDEME - Dredging, Environmental and Marine EngineeringDI - Dredging InternationalDME - Department of Minerals and EnergyDMS - Dense medium separationDOT - Department of TransportDWAF - Department of Water Affairs and ForestryEMP - Environmental Management PlanEMPR - Environmental Management Programme ReportEMS - Environmental Management SystemFeSi - FerrosiliconGRT - Gross Registered TonnageHWM & LWM - High and low water markI&APs - Interested and affected partiesIFO - Intermediate Fuel OilIMO - International Maritime OrganisationISM - International Safety ManagementISO - International Organisation for Standardisationkm - kilometrekm 2 square kilometreskm/h - kilometres per hourkV - kilo VoltskW kilo Wattm - metresm 3mg/lml/l- cubic metres- milligrams per litre- millilitres per litrem/sec - metres per secondmm - millimetresMCM - Chief Directorate of Marine and Coastal Management of the Department of EnvironmentalAffairs and TourismNO x Nitrous oxidesP&I - Protection and Indemnityppm - parts per millionSABS - South African Bureau of StandardsSAHRA - South African Heritage Resources AgencyNamagroen Prospecting & Investments October 2008

Addendum to EMPR for Concessions 8(a), 9(a) and 8(b)viiSAMSA - South African Maritime Safety Authority, a subsidiary of the Department of TransportSAN - South African NavySANCCOB South African Foundation for the Conservation of Coastal BirdsSO x - Sulphurous oxidesSSS - Sidescan Sonar SurveyTSHD - Trailing Suction Hopper DredgeVOCs - Volatile Organic Carbons% - percentageµm - micrometre< - less than> - greater thanNamagroen Prospecting & Investments October 2008

Addendum to EMPR for Concessions 8(a), 9(a) and 8(b) 1INTRODUCTIONMining licences to extract diamonds in Concessions 8(a) and 9(a) were granted to NamagroenProspecting & Investments (Pty) Ltd (henceforth referred to as Namagroen) in 1991 and 1990,respectively. The licences remain valid until the ore reserve has been exhausted, subject tocertain conditions in the mining lease agreement with the Minister of Minerals and Energy.Prospecting rights to search for diamonds in sea Concession 8(b) were first granted toNamagroen in 1985. The right was renewed in 1993 and 1998, and remains valid subject tocertain conditions. Conversion to a Mining Right is pending.Early prospecting results in these areas dating back to the late 1960s have been supplementedwith recent geophysical (bathymetric and sidescan) surveys. Between 1983 and 1984, Rio Tintoconducted an intensive sampling program focused mainly on Rooiwal Bay, but covering a fairlywide range along almost the entire coastal extent of the Namagroen Concessions 8(a) and 9(a).Since 1985, various small-scale mining contractors operating from small to medium-sizedvessels and shore-units have worked the concessions. Following a period of relatively low sandaccumulation in inshore areas during the 1980s, a substantial proportion of the 8(a) and 9(a)concessions is now characterised by mobile sandy overburden with an average thickness0.25 m. This has historically made mining by standard shore- or vessel-based contractoroperationsdifficult, as the overburden first needs to be stripped away before the targetgravels become accessible to the diver-operated suction pumps. As a consequence of, and incombination with, recent decreases in suitable diving conditions production from theseconcessions has been disappointing for many years, despite a comparatively rich inferredresource.The recent successful use of contracted Trailing Suction Hopper Dredges to mine marinegravels in areas with excessive overburden has prompted Namagroen to consider implementingmarine dredging technology to accelerate production opportunities in their shallow-waterconcessions. Consequently, Namagroen has entered into a mining contract with GeometricalEarth and Ocean Mining (Pty) Ltd (Geo-Mining) to “extract and search for diamonds andprecious stones within the concessions”. Geo-Mining in turn have formed a strategic alliancewith Dredging International (DI), one of the primary operating companies of the Belgium-basedDredging, Environmental and Marine Engineering (DEME) Group, to extract the target marinegravels using a trailing suction hopper dredger.Environmental Management Programme Reports (EMPR) for mining operations in the 8(a) and9(a) concessions and prospecting operations in Concession 8(b) were submitted to, andsubsequently approved by, the Department of Minerals and Energy (DME) in August 2003, andJanuary 2001, respectively. However, as the EMPRs do not cover diamond extraction usingdredger technology, an amendment to the approved EMPRs is required before dredgingoperations can commence. This document represents the required amendment, and is basedon the format proposed in the Generic Environmental Management Programme Report, and inaccordance with the guidelines for the preparation of an EMPR for prospecting for, and miningof offshore precious stones set by the DME.Namagroen Prospecting & Investments October 2008

Addendum to EMPR for Concessions 8(a), 9(a) and 8(b) 2This report is specifically designed around the potential impacts of proposed dredging activitieson the marine and coastal environment. In Part A the regional setting of the project is brieflydescribed and the proposed dredging activities and tools used for the project are detailed.Details on the receiving biophysical and socio-economic environments are not repeated here asthese are fully covered in the approved EMPRs. However, specific assessments of the potentialimpacts resulting from the proposed dredging operations on identified bio-physical and socioeconomicaspects are provided. Part B provides the Environmental Management Plan (EMP)specifically covering dredging operations. This represents Geo-Mining’s commitments thatform the legally binding part of the EMPR and will become part of the authorisation agreementbetween Namagroen and the Government of the Republic of South Africa, represented by DME.Literature cited in the document, and the Statutory and Legal Requirements for the proposeddredging operations are provided in Part C.Namagroen Prospecting & Investments October 2008

Addendum to EMPR for Concessions 8(a), 9(a) and 8(b) 3PART A1. GENERAL INFORMATION1.1 Name, address, telephone and fax number of the holder of the mining authorisationNamagroen Prospecting & Investments (Pty) LtdPO Box 6141, Erinvale Estate7129 SOMERSET WESTTel / Fax : +27 21 847 15661.2 Name, address and telephone number of the operations managerGeometrical Earth and Ocean Mining (Pty) Ltd (Geo-Mining)Rod Townsend31 Main Street, Albertsville,2195 JOHANNESBURGTel: +27 73 680 0406, Fax: +27 86 542 70231.3 Location of the ProjectConcessions 8(a) and 9(a) are contiguous and occupy a 65 km stretch of coast about halfwaybetween the Orange River in the north and the Olifants River in the south (latitudes 30° 26’32.2”S and 30° 57’ 55.2”S). Concession 8(a) extends from Rooiwal Bay in the north to Skuit Bayin the south, whereas 9(a) extends from Skuit Bay to ~2 km north of Strandfontein Point. Theconcessions occupy an ~ 950 m wide coastal strip, ranging from 31.49 m seaward of the lowwater mark to 1,000 m seaward of the high-water mark (see Figure 1). Concession 8(b) islocated seaward of Concession 8(a) to a straight line boundary about 5 km seaward of the highwater mark. It is between 2.5 and 4 km wide and covers an area of roughly 108 squarekilometres.1.3.1 Concession area number 8(a), 9(a) and 8(b)1.3.2 Surface area of concessions1.3.3 Name and location of nearest coastaltown(s), city, harbour and airport/field1.3.3.1 Magisterial District1.3.3.2 Municipality1.3.4 Location of onshore logistical facilityConcession 8(a): 37.219 km 2Concession 9(a): 33.884 km 2Concession 8(b): 108.342 km 2Town: Hondeklipbaai, GariesHarbour: Hondeklipbaai, Port NollothAirfield: KleinzeeNamaqualand Magisterial District administeredfrom SpringbokNamakwa District Municipality, SpringbokKamiesberg Municipality, GariesGravel stockpiling in Trans Hex’s surf-zoneconcession opposite Concession 7(a) and gravelprocessing on Farm Hondeklip.Namagroen Prospecting & Investments October 2008

Addendum to EMPR for Concessions 8(a), 9(a) and 8(b) 4Figure 1: The position of Concessions 8(a), 9(a) and 8(b), and location of proposed operations inrelation to neighbouring South African west coast marine diamond mining concessionareas.Namagroen Prospecting & Investments October 2008

Addendum to EMPR for Concessions 8(a), 9(a) and 8(b) 51.3.5 Neighbouring Concession HoldersThe location and extent of Concessions 8(a), 9(a) and 8(b) in relation to neighbouring SouthAfrican West Coast marine diamond mining concession areas were detailed in the originalEMPRs. They are summarised here for the sake of completeness (see also Figure 1).Table I: Names of adjoining concession holders and land owners.Sea Concession Area / Land AreaSurf zone opposite 8(a)Surf-zone opposite 9(a)7(a)7(b)7(c)8(b)8(c)9(b)9(c)10(a)10(b)Farming area opposite 8(a) and 9(a)Concession Holder /LandownerDe Beers Namaqualand MinesDe Beers Namaqualand MinesTrans Hex Operations (Pty) LtdSolid Pump Co. (Pty) LtdDe Beers Consolidated MinesNamagroen Prospecting & Investments (Pty) LtdDe Beers Consolidated MinesVacantDe Beers Consolidated MinesBaggers (Pty) LtdBaggers (Pty) LtdDe Beers Namaqualand Mines1.4 Description of the proposed project1.4.1 Target mineral and by-products Diamonds; no by-products1.4.2 Estimated Reserves Unknown1.4.3 Planned production rate - volume ofgravel dredged per year1.4.4 Life expectancy of project± 360,000 m 3 / yearIf the dredging trial proves successful,contracted dredging will continue for a fewmonths each year until ore reserves areexhausted.1.5 Proposed timetable, duration and sequence1.5.1 Prospecting Projects1.5.1.1 Date of Issue of prospectingpermit1985, renewals 1993, 1998 and 2007.Conversion to Mining Licence is pending.1.5.1.2 Date of submission of EMPR January 20011.5.1.3 Proposed date of starting,duration and completion of prospectingProspecting in 8(b) has been conducted sincethe 1980s; duration and end date unknown.Namagroen Prospecting & Investments October 2008

Addendum to EMPR for Concessions 8(a), 9(a) and 8(b) 61.5.2 Mining Projects1.5.2.1 Date of issuing of miningauthorisation8(a) – ML 31/93 – 10/12/19919(a) – ML 32/93 – 01/03/19901.5.2.2 Date of submission of EMPR August 20031.5.2.3 Date of starting and duration ofconstruction / setting up period1.5.2.4 Estimated dates of starting ofmining, full production and cessation ofproduction1.5.2.5 Estimated dates of progressive orpartial closure applications1.5.2.6 Estimated dates ofdecommissioning and aftercareprogramme1.5.2.7 Estimated date for final closureapplicationMining in 8(a) and 9(a) commenced in theearly-1980sMining commenced shortly after granting ofmining authorisations. Dredging operationsare expected to commence in February 2009and continue over a period of 9 weeks. Ifthe dredging trial proves successful,contracted dredging will continue for a fewmonths each year until ore reserves areexhausted.On exhaustion of ore reservesOn exhaustion of ore reservesOn exhaustion of ore reserves2. MOTIVATION FOR THE PROJECT2.1 Specific Benefits of the ProjectAs a substantial proportion of the 8(a) and 9(a) Concessions is characterised by mobile sandyoverburden, this has made mining by standard vessel-based contractor operations difficult, asthe overburden first needs to be stripped away before the target gravels become accessible tothe diver-operated suction pumps. In combination with recent decreases in suitable divingconditions, production from the concessions has therefore been disappointing for many years,despite a comparatively rich inferred resource. Exploitation of the diamondiferous gravels inthe (b)-concessions is typically difficult, as the water depth is such that the zone cannot beeffectively exploited by diver-operated units. Furthermore, the occurrence of extensiveboulder beds has made exploitation using fixed-head trenching tools and airlift systemsimpractical. The recent successful use of contracted Trailing Suction Hopper Dredges (TSHD)to extract marine diamondiferous gravels in areas with excessive overburden or in boulderstrewnterrain therefore provides an excellent opportunity to improve productionopportunities.Furthermore, the proposed land-based processing of the dredged materials will provideemployment in an area where employment levels and opportunities are low due to low levels ofagriculture and restrictions placed on industrial development by limited fresh water. JobNamagroen Prospecting & Investments October 2008

Addendum to EMPR for Concessions 8(a), 9(a) and 8(b) 7levels will include Managers (4) and Supervisors (2), as well as additional 12 work stationsoperating 24/7 at the processing facility. A further 14 short-term contracts will be required forthe pipeline launch and preparation of the reclamation site. Technical training will beprovided for all personnel as required.Indirectly, the proposed dredging and processing operations will add to the general economicactivity in the region, as operations will be provisioned from local suppliers and will utiliselocal services. This will help to create and/or maintain businesses and associated employmentin local population centres. It is also planned to renovate a hostel formerly used by Trans Hexpersonnel, thereby providing improved accommodation facilities in the town.Decades of terrestrial mining operations along the Namaqualand coastline have significantlyaltered the coastal landscape between the Orange and Olifants River mouths. Prior to theminerals Act of 1991, no rehabilitation and restoration of mining-impacted areas was required,and much of the prospecting/mining conducted on the coastal plain and fore dune area wasuninformed, unscientific and uncontrolled. On the Farm Hondeklip, for example, past miningoperations have resulted in severe disturbance and alteration of the physical profile of thecoastal strip by extensive excavations, and tailings disposal. Although the Trans Hex Grouphold the mining licence for the farm, they are not accountable for the rehabilitation ofenvironmental damage or disturbance created prior to 1980. Rehabilitation and re-vegetationof such areas will have to be conducted in co-operation between those responsible for creatingthe impact, and the relevant national and regional authorities. As a consequence many ofthese past impacts have resulted in severe long-term/permanent scarring of the landscapethereby significantly impacting both the visual quality and topographic form of the coastalenvironment. By back-filling some of the historic excavations with tailings resulting from theprocessing of dredged sediments, the proposed project represents an important milestone inthe rehabilitation of past damage to the coastal environment by terrestrial mining operations.2.2 Compatibility with policies, plans, strategies etc.The project is compatible with other marine diamond mining operations in the area. However,the coastal strip between the Spoeg and Groen Rivers is part of a proposed National Park. Theland is partly owned by the State, and partly by De Beers Consolidated Mines, who have leasedout the farms between the Spoeg and Groen Rivers, on a 99-year lease, to South AfricanNational Parks to create the national park. The seaward extent of the park has not beenfinalised, and its proclamation is undecided at present. Although situated directly offshore ofthe proposed national park, proposed dredging operations in Concessions 8(a), 9(a) and 8(b)should in no way interact with the Groen-Spoeg coastal National Park. The coastal habitats ofthe national park would only be at risk from mining operations in an emergency situation suchas the wrecking of the dredger and the associated pollution. Should a Marine Protected Areabe proclaimed offshore of the coastal National Park, conflict can be expected as regardsimpeding and prevention of mining development and expansion, particularly in concessionareas that fall within the proposed conservation areas and for which Namagroen hold indefinitemining licences.Namagroen Prospecting & Investments October 2008

Addendum to EMPR for Concessions 8(a), 9(a) and 8(b) 82.2.1 Namagroen’s Environmental Policy StatementNamagroen recognises its responsibility for the stewardship of the natural environment andresources, and is committed to sound environmental management by designating theenvironment as high operational priority to be integrated into the Company’s businessactivities. Namagroen’s environmental policy statement is provided below.NAMAGROEN PROSPECTING & INVESTMENTS (PTY) LTDENVIRONMENTAL POLICY STATEMENTIt is the policy of Namagroen Prospecting and Investments (Pty) Ltd to conduct theexploitation of marine diamond resources in an environmentally responsible manner,so as to achieve sustainable development.The management and staff of Namagroen, and all its partners and associates, arecommitted to maintain a high standard of environmental management of all shorebasedand marine prospecting and mining operations.In this regard, Namagroen undertakes to ensure the following:• Compliance with all relevant existing and forthcoming statutory obligations.• Implementation of international standards of best practice.• Proper environmental impact assessment prior to all operations.• Identification of additional environmental risks during operations.• Formulation of a proper environmental management programme (EMP).• Efficient monitoring and control of all environmental risk factors.• Conservation of natural resources through recycling and reduced wastage.• Prevention of pollution, leakages and spillages as far as possible.• Monitoring and proper containment of potentially harmful substances.• Maintenance of good relations with all interested and affected parties.• Training of all employees on environmental management procedures.• Compliance of contractors with the Namagroen environmental policy.• Regular audits to evaluate compliance with and efficiency of the EMP.• Protection of breeding grounds of all indigenous fauna.• Protection of cultural and archaeological heritages.These commitments have guided the compilation of this project-specific EMPR amendment.The Environmental Policy is specific to the Company, based upon compliance with applicablelegal, regulatory and consent requirements of the governmental authorities in South Africa,and other requirements.Namagroen Prospecting & Investments October 2008

Addendum to EMPR for Concessions 8(a), 9(a) and 8(b) 92.3 Consideration of Project AlternativesOther than using diver-assisted vessel-based mining methods for diamond mining in the (a)-concessions, there are at present no other feasible alternatives for extracting marine gravels inthe shallow, nearshore regions. Previous studies have indicated that in the dynamic nearshoreenvironment, the impacts of diver-assisted mining and dredging on marine biota is of shortduration only, with communities recovering naturally to functional similarity within a few years(Ellis 1996; Pulfrich & Penney 2001; Pulfrich 2004; Steffani & Pulfrich 2004). The associatedinfrastructure and support services necessary for the success of the project (e.g. gravelprocessing facilities and transport routes), are all already established and operational or will beof temporary nature, and no new large-scale permanent construction will be required.3. DETAILED DESCRIPTION OF THE PROJECT3.1 Mining Target AreasDiamondiferous gravels along the South African west coast are not distributed evenly on theocean floor. They have discrete distribution patterns which can vary dramatically, bothhorizontally and vertically. Deposits tend to concentrate on, and immediately above bedrock,in gulleys and potholes. They are usually covered by sandy overburden which first has to bestripped away to gain access to the mineralised sediments. The larger bays and smallerembayments along the coastline of Concessions 8(a) and 9(a) act as heavy mineralconcentration morphologies, which capture diamonds from mobile marine diamond populationsmoved up the coast by the prevailing south-westerly swell and northerly longshore drift. Thelarger bays are often also the relics of palaeo-channels, where geologically older diamondconcentrations are released into the catchment area of the bay.The larger bays are filled with and surrounded by a higher percentage sediment cover than theconcession areas as a whole. The larger submerged palaeo-channel sediment basins extendseveral kilometres seaward, across the (a)-concession boundaries and into the (b)-concessionareas. Mining targets are therefore mainly in and around the three main palaeo-channel areas,namely the Spoeg River and Bitter River areas in Concession 8(a) and the Groen River area inConcession 9(a). Three primary mining targets have been identified during approximatelytwenty years of prospecting and small-scale mining, namely Sammy Brown Bay and Rooiwal Bayin Concession 8(a), and Barnard’s Bay in Concession 9(a).For initial dredging operations, Barnard’s Bay has been selected as the preferred target area asit is the most extensively sampled of all the priority resource areas within the concessions, andtherefore offers the most secure prospect for operational cash flow. Barnard’s Bay stretchesalong two kilometres of coastline, from ~2 km north of the Groen River mouth. From north tosouth it incorporates Reef Bay, Rich Bay, Barnard’s Bay Central and Sand Bay. The target areais in two parts (Figure 2), namely:Area A - 1,460,000 m 2 located between the 1,000 m line offshore and the 5 m isobath.Of this area, 820,000 m 2 is targeted for extraction.Namagroen Prospecting & Investments October 2008

Addendum to EMPR for Concessions 8(a), 9(a) and 8(b) 10Area B - 1,000,000 m 2 located inshore of Area A between the 5 m and 2 m isobath. Ofthis area 360,000 m 2 is potentially accessible by the dredger during calmweather conditions, and has thus been targeted for extraction.A maximum overburden thickness of 0.5 m is expected at the southern limit of Concession 8(a),increasing to 5 m of sandy overburden towards the Groen River mouth in Concession 9(a).Average overburden thickness in the target area is 0.4 m. Following dredging operations in thetarget area, the extracted areas will be visually examined by divers to confirm the satisfactoryremoval of target gravels. Should sea conditions prove unsuitable for diver examination,sidescan sonar may be used to re-survey the dredged area.If initial dredging trials are successful, the following areas will be targeted in future:Concession 8(a): Grootgeut ChannelBitter River mouthStrandfontein BayBoulders BeachSammy Brown BaySpoeg River BayRooiwal BayMitchell’s BayConcession 9(a): Pampoen se Stoel ChannelSkuinsbaaiAbjoel se BaaiConcession 8(b): No specific target area defined as yet3.2 Description of the Dredging, Discharge and Processing Operations3.2.1 Trailing Suction Hopper DredgerTrailing Suction Hopper Dredge (TSHD) systems were originally developed for sand mining inshallow water, although large-scale TSHD systems have recently been adapted for deepwaterdredging, and now have the capacity to dredge in depths up to 135 m, and in swells of up to4 m (Pisces 2004; CSIR 2007) . TSHD systems offer a number of advantages over existing diveroperatedsystems or remote air-lift trenching tools, in that large volumes of gravel can berapidly retrieved, thereby rendering low-grade deposit, or those covered by thick overburdenlayers, previously considered uneconomic targets, economically viable.As part of a “quick win” scenario for Concession 9(a), Geo-Mining on behalf of Namagroen isplanning to contract an international dredging operator to dredge marine gravel deposits in 7 -20 m depth, with a TSHD. The operation will involve extracting 360,000 m 3 of overburden anddiamondiferous material from 820,000 m 2 of seabed off Barnard’s Bay and pumping it onto landvia a steel pipeline for further processing. Dredged material will be stockpiled and de-wateredin a bunded reclamation area before dry mining and subsequent treatment at a land-basedplant.Namagroen Prospecting & Investments October 2008

Addendum to EMPR for Concessions 8(a), 9(a) and 8(b) 11Figure 2: The dredging target areas in Concession 9(a).Namagroen Prospecting & Investments October 2008

Addendum to EMPR for Concessions 8(a), 9(a) and 8(b) 12The TSHD to be used will be the Marieke (97.5 m, 9,362 GRT, maximum dredging depth 33 m)(Figure 3; Vessel specification: Appendix 1). Although the required economical throughput andconfiguration of the operation will be determined during the proposed dredging trial, it isenvisaged that annual mining rates of approximately 1.9 km 2 can be achieved over a period ofapproximately three months. During this time, sufficient gravel will be produced to keep amobile treatment plant in operation for the remainder of the year. The dredger wouldtherefore be contracted on an annual basis for a few months only.The Marieke is fitted with a single 4-m-wide draghead potentially capable of excavating to anaverage depth of 0.5 m at a pass. The draghead is fitted with a 10 x 10 cm aperture screen toexclude oversize material and powerful water jets to break up cohesive muds and clays. It istrailed over the target area, with each traverse referred to as a track, and can be controlled inup to 3.5 m of swell. Suction velocity at the mining head is 5.3 m/sec thereby effectivelyextracting all loose material within a 4 m range of the suction head. When working in boulderstrewnterrain, however, the effectiveness of extracting fine material is dependent on therange of water velocity at the mining head.The dredged material is sucked up a large-diameter pipe (1-m diameter) by powerful suctionpumps (2,025 kW) and deposited into the dredger’s hopper compartments. Although maximumworkable conditions are dependent on the wave height, and the swell and wind directions, thevessel is well suited to dredging in shallow waters.The Mareike has a hopper capacity of 5,600 m 3 for material storage internal to the hull, andcan achieve a maximum dredge rate of 250,000 m 3 per month, making allowances for sailing,pumping ashore and weather. Of the material dredged in an 10-hour delivery cycle, anestimated 3,200 m 3 will be bulk target material.As the hopper fills, the density of the transported load can be increased by means of anoverflow system, whereby clarified water resulting from the settling of the sediment runsoverboard, carrying with it suspended fine material, which forms a turbid plume around thedredger. Overflowing of the low-density mixture is normally achieved through overflow funnels(spillways) in the hopper of the vessel. The vertical position of the funnels can be adjusted tosuit the overflowing level, which in turn depends on the amount of load in the hopper. Theoverflow funnels discharge down through the hull in the centre of the vessel, the outlet beingwell below the sea surface (7 m), depending on the load on board. It is estimated that allsediments

Addendum to EMPR for Concessions 8(a), 9(a) and 8(b) 13Figure 3: The trailing suction hopper dredger Mareike, and dredgehelper vessel MCS Elly to be usedfor proposed dredging operations on Concession 8(a), 9(a) and 8(b).Figure 4: The dredgehelper vessel MCS Elly to be used for pipeline launching and dredger tenderingduring proposed dredging operations on Concession 8(a), 9(a) and 8(b).Namagroen Prospecting & Investments October 2008

Addendum to EMPR for Concessions 8(a), 9(a) and 8(b) 143.2.2 Discharge to LandDredged sediments will be discharged to land through a 1-km long sinkerline, which has beenrun out through the surf-zone to 10 m depth (ca. 500 m offshore). This pipeline, which consistsof steel sections of 0.8-m diameter welded together, will be constructed on land, and duringpositioning, will be towed offshore by a tug, whilst dozers push the land-ward end into thesurf. Once in position, the pipeline will be flooded and the flexible end-section required fordredger coupling will be attached. The flexible connecting portion is buoyed. The pipelinewill also have an approximately 300-m long section onshore. A service strip approximately20 m wide will be required from the beach along the length of the onshore section of thepipeline (approximately 100 m) to reclamation area to accommodate an access path andbooster pump. The remaining 200 m will extend the length of the reclamation area. Beyondthe low water mark, the pipeline will not be buried below the seabed, but is likely to buryitself up to ¾ of the way in sandy substrate as a result of the longshore sediment drift. Shouldbreakage or kinking occur, the line would be salvaged by pulling it back onto the shore withdozers.During discharge operations, the dredger will need to enter shallow water (10 m depth) toconnect to the discharge pipeline, and remains there whilst discharging gravel. Consequently,an approach passage to the seaward end of the discharge pipeline is required for navigation ofthe dredger. Coupling of the dredger to the floating portion of the sinkerline will require swellconditions not exceeding 1.8 m. The dredger has powerful thrusters, which enables it toremain dynamically positioned whilst operating in a cross current. Two bow anchors and onestern anchor are typically deployed during hook-ups.The discharged dredged material will be stockpiled in a reclamation area or settling pondlocated eastwards of the beach road between the police station and the Trans Hex contractors’Hostel on the outskirts of the town of Hondeklipbaai. This area falls within the non-operationalHondeklipbaai Mine property managed by the Trans Hex Group. The reclamation area will beprepared by stripping and stockpiling the topsoil for later use during rehabilitation. An area of200 m x 600 m will be cleared. Dry earth moving equipment will be used to slightly excavatethe compact sandy sediments below, heaping them around the perimeter of the reclamationarea thereby forming an approximately 3 m high retaining wall around the site. The earthmovingequipment used will consist of:• D6 bulldozers for leveling of the reclamation area and preparation of the retaining walls,• CAT 330 excavators for support and preparatory works, and ultimately for stockpiling ofmarine sediments, and• CAT 966 wheel-loader for placing of the pipelines.The reclamation area can receive several hopper-loads as well as any diverted sediments,should an emergency situation arise requiring the dredger to undergo unscheduleddisconnecting procedures whilst discharging. The total capacity of the reclamation area islarge enough to receive all extracted material. Essentially the overcapacity of the reclamationarea will cover a 48-hour interruption of operations of the primary screens at the processingplant. The required infrastructure will be constructed in a previously disturbed area (Figure 5).Namagroen Prospecting & Investments October 2008

Addendum to EMPR for Concessions 8(a), 9(a) and 8(b) 15Figure 5: Map of Hondeklipbaai indicating position of proposed project infrastructure.Namagroen Prospecting & Investments October 2008

Addendum to EMPR for Concessions 8(a), 9(a) and 8(b) 163.2.3 Final Gravel ProcessingOnce in the reclamation area, the dredged sediments will be de-watered by allowing cleanwater to drain off through an overflow pipe after suspended fine material has settled. The dewateredheadfeed fraction will be transported by earth-moving vehicles along an existing roadto the modular primary screening and Dense Medium Separation (DMS) plant located within200 m of the reclamation area on the outskirts of the town of Hondeklipbaai. The plant site,which encompasses and area of 5,000 m 2 , will be located on an old sports field adjacent to theTrans Hex Hostel. The marine gravels will be fed through a Barmac crusher to remove shellgrit, and screened at 125 tons per hour to separate the fines ( 30 mm)from the heavy density product gravels. Oversize material will be stockpiled in a designatedarea adjacent to the plant before transport by truck, along existing roads, to the designatedmining pit in the Hondeklipbaai Mine. Fine material (

Addendum to EMPR for Concessions 8(a), 9(a) and 8(b) 17layer of overburden is relatively thin. The maximum percentage of potentially diamondiferoussediment cover on Concessions 8(a) and 9(a) has been determined by side-scan sonar as 15%,including thin coarse-sediment veneers on some low-lying bedrock areas.The extraction area for the first two months of the proposed dredging operations is a820,000 m 2 area located within Area A (Figure 2). Of the potential total 71 km 2 of Concessions8(a) and 9(a), only 2.5 km 2 is currently being targeted for dredging. This amounts to 3.5% ofthe total (a)-concession area held by Namagroen, and approximately 23% of the 15% ofpotentially diamondiferous sediment-covered area of the concessions.3.3 Transportation of GravelOversize and product tailings from the gravel treatment process will be stockpiled in adesignated area adjacent to the plant before transport by truck along existing roads to themining pit in the Hondeklipbaai Mine. Two discard areas have been identified, both within1.5 km of the processing plant (see Figure 5). Transport of tailings will involve on averagethree trips per hour by 10 m 3 dump-tipper.The following vehicles will be utilised:1 heavy duty crane truck1 light duty personal and stores truck4 site pick-ups and trailers1 tractor loader backhoe3.4 Waste Emissions, Discharges, Refuse generation, Disposal and Process Materials3.4.1 Emissions and DischargesThe dredging vessel and its accompanying fleet produce exhaust emissions from onboard dieselgenerators no different from those emitted by other vessels (fishing, mining, freight,passenger) operational in, or passing through, the area. As operations are limited to a fewmonths each year, diesel fume generation is considered negligible.During normal vessel operations, no oil or produced oily water, deck drainage and otherdrainage, machinery and ballast water, detergents, hydraulic fluids or other contaminatedmaterial or substances are discharged into the environment.The Contractor vessel Mareike is MARPOL compliant and is fitted with onboard sewage storageand treatment facilities that release inert sludge and chlorinated water. In accordance withMARPOL, treated wastes are only discharge beyond 4 nautical miles offshore.The processing plant at Hondeklipbaai will not produce emissions as the diamond extractionprocess is a wet process and even dust is naturally suppressed.During dredging operations suspended fine material is lost overboard in the overspill, forming aturbid plume of suspended sediment around the dredger. The extent and area over whichNamagroen Prospecting & Investments October 2008

Addendum to EMPR for Concessions 8(a), 9(a) and 8(b) 18plumes disperse will depend on the strength and direction of the prevailing currents and winds,and the particle size of the material in question. It is estimated that all sediments

Addendum to EMPR for Concessions 8(a), 9(a) and 8(b) 193.5 Utilization of Resources3.5.1 Service water3.5.2 Drinking water3.5.3 Power supply3.5.4 Fuel supplyApproximately 50,000 litres of seawater usedper day to screen and process gravel in modulartreatment plant.Approximately 2,400 litres per day of potablewater from municipal supply used at theaccommodation facilities.The contractor dredger takes on potable waterevery three weeks during fuel bunkering.132 kV from Eskom grid from the De Beersnetwork (Kleinzee) at the Processing facility.Autostart MG Set backup diesel generator inthe event of an Eskom power failure.Diesel generators onboard the dredging vessel.The dredger will return to the Port of CapeTown every three weeks to bunker fuel andreplenish supplies of potable water, provisionsand spares.The Mareike uses IFO (Intermediate Fuel Oil) 180 bunker fuel, which contains 6-7% gas oil.Maximum fuel volumes amount to 350 metric tons thereby requiring bunkering approximatelyevery three weeks. IFO 180 has moderate aquatic toxicity, as in the event of a spill, theresidual heavy fuel component (>90%) will not evaporate, and has poor dispersive properties.3.6 Onshore Logistical Support, Stockpiling and Processing FacilityDealt with under 3.2, 3.3 and 3.4.4 ENVIRONMENTAL IMPACT ASSESSMENT4.1 IntroductionThe ‘environment’ is the surroundings in which an organisation operates, including air, water,land, natural resources, flora, fauna, humans, and their interrelation. An ‘environmentalaspect’ is defined as an element or part of an organisation’s activities, products or servicesthat can interact with the environment – i.e. the source of an impact. An ‘environmentalimpact’ is any change to the environment whether adverse or beneficial, wholly or partiallyresulting from an organisation’s environmental aspect. An ‘environmental objective’ is anoverall environmental goal, consistent with the environmental policy that an organisation setsto achieve. ‘Environmental performance’ is the measurable results of an organisation’smanagement of its environmental aspects. Results can be measured against the organisation’senvironmental policy, environmental objectives, environmental targets and otherenvironmental performance requirements.Namagroen Prospecting & Investments October 2008

Addendum to EMPR for Concessions 8(a), 9(a) and 8(b) 204.2 Assessment Procedure and Rating of SignificanceTo evaluate in a systematic manner specific impacts and risks arising from the proposeddredging activity on the marine environment, the convention outlined below was used todetermine the significance rating of the impact(s). To the extent possible, allocation to rankcategories were based on quantifiable criteria which can be measured. Furthermore, whenevaluating impacts, the allocated ranks refer to the resultant impact (e.g. area of seabedaffected, or time that the result of the impact will last), and not of the cause thereof (e.g.area of seabed actually mined, or time of active impact).Each specific assessment table defines the proposed activity and reviews the type of effectthat the aspect will have on the relevant component of the environment and includes “whatwill be affected and how?”RatingDefinition of RatingStatus of the Impact – in terms of meeting the objective of maintaining a healthy environmentPositiveNegativeNeutralThe impact benefits the environmentThe impact results in a cost to the environmentThe impact has no effectProbability – the likelihood of the impact occurringImprobableProbableHighly ProbablePossibility very lowDistinct possibilityMost likelyDefiniteImpact will occur regardless of preventive measuresDegree of confidence in predictions – in terms of basing the assessment on availableinformationLowAssessment based on extrapolated dataMediumHighInformation base available but incompleteInformation base comparatively reliableExtent – the area over which the impact will be experiencedSite specificLocalRegionalNationalInternationalConfined to within < 1 km of the projectConfined to the study area or within 10 km of the projectConfined to the region, i.e. > 10 km but < NationalLimited to the coastline of NamibiaExtending beyond the borders of NamibiaDuration – the time frame over which the impact will be experiencedShort-termMedium-termLong-termPermanentdays,

Addendum to EMPR for Concessions 8(a), 9(a) and 8(b) 21RatingDefinition of RatingIntensity – the magnitude of the impact in relation to the sensitivity of the receivingenvironmentNegligible Natural functions and processes are negligibly alteredMildModerateSevereNatural functions and processes continue albeit in a modified way thatdoes not appear to have a significant disruptive effect (i.e. changes aretemporary)Natural functions and processes continue albeit in a modified way thatdoes appear to have a noticeable disruptive effect (i.e. changes are longtermto permanent)Natural functions or processes temporarily or permanently cease resultingin severe deterioration or complete disruption of the impactedenvironmentThe application of the above criteria to determine the significance of potential impacts uses abalanced combination of duration, extent and intensity, modified by probability, potentialcumulative effects and confidence. Significance is described as follows:LowMediumHighWhere the impact will have a negligible influence on the environment and nomodifications or mitigations are necessary for the given project description. Thiswould be allocated to impacts of any severity/magnitude, if at a local scale/extent and of temporary duration/time.Where the impact could have an influence on the environment, which will requiremodification of the project design and/or alternative mitigation. This would beallocated to impacts of moderate severity, locally to regionally, and of shortduartion.Where the impact could have a significant influence on the environment and, inthe event of a negative impact, the activity(ies) causing it should not bepermitted without substantial mitigation and management, and pro-activerehabilitation commitments (i.e. there could be a ‘no-go’ implication for theproject). This would be allocated to impacts of severe magnitude, locally overthe medium-term, and/or of severe magnitude regionally and beyond.4.3 Assessment of Environmental ImpactsProposed diamond mining activities will interact both directly and indirectly with existinginfrastructure, as well as with the biophysical environment. The potential impacts of dredgingactivities on the marine environment are detailed in the individual impact assessment tablesbelow. Active rehabilitation of the marine environment below the LWM is not required, asrecovery of impacted communities within this highly dynamic environment is a naturallyoccurring process. There are thus no discernable differences between impacts in the settingup,operational and decommissioning phases of the dredging operations, and consequently theimpacts on the marine environment are addressed in a single matrix. Impacts associated withland-based aspects will be treated separately in a basic assessment to be submitted to therelevant authorities.Namagroen Prospecting & Investments October 2008

Addendum to EMPR for Concessions 8(a), 9(a) and 8(b) 224.3.1 Marine Habitats and Associated CommunitiesBy their very nature, diamond mining operations will interact with the physical marineenvironment as overburden sediments and target gravels will be removed from gullies, potholesand bedrock features during the dredging process. Removal of the superficial sediments by thedredger is likely to result in the total or near-total loss of the associated benthic biota. Inaddition, the destruction of macrofauna in the mined areas reduces the amount of foodavailable to demersal fishes and/or rock lobsters and any of their prey that utilise the ssameresources.The ecological recovery of the disturbed seafloor is generally defined as the establishment of asuccessional community of species, which progresses towards a community that is similar inspecies composition, population density and biomass to that previously present (Ellis 1996).The rate of recovery (recolonisation) depends largely on the magnitude of the disturbance, thetype of community that inhabits the deposits in the mined-out area, the extent to which thecommunity is naturally adapted to high levels of sediment disturbances, the sedimentcharacter (grain size) and physical factors such as depth and exposure (waves, currents)(Newell et al. 1998). Generally, recolonisation starts rapidly after cessation of dredging, andspecies numbers may recover within short periods (weeks). Opportunistic species may recovertheir previous densities within months. Long-lived species, however, like molluscs andechinoderms need longer to re-establish the natural age and size structure of the population.Biomass therefore often remains reduced for several years (Kenny & Rees 1994, 1996; Kenny etal. 1998). Important for the recovery process is the rate of sediment movement back into themined-out areas. This is highly dependent on the water depth of the affected area. Proposeddredging operations in Concession 8(a) and 9(a) are in depths within the wave base (

Addendum to EMPR for Concessions 8(a), 9(a) and 8(b) 23in contrast to nearshore areas, where recovery rates of three years are suggested followingmining using conventional mining tools (Lane & Carter 1999). At present, no data are availablefor recovery after mining with TSHD technology, although a specifically designed benthicmonitoring programme is in place off southern Namibia.Sediment discharges from dredger overspill, and sediment re-suspension by the draghead nearthe seabed will lead to suspended sediment plumes in the water column. Distribution and redepositionof sediments from plumes are the result of a complex interaction betweenoceanographic processes, sediment characteristics and engineering variables that ultimatelydictate the distribution of suspended sediment in the water column. Ocean currents, both aspart of the meso-scale circulation and due to local wind forcing, are important in distributionof suspended sediments. Turbulence generated by surface waves can also increase plumedispersion by maintaining the suspended sediments in the upper water column. The maineffect of plumes is an increase in water column turbidity, leading to a reduction in lightpenetration with potential adverse effects on the photosynthetic capability of phytoplankton.Poor visibility may also inhibit pelagic visual predators. For example, localised plumes ofelevated turbidity in the water column may affect the feeding efficiency of seabirds either byobscuring their vision or by potentially reducing prey availability through avoidance responsesof prey species to turbid water areas. If the plumes are highly localised and of short duration(i.e. the dredging vessel is highly mobile and plumes disperse quickly), then the consequencesare likely to be negligible. Egg and/or larval development may be impaired through highsediment loading. Benthic species that may be impacted by near-bottom plumes includebivalves and crustaceans.The highly dynamic nature of the Benguela coastal region suggests that most of the marinebiota is well adapted to cope with large fluctuations in natural turbidity and short-termincreases in suspended sediments, and many can tolerate long-term burial. The response ofbenthic invertebrates to increased sediment concentrations is highly variable, and tolerancelevels range from tens of mg/l to several thousand of mg/l. Suspended sediment effects as aresult of dredging will thus occur mainly at the sublethal level (at concentrations of about100 mg/l), as lethal effects are seen at much higher concentrations (>7,000 mg/l) and atexposures of several weeks. This suggests that in areas of moderate to high water movement,adult populations are likely to survive elevated suspended sediment concentrations, and onlywhere sediment deposition occurs will sediment intolerant species be excluded. However,whereas the adults of many species will tolerate extended periods of sediment burial orelevated suspended sediment concentrations, such conditions may detrimentally affect larvalsettlement and/or juvenile survival. Smothering of reef substrate reduces both settlementstimuli, as well as the food supply for juveniles, thereby affecting the recruitment success ofthe disturbed macrobenthos and ultimately impacting the community structure. In generalthough, the impacts from suspended sediment plumes are regarded as being of low significancedue to the typically short duration times, local scale and fast dispersion rates.The resuspension of sediments and their subsequent deposition can cause smothering ofbenthic communities adjacent to the dredging target areas. Smothering involves a reduction innutrients and oxygen, clogging of feeding apparatus, as well as affecting choice of settlementsite, and post-settlement survival. In general terms, the rapid deposition of material from theNamagroen Prospecting & Investments October 2008

Addendum to EMPR for Concessions 8(a), 9(a) and 8(b) 24water column (as would occur during overburden stripping and dumping in a sacrificial dumpsite) is likely to have more of an impact on the soft-bottom benthic community than gradualsedimentation to which benthic organisms are adapted and able to respond. However, thisresponse depends to a large extent on the nature of the receiving community. Studies haveshown that some mobile benthic animals are able to migrate vertically through more than30 cm of deposited sediment (Maurer et al. 1979; Newell et al. 1998; Ellis 2000). In contrast,sedentary communities may be adversely affected by both rapid and gradual deposition ofsediment. Filter-feeders are generally more sensitive to suspended solids than depositfeeders,since heavy sedimentation may clog the gills. Impacts on highly mobile invertebratesand fish are likely to be negligible since they can move away from areas subject to redeposition.Some studies have found a positive effect of dredging in that the disturbance of sedimentsreleases sufficient organic material to enhance the species diversity and population density oforganisms outside the immediate zone of deposition of suspended material (Jones & Candy1981; Poiner & Kennedy 1984). Crushed organisms returned to the sea with the overspill mayalso cause organic enrichment (Newell et al. 1998). The upwelling regions off the SouthernAfrican West Coast are frequently exposed to hypoxic conditions (

Addendum to EMPR for Concessions 8(a), 9(a) and 8(b) 25Removal of sediments Status NegativeDirect mortality of infaunal and Probability Definite; removal of unconsolidatedepifaunal organisms, alteration ofsediments and their associated biota is anhabitat and benthic communityunavoidable consequence of dredgingcomposition, and potentialoperations.reduction in benthic biodiversity Confidence Highdue to the removal of benthic Extent Site-specific; confined to the dredgingorganisms during the dredgingtarget area.processDuration (a)-concessions:Short- to Medium-term; infill rates withinthe wave-base are expected to berelatively rapid and consequently recoveryof communities to functional similarity ispredicted to occur within a few years.(b)-concession:Long-term to Very long-term; althoughinfill rates are site-specific, beyond thewave-base they are expected to beextremely slow (3-5 mm per year) andconsequently recovery of communities tofunctional similarity is predicted to takedecades.Intensity Severe; all epifaunal and infaunal benthicorganisms in the mining target area areseverely disturbed or eliminated, andenvironmental functions and processes inthe mined and adjacent area maytemporarily and/or permanently cease.Significance HighLoss of macrofauna Status NegativeThe loss of macrofauna in the minedareas reduces the amount of foodProbability Highly probable (impact will most likelyoccur)available, both directly to demersal Confidence Mediumfishes and/or rock lobsters as well Extent Local; confined to the concession areaas to their prey utilising theseresourcesDuration (a)-concessions:Short- to Medium-term; recovery to afunctionally similar community is expectedto be rapid.(b)-concession:Long-term (

Addendum to EMPR for Concessions 8(a), 9(a) and 8(b) 26Habitat alteration Status NegativeAlteration of sediment structure / Probability Definite; removal of unconsolidatedseabed habitat due to thesediments and their associated biota is anexcavation of mined sediments andunavoidable consequence of dredgingresultant effects on benthicoperations.community structureConfidence MediumExtent Site-specific; confined to the mining targetarea.Duration (a)-concessions:Short- to Medium-term; infill rates bynaturally depositing sediments will berapid in the wave-influenced regions andchanges in seabed geomorphology will betemporary only.(b)-concession:Permanent; infill rates by naturallydepositing sediments are slow and changesin seabed geomorphology will persist in thevery long-term, possibly over decades.Intensity (a)-concessions:Mild; being dependent on the infill rate,recovery through natural recolonisationand establishment of successioncommunities will be rapid.(b)-concession:Moderate; being dependent on the infillrate, recovery through naturalrecolonisation and establishment ofsuccession communities is slow. Althoughecological processes will ultimately be reestablished,community structure may bedifferent.Significance (a)-concessions: Low(b)-concession: MediumMining excavations: WaterqualityPotential trapping of organic matterin excavations and subsequentpooling of low oxygen waterStatusProbabilityConfidenceExtentDurationIntensitySignificanceNegative(a)-concessions: Improbable(b)-concession: ProbableHighSite-specific; within the excavation.Short-term; flushing is likely to occurperiodically during storms when the wavebase reaches the seabed.Moderate; different community structuresmay develop but ecological processes willprobably be maintained.LowNamagroen Prospecting & Investments October 2008

Addendum to EMPR for Concessions 8(a), 9(a) and 8(b) 27Miningexcavations:Hydrographical changesDredging excavations and trenchesmay affect patterns in the waveregime on a regional scale, whichmay in turn affect nearshoresediment transport. This mayultimately result in correspondingchanges to beach morphodynamics.StatusNegativeProbability Unknown but improbable; any changes inwave patterns are likely to have dissipatedby the time they reach the coastline.Confidence MediumExtent Local to Regional; changes in the shorelinemay occur opposite and to the north ofpersistent trenches.Duration Long-term to Permanent; changes inhydrographical conditions andcorresponding shoreline changes maypersist over the long term, or may even bepermanent.Intensity Negligible; changes in beachmorphodynamics on the exposed coastlineas a result of shoreline changes areunlikely to severely change thecommunities associated with this habitat.Significance LowOverspill during dredging:Suspended sediment plumesVisible sediment plumes caused byfine particles suspended near thewater surface causing both a visualimpact, decrease in lightpenetration thereby affectingprimary production and lethal orsublethal effects on marineorganismsStatusNegativeProbability Improbable; although elevated suspendedsediment concentrations are a typical byproductof mining activities, effects onmarine organisms are unlikely.Confidence HighExtent Local; the extent and area over whichplumes disperse will depend on thestrength and direction of the prevailingcurrents and winds, and the particle size ofthe material in question.Duration Short-term; plumes will be rapidlydispersed and advected away from thevessel, however, potential effects willextend over the duration of the dredgingactivity in the concession area (Mediumterm).Intensity Mild; adverse effects are experiencedgenerally at suspended sedimentconcentrations higher (>100 mg/l) thanthose expected during dredging operations,or to longer exposure periods (>2 days)than typical life times of suspendedsediment plumes.Significance LowNamagroen Prospecting & Investments October 2008

Addendum to EMPR for Concessions 8(a), 9(a) and 8(b) 28Overspill during dredging:SmotheringSmothering of benthic invertebratesresulting in mortality and alterationof benthic community compositionand potential reduction in benthicbiodiversity, caused by sedimentslost in the overspillDumping of dredge spoil:SmotheringDumping of dredge spoil smothersbenthic invertebrates at thesacrificial dump site resulting inmortality and alteration of benthiccommunity composition andpotential reduction in benthicbiodiversityStatusProbabilityConfidenceExtentDurationIntensitySignificanceStatusProbabilityConfidenceExtentDurationIntensitySignificanceNegativeProbableMedium; depends on the quantity andnature of the sediments.Local; the extent and area over whichoverspilled sediments settle will depend onthe strength and direction of the prevailingcurrents and winds, the depth of thedredging target area, and the particle sizeof the material in question.(a)-concessions:Short-term; depositing sediments will berapidly re-distributed in the waveinfluencednearshore regions.(b)-concession:Medium to Long-term; recovery may takefrom

Addendum to EMPR for Concessions 8(a), 9(a) and 8(b) 29Deposition of suspendedsediments from overspill ontoreef habitatsSmothering of vulnerable benthicreef communities resulting inmortality and potential reduction inbenthic biodiversity, caused bydeposition of sediments lost in theoverspill onto reefs adjacent to thedredging target areasStatusNegativeProbability Highly probable (most likely)Confidence Medium; depends on the quantity andnature of the sediments and the proximityof reef communities.Extent Regional; emergent reefs occur insubstantial portions of both the 8(a) and9(a) and 8(b) Concessions.Duration (a)-concessions:Short-term; depositing sediments will berapidly re-distributed in the waveinfluencednearshore regions.(b)-concession:Long- to Very Long-term; depending on thedepth of the reef and the extent ofsmothering, recovery may take decades.Intensity (a)-concessions:Mild; the sediment layer thickness isexpected to be minimal and mostnearshore reef organisms are adapted tohigh natural deposition rates.(b)-concession:Moderate; most adverse effects appearonly under high sediment rates and longtermdeposition.Significance (a)-concessions: Low(b)-concession: MediumSuspended sediment effects on Status Negativerock lobstersMobilisation and redistribution of Probability Improbable; although elevated suspendedsuspended sediments may havesediment concentrations are a typical byproductsublethal or lethal impacts on rockof mining activities, effects onlobster pueruli (and the larvalmarine organisms are unlikely. However,stages of other macrofaunalthere is insufficient information availablespecies). Deposition of theon rock lobster settlement and recruitmentresuspended sediment may smotherareas on the Namaqualand coast.suitable rock lobster habitats Confidence Mediumthereby reducing settlement stimuli Extent Regional; recruitment failure on thefor pueruli and precluding larvalsettlement, and/or reducing foodshallow water reefs in Concessions 8(a) and9(a) may affect lobster populations onsupply for juveniles. This maylocal fishing grounds, as well as fishingaffect recruitment success of rocklobsters in the area. Durationgrounds further away.Medium- to Long-term; recruitment failurecan have long lasting affects on thefishery.Namagroen Prospecting & Investments October 2008

Addendum to EMPR for Concessions 8(a), 9(a) and 8(b) 30Intensity Mild; within limits, the marinecommunities of the southern African WestCoast are adapted to naturally elevatedconcentrations of suspended sediments,with adverse effects generally experiencedat suspended sediment concentrationshigher than those expected as a result ofdredging. Although a proportion of thehabitat may be impacted and somepueruli/juveniles may die, most adverseeffects will appear only under highsediment rates and long-term deposition.Significance LowRepeat Mining Status NegativeRe-mining of sediments in Probability Probable (distinct possibility)previously mined areas results in Confidence Mediumfurther impact on sediment Extent Site-specific (

Addendum to EMPR for Concessions 8(a), 9(a) and 8(b) 31sediment suspension, reduced trailing speed, use of underwater pumps to maximise solidconcentration, and/or avoidance of use of draghead water jets (ABP Research 1999).Management actions include avoiding dredging in the immediate vicinity of reefs.Furthermore, under no circumstances are overburden spoils to be dumped on, or in the vicinityof, reef habitats.Target areas to be dredged in Concessions 8(a), 9(a) and 8(b) should preferably be mined tocompletion, and then not be visited for at least five years, to allow communities to recover.The successful coverage of a specific mining area should thus be determined before moving toa new target area. Efficient, high intensity mining methods are thus preferable to repeated,smaller scale operations, provided that the larger scale operations do not cause unacceptableimpact on adjacent sensitive rocky outcrop areas.4.3.2 Chemical Effects of Sediment Resuspension and DepositionThere are several indirect effects of mining associated with sediment disturbance andincreased suspended sediment concentrations in the water column. Marine biogeochemicalprocesses may be affected by mining-induced sediment re-suspension, with potential cascadeeffects through the marine food web.The Namaqualand coastline is frequently exposed to natural hypoxic conditions owing toextremely high primary production and subsequent oxidative degeneration of organic matterbelow the thermocline (Weeks et al. 2004). During the dredging process particulate organicmatter previously associated with the sediments is re-suspended, and both the suspension andthe subsequent re-deposition thereof may lead to further reduction in near-bottom dissolvedoxygen concentrations, thereby aggravating already hypoxic conditions near the seabed (seealso Herrmann et al. 1999). However, in comparison with the high natural organic deposition,and periodic and often extensive low-oxygen events characteristic of the Benguela region, thecontribution by organic material re-suspended and deposited during dredging, and thelikelihood of this resulting in substantial hypoxia or anoxia is negligible. In the highly turbulentnearshore zone, where the surface waters down to ~25 m depth are usually well saturated,mining-induced organic enrichment are not likely to affect near-bottom oxygen concentrations,and the associated impacts are thus of low significance.Several studies have suggested that recently deposited sediments in specific areas on thecontinental shelf off the Southern African West Coast may be characterised by high levels ofheavy metals of marine and/or terrestrial origin (Calvert & Price 1970; Chapman & Shannon1985; Bremner & Willis 1990). The re-suspension of sediments during dredging can releasethese trace metals into the water column. Metal bio-availability and eco-toxicology is complexand depends on the partitioning of metals between dissolved and particulate phases and thespeciation of the dissolved phase into bound or free forms (Paulson & Amy 1993; Rainbow 1995;Galvin 1996). Although dissolved forms are regarded as the most bio-available, many of theseare not readily utilisable by aquatic organisms. Consequently those forms that are ultimatelybio-available and potentially toxic to marine organisms usually constitute only a fraction of thetotal concentration. However, such contaminants have only been occasionally foundassociated with muds. The constant turnover of sediments in the wave-influenced inshoreareas will ensure rapid diluted of any contaminants that may be present, and theirconcentrations in the water column will thus be very low. The impacts associated with therelease of contaminants from disturbed sediments is therefore considered of low significance.Namagroen Prospecting & Investments October 2008

Addendum to EMPR for Concessions 8(a), 9(a) and 8(b) 32Organic loading Status NegativeEutrophication via introductions to Probability Improbable (low likelihood)the water column of nutrients (in Confidence Highthe form of POM and/or damagedorganisms that inhabited the minedsediments) due to discard of dredgespoilsExtent Local; the extent and area over whichdischarged sediments settle will depend onthe strength and direction of the prevailingcurrents and winds, the depth of thedischarge area, and the particle size of thematerial in questionDuration Very Short; potential effects extend overthe duration of the tailings discharge anddumping activity and for some timethereafterIntensity Mild to Moderate; will depend on theamount of organic matter in the sedimentsSignificance LowBacterial decomposition Status NegativeDepletion of water column and Probability Improbable (low likelihood)near-bottom oxygen concentration Confidence Highthrough bacterial decomposition oforganic matter deposited with thedredge spoilExtent Site-specific to Local; ‘hotspots’ of organicmatter remineralisation in the mined pitsmay result in localised hypoxia.Duration Very Short; depending on the amount oforganic matter in the sediments and theaccumulation of organic matter due tocumulative effects, potential effects willpersist for the duration of mining activitiesin a target area and for some timethereafterIntensity Moderate; although most of the marinebiota of the Benguela inner shelf is welladapted to cope with large fluctuations indissolved oxygen concentrations, tolerancelevels will be species specific. Persistenthypoxia in localised ‘hotspots’ may,however, play a role in structuringmacrofaunal abundances.Significance LowRe-mobilisation of contaminants Status NegativeRe-mobilisation of trace metals andpesticides present in the tailingsProbability Improbable; low contaminant concentrationsexpected in the target sediments.thereby exceeding established Confidence Low; as a sound information base iswater quality guidelines forlacking.contaminants outside the 500 mmixing zone around the vesselExtent Local; the extent and area over whichdischarged sediments settle will depend onthe strength and direction of the prevailingcurrents and winds, and the nature of thesediments.Namagroen Prospecting & Investments October 2008

Addendum to EMPR for Concessions 8(a), 9(a) and 8(b) 33DurationIntensitySignificanceLong-term to Permanent ; exposure tocontaminants can result in permanentdamage (lifespan of organisms) or death.Negligible; contaminants concentrations inthe sediments are expected to be low andany dissolved contaminants should bequickly diluted to background levels.LowMitigation Measures and Management ActionsNo mitigation measures are necessary as any effects will be rapidly mixed and diluted.4.3.3 Other Impacts Associated with Dredging OperationsThere are a number of other interaction points between dredging operations and aspects of themarine environment, which have primarily been assessed as being of low significance. Theyare discussed briefly here for the sake of completeness.There are numerous known ship wrecks in the area around Concessions 8(a) and 9(a), andconsequently there is a high potential for encountering shipwrecks and other historical orcultural artefacts during dredging operations. Impacts of dredging operations within theimmediate vicinity of wreck material would take the form of both direct damage to wreckstructure, contents and setting, and the destabilisation of sites resulting in renewed corrosionand decay. There is also some potential for impact to discrete items of ship-borne debris. Ifnew sites are found these will be immediately reported to SAHRA.Given the limited extent of the concession areas and their proximity to the shore, dredgingactivities in 8(a), 9(a) and 8(b) are unlikely to interact with the demersal trawling, pelagicpurse-seine, and demersal and pelagic longline fisheries, all of which are conducted furtheroffshore and southwards of the concessions. The demersal (hake) trawling areas all lie indeeper water (>200 m depth). Pelagic purse-seining vessels seldom visit the northernconcession areas, their effort being primarily concentrated further south near Lamberts Bay.As fishing effort in demersal and pelagic longline fishery in this region is low, no interactionwith these fisheries is expected by nearshore mining activities. As most of the coastlineadjacent to the 8(a) and 9(a) Concessions has been proposed as a national park and marinereserve rock and surf angling, and trek- and drift-net fishing is extremely limited and nointeraction is anticipated.Commercial rock-lobster fishing takes place in depths shallower than 15 m at discrete suitablereef areas along the shore of Concession 8(a) and 9(a). However, following the fisheries andenvironmentally induced collapse of the rock-lobster resources in this region in the early 1990s,only a very small proportion of the annual catch is made in this general area, and virtually norock-lobster fishing now occurs in the concession areas. Proposed activities may interact withthis fishery during the commercial fishing season (November to April) by preventing access tospecific fishing sites whilst dredging. However, dredging operations will target only areas ofunconsolidated sediments, and as rock lobsters exhibit associations with, and a preference for,nearshore creviced reef habitats, and avoid gravel and sand areas (Pulfrich & Penney 1998,1999b, 2001), direct interactions between the two industries are unlikely. An approachNamagroen Prospecting & Investments October 2008

Addendum to EMPR for Concessions 8(a), 9(a) and 8(b) 34passage to the seaward end of the discharge pipeline will be required for navigation of thedredger, and this may similarly restrict access by the commercial rock-lobster fleet to portionsof their fishing grounds. As virtually no rock-lobster fishing now occurs in the area, interactionwith the rock-lobster fishery is predicted to be limited.Marine recreational activities along this stretch of coast are extremely limited. Interactionswith mining activities will thus be negligible, and restricted primarily to the Hondeklipbaaiarea. Dredging activities will interact indirectly with coastal tourism, with interaction beingprimarily of an aesthetic nature, and limited to isolated localities, such as the discharge site.The major shipping routes off the South African west coast generally follow the outer edge ofthe continental shelf and should not interact with dredging activities in the concession areas toany marked degree. The highest threat of interference is posed by fishing vessels, in particularsmall commercial linefishing and rock-lobster vessels which occasionally operate out ofHondeklipbaai harbour. The risk of shipping collision is therefore low.Concessions 8(a), 9(a) and 8(b) fall within Block 2 of the natural oil and gas concessions on theWest Coast. Hydrocarbon prospecting in the area is limited at present and concentratedfurther offshore, and interaction with proposed diamond mining operations will thus benegligible. Existing well-heads are located further offshore in deeper water.Equipment such as anchors and mining tools are occasionally lost on the seabed. If notretrieved, such equipment will remain a hazard on the seabed for generations. As miningequipment is expensive, every effort is made to retrieve lost equipment within weeks of theloss occurring, with accurate records being kept of the positions of all lost items. As most lostequipment will be retrieved, the impact is considered of low significance.Archaeological, palaeontologicaland historical aspectsDestruction of wrecks / damage ofsites of archaeological and/orpalaeo-environmental value duringdredging activitiesStatusProbabilityConfidenceExtentDurationIntensitySignificanceNegativeUnknown, but improbable.Low; with regard to the value of thearchaeological resource as a soundinformation base is lacking.Site-specificPermanentSevere; if ship wreck or archaeologicalartefacts or historical sites are destroyed.MediumNamagroen Prospecting & Investments October 2008

Addendum to EMPR for Concessions 8(a), 9(a) and 8(b) 35Exclusion of other users Status NegativePotential exclusion of alternative Probabilityresource users (e.g. fisheries,shipping, oil & gas) and potentialhazard due to the physical presence Confidenceof the dredger in an area, or during Extentdischarge to land of dredged DurationsedimentsIntensitySignificanceImprobable; other activities in the targetareas or around the proposed dischargepipeline at Sand Bay are currently limited.HighLocal to RegionalMedium-term; for a 2-3 month durationannually.Negligible; most commercial fishing areaslie in deeper water, or concentrate ondiscrete suitable reef areas in < 15 mdepth.LowLoss of equipment Status NegativeIrretrievable loss of dredging Probabilityequipment, resulting in the creationof seabed hazards, potentialinterference with demersaltrawling, and/or potentialentanglement of marine mammalsand fishing vessels in anchor linesand/or buoy lines marking lostequipment.ConfidenceExtentDurationIntensitySignificanceImprobable (low likelihood); deepwatermining equipment is expensive, and most issuccessfully retrieved within weeks of theloss occurring. Irretrievable equipment isunlikely to cause a hazard for other marineusers due to the operating water depthsand the very limited activity in the area ofoperation.HighSite-specificLong-term to permanentNegligibleLowVessel noise Status NegativeDisturbance of fish and marinemammals by noise emission fromthe dredgerProbability Improbable; sea noise in the nearshoreenvironment is likely to overshadow anylow-level anthropogenic sounds.ConfidenceExtentDurationIntensitySignificanceHighSite-specific; confined to the immediatemining area.Medium-term; the noise contribution isongoing as long as the dredger isoperational in the area.Negligible; most of the noise generated bymining operations is at a frequency thatdoes not interfere with marine mammals.LowNamagroen Prospecting & Investments October 2008

Addendum to EMPR for Concessions 8(a), 9(a) and 8(b) 36Disturbance of marine life Status NegativeExtraction of sediments during the Probability Improbable (low likelihood)dredging process may result in: Confidence High- loss of fish and lobsters by suckingthem up with the sediments duringExtent Local to Regional; confined to the projectarea.mining,Duration Medium-term; the potential disturbance is- entanglement of marine mammalsongoing as long as the dredger isand disruption of migration routesoperational in the area.Intensity MildSignificance LowAir pollution Status NegativeExceeding international standards Probability Improbable; due to the low sulphurfor exhaust emissions of NOx, SOx,content of the fuel used by the contractedCO 2 , Volatile Organic Carbonsdredger.(VOCs) from the dredgerConfidence MediumExtent Site-specific; confined to the immediatevicinity of the mining area.Duration Short-term; dilution of emissions will berapid.Intensity NegligibleSignificance LowResource use Status NegativeDepletion of natural and nonrenewableProbability Definite; impact will occur regardless ofresources throughprevention measures.engine machinery operation, Confidence Highelectricity generation, fresh water Extent Site-specificconsumption, paper consumptionetc.Duration Medium-term; for as long as the dredger isoperational in the area.Intensity MildSignificance LowMitigation Measures and Management ActionsIf shipwreck material or other archaeological artefacts are encountered in the course ofsampling or mining operations :- Immediately inform the Project Manager who will inform SAHRA.- Retain artefacts recovered and where possible take photographs of them. Note thedate, time, location and types of artefacts found in the Operator’s logbook.- Contract a marine archaeologist to survey the site (if feasible).- Avoid mining within 500 m from the centre of the site until the area has beensurveyed and clearance to continue activities has been obtained from SAHRA.To avoid conflict with the commercial rock lobster fishery operating out of Hondeklipbaai:- Schedule dredging operations such that they fall outside the commercial rock lobsterfishing season.- Provide the rock lobster industry with a map indicating the exact location of thedredger discharge pipeline and the extent of the “exclusion zone” around this.Namagroen Prospecting & Investments October 2008

Addendum to EMPR for Concessions 8(a), 9(a) and 8(b) 37- Clearly mark any exclusion zone(s) using light buoys and/or radar reflectors.- Maintain ongoing communication with the lobster fleet when they are operational inthe area where mining is being conducted.Management Actions in the case of lost equipment should include:- Maintain a database of any equipment lost off the dredger.- Wherever feasible, every attempt should be made to recover lost equipment.4.3.4 Onboard Waste and Materials ManagementThe types of wastes generated by the dredger will include:- gas emissions from engine/generator exhausts utilising bunker fuel and/or gas oil;- various hydrocarbon substances (including bunker fuel, gas oil, hydraulic oil,lubricating oil and solvents), which collect in the bilges;- sewage and organic wastes; and- domestic refuse.The contracted dredging company Dredging, Environmental and Marine Engineering (DEME) isISO 14001 certified, and stringent waste management systems are thus in place on all vessels.This includes oil spill management plans and the relevant insurances in the event of a vesseldisaster. The impacts of wastes generated by the contracted dredger are thus of lowsignificance.Waste disposal Status NegativeExceeding MARPOL international air Probability Improbable; only IMO-approved shipboardpollution guidelines/requirementsincinerators are installed and only generalfor shipboard waste incineration -waste will be incinerated.SO 2 , CO 2 , Volatile Organic Carbons Confidence Medium(VOCs), metals, particulates, ashemissionsExtent Site-specific; limited to immediate areaaround the dredger.Duration Short-term; dilution of emissions will berapid.Intensity NegligibleSignificance LowOrganic waste disposal Status NegativeViolating MARPOL standards for Probability Improbable; due to proceduresdisposal of organic wastes (foodwaste) at seaimplemented to ensure that food waste ismacerated before disposal to sea andadherence to MARPOL requirementsregarding disposal in relation to distancefrom shore.Confidence HighExtent Site-specific; limited to immediate areaaround the dredger.Duration Short-term; dispersal and dilution ofmacerated food waste will be rapid.Intensity NegligibleSignificance LowNamagroen Prospecting & Investments October 2008

Addendum to EMPR for Concessions 8(a), 9(a) and 8(b) 38Sewage disposal Status NegativeViolating MARPOL standards for Probability Improbable; due to adherence to MARPOLdisposal of organic wastes (sewage)at searequirements and/or the installation ofsewage plants onboard the vessel.Confidence HighExtent Site-specific; limited to immediate areaaround the dredger.Duration Short-term; dispersal and dilution oftreated sewage will be rapid.Intensity NegligibleSignificance LowSpillages and transfer of wastes Status NegativePollution event(s) caused by the Probabilityaccidental spill or leak duringhandling, storage, transfer to shoreand disposal of hazardous waste(fuels, hydraulic oils, paints, Confidencechemicals, etc.), or supplies ExtentDurationIntensitySignificanceImprobable; due to strict control overlifting, transfer, packaging, storage anddisposal procedures, and the limited use ofhazardous materials onboard the vessel.HighSite-specific; limited to immediate areaaround the dredger during transfer.Short-termNegligibleLowDischarge of bilge and ballastwaterDischarge of pollutants in bilgewater and introduction of alienspecies through discharge of ballastwaterStatusNegativeProbability Improbable; due to adherence to MARPOLrequirements with regards discharge of oilywater and ballast waterConfidence HighExtent LocalDuration Short-term; dispersal and dilution ofcontaminants will be rapid.Intensity NegligibleSignificance Low4.3.5 Accidents & EmergenciesFire Status NegativeAir pollution and pollution from fire Probability Improbable; based on standards andfighting residues resulting from afire in any areaprocedures implemented and long trackrecord.Confidence MediumExtent Site-specific; limited to immediate areaaround the dredger.Duration Short-term; fires likely to be rapidlyextinguished.Intensity MildSignificance LowNamagroen Prospecting & Investments October 2008

Addendum to EMPR for Concessions 8(a), 9(a) and 8(b) 39Hydraulic fluid spills Status NegativeMarine pollution in the event of a Probability Improbable; based on standards andhydraulic fluid spill due to ruptureprocedures implemented and long trackof pipes /failure of hydraulicrecord.equipment which cannot be Confidence Highcontained on the vesselExtent Site-specific; limited to immediate areaaround the vessel.Duration Short-term; dispersal of low volume spillswill be rapid.Intensity MildSignificance LowRe-fuelling spillages Status NegativeMarine pollution from small spills Probabilityduring connection anddisconnection of refuelling hoseswhile oil bunkeringConfidenceExtentDurationIntensitySignificanceConfidenceExtentDurationIntensityImprobable; based on standards and strictcontrol and procedures implemented andlong track record.MediumSite-specific; limited to immediate areaaround the dredger during transfer.Medium- to Long-term; bunker fuels aremore persistent and likely to have physicalimpacts on wildlife.Mild to Moderate; oil bunkering takes placeunder controlled conditions in port only.LowGrounding / sinking of dredger Status NegativeMarine pollution caused by thegrounding or sinking of the dredgerProbability Unknown, the likelihood of oil spillsresulting from possible accidents duringduring nearshore dredgingdredging, or from massive oil spills as aoperations and/or discharge ofresult of wreckage, depend on the vesselsediments to landcapabilities whilst operating anddischarging in very shallow water.SignificanceHighRegional / National; oiled seabirds or sealsthat feed in the area may utilise distantbreeding sites; slicks may be dispersedalongshore.Medium- to Long-term; bunker fuels aremore persistent and more likely to havephysical impacts by potentially reducingbreeding success of affectedseabirds/seals.Severe; if the affected seabirds/marinemammals die, or their breeding success isreduced.High; where species endemic to southernAfrica are affected, impacts would haveinternational implications through theBiodiversity Convention and IUCNconservation classification.Namagroen Prospecting & Investments October 2008

Addendum to EMPR for Concessions 8(a), 9(a) and 8(b) 40Mitigation Measures and Management ActionsManagement actions should include:- Maintain high safety standards and employ “good housekeeping” onboard the vessel.- Ensure that stringent waste management practices are in place onboard vessels.- Ensure that oil spill contingency plans, adequate insurances and internationallyaccepted onboard environmental management systems are in place for the miningvessels. These should incorporate plans for emergencies.4.3.6 Onshore Gravel ProcessingThe land-based operations associated with the project will be located in Sand Bay to the southof the town of Hondeklipbaai, and will extend from a few metres to a few hundred metresinshore of the high water mark.The reclamation dam, processing facility and associated infrastructure will be located withinthe non-operational Hondeklipbaai Mine property managed by the Trans Hex Group. Theterrestrial footprint of the project is therefore embedded in previously disturbed areas, and inmost cases will utilise existing infrastructure.The gravel processing and accommodation facilities at Hondeklipbaai fall into the Spoeg Rivercatchment area. As fresh water consumption at the plant site and accommodation facilitieswill be restricted to that necessary for domestic use, the fresh water demand is thusinsignificant. No watercourse is impacted by the operations of the gravel processing facility.Tailings from the processing facility will be transported by truck and trailer to an old miningexcavation on the Hondeklipbaai Mine. As vehicles will use mainly tertiary gravel roads, theimpact of gravel-transporting vehicles on existing traffic densities is negligible. Public usage ofthese roads is limited, and interaction between mining vehicles and other traffic is thereforeinsignificant.Construction of Treatment Plantand Reclamation AreaConstruction will be accompaniedby:- the clearing of vegetation, soiland associated biota,- potentially impacting localisedpopulations of endemic and nearendemicplant species,- establishment of infrastructure(treatment plant and offices,power, water and fuel supply,handling and storage),- visual impacts of associatedinfrastructure, reclamation pond,tailings heaps etc.StatusProbabilityConfidenceExtentDurationIntensitySignificanceNegativeHighly probable; although the area isalready severely disturbed, establishedvegetation is present.HighSite-specific.Medium- to Long-term; restoration ofdisturbed areas and successful restorationof plant communities usually takes >1 year,even where intervention is intensive.Mild; although the total area of vegetationaffected is relatively large, the vegetationand soils have already been impacted.LowNamagroen Prospecting & Investments October 2008

Addendum to EMPR for Concessions 8(a), 9(a) and 8(b) 41Stockpiling of marine gravels Status NegativeStockpiling of large volumes of Probabilitymarine sediments on land may :- disturb or smother terrestrialplants and animals and damage /destroy coastal habitats,- change the sediment compositionand soil chemistry, thereby Confidenceaffecting the rehabilitation Extentpotential.DurationIntensitySignificanceHighly probable; although mined sedimentswill be stockpiled in areas which arealready severely disturbed, sedimentcomposition and soil chemistry is likely tobe altered sufficiently to compromise therehabilitation potential of the area.HighSite-specific.Long-term; for the duration of the projectand thereafter.Severe; the biota in the area of thereclamation dam will be eliminated.MediumDisposal of recovery tailings Status PositiveTreatment of the marine sediments Probability Definite; recovery tailings are anproduces recovery tailings, whichwill be used to back-fill mined-outunavoidable product of land-based graveltreatment.areas.Confidence HighExtent Site-specific.Duration Long-term; back-fill areas will re-vegetatenaturally over a period of decades.Intensity NegligibleSignificance MediumDisposal of fine tailings Status NegativeScreening of marine gravels Probabilityproduces small quantities of finetailings, which will be discardedinto a settling pond with the Confidence Mediumprocess water, thereby potentially- contaminating groundwater,- changing the sedimentExtentcomposition, soil chemistry andwater retention properties, therebyDurationaffecting the rehabilitationpotential of settling pond areas,- posing a risk to animals andIntensityhumans if they fall intounconsolidated tailings ponds,- fine dust associated with dry Significance Lowtailings.Improbable; as the quantities discardedare relatively small and they constituteprimarily sands.Site-specific.Long-term; for the duration of the projectand until settling pond areas have beenrehabilitated.Negligible; fine tailings volumes will beinsignificant.Namagroen Prospecting & Investments October 2008

Addendum to EMPR for Concessions 8(a), 9(a) and 8(b) 42Production of dust duringtransport of tailingsTrucking of discard tailings ongravel roads will result in increasedproduction of dust. This may:- impair vegetation growth andreproduction, and decreasepopulation sizes in the vicinity ofthe roads.Increased traffic on roads andaccess routesIncreased traffic associated withmining activities may:- increase the accident risk withlocal traffic in the town, orrecreational traffic along the coast,- lead to accidents with largemammals, thus impacting on theirpopulation sizes.StatusProbabilityConfidenceExtentDurationIntensitySignificanceStatusProbabilityConfidenceExtentDurationIntensitySignificanceNegativeProbable; dust will definitely be produced,but due to high winds in the whole region,will be dissipated quickly.MediumSite-specific to Local; ranging from theimmediate vicinity of the plant to furtherafield in the case where tailings aretransported to the discard pits.Long-term; the impairment of physiologicalprocesses to the extent that theyinfluences population sizes will occur overmany years.Negligible; the total area of the impactsare unlikely to be large enough tosignificantly impact on population sizes.LowNegativeImprobable; the increase in traffic isunlikely to be large enough to have anadded effect to what is already occurring.MediumSite-specific to LocalMedium- to Long-term; for the duration ofgravel processing activities.MildLowPotable water consumption Status NegativeExpansion of mining operations Probability Highly probableresults in increased requirements Confidence Highfor potable water.Extent Site-specific.Duration Medium- to Long-term; for the duration ofthe project.Intensity MildSignificance LowConsumption of electricity Status NegativeDepletion of non-renewable Probability Definite (impact will occur regardless ofresources through increaseprevention measures).electricity consumption for Confidence Highpowering of machinery and Extent Regional to Internationalinfrastructure. This may:- increase the carbon footprint ofthe company at a time that itDuration Long-term to Permanent ; the impacts ofhigh carbon levels in the atmosphere willbe felt for generations.should be declining,Intensity Mild; the level of usage is minimal relativeto that used by the mines in the vicinity.Significance LowNamagroen Prospecting & Investments October 2008

Addendum to EMPR for Concessions 8(a), 9(a) and 8(b) 43Mitigation Measures and Management ActionsManagement actions should include:- Wherever possible, stockpile marine gravels only in previously disturbed areas.- Re-use tailings for backfilling excavations, and for dust control around offices.- Confine tailings dumps to mineral processing area.- Wet haul roads with grey water / sea water whenever necessary.- Limit speed to 50 km/h in areas at risk.- Implement and rigorously enforce potable water and electricity saving measures.- Make all employees aware of the importance of saving water and electricity.- Install only low-flush toilets and low pressure taps and showers, and use low-energydevices wherever possible.- Preferentially use desalinated seawater and recycled water where at all possible.4.3.7 Waste Management and Pollution Control on LandThe types of wastes generated at the land-based infrastructure will include:- gas emissions from engine/generator exhausts utilising gas oil;- various used hydrocarbon substances (including hydraulic and lubricating oils andsolvents);- sewage and organic wastes; and- domestic refuse.Production and disposal ofsewage, waste oil and solid wasteIncrease mining operations in anarea require an increase staffcomplement, with concomitantincreases in the production ofdomestic and industrial wastes, andsewage. This may:- increase health hazards to humansand animals.StatusNegativeProbability Probable.Confidence HighExtent Site-specific; restricted to plant andaccommodation site.Duration Medium- to Long-term; depending on thetype of waste, degeneration times canextend over years or even decades.Intensity Mild; the total amount of sewage and solidwastes is unlikely to be significantly morethan what is already being produced.Significance LowSpillages and transfer of wastes Status NegativePollution event(s) caused by: Probability Probable.- accidental spills or leaks during Confidence Highhandling, transfer, storage and Extent Site-specific; limited to immediate areadisposal of hazardous wastes (fuels,around the plant.hydraulic oils, paints, chemicals, Duration Long-term; diesel and hydrocarbons persistetc.), or supplies,in soils for decades if not actively- equipment maintenance (vehiclesbioremediated.and machinery).IntensitySignificanceNegligibleLowNamagroen Prospecting & Investments October 2008

Addendum to EMPR for Concessions 8(a), 9(a) and 8(b) 44Air Quality Status NegativeExceeding international standards Probabilityfor exhaust emissions of NOx, SOx,CO 2 , Volatile Organic Carbons(VOCs) from plant, or exceeding Confidencehealth and safety standards due to Extentdust generation during on-shoreoperations.DurationIntensitySignificanceImprobable; due to the limited use ofhydrocarbons, and close proximity to theshore.HighSite-specific to local; primarily confined tothe plant site, but extending beyond duringgravel transport.Short-term; dilution of emissions will berapid.NegligibleLowMitigation Measures and Management ActionsManagement actions should include:- Ensure that stringent waste management practices are in place at all times.- Maintain high safety standards and employ “good housekeeping” on the plant site.This should incorporate plans for emergencies.- Use appropriate fuel and oil storage containers, and regularly inspect theirintegrity. All containers must be bunded against accidental spillage.- Use drip trays and bunding where losses are likely to occur.- Dispose of waste fuel and oil into suitable containers for collection by Shell OilCompany on a regular basis for recycling.- Collect and dispose polluted soil at appropriate bio-remediation sites.4.3.8 Socio-economicsEmployment Status PositiveThe proposed dredging operations Probability Definitive; if project is implemented.and land-based processing will Confidence Highprovide employment for 34 people Extent Mostly local and national, limitedthereby boosting local economyinternational impact; employees aremostly South Africans.Duration Medium-term; for the “quick win”scenario.Long-term; if the project continues in thefuture.Intensity MildSignificance MediumNamagroen Prospecting & Investments October 2008

Addendum to EMPR for Concessions 8(a), 9(a) and 8(b) 45Training and skills transfer Status PositiveTraining and development of new Probability Definite; if the project proceeds.employees will take placeConfidence HighExtent National; upliftment of South African fromall regions.Duration Long-term to Very long-term; over theproject life span and beyond.Intensity Mild; limited to general training anddevelopment; no specific gains in terms ofskills transfer are expected.Significance LowThe planned capital expenditure for the project for 2009 is R 30 million. Revenue toNamagroen will total R80 million, with R120 million being paid to the dredging contractor. Anestimated 5% of profits will be paid to the Government in the form of diamond tax.Payment of Taxes / Royalties Status PositiveContribution to national economy Probability Definitivethrough payment of taxes and Confidence MediumroyaltiesExtent National to International; Namagroen willalso use international contactors andvendors for dredging-related operations.Duration Medium- to Long-term; for the duration ofthe project.Intensity ModerateSignificance Low4.4 Conclusions of this AssessmentThis EMPR has carried out an assessment of potential impacts resulting from the proposeddredging operations in Concessions 8(a), 9(a) and 8(b). Most impacts predicted are negativeand of low to medium significance due to the location of target areas in the dynamic waveinfluencednearshore zone, and land-based infrastructure in previously disturbed areas.4.4.1 Positive AspectsTwo positive impacts of medium significant were identified, namely the infilling of mined-outpits thereby contributing to the rehabilitation of these long-term disturbances of the terrestrialenvironment, and the provision of employment.4.4.2 Negative AspectsThree highly significant negative aspects were identified:• Removal of sediments during mining and destruction of associated organisms (Definite).• Chronic impacts of macrofaunal communities through repeat mining before affectedbiota have fully recovered (Probable).Namagroen Prospecting & Investments October 2008

Addendum to EMPR for Concessions 8(a), 9(a) and 8(b) 46• Effects of an accidental oil spill on the marine environment, especially seabirds,through grounding or sinking of the dredger (Unknown, as it depends on the vesselcapabilities).Since the loss of organisms in the mining area due to the removal of sediments is anunavoidable impact of mining operations, there can be no mitigation.Proposed mitigation measures that will bring the other aspects to acceptable levels are:• To allow impacted communities to recover to functional similarity, mining target areasshould preferably be mined to completion, and then not be re-visited for at least fiveyears. Efficient, high intensity mining methods are thus preferable to repeated, smallerscale operations, provided that the larger scale operations do not cause unacceptableimpact on adjacent sensitive rocky-outcrop areas.• Determine and clarify the capabilities of dredgers to operate in inshore waters on theSouthern African west coast, and what measures are in place to prevent these fromwrecking in adverse weather and sea conditions. Ensure that oil spill contingency plansand adequate insurances are in place. Reduce the probabilities of accidental and/oroperational spills through enforcement of stringent onboard oil spill managementsystems, which should incorporate plans for emergencies.Aspects assessed with medium significance are:• Habitat alteration due to excavation of sediments when dredging in deeper water in the(b)-concession (Definite).• Smothering of vulnerable deep water reef habitats and associated biota adjacent to themining targets by depositing overspill (Highly Probable).• Effects on archaeology – wrecks and buried terrestrial artefacts (Unknown butImprobable).• Impacts on the terrestrial environment from stockpiling of marine gravels (Highlyprobable).Since the removal of sediments is an unavoidable impact of mining operations, there can be nomitigation.Because the archaeological value of the area is largely unknown, the precautionary principleshould be applied. The mitigation measures proposed for shipwreck material or otherarchaeological artefacts encountered in the course of mining or land-based processingoperations are:• Immediately inform the Project Manager who will inform the South African HeritageResources Agency (SAHRA).• Retain artefacts recovered and where possible take photographs of them. Note thedate, time, location and types of artefacts found in the Operator’s logbook.• Contract a marine archaeologist to survey the site (if feasible).• Avoid mining within 500 m from the centre of the site until the area has been surveyedand clearance to continue activities has been obtained from the National MonumentsCouncil.Namagroen Prospecting & Investments October 2008

Addendum to EMPR for Concessions 8(a), 9(a) and 8(b) 47Mitigation measures recommended to ensure that impacts associated with land-basedoperations are minimised include:• avoiding areas where vegetation has recovered after historic disturbance until thestatus of the plant communities has been documented by an appropriate vegetation andrehabilitation specialist;• stockpiling marine gravels only in previously-disturbed areas, and keeping thereclamation area to the minimum required for operations.Given the limitations imposed on nearshore mining operations by the sea conditions, and thearea’s current low level of use, the actual and potential negative effects of the proposedoperations will not be substantial if properly managed, and will be outweighed by the potentialbenefits accruing to society. If the management procedures and guidelines contained in Part Bare implemented and adhered to, the negative effects should be reduced to a level acceptableto all stakeholders and interested parties.4.5 Assessment of Cumulative ImpactsEvaluation and monitoring of the cumulative impacts of mining are important aspects toconsider. Cumulative impacts can be separated into three main categories:• Impacts arising as a consequence of the “knock-on” effects of an activity (e.g. uncontainederosion of roads and tracks used to access mining sites, damage to vegetation, disturbanceof seals, seabirds and terrestrial animals, effects on eco-tourism),• Impacts resulting from multiple effects of the same activity (e.g. repetitive mining of thesame bay), and• Impacts arising due to increases of an activity on a spatial and temporal scale (e.g. increasein number of mining vessels).Most of the incidental or “knock-on” impacts, as well as multiple effects of the same activity inthe concessions under review are covered in this EMPR. Management of these throughmitigation and/or monitoring will be implemented as part of the EMP, and the informationforwarded to DME on a regular basis. Cumulative impacts arising due to increases in dredgingon a spatial and temporal scale are, however, difficult to assess at this stage, and wouldrequire co-ordinated monitoring of biological and physical impacts by all mining companiesoperational along the coast.The BCLME Project on cumulative effects of marine diamond mining operations on the SouthAfrican and Namibian coastlines (Penney et al. 2007) placed mining impacts in context with thenatural disturbances inherent in the Benguela ecosystem. This study suggested that at themining rates currently typical of inshore areas in the scope of the proposed dredging project,there is no cause for concern of enduring cumulative impacts. Nonetheless, if dredging provesto be a feasible approach to diamond production on the 8(a), 9(a) and 8(b) Concessions,Namagroen should consider implementing monitoring programmes to ascertain the magnitudeNamagroen Prospecting & Investments October 2008

Addendum to EMPR for Concessions 8(a), 9(a) and 8(b) 48and duration of dredging impacts on benthic communities, and be in a state of readiness toimplement mitigation measures if any cumulative impacts are detected.4.6 Monitoring RecommendationsConfidence in impact predictions for the proposed dredging project is relatively high.However, baseline and monitoring data should be collected prior to, during and afteroperations, from control and impact sites, to inform the assessment and to improve theaccuracy of predictions for expanded mining operations. Well-structured baseline andmonitoring surveys of key aspects should therefore be implemented and continued duringfuture dredging operations. Recommendations for such studies are detailed below:• Monitoring of suspended sediment concentrations and water quality in the vicinity ofdredging and at the discharge points of the reclamation area is essential in establishingcompliance with the water quality guidelines.• Conduct high resolution geophysical surveys (SSS and seismic profiling) of the dredgetargets prior to dredging, and then ~1 year post-dredging (2-3 years post dredging whentargeting Concession 8(b))to determine the depth, wall steepness and infilling rates ofthe dredged areas.• Develop a carefully designed Before-After/Control-Impact benthic macrofaunalmonitoring programme and implement this programme before operations commence.Surveys using relevant benthic sampling techniques should be conducted prior todredging, and regular monitoring of impacted sites should commence once geophysicalsurveys have determined that sufficient infilling of dredge pits has occurred to enablequantitative grab sampling (~1-2 years after disturbance). In this way recovery ofbenthic communities following dredging can be monitored.• A mammal watch programme should be put in place during dredging and dischargeoperations. The number of large mammals sighted, together with their proximity to thevessel and behaviour patterns should be recorded.• Measure and periodically assess the levels of water and electricity consumption at theproject site and implement extra saving measures where necessary.• Monitor the production of waste and the amount of waste that is recycled. Frequentlyassess the integrity of all waste storage containers.4.7 ConclusionIf all environmental guidelines, appropriate mitigation measures and monitoringrecommendations in line with the Environmental Management Plan are implemented, there isno reason why the project should not proceed.Namagroen Prospecting & Investments October 2008

Addendum to EMPR for Concessions 8(a), 9(a) and 8(b) 49PART BENVIRONMENTAL MANAGEMENT PLAN1. IntroductionNamagroen's Environmental Management Plan for dredging operations outlines how Namagroen,and it’s contractor Geo-Mining intend to manage all activities that will significantly impact onthe environment, or that may potentially be of high risk in the long-term. By implementingthis management plan, Namagroen aims to minimise environmental damage.Namagroen’s commitments to responsible and sound environmental management of all itsactivities are reflected in its Environmental Policy.1.1 Environmental ObjectivesNamagroen's environmental objectives for this EMP are as follows:EMP ProcessTo achieve all actions plans outlined in this EMP, including compilation of a PerformanceAssessment for proposed dredging operations.Vessels at SeaTo minimise disruption to other legitimate users of the marine environment by respecting theirrights, effectively managing waste flows to minimise marine and air pollution using a cradle-togravephilosophy, promoting reuse/recycling, and being conservative in use of naturalresources.Land-based OperationsTo use existing facilities where possible, thereby minimising disturbance of terrestrial flora andfauna. The use of materials, energy, water and the environmental impacts of emissions,effluent, waste, goods and services will be monitored and measured, so as to conserve naturalresources and prevent pollution. To effectively manage waste flows to minimise pollutionusing a cradle-to-grave philosophy, promoting reuse/recycling, and being conservative in use ofnatural resources. To undertake appropriate rehabilitation during and after mining operations.EmergenciesTo have appropriate systems in place to deal with emergencies to cater for at least legalrequirements.Socio-Economic IssuesTo make a contribution to the local economy, particularly in Hondeklipbaai.Namagroen Prospecting & Investments October 2008

Addendum to EMPR for Concessions 8(a), 9(a) and 8(b) 501.2 Action Plans and Control MeasuresThe Environmental Management Plan has been summarised into tabular form, for ease ofreference and for subsequent performance reporting. Both the operational anddecommissioning phase and closure are covered. The table is structured according to the EMPenvironmental objectives as outlined above, and details:• the activities;• applicable legal and other requirements aspects;• the environmental aspects and associated environmental impacts;• the management objectives;• the action plans and control measures; and• the personnel responsible for the management of these impacts.The first two sections of the Table relate to the EMPR process. The remaining sections coverall impacts of marine- and land-based operations. The final section covers aspects of themonitoring plan for the proposed dredging project.Generic environmental issues of concern typical to mining operation are addressed. This EMPtherefore covers items of specific consequence to the dredging and processing activities. Itdoes not cover health and safety issues since these are documented elsewhere.The Environmental Management Plan also forms the bulk of the legally binding agreement thatstipulates how the environmental monitoring, management and mitigation undertakenregarding the dredging operations will be conducted. These commitments will become part ofthe authorisation agreement between Namagroen and the Government of the Republic of SouthAfrica, represented by the Department of Minerals and Energy (DME), required to obtainauthorisation to conduct the proposed operations. Non-compliance with the specifiedmanagement actions and standards could result in government permits being withheld.Namagroen also carry full responsibility for the actions of contractors hired to carry out aspectsof the project.1.3 Monitoring, EMP Performance Assessment and Submission of Information1.3.1 Monitoring and ongoing assessment of impactsThe monitoring of activities with significant impacts is detailed in the EMP Table, giving theobjectives, description, compliance points where relevant and the timing of monitoring.Section 1 of Table B.1.1 outlines the procedure used for continually ensuring that all existingand new or modified activities, products and services are evaluated against standard criteria todetermine the significance of their aspects/impacts, and to ensure that the necessary action istaken to mitigate negative and enhance positive impacts.In order To ensure for continual improvement and full compliance with the managementprocedures of Namagroen’s EMP, environmental records will be captured regularly, andforwarded to the Operations Manager on a monthly basis. Non-conformance records will beforwarded immediately after the event.Namagroen Prospecting & Investments October 2008

Addendum to EMPR for Concessions 8(a), 9(a) and 8(b) 511.3.2 EMP Performance AssessmentEMP AuditingNamagroen is committed to conducting regular environmental audits to evaluate complianceand effectiveness of the EMP, as well as compliance with statutory requirements. This includesboth internal audits and external surveillance audits.Submission of informationOn an annual basis, a written Environmental Performance Report will be submitted to theDepartment of Minerals and Energy demonstrating compliance with the EMP, statutoryrequirements, as well as ongoing assessment of impacts and gathering of information1.4 Applicable Legal and Other RequirementsThis includes all authorisations and permissions granted (e.g. mining licences), applicationssubmitted (e.g. safety certificates, storage of fuel/oil, oil spill notification), and exemptions(e.g. proximity to whales, effluent disposal), and current and future applicable legal and otherrequirements.1.5 Financial ProvisionProtection and Indemnity (P&I) Insurance Cover will be maintained by the dredging contractorto allow for cleanups in the event of oil spills, and for other eventualities. Ultimate costs forfinal rehabilitation of disturbed onshore areas are carried by Geo-Mining. Rehabilitation andrestoration activities that are run concurrently with mining activities are covered by currentoperational budgets.1.6 ResponsibilitiesThe responsibility for the implementation of all management actions specified inenvironmental management and monitoring plans rests with Geo-Mining. Although the personsresponsible for specific management actions outlined in the EMP have not as yet been assigned,Geo-Mining will appoint appropriate resource to effectively manage the various aspects of theEMP before commencement of operations.1.7 Decommissioning and ClosureActive rehabilitation of the marine environment below the LWM is not required, asrehabilitation within this highly dynamic nearshore area is a naturally occurring process.Restoration and rehabilitation of areas disturbed by Namagroen’s mining operations thusapplies to the gravel processing facility at Hondeklipbaai as well as infrastructure associatedwith gravel discharge.Namagroen and Geo-mining are committed to full restoration and rehabilitation of damagecaused to the coastal zone environment as a consequence of activities incidental to theirmining operations, and will be undertaken to the satisfaction of the DME.Namagroen Prospecting & Investments October 2008

Addendum to EMPR for Concessions 8(a), 9(a) and 8(b) 52Table B.1.1: Environmental Management Plan for proposed dredging operations, including land-based treatment of gravels.1. SYSTEM ADMINISTRATIONManagement Objectives:SYSTEM ADMINISTRATION−−−−−−−−Employ the EMP process so that operations are conducted in an environmentally responsible manner,Achieve all action plans outlined in the EMP, including continued consultation with all stakeholders and compilation of Performance Assessments,Increase understanding about potential impacts of dredging operations and environmental management,Instil in all staff and contract workers an ethic of environmental responsibility,Maintain good relations with stakeholders on environmental matters of mutual concern,Promote industrial relations, and otherwise contribute to socio-economic stability,Optimise economic benefits to people of South Africa and particularly coastal communities, where feasible, andPlan and make adequate provision for rehabilitation and restoration of impacts.# ASPECT IMPACT DESCRIPTION MITIGATION MEASURES AND MANAGEMENT ACTIONS1.1 Implementation of theEMPImproved EnvironmentalManagement and Awareness‣ Define the roles, responsibilities and authorities of staff members (and anyspecialist consultants) responsible for implementation of the various facets ofthis EMP.‣ Address training needs of staff required to implement specialised aspects ofthe EMP.‣ Incorporate environmental impact considerations into criteria for mineplanning (including equipment design, operating strategies, procurement ofgoods and services).‣ Establish liaison with marine users and government agencies to inform them ofoperational plans and ascertain who interested and affected parties may bethat should be contacted;‣ Plan and make adequate provision for rehabilitation and restoration activitiesto run concurrently with mining activities.‣ Maintain records of plans, decisions, data collected, communications made,emergency responses, etc., which document the implementation of the EMP.RESPONSIBLEPERSON/SNamagroen Prospecting & Investments October 2008

Addendum to EMPR for Concessions 8(a), 9(a) and 8(b) 53SYSTEM ADMINISTRATION# ASPECT IMPACT DESCRIPTION MITIGATION MEASURES AND MANAGEMENT ACTIONS1.2 Internalcommunication aboutthe EMP1.3 Instructions to allstaff, includingcontractors1.4 EMP Monitoring andPerformanceAssessmentsImproved EnvironmentalManagement and AwarenessImproved EnvironmentalManagement and AwarenessImproved EnvironmentalManagement and Awareness‣ All personnel and contractors will be made aware of the contents ofNamagroen’s Environmental Policy Statements.‣ All personnel who are in a position to make decisions or take actions that willinfluence environmental protection and management will be made aware ofthe contents, and their respective responsibilities for implementation, of theEMP.‣ Specify the job description and responsibilities of persons involved inenvironmental management.‣ Provide instructions and appropriate training to all staff about aspects of theEMP that affect their specific work, including hydrocarbon pollution preventionand clean-up, general waste management, protection of natural resources,and rehabilitation.‣ Incorporate environmental aspects and management interventions applicableto particular outsourced tasks into contracts and where applicable inperformance appraisals to improve environmental awareness and performance,and specify penalties when necessary for non-compliance.‣ Report all environmental incidents.‣ Undertake formal EMP performance assessments every 12 months to checkprogress in meeting the objectives and targets of this EMP.‣ Compile and submit annual reports to the Director: Mineral Development,Department of Minerals & Energy (DME) on the implementation of the adoptedenvironmental plan.‣ Request the DME to acknowledge receipt of the Report, and to contactNamagroen within 4 months should they wish to respond on significant issues.RESPONSIBLEPERSON/SNamagroen Prospecting & Investments October 2008

Addendum to EMPR for Concessions 8(a), 9(a) and 8(b) 54SYSTEM ADMINISTRATION# ASPECT IMPACT DESCRIPTION MITIGATION MEASURES AND MANAGEMENT ACTIONS1.5 EMP Amendments Improved EnvironmentalManagement and Awareness1.6 Communications withstakeholders1.7 Pecuniary provision/Allocation ofenvironmentalManagement FundingImprovedrelationshipsstakeholderImproved EnvironmentalManagement‣ On an ongoing basis, assess the applicability of actions and activities requiredby the EMP, identify and address all new environmental issues arising fromchanged operations and/or communications with interested parties, throughamendments to the EMP if/where necessary.‣ Communicate and consult with I&APs to inform them of proposed changes andaddress any concerns if/when necessary.‣ Submit revised and amended Environmental Management Programme Reportsto the DME as and when required.‣ Request the DME to acknowledge receipt of the Report, and to contactNamagroen within 4 months should they wish to respond on significant issues.‣ Maintain an up-to-date I&AP database.‣ Maintain open communication with relevant stakeholders informing them ofproposed changes to the EMP, addressing any issues of concerns that mayarise, maintain records of communications, and where relevant, address theirneeds.‣ Keep a record of all communications with interested parties, the points raised,and how these points have been addressed.‣ Participate actively in appropriate fora to share information and co-operatewith other stakeholders and resource managers on matters applicable to themarine environment‣ Allocate operational costs to meet EMP objectives, including all associatedrequirements, e.g. funding of research and monitoring to understand, andwhere possible, mitigate impacts.‣ Maintain Protection and Indemnity (P&I) Insurance Cover to allow for cleanupsin the event of oil spills, and for other eventualities.RESPONSIBLEPERSON/SNamagroen Prospecting & Investments October 2008

Addendum to EMPR for Concessions 8(a), 9(a) and 8(b) 55SYSTEM ADMINISTRATION# ASPECT IMPACT DESCRIPTION MITIGATION MEASURES AND MANAGEMENT ACTIONS1.8 Notification to DME ofintention to start orstop miningImprovedrelationshipsstakeholder‣ Notify the Director: Mineral Development of DME in writing, at least 14 days inadvance of any commencement or cessation of activities, and provideparticulars regarding the location, nature and extent of such operations.RESPONSIBLEPERSON/S1.9 Mine Closure Rehabilitation of terrestrialdisturbance‣ When Namagroen intends closing an operation as contemplated in the Act, afinal EMP performance assessment shall be conducted and a report shall besubmitted to the satisfaction of the Director: Mineral Development to ensurethat:- The requirements of the relevant legislation have been complied with;- The closure objectives as described in the EMP have been met;- All residual and latent environmental impacts resulting from Namagroen’soperations have been identified, and the risks thereof have beenidentified, quantified and arrangements for the management thereofhave been finalised.‣ Namagroen will undertake rehabilitation, as required in their Closure Plan,until the Director: Mineral Development of DME issues a closure certificate.Namagroen Prospecting & Investments October 2008

Addendum to EMPR for Concessions 8(a), 9(a) and 8(b) 562. SAFETY, HEALTH AND ENVIRONMENTAL MANAGEMENTManagement Objectives:SAFETY, HEALTH AND ENVIRONMENTAL MANAGEMENT−−−−Prevent and/or minimise air pollutionComply with the standards in the Labour Act and mining regulationsComply with occupational standards regarding exposure to dust and noiseComply with international recommendations regarding the use of CFCs# ASPECT IMPACT DESCRIPTION MITIGATION MEASURES AND MANAGEMENT ACTIONS2.1 MaintainEnvironmentalManagement(EMS)System2.2 Integration ofEnvironmentalManagement2.3 International SafetyManagement (ISM)Code for the SafeOperation of Ships andforPollutionPreventionImproved EnvironmentalManagementImproved EnvironmentalManagement‣ Ensure that all requirements of the Company’s Environmental ManagementSystem are met, including compliance with legislation, environmentalawareness training, environmental monitoring, waste management andpollution control.‣ Submit copies of External Audit Reports with Environmental PerformanceReports to relevant authorities.‣ Include environmental management in Namagroen’s Strategic Long-termBusiness Plan, by integrating environmental management through all phases ofthe life cycle of the mine, starting with the Exploration Phase.‣ Integration of future mine plans with proposed Marine Protected Areas in thelong-term.Improved Health and Safety ‣ Ensure compliance of the contracted vessels with the International MaritimeOrganisation’s International Safety Management (ISM) Code developed for theproper development, implementation and assessment of safety and pollutionprevention management in accordance with good practice.‣ Ensure that the required external assessments of compliance to the ISM Codeare conducted.‣ Submit certificates of compliance with Environmental Performance Reports tothe relevant authorities.RESPONSIBLEPERSON/SNamagroen Prospecting & Investments October 2008

Addendum to EMPR for Concessions 8(a), 9(a) and 8(b) 57PROSPECTING AND DREDGING3. PROSPECTING AND DREDGINGManagement Objectives:− Minimise direct effects on the marine environment such as damage to, or loss of, benthic habitat− Minimise disruption to other legitimate users of the sea by respecting their rights− Minimise conflict between the fishing industry and diamond mining by maintaining open and frequent communications− Prevent pollution of marine habitats and resources− Effectively manage waste flows to reduce wastage and promote reuse/recycling of resources− Undertake research and monitoring of the direct impacts of sampling/mining on the environment− Manage mining-related impacts on the marine environment to avoid compromising future exploitation of renewable marine resources− Monitor the information base that will provide improved insight into the cumulative impacts of mining on marine biota− Establish recovery rates of marine habitats impacted or destroyed during mining and allow for recolonisation of areas within a reasonable period of time− Protect key habitats of high ecological sensitivity and importance (e.g. nearshore reef areas and kelp beds)− Minimise conflict between the fishing industry and diamond mining by maintaining open and frequent communications− Protect archaeological and historic sites thereby preventing the loss of information and research material− Promote information exchange with all relevant stakeholders# ASPECT IMPACT DESCRIPTION MITIGATION MEASURES AND MANAGEMENT ACTIONS3.1 Presence of miningvesselsPotential exclusion ofalternative resource use(e.g. rock lobster fishing,shipping)‣ At least 14 days in advance of commencement of dredging activities:- notify the DME in writing providing particulars regarding the location,nature and extent of such operations.- notify other potential user groups (maritime authorities, fishing industry)in the area in writing, providing particulars regarding the location, natureand extent of such operations.- request in writing the SAN Hydrographic Office at Silvermine to put outRadio Navigation Warnings of intended activities, light buoys andexclusion zones throughout the operational period, and to publishparticulars in the Notices to Mariners.‣ Inform the SAN Hydrographic Office on completion of operations.‣ In the vessel logbook, record sightings of and interactions with other vessels tonote potential conflicts over rights of passage and access to resources.RESPONSIBLEPERSON/SNamagroen Prospecting & Investments October 2008

Addendum to EMPR for Concessions 8(a), 9(a) and 8(b) 58PROSPECTING AND DREDGING# ASPECT IMPACT DESCRIPTION MITIGATION MEASURES AND MANAGEMENT ACTIONS3.2 Presence of miningvessels3.3 Presence of miningvessels3.4 Presence of miningvesselsScheduling of dredgingoperationsExclusion zone arounddischarge pipelineVibration or noisedisturbance of marinemammals and seabirds,accidental loss of fish orlobsters, loss of habitat,food source andrecruitment areas,entanglement of marinemammals3.5 Refuelling Pollution of the sea bybunker fuel and/or gas oil3.6 Release of ballastwaterMarine pollution andintroduction of alienspecies‣ If feasible, schedule dredging operations to avoid potential conflict duringdredger discharge with the commercial rock lobster fishery operating in thearea between November and April.‣ Provide the rock lobster industry with maps indicating the exact location ofthe discharge pipelines and the extent of the exclusion zones.‣ Clearly mark any exclusion zones using light buoys and/or radar reflectors.‣ Maintain radio communication between the dredger and any lobster vessels inthe area whilst the dredger is in inshore waters.‣ Implement a Marine Life Sightings Programme (including turtles, jellyfish, rocklobsters and anything else of interest) from the contracted dredger, to recordthe presence, proximity to and behaviour patterns of marine mammals,particularly during operations.‣ To avoid disturbance of whales, vessels should not approach within 300 m of awhale whilst underway (particularly during dredging).‣ If a whale surfaces within this distance of the vessel when at anchor, or duringdischarging of dredged sediments, the vessel should remain stationary until thewhale has moved to a distance 300 m away.‣ Schedule dredging operations to avoid overlap with the presence of whales inthe area (June to November).‣ Undertake oil bunkering and refuelling of contracted dredger under controlledconditions in a harbour only.‣ In the event of an oil spill:- Follow the Shipboard Oil Spill Emergency Response Manual procedure.- Notify the Principle Officer of the nearest SAMSA office and the ChiefDirectorate of Pollution and Waste Management (DEAT) in Cape Town.‣ Ballast water may only be released when the vessel is more than 12 miles fromland and in water depths greater that 25 m.RESPONSIBLEPERSON/SNamagroen Prospecting & Investments October 2008

Addendum to EMPR for Concessions 8(a), 9(a) and 8(b) 59PROSPECTING AND DREDGING# ASPECT IMPACT DESCRIPTION MITIGATION MEASURES AND MANAGEMENT ACTIONS3.7 Incidental loss ofequipment3.8 Removal of sedimentduring dredgingSeabed hazards ‣ Maintain hazards database listing the type of gear left on the seabed with thedates of loss and locations and where applicable, the dates of retrieval.‣ If requested, report these data to the relevant authorities.Disturbance of benthiccommunities and habitat‣ Undertake to develop a biological monitoring programme using appropriatesampling techniques to assess:- impacts of dredging on benthic macrofaunal communities.- recovery rates of impacted communities.‣ Undertake to conduct benthic macrofaunal surveys to record seabedtopography and types of marine life present to gain an understanding of themarine environment, using a suitable sampling device or combination ofdevices, which include:- Grab sampling or box-coring surveys.- Video footage collected from a Remotely Operated Vehicle.- Geophysical (high resolution AUV) surveys.‣ Determine areas that could be considered as “conservation corridors” withinthe Namagroen Concession area in consultation with the South Africangovernment.‣ Calculate annual and cumulative mined areas and compare to limit of 1% peryear of the total concession area suggested by Currie et al. (2007).‣ Report to DME annually areas mined in terms of location and volume of gravelremoved.‣ Mine target areas to completion and avoid remining for at least five yearswhere possible, to allow communities to recover.RESPONSIBLEPERSON/SNamagroen Prospecting & Investments October 2008

Addendum to EMPR for Concessions 8(a), 9(a) and 8(b) 60PROSPECTING AND DREDGING# ASPECT IMPACT DESCRIPTION MITIGATION MEASURES AND MANAGEMENT ACTIONS3.9 Mining excavations Destruction of geologicalrecord, reorganisation ofsediment structures, andhydrological changes3.10 Hopper overspillduring dredging3.11 Hopper overspillduring dredging anddumping of dredgespoils‣ If requested, provide non-sensitive information on the geological record andsediment structure, derived from sampling, to specialist scientists.‣ Conduct high resolution geophysical (SSS, bathymetry and seismic profiling)prior to dredging, and of the target areas ~1-2 years post- dredging todetermine the depth, wall steepness and infilling rates of dredgingexcavations.Suspended sediment plumes ‣ During dredging operations:- Record wind speed and direction in vessel’s bridge log.- Conduct visual observations of the plumes.- Monitor the proportion of clay (

Addendum to EMPR for Concessions 8(a), 9(a) and 8(b) 61PROSPECTING AND DREDGING# ASPECT IMPACT DESCRIPTION MITIGATION MEASURES AND MANAGEMENT ACTIONS3.13 Archaeological Sites Destruction of wrecks ‣ Do not disturb in any way a shipwreck older than 60 years without a permitfrom SAHRA.‣ The following actions will be undertaken if shipwreck material is encounteredin the course of dredging:- Immediately inform the Project Manager who will inform the SAHRA;- Retain artefacts recovered and, where possible, maintain a photographicrecord. Note the date, time, location and types of artefacts found in thelogbook;- Contract a marine archaeologist to survey the site;- Avoid mining or prospecting within 500 m from the centre of the site untilthe area has been surveyed.RESPONSIBLEPERSON/SNamagroen Prospecting & Investments October 2008

Addendum to EMPR for Concessions 8(a), 9(a) and 8(b) 62ACCIDENTS AND EMERGENCIES4. ACCIDENTS AND EMERGENCIESManagement Objectives:− to have appropriate systems in place to deal with emergencies to cater for at least legal requirements# ASPECT IMPACT DESCRIPTION MITIGATION MEASURES AND MANAGEMENT ACTIONS4.1 Grounding / sinking ofvessel or vesselcollisionMarine pollution ‣ Seek to reduce the probabilities of accidental and/or operational spillsthrough enforcement of stringent oil spill management systems.‣ Prepare monthly fuel/oil consumption reports, which provide information onremaining oils onboard each unit.‣ Maintain all emergency procedures as required legally and by ISO 14001.‣ In the event of an emergency including fire, grounding or sinking, or oil spillfollow procedures in the Shipboard Emergency Response Manual, Shipboard OilPollution Emergency Plan, Shipboard Hazardous Spill Manual, and the FireAttack Plans and Muster Bills.‣ In the event of an oil spill, immediately notify the Principle Officer of thenearest SAMSA office and the Chief Directorate of Pollution and WasteManagement (DEAT) in Cape Town.‣ Provide the following information when reporting a spill includes:i) The volume of oil spilled (so DEAT can determine weather or not it issignificant)ii) The type and circumstances of incident, ship type, port of registry,nearest agent representing the ship’s companyiii) Geographic location of the incident, distance offshore and extent of oilspilliv) Prevailing weather conditions, sea state in affected area (wind directionand speed, weather and swell)v) Persons and authorities already informed of the spillvi) Estimates of the numbers of different species of mammals and seabirds inthe vicinity, and of the numbers of each species oiled.RESPONSIBLEPERSON/SNamagroen Prospecting & Investments October 2008

Addendum to EMPR for Concessions 8(a), 9(a) and 8(b) 63ACCIDENTS AND EMERGENCIEScont. ‣ In the event of an oil spill, where feasible, provide facilities to rescue,stabilise, and fly oiled seabirds to SANCCOB for further rehabilitation.‣ Inform SAMSA & DEAT in the event of fire, grounding or sinking, or collision.Namagroen Prospecting & Investments October 2008

Addendum to EMPR for Concessions 8(a), 9(a) and 8(b) 645. ONSHORE LOGISTICAL SUPPORT AND GRAVEL PROCESSINGManagement Objectives:ONSHORE LOGISTICAL SUPPORT AND GRAVEL PROCESSING−−−Minimise disturbance of fauna and floraeffectively manage waste flows to minimise pollution using a cradle-to-grave philosophypromoting reuse / recycling and being conservative in use of natural resources# ASPECT IMPACT DESCRIPTION MITIGATION MEASURES AND MANAGEMENT ACTIONS5.1 On-site mininginfrastructure andequipmentDamage to the terrestrialenvironment‣ As far as possible, use only existing infrastructure, facilities and services forland-based gravel treatment.‣ Develop and use infrastructure that does not degrade terrestrial habitats orthe aesthetic values of the coastal region.‣ All offices, housing and processing facilities at Hondeklipbaai must complywith building regulations and standards.‣ Compile layout plans demarcating the position of all infrastructurerequirements (roads, vehicle maintenance areas and processing areas etc) andif necessary submit these to the relevant authority for approval prior toconstruction.‣ Contact the relevant local authority to ascertain what planning regulationsapply to the erection of new structures.‣ Site land-based infrastructure only in previously disturbed areas.‣ Do not establish processing areas within 100 m of the edge of a river channelor estuary mouth.‣ Keep the laydown area required for land-based infrastructure to the absoluteminimum required for the planned construction and operations.‣ As far as possible, avoid disturbing vegetation that has re-establishednaturally.‣ Parking and storage areas should be kept to the absolute minimum requiredfor the construction and operational phases, in number and in surface area.RESPONSIBLEPERSON/SNamagroen Prospecting & Investments October 2008

Addendum to EMPR for Concessions 8(a), 9(a) and 8(b) 65ONSHORE LOGISTICAL SUPPORT AND GRAVEL PROCESSING# ASPECT IMPACT DESCRIPTION MITIGATION MEASURES AND MANAGEMENT ACTIONScont. ‣ Prevent pollution by providing and designating adequate facilities for storageand disposal of waste.‣ Ensure that the plant site is secure and contractors/staff have safe workingenvironment.5.2 Use and maintenanceof infrastructureroutesDamage to the terrestrialenvironment‣ Wherever possible use only existing, well-defined and stabilised roads whentransporting tailings from the plant to the disposal site.‣ To avoid proliferation of unnecessary tracks, restrict access to the reclamationsite to one demarcated road only.‣ Restrict vehicle movement to the clearly demarcated road network and ensurethat all mining staff and contractors adhere to this restriction.‣ Designate specific areas for parking, storage and work areas during anyrequired construction activities and assembly of equipment. These should beclearly demarcated, and adhered to during construction and operations.‣ Prohibit off-road driving.‣ Ensure roads have acceptable surfaces, are free from erosion, and haveeffective, natural drainage.‣ Maintain access roads in a good condition by implementing suitable trackmaintenance schedules.‣ During road maintenance, use only material from nearby existing borrow pits,processed plant tailings or beach material as surfacing material. Under nocircumstances should new borrow pits be created.‣ Implement all required safety measures when collecting road constructionmaterial and during transport thereof.‣ Limit traffic on the beach to the absolute minimum required.‣ Clearly demarcate all sensitive areas adjacent to the operation sites.RESPONSIBLEPERSON/SNamagroen Prospecting & Investments October 2008

Addendum to EMPR for Concessions 8(a), 9(a) and 8(b) 66ONSHORE LOGISTICAL SUPPORT AND GRAVEL PROCESSING# ASPECT IMPACT DESCRIPTION MITIGATION MEASURES AND MANAGEMENT ACTIONS5.3 Construction activities Concrete pollution ‣ Concrete must be transported onto site and no batching or mixing activities ofany kind should occur on site.‣ All visible remains of excess concrete and aggregate are to be physicallyremoved on completion of each plaster or concrete pour section, and disposedof accordingly.‣ Dumping or washing of concrete remains into the ground is not permitted.5.4 Stockpiling of marinegravels5.5 Vehicle andequipmentmaintenance5.6 Discard of recoverytailings from thetreatment plant5.7 Discharge of finetailings to the settlingpondDamage to terrestrialhabitats, changes in soilchemistry‣ Stockpile marine gravels only in specifically demarcated previously disturbedareas.‣ Ensure that the reclamation area is sufficiently bunded and that suitabledrainage is provided.Hydrocarbon pollution ‣ Restrict vehicle maintenance to the maintenance yard area, except inemergencies.‣ For equipment maintained in the field, oils and lubricants to be contained andcorrectly disposed of off-site.‣ Maintain all equipment to ensure that no oils, diesel, fuel or hydraulic fluidsare spilled.‣ Vehicles used for the activity should have a spill kit (peatsorb/drip trays)onboard in the event of a spill.Back-filling mined-out areas ‣ Discard headfeed tailings only in designated excavations.‣ Confine tailings stockpiles to mineral processing area.‣ Assess colonisation of back-filled pits by vegetation and other biota on aregular basis.Additional source of windblowndust, risks toanimals, contamination ofground water‣ Obtain the relevant permit for discharge of fine tailings on land from theDepartment of Water Affairs and Forestry (DWAF) and monitor compliance topermit conditions.‣ Keep records of discharge volumes and particle size composition.‣ Ensure settling pond area is safe to humans and wildlife.RESPONSIBLEPERSON/SNamagroen Prospecting & Investments October 2008

Addendum to EMPR for Concessions 8(a), 9(a) and 8(b) 67ONSHORE LOGISTICAL SUPPORT AND GRAVEL PROCESSING# ASPECT IMPACT DESCRIPTION MITIGATION MEASURES AND MANAGEMENT ACTIONS5.8 Discharge of seawaterused for gravelprocessing5.9 Use of FeSi in DMS,and loss thereofPotential contamination ofsoil and ground waterPotential contamination ofsoil and ground water‣ If necessary, obtain a section 21 permit from DWAF to discharge service waterused to process gravels, and comply with conditions set by DWAF.‣ If the processing area is situated away from the beach, implement systems toensure seawater is contained at all times to prevent seepage of saline waterinto the soil.‣ Ensure that waste water run-off from the plant does not significantly impacton water quality.‣ Minimise the use of ferrosilicon (FeSi) and retrieve as much as possible so as toreduce the iron levels in discharged water (e.g. use shell crushing equipmentto maximise retrieval of FeSi where operating in shelly substrates as thiscompound accumulates in shells; or a magnet to recycle the FeSi).‣ Monitor FeSi consumption on an ongoing basis, set targets and put action plansin place should targets be exceeded.RESPONSIBLEPERSON/SNamagroen Prospecting & Investments October 2008

Addendum to EMPR for Concessions 8(a), 9(a) and 8(b) 686. WASTE MANAGEMENT AND POLLUTION CONTROLManagement Objectives:WASTE MANAGEMENT AND POLLUTION CONTROL−−−To prevent pollution of terrestrial, marine and fresh water habitats and resourcesTo effectively manage waste flows to minimise pollution using a cradle-to-grave philosophyPromoting reuse / recycling and being conservative in use of natural resources# ASPECT IMPACT DESCRIPTION MITIGATION MEASURES AND MANAGEMENT ACTIONS6.1 Waste generation -generalPollution of terrestrial,aquatic and marine habitats‣ Comply with all legal requirements for waste management and pollutioncontrol, and employ “good housekeeping” and monitoring practices.‣ Follow stringent ‘cradle to grave’ waste management practices.‣ Conduct environmental awareness programmes for waste management.‣ As far as possible, separate all wastes.‣ Maintain records on the types and amounts of waste disposed.RESPONSIBLEPERSON/SNamagroen Prospecting & Investments October 2008

Addendum to EMPR for Concessions 8(a), 9(a) and 8(b) 69WASTE MANAGEMENT AND POLLUTION CONTROL# ASPECT IMPACT DESCRIPTION MITIGATION MEASURES AND MANAGEMENT ACTIONS6.2 Waste Managementonboard contractedvesselsMarine Pollution throughorganic waste disposal,discharge of bilge water,spillages‣ Ensure that waste management practices are enforced on all contractedvessels.‣ Those items not covered elsewhere because of the practices in place on boardthe contractor vessel:- employ “good housekeeping”;- awareness for waste reduction through re-use and recycling maintained;- only water containing

Addendum to EMPR for Concessions 8(a), 9(a) and 8(b) 70WASTE MANAGEMENT AND POLLUTION CONTROL# ASPECT IMPACT DESCRIPTION MITIGATION MEASURES AND MANAGEMENT ACTIONS6.3 Waste generation -Treatment PlantPollution of terrestrial,aquatic and marine habitats6.4 Human waste disposal Pollution of terrestrial,aquatic and marine habitats6.5 Disposal of domesticwaste-waterPollution of terrestrial,aquatic and marine habitat6.6 Scrap metal Pollution of terrestrial,aquatic and marine habitats6.7 Construction material Pollution of terrestrial,aquatic and marine habitats‣ Regularly remove all mining or domestic solid wastes (e.g. old piping, plasticsheeting, litter etc.) from the plant site and adjacent shoreline, and disposeof appropriately.‣ Prevent pollution during operations by providing suitable containers anddesignating adequate facilities for storage and disposal of biodegradable andnon-biodegradable waste.‣ Collect and store biodegradable and non-biodegradable refuse (e.g. glassbottles, plastic bags, metal scrap etc) at a collecting point for collection on aregular basis for disposal at the municipal dump.‣ Ensure dog-proofing for interim (soft refuse) waste collecting points at theplant site.‣ Do not leave any litter in any place except in specially demarcated containers.‣ Provide sufficient ablution facilities at appropriate places during graveltreatment operations.‣ Septic drain systems must be provided at all sanitary facilities.‣ Sanitary effluents must comply with DWAF standards.‣ Use bio-degradable cleaning agents.‣ All domestic effluents, including wash-water (i.e. not containing fuel, grease,solvents etc) will be disposed of in a septic tank.‣ Remove all metal waste from the plant site when no longer needed.‣ Recycle metal wastes through resale of scrap metal and keep records of scraprecycled.‣ Dispose of non-recyclable metal objects at the Hondeklipbaai waste site.‣ Dispose of rubble and other waste construction materials at the nearestdesignated landfill site (Hondeklipbaai).RESPONSIBLEPERSON/SNamagroen Prospecting & Investments October 2008

Addendum to EMPR for Concessions 8(a), 9(a) and 8(b) 71WASTE MANAGEMENT AND POLLUTION CONTROL# ASPECT IMPACT DESCRIPTION MITIGATION MEASURES AND MANAGEMENT ACTIONS6.8 Storage and disposalof hazardous materials6.9 Loading of marinesedimentsPollution of terrestrial,aquatic and marine habitatsGeneration of wind-blowndust6.10 Vehicle traffic Generation of dust andemissions, increased trafficon haul roads6.11 Use and disposal ofCFCsGeneration of greenhousegases‣ Secure storage areas and ensure all hazardous substances and stocks (e.g.diesels, oils, detergents etc) are stored therein.‣ Follow Shell guidelines or the SABS Code of Practice for fuel and oilinstallation. These are drawn up for site-specific installations.‣ Ensure emergency response plans are in place for storage and transport oflarge quantities of oils and fuels.‣ Contain all waste oils, grease, hydraulic fluids and other hazardous substancesin separate, suitable receptacles and transfer to a recognised land-basedhazardous waste disposal facility, or contract a private company to regularlyremove and dispose of it.‣ Use drip trays and bunding where losses cannot be prevented and are likely tooccur.‣ Use low toxicity biodegradable detergents to clean up spills.‣ Avoid spilling toxic chemicals but if spillages occur then clean up spilledchemicals immediately and place rags used for this purpose in a toxic wastecontainer for safe disposal ashore.‣ Keep records of spillages and estimate amounts not retrieved by clean upactions.‣ Treat polluted soil in situ. In the event of large spills, collect and remove thepolluted soil and dispose at a designated bio-remediation site.‣ Keep records of hazardous waste management.‣ Monitor dust loads at the discharge site and treatment plant.‣ Enforce wearing of protective devices where dust levels are exceeded.‣ Spray heavily frequented gravel roads with ‘grey’ or recycled water.‣ Ensure proper tuning of vehicle engines to minimise smoke and partiallyburned hydrocarbons and sulphur oxides.‣ Use environmentally friendly substitutes for CFCs where feasible.RESPONSIBLEPERSON/SNamagroen Prospecting & Investments October 2008

Addendum to EMPR for Concessions 8(a), 9(a) and 8(b) 72WASTE MANAGEMENT AND POLLUTION CONTROL6.12 Workshops operations Gaseous emissions ‣ Provide adequate ventilation and extraction systems at the work place.‣ Minimise emission of exhaust gases (e.g. CO 2 , CO, SO 2 and NO x ) and sootthrough regular maintenance of diesel motors and generators.6.13 Gravel screening,earth movingequipment, andworkshopsGeneration of noise ‣ Implement noise reduction at source.‣ Enforce wearing of ear protection devices in high noise zones.‣ Monitor noise levels.Namagroen Prospecting & Investments October 2008

Addendum to EMPR for Concessions 8(a), 9(a) and 8(b) 737. BIOLOGICAL DIVERSITY AND RESOURCE USEManagement Objectives:BIOLOGICAL DIVERSITY AND RESOURCE USE−−−−Minimise disturbance of wildlifeProtect key habitats important for wildlife thereby conserving biological diversityConserve energy and fresh waterReduce wastage and minimise fuel use# ASPECT IMPACT DESCRIPTION MITIGATION MEASURES AND MANAGEMENT ACTIONS7.1 Illegal hunting andfishingIllegal plant collectionDestruction and loss of floraand fauna7.2 Fire lighting Destruction and loss of floraand fauna‣ Namagroen personnel and contractors will not:- Disturb, catch, remove, injure, kill or feed, any wild animal or bird whichoccurs in the area.- Break, damage, destroy, disturb or remove any birds egg or nest.- Intentionally remove, injure or kill any sea-life.- Pick, uproot, fell or damage any plant growing in the coastal area withouta permit - other than according to the approved EMP which will providenecessary mitigation measures.‣ Disciplinary action will be undertaken, and strict penalties imposed in case oftransgressions.‣ Namagroen personnel and contractors will not light any fires at any placeother than amenities provided (to avoid the risk of loss of habitat, and reducehazards posed by uncontrolled fires).‣ Ensure that firewood is not collected from the surrounding veld unless exotictrees (e.g. Port Jackson) are available.7.3 Presence in the area Disturbance of wildlife ‣ Minimise the disturbance of wildlife in the area by staying on demarcatedroads and adhering to speed limits.RESPONSIBLEPERSON/S7.4 Presence in the area Recreational fishing andshellfish collection‣ No shellfish (including abalone, rock lobster, mussels) will be collectedwithout a permit from the Directorate of Marine & Coastal Management.‣ Contractors and staff will be expected to adhere to all fishing regulationsunder the Marine Living Resources Act.Namagroen Prospecting & Investments October 2008

Addendum to EMPR for Concessions 8(a), 9(a) and 8(b) 74BIOLOGICAL DIVERSITY AND RESOURCE USE# ASPECT IMPACT DESCRIPTION MITIGATION MEASURES AND MANAGEMENT ACTIONS7.5 Fine tailings disposalinto settling pond7.6 Use of naturalresources7.7 Use of naturalresourcesRisk to animals, generationof dust, contamination ofgroundwaterConsumption of fuel andelectricityConsumption of potablewater7.8 Seawater Consumption Contamination ofgroundwater and decreasein rehabilitation potentialof saline sediments‣ Ensure pond area is safe to wildlife.‣ Apply to local Eskom authority to secure access to grid.‣ Reduce consumption of fuels and other petrochemical materials to minimisethe release of green house gases by:- Installing fuel-efficient equipment and low-energy devices.- Servicing all equipment regularly and repairing as required.- Periodically assessing energy use and making improvements wherepossible.- Keep records of fuel consumption, set targets and put action plans inplace when targets are exceeded.‣ Ensure relevant water permits are in place.‣ Minimise the use and wastage of potable water by:- Installing low-flush or seawater toilets, low pressure taps and showers.- Using desalinated seawater and recycled water where at all possible.- Periodically assessing water use and making improvements wherepossible.- Conducting water conservation awareness programmes and water savingcampaigns.‣ Keep records of quantities of fresh water used.‣ Keep a water balance of the area.‣ Recycle process water where feasible.‣ Minimise wastage of water.‣ Implement water saving methods in the treatment plant to reduce the amountof water required for processing.RESPONSIBLEPERSON/SNamagroen Prospecting & Investments October 2008

Addendum to EMPR for Concessions 8(a), 9(a) and 8(b) 758. SOCIO-ECONOMIC ISSUESManagement Objectives:SOCIO-ECONOMIC ISSUES−−−−−−−Optimise economic benefits to people of Namibia, where feasibleStrike a balance between economic, social and environmental responsibilitiesProvide opportunities for local business, promote industrial relations, and otherwise contribute to socio-economic stabilityProvide training and development opportunities for all staffConsult with relevant stakeholders on a regular basisPromote and maintain good working and living conditions for Namagroen employees# ASPECT IMPACT DESCRIPTION MITIGATION MEASURES AND MANAGEMENT ACTIONS8.1 EnvironmentalCommunicationImprovedAwarenessEnvironmental‣ During compilation of the EMPR Amendment consult with the following toidentify their rights and/or other legitimate interests:- Government departments with jurisdiction over resources or activities inthe concession areas.- Representatives of any other interest group (e.g. fishing industry, miningindustry).‣ Improve stakeholder relationships by maintaining open communication withrelevant I&APs on issues that may arise, and where relevant, address theirneeds.‣ Keep a record of all communications with I&APs, the points raised, and howthese points have been addressed.‣ Publicise and make available information on Namagroen’s environmentalmonitoring programmes and environmental performance.‣ Where feasible, comply with the local development objectives, spatialdevelopment framework and integrated development planning of the area,and promote co-operative governance and integrated decision-making.RESPONSIBLEPERSON/SNamagroen Prospecting & Investments October 2008

Addendum to EMPR for Concessions 8(a), 9(a) and 8(b) 76SOCIO-ECONOMIC ISSUES# ASPECT IMPACT DESCRIPTION MITIGATION MEASURES AND MANAGEMENT ACTIONS8.2 Employment Boosts local economy ‣ Give hiring priority to suitably qualified or experienced local South Africancitizens, as positions become available.‣ Continue to provide employees with training to develop skills.‣ Outsource services where possible.‣ Use local South African suppliers of goods and services where economicallyfeasible.‣ Wherever possible, include local Small, Medium and Micro enterprise serviceproviders in the tendering process for supplies and services, giving preferenceto companies with a labour-intensive focus and Black Economic Empowerment(BEE) companies.8.3 Training and Skills Transfer ‣ Provide employees with training to develop skills by:- Addressing training needs of all staff required to implement specialisedaspects of the Dredging Project.‣ Incorporate environmental aspects and management interventions applicableto particular outsourced tasks into contracts and performance appraisals toimprove environmental awareness and performance.‣ Emergency preparedness and response teams/contractors are to trainemployees and contractors on appropriate skills.8.4 Contribution to NorthernCape region‣ Within the resources available, support appropriate initiatives to improvecommunity welfare, particularly in Hondeklipbaai.‣ Use local suppliers of goods and services whereever possible.RESPONSIBLEPERSON/S8.5 Taxes / royalties Contribution to nationaleconomy8.6 Use of harbours Financial contribution toharbours‣ Pay all applicable taxes and royalties to the government as required.‣ Pursue targets and standards set out in Namagroen’s Strategic Business Plan.‣ Maintain or increase current level of production.‣ Internally track efficiency to ensure maintenance of profits.‣ Pay all applicable fees at harbours.‣ Use Hondeklipbaai harbour infrastructure and services where possible (e.g. forinstallation of discharge pipeline).Namagroen Prospecting & Investments October 2008

Addendum to EMPR for Concessions 8(a), 9(a) and 8(b) 77ENVIRONMENTAL MONITORING PLANA summary of the scheduling of proposed monitoring for the Dredging Project is outlined below (Table B.2.1). The responsibility of implementationof the monitoring plan rests with Namagroen’s and Geo-Mining’s Management.Table B.2.1: Environmental Monitoring Plan for dredging operations.Aspect Variables FrequencyDREDGING AND MINING OPERATIONSExcavations in the seabed • Excavation depth, wall steepness and infill rates.Destruction of infaunal and/orepifaunal benthic organismsSuspended sediment plumesShipwrecks and/or archaeologicalsites discovered during miningRock lobsters and other marine life• Pre-dredging benthic macrofaunal survey.• Sediment sample analysis.• Post-dredging benthic macrofaunal monitoring surveys toassess recovery.• Sediment sample analysis.• Aerial photographs of plumes.• Record wind speed and direction in vessel’s bridge log.• Conduct visual observations of the plumes.• Record the date, time, location and types of artefactsfound in the vessel’s logbook.• Keep a record of the numbers of rock lobsters appearingin the dredger’s hopper compartment during operations.High-resolution geophysical surveys ~1-2 years postdredging.Before commencement of operations.Concurrently with benthic survey.~1-2 years after dredging operations have ceased.Concurrently with benthic survey.During each dredging eventDuring each dredging eventIn 4-hourly intervals during operations.Hourly during operations.On location of shipwreck/archaeological material.Continuously during operations.Marine mammals and seabirds• Record the number of large mammals sighted, togetherwith their proximity to the vessel and behaviour patterns.• Record the numbers and species of birds sighted duringdredging and discharge operations.Daily during dredging operations.Daily during operations.Namagroen Prospecting & Investments October 2008

Addendum to EMPR for Concessions 8(a), 9(a) and 8(b) 78Aspect Variables FrequencyTRANSPORT AND DISCHARGE OF GRAVELSPresence of vessels in the areaDischarge of dredged sedimentsMINING AND PROCESSING OF GRAVELSDisposal of recovery tailings ontolandDischarge of fine tailings intosettling pondWASTE MANAGEMENTFeSiDustEnergy use• In the vessel logbook, record sightings of and interactionswith other vessels to note potential conflicts over rightsof passage and access to resources.• Communicate position of the discharge pipeline andextent of exclusion zone to the rock lobster industry.• Maintain communications with rock lobster vessels in thearea, and record communications in the vessel’s logbook.• Keep records of the volumes of dredged sedimentsdischarged for stockpiling.• Keep records of the volumes of plant tailings discarded.• Obtain the relevant permit for discharge of fine tailingson land from the DWAF monitor compliance to permitconditions.• Keep records of discharge volumes and particle sizecomposition.• Monitor FeSi consumption, set targets and put actionplans in place should targets be exceeded.• Ambient particulate concentration [if required by healthstandards], otherwise visual observations.• Oil and fuel consumption.• Emissions (CO 2 per ton) from oil and fuel consumption.• Visual inspection for oil spills and leaks.When they occur.Before and during installation of the pipeline.Daily during operations.Daily during operations.Monthly during operations.Before commencement of operations.Monthly during operations (Visual)Monthly during operations.During operations.Monthly during operations.Namagroen Prospecting & Investments October 2008

Addendum to EMPR for Concessions 8(a), 9(a) and 8(b) 79Aspect Variables Frequency• Electricity use.Noise • Monitor noise levels. During operations.Water useWater qualityHazardous substancesWastes and scrapIncidental loss of equipment at seaEmployment and expenditure• Keep records of quantities of fresh water used, purposesof use, and sources of supply.• Monitor water quality of sewage effluents (chemical andmicrobiological indicators).• Keep records of quantities of hazardous substances usedand disposed of.• Keep records of accidental spills and how these wereremediated.• Maintain an Official Garbage Record Book onboard thevessel for all discharges of waste/incinerations.• Maintain records of the types and amounts of wastedisposed of at the treatment plant.• Keep records of any waste or scrap recycled.• Frequently assess the integrity of all waste storagecontainers.• Maintain a hazards database listing the type of gear lefton the seabed with the dates of loss and locations and,where applicable, the dates of retrieval.• Keep records of employees and sub-contractors involvedin operations.Monthly during operations.According to permit conditions.Monthly during operations.Monthly during operations.Weekly during operations.Monthly during operations.Monthly during operations.Monthly during operations.Continuously during operations.AnnuallyEconomic benefits • Keep a record of total expenditure. Annually – to shareholders and investorsNamagroen Prospecting & Investments October 2008

Addendum to EMPR for Concessions 8(a), 9(a) and 8(b) 80REHABILITATION AND CLOSURE PLANClosure objectives specific to the Dredging Project should be set in striving to ensure that the area will be restored to the extent that it does notextract from eco-tourism in the area.Table B.3.1: Rehabilitation and Closure Plan.REHABILITATION AND CLOSUREManagement Objective:− Establish the direct and cumulative impacts of diamond mining on key marine ecosystems and biota− Establish recovery rates of disturbed marine habitats− Allow natural recovery of marine habitats so as not to compromise other marine resource users (e.g. fishing sector)− Undertake appropriate rehabilitation during mining operations− Rehabilitate the mining area in a way that does not compromise future land-use options, particularly tourism, conservation and mariculture− If feasible, rehabilitate altered landforms, vegetation and soils as close as possible to pre-impact conditions− Leave disturbed areas, which cannot be rehabilitated, in a state that facilitates natural re-colonisation by animal and plant communities to an ecologically stablesystem in the long term− Remove or demolish all infrastructure not required by future land users− Ensure, as far as is practically possible, that all infrastructure, which cannot be removed or demolished, is safe to humans and animals− Ameliorate all physical hazardsNOTE: Active rehabilitation of the seabed below the low water mark is not required, as recovery within this highly dynamic nearshore area is a rapid and natural process.# ASPECT IMPACT DESCRIPTION MITIGATION MEASURES AND MANAGEMENT ACTIONS1 Closure of Operations Termination ofcontributions to theeconomy including taxes,employment, support tosecondary industries‣ As an interdisciplinary initiative between all involved internal and externalstakeholders, undertake to develop a Rehabilitation and Closure Plan, whichgives attention to:- approximate dates of closure applications,- objectives of closure planning,- relevant decommissioning and rehabilitation monitoring programmes,- financial provisioning for rehabilitation, restoration and reclamationactivities associated with mine closure,RESPONSIBLEPERSON/SNamagroen Prospecting & Investments October 2008

Addendum to EMPR for Concessions 8(a), 9(a) and 8(b) 81REHABILITATION AND CLOSURE# ASPECT IMPACT DESCRIPTION MITIGATION MEASURES AND MANAGEMENT ACTIONScont. - provisioning for the development of a social and labour plan for closure,- identification of end land use,- rehabilitation actions required to obtain end land use,- allocation of responsibilities for rehabilitation,- human resources and community plan of action,- communication strategy, and- actions required for sustainability.2 Closure Planning Improved management ofclosure and rehabilitation3 Financial Provisioning Improved management ofclosure and rehabilitation‣ Ensure that closure planning forms an integral part of mining operations fromstart-up and continues throughout the life of the operation.‣ Gather relevant information throughout the life of mine to ensure thatenvironmental risks are quantified and managed proactively.‣ Identify, and include all necessary steps for rehabilitation of negative landbasedimpacts on cessation of operations, including the removal of abandonedequipment and garbage, minimisation of air and water pollution, tailingshandling, re-establishment of vegetation.‣ Incorporate the suggestions of government authorities and interest groups intoplans for rehabilitation. Consider compatibility with the short and long-termpotential use of the area after mining, other current users of the area, and theproximity to nature protection areas/ islands or population centres.‣ Ensure that Safety and Health requirements are complied with.‣ Clearly allocate timing and responsibility for rehabilitation to mine operators.Ensure that requirements in terms of financial provision for remediation ofenvironmental damage are met by:‣ Allocate operational costs to maintain an EMS and meet EMP objectives,ensuring that environmental impacts are integrally managed or monitored toprevent or minimise them.‣ Maintain adequate Protection and Indemnity (P&I) Insurance Cover to allow forcleanups in the event of oil spills and other eventualities associated with theProject.RESPONSIBLEPERSON/SNamagroen Prospecting & Investments October 2008

Addendum to EMPR for Concessions 8(a), 9(a) and 8(b) 82REHABILITATION AND CLOSURE# ASPECT IMPACT DESCRIPTION MITIGATION MEASURES AND MANAGEMENT ACTIONS4 Marine habitatmodification5 Terrestrial habitatmodificationPollution of marine habitatsby mining units andassociated infrastructureVisual impacts and reducedfuture land-use capabilityof treatment plants andinfrastructure‣ Allocate operational costs to monitor and demonstrate natural recovery of theseabed through pre- and post-mining benthic faunal and seabed surveys.‣ Provide sufficient funds for post-closure environmental surveys (seabed and/orbenthic faunal survey, vegetation surveys) in the event that on closure, themonitoring programmes have not been completed or have not been able todemonstrate sufficiently that natural recovery processes are occurring.‣ Plan for the demolition and removal all infrastructure not identified for futureuse from the beach and coastal areas.‣ Clean up and remove discarded equipment within the intertidal zone.‣ Remove all wastes from the beach.‣ Plan for the demolition and removal all infrastructure not identified for futureuse, and the restoration of the land surface above HWM.‣ Clean up and remove discarded equipment, abandoned structures andfacilities established during mining activities or for accessing a mining site aspart of responsible environmental management in new or renewed operations.‣ Demolish concrete slabs and dispose of other building rubble in designatedarea.‣ Remove all powerlines and associated structures if not identified for futureuse.‣ Follow same environmental guidelines during removal and clean-up operationsas during erection of infrastructure (i.e. stay on existing roads and tracks,minimise disturbance).‣ If practical and feasible, rehabilitate remaining disturbed area by:- Creating an uneven hummock-like surface.- Re-planting with succulent shrubs.‣ Protect rehabilitated areas from future damage.‣ Monitor rehabilitation of vegetation.‣ Removal of infrastructure, roads, remaining waste, oil spills should beassessed 5 years after mine closure, together with future land owner.RESPONSIBLEPERSON/SNamagroen Prospecting & Investments October 2008

Addendum to EMPR for Concessions 8(a), 9(a) and 8(b) 83REHABILITATION AND CLOSURE# ASPECT IMPACT DESCRIPTION MITIGATION MEASURES AND MANAGEMENT ACTIONS6 Terrestrial habitatmodificationReduced future land-usecapability of reclamationarea and excessive roads‣ Place barriers (e.g. large rocks, fences) across the entrances of tracks nolonger used and signpost intention to rehabilitate.‣ Where the surface of the track has become compacted, scarify the surface inplaces to encourage the establishment of vegetation.‣ Remove foreign road-construction materials which may hamper vegetationregrowth and use lifted road material to fill voids left from mining.‣ Level all stockpiles inside reclamation area.‣ Cover reclamation area with stored topsoil to facilitate natural re-growth ofvegetation.‣ Ensure that all personnel undertaking rehabilitation are appropriatelyqualified and trained.‣ Keep a record of rehabilitation areas for consideration in future projects.‣ Regularly monitor re-vegetated areas.‣ Protect rehabilitation areas from future damage.RESPONSIBLEPERSON/S7 Oil spills Pollution of soil reducingfuture land-use capability‣ Clean up all areas where oil spills occurred (i.e. collect and dispose ofpolluted soil at a designated bio-remediation plant or suitable alternative).Namagroen Prospecting & Investments October 2008

Addendum to EMPR for Concessions 8(a), 9(a) and 8(b) 84REHABILITATION AND CLOSURE# ASPECT IMPACT DESCRIPTION MITIGATION MEASURES AND MANAGEMENT ACTIONS8 Closure Certificate Improved management ofclosure and rehabilitation‣ When Namagroen intend closing operations, a final EMP performanceassessment should be conducted to ensure that:- the requirements of the relevant legislation have been complied with;- the monitoring that has been conducted (including the total areadisturbed) is summarised;- the closure objectives as described in the Closure Plan have been met;and- all residual and latent environmental impacts and the risks thereofoccurring have been identified, quantified and arrangements for themanagement thereof have been finalised.‣ When applying for closure, submit the following documentation to the DME:− The Closure Plan− An Environmental Risk Report− The Final Performance Assessment Report− An application form to transfer environmental responsibilities andliabilities, if such transfer has been applied for.RESPONSIBLEPERSON/SNamagroen Prospecting & Investments October 2008

Addendum to EMPR for Concessions 8(a), 9(a) and 8(b) 85PART C1. REFERENCESABP RESEARCH, 1999. Good practice guidelines for ports and harbours operating within or near UKmarine Special Areas of Conservation. English Nature, UK Marine SACs Project. 120 pp.AIROLDI, L. & F. CINELLI, 1997. Effects of sedimentation on subtidal macroalgal assemblages: anexperimental study from a Mediterranean rocky shore. J. Exp. Mar. Biol. Ecol., 215: 269-288.AIROLDI, L. & M. VIRGILIO, 1998. Responses of turf-forming algae to spatial variations in thedeposition of sediments. Mar. Ecol. Prog. Ser., 165: 271-282.AIROLDI, L., RINDI, F. & F. CINELLI, 1995. Structure, seasonal dynamics and reproductive phenologyof a filamentous turf assemblage on a sediment influenced, rocky subtidal shore. Bot. Mar.,38(3): 227-237.BREMNER, J.M. & J.P. WILLIS, 1990. Mineralogy and geochemistry of the clay mineral fraction ofsediments from the Namibian continental margin and the adjacent hinterland. Mar. Geol.,115: 85-116.CALVERT, S.E. & N.B. PRICE, 1970. Minor metal contents of recent organic-rich sediments off SouthWest Africa. Nature, 227: 593-595.CHAPMAN, P. & L.V. SHANNON, 1985. The Benguela Ecosystem. Part II. Chemistry and relatedprocesses. Oceanogr. Mar. Biol. Ann. Rev., 23: 183-251.CSIR, 2007. Marine Dredging Project. Feasibility Phase. Environmental Impact Assessment ReportCSIR/NRE/RBSD/ER/2007/0156/C. Stellenbosch. x pp including Appendices and Summary.Prepared for De Beers Marine Namibia (Pty) Ltd.DALY, M.A. & A.C. MATHIESON, 1977. The effects of sand movements on intertidal seaweeds andselected invertebrates at Bound Rock, New Hampshire. Mar. Biol., 43: 45-55.DAY, E.G., BRANCH, G.M. & C. VILJOEN, 2000. How costly is molluscan shell erosion ? A comparisonof two patellid limpets with contrasting shell structures. J. Exp. Mar. Biol. Ecol., 243: 185-208.DETHIER, M.N., 1984. Disturbance and recovery in intertidal pools: maintenance of mosaicpatterns. Ecol. Monogr., 54:99-118DEVINNY, J.S. & L.A. VOLSE, 1978. Effects of sediments on the development of Macrocystis pyriferagametophytes. Mar. Biol., 48: 343-348.EGGLESTON, D., 1972. Factors influencing the distribution of sub-littoral ectoprocts of the south ofthe Isle of Man (Irish Sea). J. Nat. Hist., 6: 247-260.ELLIS, D.V., 1996. Practical mitigation of the environmental effect of offshore mining. OffshoreTechnology Conference, Houston Texas, 6-9 May 1996.ELLIS, D.V., 2000. Effect of mine tailings on the biodiversity of the sea bed: example of the IslandCopper Mine, Canada. In: Seas at the Millennium: An Environmental Evaluation. Volume III,Namagroen Prospecting & Investments October 2008

Addendum to EMPR for Concessions 8(a), 9(a) and 8(b) 86Global Issues and Processes. Sheppard, C.R.C. (ed.). Pergamon, Elsevier Science,Amsterdam, Lausanne.GALVIN, R.M., 1996. Occurrence of metals in waters: An overview. Water SA, 22: 7-18.HERRMANN, C., KRAUSE, J. CHR., TSOUPIKOVA, N. & K. HANSEN, 1999. Marine Sediment extractionin the Baltic Sea. Status Report. Baltic Sea Environment Proceedings, No. 76. 29 pp.HISCOCK, K., 1983. Water movement. In: EARLL, R. & D.G. ERWIN (eds). Sublittoral Ecology: theEcology of the Shallow Sublittoral Benthos. Clarendon Press, Oxford, pp. 58-96.HUNT, H.L. & R.E. SCHEIBLING , 1997. Role of early post-settlement mortality in recruitment ofbenthic marine invertebrates. Marine Ecology Progress Series 155:269-301.JONES, G. & S. CANDY, 1981. Effects of dredging on the macrobenthic infauna of Botany Bay. Aust.J. Mar. Freshwater Res., 32: 379-399.KENNY, A. J., REES, H. L., GREENING, J., & S. CAMPBELL, 1998. The effects of marine gravelextraction on the macrobenthos at an experimental dredge site off north Norfolk, U.K.(Results 3 years post-dredging). ICES CM 1998/V:14, pp. 1-8.KENNY, A.J. & REES H.L., 1994. The effects of marine gravel extraction on the macrobenthos: Earlypost-dredging recolonisation. Mar. Poll. Bull., 28: 442-447.KENNY, A.J. & REES H.L., 1996. The effects of marine gravel extraction on the macrobenthos:Results 2 years post-dredging. Mar. Poll. Bull., 32: 615-622.LANE, S.B. & R.A. CARTER, 1999. Generic Environmental Management Programme for MarineDiamond MIning off the West Coast of South Africa. Marine Diamond Mines Association,Cape Town, South Africa. 6 Volumes.LITTLER, M. M. 1980. The effects of recurrent sedimentation on rocky intertidal macrophytes. J.Phycol., 16: 26.LITTLER, M. M. & D.S. LITTLER, 1981. Intertidal macrophyte communities from Pacific BajaCalifornia and the upper Gulf of California: relatively constant vs. environmentallyfluctuating systems. Mar. Ecol. Prog. Ser., 4: 145-158.LITTLER, M.M., MARTZ, D.R. & D.S. LITTLER, 1983. Effects of recurrent sand deposition on rockyintertidal organisms: importance of substrate heterogeneity in a fluctuating environment.Mar. Ecol. Prog. Ser., 11: 129-139.MAURER, D.L., W. LEATHEM, P. KINNER & J. TINSMAN, 1979. Seasonal fluctuations in coastal benthicinvertebrate assemblages. Est. Coast. Shelf Sci., 8: 181-193.McQUAID, C.D. & K.M. DOWER, 1990. Enhancement of habitat heterogeneity and species richnesson rocky shores inundated by sand. Oecologia (Berlin), 84: 142-144.NEWELL, R.C., SEIDERER, L.J. & HITCHCOCK, D.R., 1998. The impact of dredging works in coastalwaters: a review of the sensitivity to disturbance and subsequent recovery of biologicalresources on the seabed. Oceanogr.Mar. Biol. Ann. Rev., 36: 127-178.PARKINS, C.A. & J.G. FIELD, 1998. The effects of deep sea diamond mining on the benthiccommunity structure of the Atlantic 1 Mining Licence Area. Annual Monitoring Report –1997. Prepared for De Beers Marine (Pty) Ltd by Marine Biology Research Institute, ZoologyDepartment, University of Cape Town. pp. 44.Namagroen Prospecting & Investments October 2008

Addendum to EMPR for Concessions 8(a), 9(a) and 8(b) 87PAULSON, C.& G. AMY, 1993. Regulating metal toxicity in stormwater. Water Environ. Technol.,July 44-49.PENNEY, A.J., PULFRICH, A., ROGERS, J., STEFFANI, N. & V. MABILLE, 2008. Project:BEHP/CEA/03/02: Data Gathering and Gap Analysis for Assessment of Cumulative Effects ofMarine Diamond Mining Activities on the BCLME Region. Final Report to the BCLME miningand petroleum activities task group. December 2007. pp410.PISCES ENVIRONMENTAL SERVICES (PTY) LTD, 2004. Marine Dredging Project Pre-Feasibility Study,Environmental Impact Assessment, Volume I: Scoping Report, Environmental Impact Report& EMP. Prepared for De Beers Marine (Pty) Ltd. and Namdeb Diamond Corporation (Pty) Ltd.POINER, I.R & R. KENNEDY, 1984. Complex patterns of change in the macrobenthos of a largesandbank following dredging. Mar. Biol., 78: 335-352.PULFRICH, A. 2004. The potential impacts of marine dredging operations on nearshore reefcommunities and the rock lobster fishery. Specialist Study 1. Specialist Study for theEnvironmental Impact Report for the Pre-feasibility Phase of the Marine Dredging Project inNamdeb’s Atlantic 1 Mining Licence Area and in the nearshore areas off Chameis. Preparedfor De Beers Marine Namibia (Pty) Ltd by PISCES Environmental Services (Pty) Ltd,September 2004.PULFRICH A. & A.J. PENNEY, 1998. Assessment of the impact of diver-operated nearshore diamondmining on marine benthic communities in the Zweispitz area, Namibia. Report to NAMDEBDiamond Corporation (Pty) Ltd., Oranjemund, Namibia, 33 pp.PULFRICH, A. & A.J. PENNEY, 1999a. The effects of deep-sea diamond mining on the benthiccommunity structure of the Atlantic 1 Mining Licence Area. Annual Monitoring Report –1998. Prepared for De Beers Marine (Pty) Ltd by Marine Biology Research Institute, ZoologyDepartment, University of Cape Town and Pisces Research and Management Consultants CC.pp 49.PULFRICH A. & A.J. PENNEY, 1999b. Assessment of the impact of diver-operated nearshore diamondmining on marine benthic communities near Lüderitz, Namibia. Final Report to NAMDEBDiamond Corporation (Pty) Ltd., Oranjemund, Namibia, 40 pp.PULFRICH A. & A.J. PENNEY, 2001. Assessment of the impact of diver-operated nearshore diamondmining on marine benthic communities near Lüderitz, Namibia. Phase III Report to NAMDEBDiamond Corporation (Pty) Ltd., Oranjemund, Namibia, 50 pp.RAINBOW, P.S., 1995. Biomonitoring of heavy metal availability in the marine environment. Mar.Pollut. Bull., 31: 183-192.RODRÝGUEZ, S.R., OJEDA, F.P. & N.C. INESTROSA, 1993. Settlement of benthic marineinvertebrates. Mar. Ecol. Prog. Ser., 97: 193–207.SEAPY, R.R. & M.M. LITTLER, 1982. Population and species diversity fluctuations in a rockyintertidal community relative to severe aerial exposure and sediment burial. Mar. Biol.,71: 87-96.STEFFANI, N. & A. PULFRICH. 2004. The potential impacts of marine dredging operations on benthiccommunities in unconsolidated sediments. Specialist Study 2. Specialist Study for theEnvironmental Impact Report for the Pre-feasibility Phase of the Marine Dredging Project inNamdeb’s Atlantic 1 Mining Licence Area and in the nearshore areas off Chameis. Preparedfor PISCES Environmental Services (Pty) Ltd, September 2004.Namagroen Prospecting & Investments October 2008

Addendum to EMPR for Concessions 8(a), 9(a) and 8(b) 88VAN TAMELEN, P.G., 1996. Algal zonation in tidepools: experimental evaluation of the roles ofphysical disturbance, herbivory and competition. J. Exp. Mar. Biol. Ecol., 201: 197-231.WEEKS, S.J., CURRIE, B., BAKUN, A., PEARD, K.R., 2004. Hydrogen sulphide eruptions in theAtlantic Ocean off southern Africa: implications of a new view based on SeaWiFS satelliteimagery. Deep-Sea Research I, 51:153-172.ZOUTENDYK, P. & I.R. DUVENAGE, 1989. Composition and biological implications of a nepheloidlayer over the inner Agulhas Bank near Mossel Bay, South Africa. Trans. Roy. Soc. S. Afr.,47: 187-197.Namagroen Prospecting & Investments October 2008

Addendum to EMPR for Concessions 8(a), 9(a) and 8(b) 892. STATUTORY AND LEGAL REQUIREMENTSManagement of the environment during and after mining operations is an obligation under theConstitution as well as a number of national statutes. Mining activities on all Namagroenmining areas are conducted in terms of current mining legislation (Minerals Act, 1991 and MineHealth & Safety Act, 1996), including the conditions imposed by the Minister of Minerals andEnergy by way of the mining/mineral lease. Other activities conducted within the boundariesof the mining area which are not regulated by said legislation, are managed in accordance withthe provisions of other legislation, i.e. in those instances where mining has not been excludedor exempt from the provisions of such non-mining legislation.In summary, the following Acts and the Regulations promulgated there under are known toapply:- Atmospheric Pollution Prevention Act (45/1965)- Cape Nature and Environmental Conservation Ordinance 19 of 1974- Common Law of Nuisance- Constitution of the Republic of South Africa Act (108/1996)- Diamonds Act and Regulations (56/1986)- Environmental Conservation Act (73/1989)- Explosives Act (26/1956)- Hazardous Substances Act (15/1973)- Marine Living Resources Act (18/1998)- Mine Health & Safety Act (29/1996)- Minerals Act (50/1991)- Mineral and Petroleum Resources Development Act and Regulations (2002)- National Environmental Management Act (107/1998)- National Heritage Resources Act (25/1999)- National Monuments Act 13 of 1981- National Parks Act (57/1976)- National Water Act (36/1998)- Nuclear Energy Act 131 of 1993- Occupational Health & Safety Act (85/1993)- Road Traffic Act (29/1989)- Seabird and Seals Protection Act (46/1973)- Sea Fisheries Act (12/1988)- Seashore Act (21/1935)- Water Act and Regulations (54/1956)For mining activities conducted from vessels the following Acts and their Regulations apply:- Carriage of Goods by Sea Act (1/1986)- Dumping at Sea Control Act (73/1980)- Marine Notices 15 of 1993, 2 of 1996, 23 of 1998, 26 of 1998- Marine Pollution (Control and Civil Liability) Act (6/1981)- Marine Pollution (Prevention of Pollution from Ships) Act (2/1986)- Marine Pollution (Intervention) Act (64/1987)Namagroen Prospecting & Investments October 2008

Addendum to EMPR for Concessions 8(a), 9(a) and 8(b) 90- Marine Traffic Act (2/1981)- Maritime Zones Act (15/1994)- Merchant Shipping Act (51/1957)- Prevention and Combating of Pollution of the Sea by Oil Act (6/1981)- Ship Registration Act (58/1998)- South African Maritime Safety Authority Act (5/1998)- South African Maritime Safety Authority Levies Act (6/1998)- South African Transport Services Act (65/1981)- Wreck and Salvage Act (94/1996)International Conventions that apply to the proposed dredging operations include:- MARPOL 1973/78- International Convention Relating to Intervention on the High Seas in Cases ofOil Pollution Casualties- United Nations Framework Convention on Climate Change- Montreal Protocol on Ozone Depleting Substances- International Convention for the Safety of Life at Sea (SOLAS)- United Nations Convention on the Law of the Sea (LOSC)- Ramsar Convention on Wetlands of International Importance especially asWaterfowl Habitat- London Convention on the Prevention of Marine Pollution by Dumping ofWastes and Other Matter- Convention on Biological DiversityFuture legal and statutory requirements will include:- White Paper: A Minerals and Mining Policy for South Africa, Oct 1998- Draft White Paper for Sustainable Coastal Development in South Africa- MARPOL 1973/78 - Annex VI: Regulations for the Prevention of Air Pollutionfrom Ships- Draft White Paper on Integrated Pollution and Waste Management for SouthAfrica- White Paper on Biological DiversityOf particular relevance to the proposed dredging operations is the Convention on thePrevention of Marine Pollution by Dumping Wastes and Other Matter (London Convention,1972). The Convention contributes to the international control and prevention of marinepollution. It prohibits the dumping of certain hazardous materials, requires a prior specialpermit for the dumping of a number of other identified materials and a prior general permit forother wastes or matter. South Africa is a signatory of the agreement."Dumping" has been defined as the deliberate disposal at sea of wastes or other matter fromvessels, aircraft, platforms or other man-made structures, as well as the deliberate disposal ofthese vessels or platforms themselves. Wastes derived from the exploration and exploitationof sea-bed mineral resources are, however, excluded from the definition. The provisions alsoNamagroen Prospecting & Investments October 2008

Addendum to EMPR for Concessions 8(a), 9(a) and 8(b) 91do not apply when the safety of human life or vessels are at stake.In 1986, a special set of guidelines for dredged material was adopted as part of the Conventionon the Prevention of Marine Pollution by Dumping Wastes and Other Matter (London Convention1972). These have recently been revised as the Dredged Material Assessment Framework(DMAF), which is a generic guideline for decision-makers in the field of management of dredgedmaterial. The DMAF provides a clear set of guidelines for dredging and disposal operations toensure that these are carried out in such a way as to limit environmental damage. It includesland-based disposal and treatment options, which are not incorporated by the Convention or its1996 Protocol. The framework is illustrated in Figure 6.3. CONFIDENTIAL INFORMATIONThere is no confidential information.Namagroen Prospecting & Investments October 2008

Addendum to EMPR for Concessions 8(a), 9(a) and 8(b) 92Figure 6: Dredged Material Assessment Framework.Namagroen Prospecting & Investments October 2008

Addendum to EMPR for Concessions 8(a), 9(a) and 8(b) 93APPENDIX ITechnical Specifications of the Vessels used to dredge Concessions 8(a), 9(a) and 8(b)Mareikeconstruction year // 2006Dimensions: Length over all 97.50 mBreadth over all21.60 mMoulded depth7.60 mMaximum draught7.10 mMaximum dredging depth:22.00 / 33.00 mSuction pipe Ø:1,000 mmDischarge pipe Ø:900 mmHopper capacity: 5,600 m 3Loading capacity:8,106 tonsMaximum speed loaded:12.30 knotsPower: Total installed 6,826 kWOn pumps dredging max.2,025 kWShore delivery max.4,050 kWPropulsion sailing4,050 kWTrailing3,450 kWNamagroen Prospecting & Investments October 2008

Addendum to EMPR for Concessions 8(a), 9(a) and 8(b) 94MCS EllyVessel TypeDredgehelperClassBureau Veritas 1 3/3(E) + Tug Coastal WatersFlagUnited KingdomYear Built 1997Dimensions25.4 x 10 x 2.3(draft) mGRT 196Deck/Load capacity 5 tons per m 2PropulsionTwin screw, fixed pitch propellers in nozzlesMain Engine Output2 x Cummins type KTA 19-M3 1215BHPBollard pull16.5 tonsFree Running Speed9.4 knotsApproximate fuel consumption (full load) 125 litres per hourAuxiliary Engines/Gen Sets77 KVA Cummins / 22 KVA HATZElectrical System220/380 V AC 50 Hz, 24 V DCMain Anchor Handling Winch100 tonsTowing Winch45 tonsHydraulic CraneHeila 140 tm (fore ship), Heila 70 tm (aft ship)Fuel capacity104 m 3 dieselPotable water 60 m 3Accommodation4 persons with sanitary facilitiesNavigation EquipmentRadar, SSB radio, VHF (2), echosounder, GPS,Navtex, autopilotNamagroen Prospecting & Investments October 2008