PS1: Social and Environmental Assessment and Management System
Petra has committed to maintain and improve on the existing management systems that were developed and implemented at Finsch by De Beers. The mine will adopt the EMPR and continue the good work that was started during De Beers’ ownership and will maintain ISO 14001 & OHSAS certification. The mine will also maintain adherence to the strong, well enforced South African environmental laws, regulations and requirement which IFC is satisfied with. As noted above, both the MPRDA and NEMA are used to guide practice, as well as various international best practice standards which are in line with IFC’s Performance Standards. In addition and to aid the continuity, Petra retained the majority of the Finsch staff including the senior management team and personnel responsible for environmental and social issues – see retrenchment section below. Thus, IFC is satisfied that the Finsch operations will remain in compliance with the environmental, health & safety and social regulations, policies and guidelines of South Africa and IFC.
Assessment: A number of EMPRs have been drawn up for the mine under previous legislation (Minerals Act No 50 of 1992 – since replaced by the MPRDA) and approved by the lead authority, the Department of Mineral Resources of South Africa (DMR). Currently, Finsch operates with two approved EMPRs; the main one being Finsch EMPR, July 2007, and Finsch EMPR for Construction of new Fine Residue Deposit – Amendment to EIA/EMP Report, dated November 2006. Each EMPR contains an Environmental Management Plan (EMP) containing agreed management commitments with respect to environmental, mitigation measures arising from the assessment process. Social issues are addressed in the Social and Labour Plan (SLP).
The approved Finsch EMPR is currently being updated; it was decided that a complete re- write of the document would be preferable to an amendment as there are significant changes to be made, including alignment with new legislation. Whilst much of the content of the current EMPR is relevant, impacts of operational changes that are expected to take place at Finsch within the next 5 years, including the expansion project, will be assessed and included in the document. The final updated EMPR is scheduled to be completed and submitted to DMR on 30 April 2012.
Through the EMS, activities that may have a significant impact on the environment are managed with operational procedures and monitoring systems and environmental objectives and targets based on the significance rating of each of the environmental aspects. These objectives are addressed by action plans which form part of the mine’s EMS.
The mine is legally obliged to undertake performance assessments on the commitments contained in the approved EMPRs every two years and to submit the report to DMR. To satisfy these requirements, De Beers commissioned an independent consultant to undertake performance assessments on the two EMPRs in August 2011 prior to the acquisition of the mine by Petra. The assessments covered the period July 2009 to August 2011. During the same time, De Beers commissioned another independent consultant to conduct a legal compliance evaluation against all relevant environmental legal requirements applicable to the mine. The aim of the audit was to identify deviations from the applicable requirements of environmental laws, procedures and policies. Three separate reports were compiled according to the requirements of the MPRDA and submitted to the DMR. The previous performance assessments on both EMPRs were done in 2008 also by external specialists.
The performance assessment and environmental legal audit reports identified a number of non-compliances and made recommendations to achieve compliance. None of these are PS non-compliances.
Management systems and training: During De Beers’ ownership of Finsch, an EMS was developed which was certified to ISO 14001. De Beers also obtained OHSAS 18001 certification for the site. The most recent ISO 14001 surveillance audit – March 2011, a copy of which has been reviewed by IFC, concluded that the EMS is implemented effectively and meets the minimum requirements of ISO 14001. This assessment was undertaken at the time Petra was in the process of acquiring the mine from De Beers. Petra will maintain the mine’s ISO 14001 & OHSAS certification.
Environmental awareness and competence training of employees is undertaken according to the mine’s Training procedure.
Organization: As an established mining operation, Finsch employs an Environmental Specialist supported by a Senior Environmental Officer, an Environmental Officer and an Environmental Administrator. The Specialist, together with the Chief Safety Officer and Proto (Mine Rescue) Team Coordinator, report to the Risk Manager at the mine, and has a dotted line reporting to the Group Environmental Coordinator based at Cullinan Diamond Mine. There is a Community Relations Practitioner who reports to the Finsch Human Resources Manager and also by a dotted line to the Group Human Resources Development Manager. The practitioner, who is supported by a Community Development Coordinator, is in charge of the Corporate Social Investments (CSI) in close coordination with, Finance and Human Resources departments, National Union of Mines (NUM) and Labour Sending (centres/towns of main sources of labour) Areas representatives.
Although top management carry the responsibility for ensuring the successful implementation of the EMS, environmental management is part of the day-to-day operational activities and is regarded as a line function.
Environmental Policy: Finsch has adopted the Petra Environmental Policy which states, amongst other commitments, that the company is committed to maintaining a high standard of environmental performance and will comply with the environmental laws, regulations and requirements of the country in which it operates and will adopt international best practices where possible.
Monitoring: Finsch applies a number of mechanisms to monitor the effectiveness of the EMS and these include: external certification and performance audits; internal audits; annual management review meetings; review of the aspects and impacts register; physical monitoring (water quality and quantity, dust fallout, noise, waste generation, rehabilitation, etc.); legal compliance audits and updating of the legal register; and incident and accident reporting and addressing external complaints. All these mechanisms have clearly defined procedures.
The non-conformance and corrective and preventive action procedure is seen as one of the most important mechanisms on the mine used to ensure the effective use and implementation of the environmental management system. This system is used to report any environmentally related non-conformances, investigate the non-conformance, identify appropriate corrective and preventive action and implement these actions to prevent occurrence and recurrence.
Reporting: Petra publishes an annual Sustainable Development Report for which the current one covers 1 July 2009 to 30 June 2010 – FY10. Thus Finsch’s environmental, health & safety and social performance will appear in the FY12 (1 July 2011 – 30 June 2012) Petra Sustainable Development Report which is expected to be published in December 2012. This sustainability report contains good aggregate coverage of key environmental, social, health and safety indicators.
At the mine, non-conformances are recorded in the Isometrix database and the required corrective and preventive action taken.
In accordance to the requirements of the MPRDA and as already highlighted above, EMPR performance assessment reports are submitted to DMR. Finsch’s EMPRs are also posted on the Department of Water Affairs (DWA) website as case studies.
PS2: Labor and Working Conditions
Finsch currently employs 754 employees, including four foreign nationals. The majority of the local employees are from the towns of Kuruman/Kudumane, Danieskuil, Kimberley, Taung and Postmasburg. The employment of foreign personnel is conducted in accordance with the guidelines of South African immigration laws regarding employment of foreigners. Finsch is committed to complying fully with the spirit and requirements of government and industry agreements to ensure non-discrimination against foreign migrant labour. In compliance to the MPRDA, the mine has an approved Social and Labor Plan which outlines commitments relating to the workforce, including training, grievance mechanisms and reporting and monitoring. Finsch does not employ child or forced labor anywhere at the mine.
Finsch Diamond Mine is currently engaged in agreements with several contractors based on a defined scope and outsourcing of services such as transport, repair and maintenance of underground trackless mining equipment, maintenance of the slimes dams, electrical works, and building maintenance etc. Through these contractual agreements, the mine employed 322 contractors as at the end of June 2011.
Finsch has 1213 units of housing that are allocated to Mine employees. Allocation of houses is governed by the Accommodation and Housing Committee Policies. Between 2000 & 2005 the previous hostel was modified with 55% being converted to single rooms (single quarters) and 45% converted to family accommodation.
There are three accredited labor unions active at Finsch, NUM – 465 members, Solidarity – 73 members and United Association of South Africa – 7 members. All workers are guaranteed Freedom of Association as part of a formal agreement between Finsch and these unions. Petra signed a Recognition/Collective Agreement on August 5th 2011 with NUM. The agreement covers all of Petra’s current mines and any other mine which the group may purchase in future. The key objective of this legally binding agreement is to lay down principles and procedures which will regulate industrial relations between Petra and the Union.
In keeping with its policy of fair and equitable employment practices, Finsch is committed to complying fully with the requirements of the MPRD Act and the Employment Equity Act, 55 1998. To this end, the company sets itself a five year plan to achieve Employment Equity numerical targets by 2012. The MPRD Act puts a premium on the employment of Historically Disadvantaged South Africans (i.e. non-whites), and has set targets which companies must comply to. The mine aspires to the inclusion, continuous employment and recruitment of disabled individuals towards the manpower of the operation. The disability progress is monitored on a monthly basis through a graph that shows overall mine wide progress and departmental progress. The quarterly employment equity meetings are also used to track progress and also to seek solution in addressing this challenge.
Finsch has also made good progress in employing women, currently comprising 12.38% of the total labour force against a legislated target of 10%. The Women in Mining Learnerships form part of the normal learnership programme. Women from the local community form part of the learnership programme within the following disciplines; mining, metallurgy and engineering.
In response to a number of challenges related to the 2009 economic crisis Finsch issued section 189A notice (notice to retrench) to all its employees in May 2010. Section 189 notice was issued in the prescribed and correct manner to the entire mine’s employees. In addition, and in compliance with the Social and Labour Plan, a Future Forum was established at the mine comprising of management and the respective employee representative bodies, including the NUM. One of the key focus areas of the Future Forum was to play an active role in coming up with means to mitigate the impact of retrenchments on employees, including identifying portable skills training to be provided to the affected employees. After several consultative meetings between the company, NUM and Solidarity, facilitated by the Commission of Conciliation, Mediation and Arbitration, 63 employees were terminated against an initial estimate of 350 positions. IFC is satisfied that the retrenchment process was conducted in line with PS2 (2006) requirements. No further retrenchment is anticipated under Petra ownership of the mine.
The LTIFR statistics for Finsch are excellent with an LTIFR of 0.38 which compares with an average for Petra operations of 0.76. The last fatality at the mine occurred in November 2008, 12 years after the previous fatality. There have been no fatalities at Finsch since the Petra acquisition.
The mine has in place a comprehensive Anti Retroviral Treatment Programme for its employees and their life partners. Voluntary HIV/AIDS testing is conducted with counseling and education programmes. There is an HIV/AIDS coordinator who is working on a full time basis giving HIV/AIDS counseling and promoting an HIV/AIDS awareness programme in and around the vicinity of the mine
PS3: Pollution Prevention and Abatement
Finsch applies specific pollution prevention and control measures plus waste management practices that are supported by robust procedures and consistent with good practice. Some of these measures and management plans are highlighted in the sections below.
Waste Management: Waste at Finsch is managed according to the mine’s waste management procedure for which the main objectives are to dispose of waste in a safe manner to prevent contamination of the environment so as not to pose a health hazard. Finsch has an inventory of the wastes generated at the mine where identification and characterization is an on-going process subject to continual revision. Waste is separated at source as far as possible into hazardous, domestic, scrap metal and garden waste and mine mineral processing waste. Hazardous waste is further classified according to the South African National Standards - SANS Code 10228 which specifies minimum requirements for the handling, classification and disposal of hazardous waste.
The volumes of all waste produced at the mine including waste that is recycled are recorded. Waste recycled includes scrap metal, paper and used oil.
As part of the waste management system there are several waste management facilities at the mine which include the waste management yard, general waste landfill, temporary hazardous waste storage area, bioremediation site, incinerators and mine residue disposal sites. The waste management yard is a designated managed site that exists for the receipt, collection and control of waste generated at the mine. The yard includes a hazardous waste storage area, a general waste disposal landfill site as well as a bioremediation site. A monitoring system is implemented in order to monitor seepage from the site. The Department of Water Affairs and Forestry (DWAF) have authorised the disposal of general waste to this landfill.
The mine operates two incinerators, one outside the security area of the mine (situated at the Sewage Plant) which is used for the burning of sewerage screenings, and a second located inside the Recovery Plant for general waste. Finsch adheres to the operating procedure as required by the Atmospheric Pollution Prevention Act, 1965 (Act 45 of 1965), as stipulated in the accompanying certificates for the two incinerators.
Mine residues at Finsch are classified as fine residue deposits (FRD) and coarse residue deposits (CRD and waste rock. The mine is committed to the systematic management of all of its residue deposits in a consistent, environmentally sustainable and safe manner. Residue deposits are managed according to a regulated Code of Practice which is integrated with mining operations.
The main difference between the tailings and that of the fines residue is the particle size of the fines residue which is smaller than that of the tailings particles. These FRDs – three currently - will be permanent structures and will be rehabilitated according to the rehabilitation plan (2011). The pre-1979 CRD are considered as resources and are being reprocessed. The post-1979 CRD could also be reprocessed in future depending on market demand. The Open Pit Waste rock dump is partially rehabilitated and three smaller waste rock dumps are rehabilitated
All mine residue deposits at Finsch are inspected and monitored for the ongoing raising and operation on a quarterly basis by an independent consulting engineering firm.
Water use: Finsch has a water management system which is based on principles such as pollution prevention, management of affected water at source, optimal re-use/recycling of affected water. The mine water reticulation is a closed system.
Water Sources:
Bonza Quarry: In compliance with the National Water Act, Finsch has an approved Water Use License which entitles the mine to withdraw 2.4 million m3 of non-potable water from their Bonza Quarry. The major source of water for the Bonza quarry however was water that was pumped over from an adjacent PPC Quarry. This water source has diminished over the last two years and a continued supply depends on further negotiations with the neighbouring PPC mine and water authority.
Dewatering of the Mine: Finsch has a Water Use License to use a maximum of 2.4 million m3 from the dewatering of the mine although only 1.2 million m3 from the dewatering of the underground workings is actually pumped; this figure has proved to be consistent over the years.
Vaal Gamagara (VG) Pipeline water provided by Sedibeng. (Potable): Finsch is authorized by Sedibeng to abstract approximately 3.2 million m3potable water from the VG pipeline. The expansion projects and projected increased water requirements for the next 6 years was communicated to Sedibeng in July 2011.
Water consumption for production purposes depends on the balance of underground rock mined and tailings treated since tailings treatment requires less water. The average overall consumption rate for production purposes for 2011 up to August is 0.63m3/ton. The indications are that this figure will not change with the proposed increase in production to 2 MCts since the expansion involves mining higher grade ore and therefore the tonnage of rock processed will remain roughly the same as at present (the plant throughput capacity is 7.2 million tons per annum). The water required for production is mainly sourced from underground dewatering plus water from the VG pipeline. The water from the PPC quarry was often used in the past to supplement the water requirements for production, thus reducing the amount of potable water used from the VG pipeline. However, although Finsch holds a Department of Water Affairs permit for pumping water from the Bonza quarry which PPC supplies with water, the water supply system in the Northern Cape is undertaken by the Sedibeng Water Authority and they stopped Finsch from using this water as Finsch had historically obtained the water free of charge. Finsch will in future have to pay for this water and this is under negotiation with the Sedibeng Water Authority. Until this is resolved, Finsch is using a proportion of the potable water from the Vaal pipeline for production purposes (1.8 m3 in 2011).
PPC Lime (the owners of the quarry) does not have an integrated water use licence yet and this is causing the delay in addressing the Bonza quarry water issue. Once this is resolved, Finsch will update its Water Uses and relevant authorizations.
Finsch has conducted hydrogeological studies for various reasons since the early 1990s. Numerical groundwater modeling was undertaken to determine the impacts of dewatering on the local water regime when underground mining commenced, groundwater water quality monitoring started in 1998 and in 2005 a groundwater impact assessment and pollution plume model project was initiated; this project is in the final phase of implementation this year.
The mine has a good groundwater monitoring programme in place where 60 boreholes surrounding the residue deposits are sampled on a regular basis (i.e. monthly or bimonthly) and neighbouring farm borehole levels are monitored annually.
The geology of the eastern side of the mine is comprised of dolomites and this is the focus area of the groundwater impact studies Water levels on farms adjacent to the mine lease area on the western side of the mine have been found, through surveys, to be similar to the pre-mining water levels; an indication that the dewatering cone of depression due to the mining operation is of a limited extent. The impacts on the groundwater to the eastern side of the mine are more complex due to the influence of the PPC mining activities and this area is included in the current study
Sewerage: Finsch provides sewerage services to 98% of the residential areas of Lime Acres. The remaining outlying facilities which are not located within the vicinity of the sewer services are serviced with conservancy and septic tanks. The activated sludge plant, which has been operational for approximately forty years, is operated as a joint facility by PPC Lime and Finsch and the operation is managed by Finsch. The final effluent from the sewage treatment works is returned to the process water reticulation system after it is disinfected with chlorine gas to ensure that there are no faecal coliforms which could pollute the process water system. The water is tested regularly. The composting process is managed by the Environmental Management Section which uses the compost as topdressing material for the rehabilitation of mine residue dumps. Use of this compost for this purpose was authorized by the Department of Water Affairs in 2001.
Kgatelopele municipality sewer services empty the conservancy tanks and dispose the sewage effluent at the Sewage Treatment works in Danielskuil. The septic tanks are desludged when necessary by Finsch services section and the sludge is disposed of at the Lime Acres treatment works. The joint Finsch/PPC Sewage Treatment Works are operated according to the required SANS standards and well maintained by suitably trained employees. The works are also regularly monitored by an independent external consultant. A monthly report is generated by the consultant and non conformances are discussed and actioned appropriately by the Engineering Services section of the mine.
Closure and Rehabilitation: Finsch has an updated rehabilitation plan which focuses on the end state of mine for closure; but due to the extended life of mine the rehabilitation planning timelines and closure plan will be reviewed and aligned with the new EMPR.. The closure costs make provisions for immediate closure and Life of Mine closure, and include decommissioning and restoration costs. These plans are updated on a regular basis and were developed according to the Anglo Toolbox Kit and requirements of MPRDA.. The mine’s rehabilitation and closure obligations are fully funded via a financial guarantee that is lodged with the Department of Mineral Resources.
Emergency Preparedness and Response: Potential environmental incidents that could result in environmental emergencies have been identified on the mine and plans and procedures have been established to ensure that there will be an appropriate and adequate response to any emergency incident. These potential incidents include petrochemical/chemical spillages, fires, fine tailings (slimes dam) spillages and failures, untreated effluent spillages, and surface flooding. Emergency drills are scheduled regularly and conducted to identify potential areas for improvement. Records of these drills are kept. Some of the emergency related procedures at the mine are:
• Maintenance activities, breakdowns and emergency cleanups,
• Emergency evacuation procedures in case of an emergency underground and FRD wall failure,
• Surface and underground flooding,
• Surface and underground fires,
• Spill management, and
• Emergency Preparedness and Response
All employees and contractors are responsible for reporting any emergency incident to their supervisor or the responsible person of the area or to the Resources Protection Services Control Room immediately.
Energy: The mine is served by the Eskom power grid from which it draws an average of 168 779 769 kWh of electricity per year based on the actual yearly consumption between 2000 and 2010. During the same period, the diesel consumption averages 2 364 984 litres per annum which roughly translates to an average of 0.45 litres per ton of ore mined and processed. The mine has very little fixed diesel equipment (incinerators and standby gen sets) which is estimated to consume approximately 0.01% of monthly consumption. The majority of the diesel is consumed by mobile vehicles.
Finsch does record CO2 generated in terms of Fossil Fuel consumption and indirectly from electricity purchased. Thus the average total carbon emission between 2000 and 2010 is 156 528 tons per year.
The mine has embarked on a number of initiatives to reduce electricity consumption. These include the ongoing replacement of old generation Light Fittings with LED Light Fittings in the Plant and Workshops, and ongoing replacement of old motors in the Plant and Mining with High Efficiency Motors (about 50% of the Plant is currently running on High Efficiency Motors). Finsch has also decommissioned the old High Tension as well as mini substations to reduce passive load. All houses are now fitted with compact fluorescent lamps (energy saving lamps) after Eskom’s 2009/2010 sponsored and audited project. In the coming year, Finsch plans to investigate (with Eskom) the replacement of village geysers with solar units, a project with a potential load reduction of 2 MW.
PS4: Community Health, Safety and Security
The effects of noise, air quality (i.e. dust and to a lesser extent SO2) and water pollution on surrounding sparsely populated farming, Finsch and PPC communities are monitored by independent consultants on a regular basis and presented to the mine and the relevant authorities. The potential dust sources include the mine residue deposits, mining activities, haul roads and conveyor belts. There are procedures in place on the mine to minimize these occurrences.
The emissions from the incinerator are of such a low magnitude that the impact can be considered negligible. PPC Lime generates air emissions from the kilns and dust from loading and hauling activities; they currently monitor the stack emissions. Finsch also commissioned an independent consultant to perform a diesel vehicles emissions measurement exercise for all mine vehicles in 2010. The primary objective of this survey was to determine whether mobile self-propelled vehicles used on the mine complied with environmental and health legislation regarding gas and smoke emissions. The findings confirmed compliance.
Finsch recently contracted an independent contractor to develop an integrated air quality management plan which will ensure that impacts related to air quality management are addressed and that the mine remains in compliance to the relevant sections of the National Air Quality Management Act.
Noise is generated by traffic, earth moving machinery and the processing plant. All vehicles and earth moving equipment are fitted with standard exhaust mufflers in order to minimize noise. All the machinery of the processing plant is contained in buildings at Finsch to reduce noise. Noise surveys have indicated that the noise projected to the outside of the mines (Finsch and PPC) is minimal and does not affect the nearby population.
In compliance to its commitment to fight HIV and AIDS, Finsch has taken an active role in being a partner with the South African Government to align its strategies to the government Strategic Plan as well as the Mining Charter and Social Labour Plan. To this end all initiatives (including communication/awareness campaigns, proactive prevention strategies and Anti Retroviral Treatment Programme, etc.) that have been adopted on the mine for the employees are being extended to the surrounding community of Lime Acres, Groenwater as well as Danielskuil.
The HIV and Aids Initiatives are driven though an HIV Policy as well as Occupational, and Medical Procedures which are communicated to all employees on a regular basis and reviewed continuously in order to address the changing health scenario at the mine as well as in the country.
Should an emergency situation arise at Finsch there is a well established communication system to notify local authorities such as Police, Fire and Emergency Department, Environmental authorities and surrounding communities.
Due to the high value nature of diamonds with risk of attempted robbery, Finsch requires a full time security force. Thus, the mine has in place a Security Department which has a number of firearms at its disposal for use by Security Officials in performance of such tasks as bank/cash escorts and production shipment. There is a working practice in place to ensure that all designated security officials are aware of the safety regulations pertaining to the issuing and handling of firearms, know when to use a firearm and the legal implications thereof and that proper control is maintained. The practice generally follows the UN Voluntary Principles on Safety and Security. All designated security officials were trained and found competent.
The mine also works with the local municipality/police to improve local security. Further details of the security operation will not be made publically available due to the security sensitive nature of the information.
