PS 1. Social and Environmental Assessment and Management Systems
Social and environmental assessment: Williamson mine has used consultants MTL Consulting Company Limited (“MTL”) based in Dar es Salaam for several years to undertake audit, monitoring and environmental management planning work. Their involvement started during De Beers ownership of the mine and has continued to the present time.
The earliest available environmental impact identification and analysis dates from a comprehensive environmental audit undertaken by MTL in March 2003. Following completion of the audit, Williamson mine prepared and submitted an Environmental Impact Statement and Environmental Management Plan Reports as required by the Tanzanian “Mining (Environmental Management and Protection) Regulations, 1999: Second Schedule”. MTL carried out two further reviews to assess the socio-economic impacts of the project in December 2004 and an assessment of the implementation of the recommendations of the 2003 audit in January 2005.
The WDL Environmental Management Plan (EMP) was finalized in April 2005 and has been subjected to annual audits which are submitted in the form of an Annual Environmental Monitoring Report to the Ministry of Energy and Minerals in Dar es Salaam. The most recent audit, a copy of which has been reviewed by IFC, covers the 2009 calendar year. These audits will be expanded in scope to meet IFC reporting requirements and will also include community related matters (e.g.: water quality monitoring at village drinking water sources).
Currently Petra is in the process of commissioning a complete review of the EMP covering the processing plant and infrastructure expansion and upgrading programme. This process will also include a full Environmental & Social Impact Assessment (ESIA) of the expansion project. IFC has reviewed the outline scope of work for this process and will work with Petra to ensure full compliance with IFC Policy and Performance Standards which will include consultation and disclosure of the updated documentation.
The main elements of the existing 2005 EMP are as follows:
Land Management Plan
Rehabilitate the old surface mining areas by levelling and revegetation
Rehabilitate and revegetate slimes dam walls
Rehabilitate mine waste dumps
Minimise the further extent of land disturbance
Rehabilitate new mining areas as part of the mining process
Prevent land degradation by overgrazing
Remove invasive exotic plant species
Infrastructure Management Plan
Remove redundant infrastructure in the mining lease area
Renovate and maintain current infrastructure in the mining lease area
Identify and preserve infrastructure of historic interest (cultural sites)
Water Management Plan
Strive to prevent pollution of ground and surface water
Optimise water use in the mining and treatment process
Minimise water wastage
Provide clean water to Mwadui for domestic use
Share water resources with local communities
Maintain infrastructure for surface water abstraction
Integrated Waste Management Plan
Clean up historical waste
Dispose of all waste in an environmentally responsible manner, acceptable to the local community and the Mine waste management procedure
Apply the principles of re-use and recycling before disposal where practicable
Hazardous Materials Management Plan
Use, transport, store and dispose of hazardous materials in an environmentally responsible and safe way
Pollution Control and Remediation Plan
Clean up all pollution
Strive to prevent pollution
Conservation Plan
Protection of the forest in the mine lease area (fauna and flora)
Educate employees and local communities about the importance of conservation
Community Plan
Develop good relationships with local communities
Where practicable, assist in the socio-economic development
Closure Plan
Sustainable rehabilitation of slimes dams, mine areas and tailings dumps
Remove all infrastructure for which a post-mining use has not been identified
Contribution to sustainable community development after mining has finished in the area
Management systems and training: During De Beers ownership of WDL, an Environmental Management System was developed which was certified to ISO 14001. De Beers also obtained OHSAS 18001 certification for the site. However, these certifications lapsed prior to the Petra acquisition. The company’s Environmental Policy provides a general sustainability framework and continues to use an Environmental Management System which is broadly aligned with the ISO 14001 requirements to ensure compliance with the EMP. Training of employees in EMS is undertaken in all the company’s operations.
Organization: As an established mining company, WDL employs a Safety, Health and Environment Officer (with a staff of 3) on the same level as key other functional department heads / managers. There is a Human Resources manager with a staff of 3 who is also responsible for community liaison (one of the staff is an HIV / AIDS co-ordinator). At present the community liaison function is the responsibility of the HR manager. WDL will strengthen this function by employing a full time Community Liaison Officer who will work with the village representatives in each of the 8 surrounding villages.
Environmental Policy: WDL has an Environmental Policy which states that the company is committed to a principle of continual improvement in Safety Health and Environment (SHE) management system and performance in its activities; as part of Petra. By this commitment WDL is committed to, preventing all forms of pollution of the environment, creating a healthy and safe working environment, provide appropriate training for all employees and comply with applicable laws and regulations.
Petra has committed to working within IFC’s Performance Standards (PS) and the EMP review and ESIA for the expansion will be undertaken to meet the Performance Standards.
Monitoring: Consultants MTL conduct independent audits biannually and submit on annual basis, an environmental monitoring report reviewing the performance of various environmental parameters. The audits cover the following elements:
Reviewing all monitoring data and, if deemed warranted by the auditor, undertaking an independent round of monitoring.
Reviewing all environmental reports compiled throughout the year.
Reviewing operations, inspecting facilities and observing monitoring activities to assess the effectiveness of the WDL environmental management procedures and their implementation and, if appropriate, identifying potential improvements.
Preparing an audit report, complete with photographic record and recommendations.
The final audit report, together with monitoring data for the previous year, is distributed to the Ministry of Energy and Mines, Division of Environment, and the National Environmental Management Council for review, guidance and comments.
All ongoing monitoring is participatory involving both communities and government.
This annual audit will be upgraded to meet IFC reporting requirements and will in future include community development aspects.
Reporting: Petra publishes an annual Sustainable Development Report. This contains good aggregate coverage of key environmental, social, health and safety indicators. Some statistics such as safety trends are shown for each mine but others such as GRI indicators are aggregated. Other than the data included in the Petra Sustainability Report, WDL do not currently publically report on the environmental and social aspects of their operations. Petra will provide the upgraded annual audit (as described above) in a format that meets the Annual Monitoring Report requirement for IFC. This will detail environmental, social, health and safety data and incidents and monitoring at WDL, this document will also include overview data from Petra’s other operations as appropriate.
PS 2. Labor and Working Conditions
WDL has a well developed HR Policy which contains General Terms and Conditions of Employment as well as prohibitions on child and forced labour. There is also a recognition agreement between WDL and the Tanzania Mines, Energy, Construction and Allied Workers’ Union (TAMICO) of which about 85% of the workforce are members. The conditions of employment comply with national law, provide for equal opportunity principles, and have a grievance mechanism. The organizational responsibility for human resources resides at Petra''s head office in Johannesburg, although each operation is responsible for the direct management of people through a HR Manager. Petra is committed to be an equitable employer and providing a healthy and safe environment for its workers. Conditions of employment are compliant with the requirements of IFC Performance Standard 2.
One of the priorities for Petra at Williamson is protection of jobs by upgrading and expanding operations that might otherwise be scaled down or closed by maintaining opportunities for local employment in its mines. Currently, the company employs about 1000 people (including contractors) at Williamson mine.
Occupational Health and Safety (OHS): Petra publishes LTIFR and shift loss statistics for each mine in its Annual Sustainability Report. The statistics for Williamson are excellent with an LTIFR of 0.13 per 200,000 shifts which compares with an average for Petra operations of 0.76. There have been no fatalities at Williamson since the Petra acquisition.
PS 3. Pollution Prevention and Abatement
Water Quality and Use: The supply of water for both domestic and industry uses at WDL is dependent on the surface water sources, i.e., the water dams. Surface water sources include Nhumbu dam, Songwa dam and New Alamasi dam, which supply water to the mine as well as to Mwadui Township. Water quantity has historically been insufficient to sustain mining levels and domestic demands which necessitate water control measures, especially during the dry season. The operations and the surrounding community have been dependant on good rainfall to ensure that there is enough water. For the expansion programme WDL recognize that it will be critical to have sufficient water and therefore groundwater potential in the area will be investigated as part of the ESIA for the expansion programme to ensure sustainability of water abstraction such that community and mine needs can be met. This work will also include preparation of a water balance to fully understand the interaction between ground and surface water resources, together with the mine and community water needs.
Waste Management System: In accordance with the Tanzanian Environmental Management Act of 2004, waste streams at WDL have been kept separate where practicable, in order to improve waste management onsite. This includes clear classification, sorting and handling of the different wastes that result from mining operations, and accommodation facilities.
The objectives for waste management are:
Clean up historical waste
Dispose of all waste in an environmentally responsible manner, acceptable to the local community
Apply the principles of re-use and recycling before disposal where practicable
Whilst segregating waste streams at WDL aids in minimizing costs (by recycling); enhances re-use strategies (by re-using or selling off salvageable material); assists surrounding communities by donating some re-usable waste material; it also improves general environmental management and practice. WDL have classified their waste into three categories i.e. Domestic waste, Medical waste and Industrial waste. All waste streams are quantified and reported on annually.
The waste management system at WDL is supported by comprehensive procedures on waste management, rehabilitation, bioremediation and spill handling.
Solid Waste: Primarily includes mineral waste, domestic waste, and industrial waste, i.e. scrap metal, used conveyor belts and tyres and used drums.
Mined kimberlite and tailings materials are screened into size fractions and the material concentrated using ferrosilicon (FeSi) dense media separation (DMS). Waste generated during the DMS process is disposed into waste dumps in secure areas since the waste may still contain some diamonds.
General waste is disposed in a landfill and medical wastes are incinerated at the hospital using three incinerators including one certified for needles. These are certified to appropriate international standards with incineration temperatures up to 1,200 degrees centigrade.
Scrap metal and used conveyor belts and tyres are sorted and collected by a contractor for reuse. Used tyres are recycled for a number of purposes around the mine including ground stabilization and use as markers and road barriers. However, in such use tyres may collect water and thus become a breeding ground for mosquitoes. WDL will implement a programme to fill such tyres with waste material to prevent water build up. Empty FeSi and cleaned oil drums are used as waste bins in the township and mining area.
Liquid Waste: Primarily includes sanitary and domestic wastewater from the 15,000 Mwadui Township mine community referred to above, used oil and process effluent.
All sanitary and domestic wastewater is directed to the waste stabilization ponds for treatment. Four waste stabilization ponds are operational at WDL and these are Kawawa Pond (KP), Main Gate Pond (MGP), Mine Crescent Pond (MCP) and Mwadui Pond (MP). Stabilized sewage effluent is discharged into the immediate environment and the water is sampled on a quarterly basis for bacteriological, chemical and physical analysis for which maximum acceptable effluent concentrations have been set by the Tanzanian authorities. However, discharge water from at least one pond is directly used for informal crop irrigation about 10 metres from the outflow and therefore in future WDL will utilize the more stringent standard for irrigation purposes. The SGS Laboratory in Mwanza, analyzes all water samples for all parameters. Water analysis for the year 2009 was done twice i.e. August and December. The sewage ponds water quality monitoring results are compared with the Maximum Permissible Concentration Level (MPC) for effluent water standards as set out under the Fifth Schedule of the Mining (Environmental Management and protection) Regulations, 1999. This data indicates several exceedances for BOD, COD and pH. However, the key parameter of e-coli was not included in the monitoring data provided but will be covered by future monitoring.
WDL have committed to upgrade the sewage treatment system to ensure that the pond discharge meets Tanzanian irrigation standards as well as IFC guidelines.
Currently there are no dedicated monitoring boreholes around the ponds and the volume of stabilized sewage effluent discharged is not quantified. In addition, WDL will strengthen its malaria vector control to ensure that the ponds are not a breeding ground for mosquitoes; malaria was identified by the WDL Medical Doctor as one of the main diseases in the area.
Petra recognizes that water management and the prevention of pollution are key to its operations and have committed to improve sewage treatment at WDL within the next year. This improvement would include an assessment of the water discharge and appropriate engineering modifications and groundwater monitoring boreholes and well sampling (supplementing existing shaft and well sampling) which will allow WDL treated sewage to comply with Tanzanian standards for irrigation as well as IFC guidelines.
As highlighted above, the finer materials and clay that are removed from the ore, are sent to slimes dams. Water draining from the slimes dams is collected in sediment ponds from which clear water is recycled to Dam No. 7 from where it is pumped back for reuse in the processing plant. Since no chemicals are used at this stage in the process, and the material is not acid generating, the slimes dams pose minimal risk. As with the sewage ponds above, there are currently no monitoring boreholes at the slimes dams.
Petra has committed to commissioning a hydrological study at WDL to: a) identify groundwater location and flows; b) prepare water balance to define sustainable water surface and groundwater resources that will ensure sufficient year-round provision of process and community water for the expanded project; c) implement key recommendations arising from these investigations including installation of monitoring boreholes; d) include village water resources in the WDL baseline water monitoring programme and e) link results to EMP and Annual Monitoring Report at WDL.
Used oil is collected by a contractor for reuse in steel industries.
Pollution Prevention: WDL recognizes the importance of water conservation and is striving to implement good practice standards in the management of its water on site through minimizing its use of water from water storage dams and maximizing opportunities for reusing process waters and capturing and recycling storm water runoff. This is made possible through the design and operation of the site’s comprehensive surface water capture and reuse program. Surface water is sampled quarterly from a number of clearly identifiable sampling points for bacteriological, chemical and physical analysis for which maximum acceptable concentrations have been set. No groundwater monitoring currently exists at the mine.
All storm water is collected in drains that flow to selected containment ponds for storage before being reused on site. Three dams have been constructed on site to capture storm water.
Water from oil/water separators is sampled and monitored for hydrocarbons. Water is collected at the outlet of the oil/water separating sumps which are located at all wash bays and workshops. Four oil/water separating sumps are available on the site and currently the fifth oil/water separating sump is being constructed.
Petra has committed to strengthen their water monitoring at WDL to be in line with their South African operations. To ensure that sufficient water resources exist to supply both the proposed expansion and the local communities, Petra will commission a hydrological study which will establish a water balance for the operation. This will enable the sustainable water abstraction rates from the various resources to be established. The study will also lead to the installation of groundwater monitoring boreholes at all effluent holding facilities at the mine. Additional, WDL will also monitor groundwater levels and quality at selected nearby community drinking water sources.
WDL run a bioremediation area on site. In the event of an oil, fuel or lubricant spill as much of the contaminated material / soil as possible is lifted and removed to the bio-remediation area. The site of the oil spill is treated with a suitable bioremediation product in accordance with the manufacturer’s instructions. The bioremediation area provides an improved method for enhancing the bioremediation of hydrocarbon contaminated soil by stimulating the growth and activity of naturally occurring, hydrocarbon assimilating, and micro-flora and by rendering the hydrocarbon contaminant more accessible to the micro flora.
Energy use: WDL’s annual energy requirement is 28 million kWh (which is expected to increase with the new mill operations) and is primarily electricity sourced from the national energy utility, Tanzania’s National Electricity Company, TANESCO. However, due to energy constraints in Tanzania WDL has two backup Mirrlees diesel generators with a capacity of 2.5 MW each. When running (approximately 43 hours every month), the two Mirrlees generators consume an average of 500L each per hour of heavy fuel oil. As a result of this requirement, WDL (through their fuel contractor, Oryx, keep 100,000L of heavy fuel oil and 100,000L of diesel fuel (for vehicles) on site. Four 50,000 liter fuel storage tanks are situated at ground level and provided with adequate secondary containment structures. WDL uses an average of 30,000 liters of diesel fuel a month and the bulk of the fuel is used by its mining contractor, Caspian Mining.
PS 4. Community Health, Safety, and Security
Surrounding Communities: There are eight communities in the area close to the mine which WDL considers to be in its zone of influence. These are Buganika, Idukilo, Ikonongo, Maganzo, Masagala, Nyenze, Songwa and Utemini. Together approximately 30 000 people are estimated to live in these villages. Each village has appointed a representative to liaise with WDL on community matters. The mine community of Mwadui Township has a population estimated at 10,000 people, a little over 1,000 of whom are either directly or indirectly employed by the mine although WDL provides all services and infrastructure maintenance within the town.
The main health concerns amongst local communities are malaria and HIV / AIDS. Although WDL co-ordinates with the Tanzanian authorities on malaria rollback this is mainly focused on education and provision of bed nets. A greater emphasis will in future be placed on vector control such as avoidance and spraying of standing water and other breeding grounds (e.g.: the sewage oxidation ponds, old tyres). WDL has an HIV / AIDS programme and provides ARV drugs to staff and dependents. The incidence rate is not known but some 1,105 people in Mwadui have been tested as HIV positive since 1989. Some 302 are currently receiving ARV drugs (only 15 of these are current WDL employees).
Security Personnel Requirements: Due to the high value nature of diamonds with risk of attempted robbery, WDL requires a full time security force. The security operation has several tiers comprising WDL security staff, contractor Group 4 Securicor (G4S) and the Tanzanian Police who have a station in Mwadui. Further police back up is available from other nearby towns. WDL maintain an extremely effective local intelligence network and employ villagers from all the nearby villages in a “neighbourhood watch” type system. Further details of the security operation will not be made publically available due to the security sensitive nature of the information.
Some of the security guards are armed and WDL and Petra have committed to follow the UN Voluntary Principles on Safety and Security at Williamson.
Emergency Preparedness and Response Plan: The 2005 EMP stated that WDL was in the process of setting up an Emergency Preparedness and Response Plan (EPRP) but this was not completed. WDL have now committed to completing this EPRP that will ensure;
A safe environment for all employees, contractors, visitors and neighbours.
That all activities are conducted in an environmentally responsible manner consistent with environmental regulations, guidelines and best practices.
The identification and management of all significant environmental risks.
The existence of a comprehensive system for managing emergencies and a high degree of emergency preparedness.
That the response to emergencies is predicated primarily on the preservation of human life and the safety of emergency response personnel.
The containment of emergencies and their effects within facility boundaries.
Cooperation with external emergency response organizations.
A safe return to normal operations.
Implementation of the EPRP will be the responsibility of the HSE Department.
