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AFRICAN MINERALS LIMITED



Tonkolili Iron Ore Project



Stage 1 Environmental, Social and

Health Impact Assessment



305000-00006-0000-EN-REP-0020

18 Jun 2010



Parkview, Great West Road

Brentford Middlesex TW8 9AZ London

United Kingdom

Telephone: +44 (0) 20 8326 5000

Facsimile: +44 (0) 20 8710 0220

www.worleyparsons.com



© Copyright 2010 WorleyParsons



AFRICAN MINERALS LIMITED

STAGE 1 ENVIRONMENTAL, SOCIAL AND HEALTH IMPACT ASSESSMENT

TONKOLILI IRON ORE PROJECT



SYNOPSIS

African Minerals Limited (AML) is developing a new iron ore mine identified as the Tonkolili Iron Ore

mine in Sierra Leone on the west coast of Africa. The Project has three phases of production as

summarised below.

Phase 1 involves mining, beneficiation and export of a surface hematite deposit at a maximum rate of

8 Mtpa. Transport and export of the ore will use a combination of road, rail, stockpiling at the

refurbished port facility at Pepel and transshipment to cargo vessels moored off-shore. Phase 1 is

due to start production in early 2011 and early enabling works are either already underway or close to

starting. The focus of this Environmental, Social and Health Impact Assessment (Stage 1 ESHIA) is

the Phase 1 project.

Phase 2 involves the mining and processing of additional transition material at a rate of approximately

17Mtpa as well as continuation of the phase 1 mining to give a combined production rate of 25Mtpa.

Phase 3 comprises mining a deeper, hard-rock magnetite deposit, processing the magnetite to a

concentrate and export at a design rate of 45Mtpa. This will potentially rise to higher rates of

production depending on the confirmation of subsequent geological resource models. Phase 2 and 3

infrastructure is configured substantially differently from Phase 1 and will transition from light-rail or

road trucking progressively towards dedicated heavy-haul rail transport from the mine to a new deep

water port facility to be located at Tagrin. Phase 2 and 3 are due to commence circa 2014 and are

the subject of a forthcoming ‘Stage 2 ESHIA’ that will follow this document. The Stage 2 ESHIA

therefore primarily evaluates the environmental and social issues that could potentially manifest

during mining phases 2 and 3. The Stage 2 ESHIA will also provide an opportunity to update the

impact assessment with additional findings from an ongoing programme of studies and monitoring.

This ESHIA has been prepared for submission for approval on the understanding that elements of the

infrastructure design and ESHIA study are not yet fully developed. In recognition of this, the

proponent (AML) has committed to undertake completion of the various ESHIA studies, which are

either ongoing or soon to be undertaken and will be reported on in updates to the Environmental

Management Plan (EMP) and as part of the Stage 2 ESHIA. Comprehensive environmental and

social (E&S) management will continue, with the studies inputting to project design, construction and

development. It is recommended that rigorous risk review is applied in the interim ahead of ESHIA

Stage 2 submission in order to identify appropriate Environmental and Social (E&S) management

measures, which will be delivered through the ongoing EMP that will extend into the operational

phase.

This ESHIA includes a review of the legislation framework associated with environmental, social and

health management and assessment. The ESHIA considers the Phase 1 project, the existing physical

conditions i.e. the environmental and human baseline and the likely impacts that may arise, both

positive and negative. Where there are impacts identified that could cause adverse effects, the

ESHIA considers alternatives, mitigating measures and what the likely remaining or residual impact

will be after such intervention. Finally, the ESHIA sets out requirements for ongoing management,

assessment, monitoring and institutional relations.



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AFRICAN MINERALS LIMITED

STAGE 1 ENVIRONMENTAL, SOCIAL AND HEALTH IMPACT ASSESSMENT

TONKOLILI IRON ORE PROJECT



A significant volume of physical and social data collection as well as assessment work has been

compiled into this impact assessment to comply with regulatory requirements ensure an adequate

understanding of the project is available for decision making. In some areas, it is recognised that

further work is required, including further project definition in order to be able to define more specific

impacts and mitigation measures and develop effective management strategies. However, the

ESHIA is thought to be sufficiently complete for it to meet its intended decision-making purpose.

Furthermore, an Environmental Management Plan (EMP) has been prepared which provides a

framework for managing the delivery of mitigation measures, further monitoring and continual

improvement in the project’s environmental and social performance. The EMP is a live document that

is part of a management system reporting on updated information as it becomes available, and

allowing feed into ongoing design work.

Where construction management plans can be prepared based on the currently available information,

these have been provided. In other instances, the management plans will need to be formulated

pending further work. All that can be presented at this time is a thematic management plan that

outlines the scope of the management intervention that will likely be necessary.

The EMP in this Stage 1 ESHIA includes a number of thematic plans, describing how mitigation will

be delivered where required and these will be updated with new survey data as it becomes available

and as infrastructure designs progress, enabling decision making to ensure minimisation of potential

adverse effects.

This is particularly important for the terrestrial and marine eco-systems that could be affected by the

project. To date it has been recognised that areas under the direct footprint of the project contain

either recognised high conservation value species or habitat that is of major significance. An

integrated approach involving additional assessment, avoidance wherever possible of critical areas,

mitigation, development of compensatory programmes and community development programmes is

required. Further study work is required and will be included in a Stage 2 ESHIA later in 2010 that

will provide more specific design and definition to these programmes.

It is also important that management plans take into account consequential impacts that will arise,

many of which will be unintended and difficult to control. This includes impacts associated with

speculative influx of migrant workers and accelerated degradation of habitat in areas that was hitherto

relatively inaccessible and sparsely populated. Management plans need to describe a clearer

understanding of how compensation, alternative livelihood schemes, regulation and sustainable

community development can be effectively implemented in order to reduce secondary impacts.

Recommendations are given for ongoing monitoring, auditing and performance evaluation of the

environmental and social elements of the project so that continued improvement, adherence to

agreed standards and effective liaison with SLEPA is maintained.

Monitoring will involve internal and external inspections as well as auditing of performance and

compliance with contract documents. Where a degree of capacity building is required to ensure that

inspection visits and audits by the competent authority (SLEPA) can be achieved then it is understood

and has been recorded (Appendix 1) that AML will make provision for this. In addition, inspection

visits and audits by independent consultants, appointed by AML, will produce monitoring reports that

SLEPA can access and comment on. Currently this has been done by the ESHIA consultants in

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STAGE 1 ENVIRONMENTAL, SOCIAL AND HEALTH IMPACT ASSESSMENT

TONKOLILI IRON ORE PROJECT



CONTENTS

EXECUTIVE SUMMARY ...................................................................................................................1

1



INTRODUCTION ................................................................................................................9

1.1



Background.........................................................................................................................9



1.2



Purpose.............................................................................................................................10



1.3



The Project Proponents ....................................................................................................12



1.4



Distribution and Intended Audience..................................................................................12



1.5



Glossary............................................................................................................................13



1.6



Referenced Documents ....................................................................................................15



2



ESHIA PROCESS.............................................................................................................16

2.1



Relationship between Phase 1, Phase 2 and Phase 3 of the Tonkolili Iron Ore Project..16



2.2



ESHIA Steps .....................................................................................................................17



2.3



2.2.1



Screening .............................................................................................................17



2.2.2



Scoping ................................................................................................................17



2.2.3



Impact Assessment..............................................................................................18



Terms of Reference for ESHIA .........................................................................................19

2.3.1



Terms of Reference .............................................................................................19



2.3.2



Scope ...................................................................................................................22



2.3.3



Exclusions ............................................................................................................23



2.4



The Stakeholder Engagement Process............................................................................24



2.5



The Structure of this Report..............................................................................................25



3



PROJECT DESCRIPTION ...............................................................................................26

3.1



Project Overview...............................................................................................................26



3.2



Proposed Development ....................................................................................................26

3.2.1



Element 1 - Mining Area ......................................................................................28



3.2.2



Element 2 -Transport Corridor .............................................................................32



3.2.3



Element 3 - Port Facilities ....................................................................................42



3.2.4



Element 4 – Offshore (Marine engineering).........................................................47



Dredge Disposal..........................................................................................................................55

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TONKOLILI IRON ORE PROJECT



Duration.......................................................................................................................................57

3.3



3.4

4



Supporting Infrastructure ..................................................................................................57

3.3.1



Power supply........................................................................................................57



3.3.2



Water supply ........................................................................................................59



3.3.3



Fuel Supply ..........................................................................................................60



3.3.4



Bulk material management ..................................................................................61



3.3.5



Demand on existing facilities/ resources .............................................................62



3.3.6



Solid Waste Management....................................................................................63



3.3.7



Waste Water Treatment.......................................................................................64



Project Options & Alternatives ..........................................................................................65

LEGAL, POLICY AND ADMINISTRATIVE FRAMEWORK ..............................................67



4.1



Institutional Bodies............................................................................................................67



4.2



Relevant Sierra Leone Legislation....................................................................................68

4.2.1



Legislation Relevant to Ecological Protection......................................................68



4.3



ESHIA Legislative Requirements......................................................................................69



4.4



ESHIA requirements in the Mines and Minerals Act 2009 ...............................................70



4.5



Mine Technical Assistance Project (MTAP) .....................................................................71



4.6



MTAP Resettlement Policy Framework ............................................................................72



4.7



International Conventions to which Sierra Leone is signatory..........................................73



5



REGIONAL BASELINE.....................................................................................................75

5.1



5.2



Climate, Air & Hydrology...................................................................................................75

5.1.1



Climate .................................................................................................................75



5.1.2



Hydrology .............................................................................................................76



Geology, Hydrogeology, Soils, Land Use & Ecosystems .................................................76

5.2.1



Regional Geology ................................................................................................76



5.2.2



Hydrogeology .......................................................................................................77



5.2.3



Soils .....................................................................................................................78



5.2.4



Land Use..............................................................................................................78



5.2.5



Ecology ................................................................................................................79



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STAGE 1 ENVIRONMENTAL, SOCIAL AND HEALTH IMPACT ASSESSMENT

TONKOLILI IRON ORE PROJECT



5.3



5.4



Marine ...............................................................................................................................81

5.3.1



Physical Environment ..........................................................................................81



5.3.2



Water and Sediment Quality ................................................................................82



5.3.3



Coastal and Marine Habitats................................................................................82



5.3.4



Marine fauna ........................................................................................................83



5.3.5



Protected Areas ...................................................................................................85



Population & Demographics .............................................................................................86

5.4.1



6



Health Status Summary .......................................................................................87



PROJECT AREA BASELINE............................................................................................92

6.1



Baseline Study Techniques ..............................................................................................92



6.2



Mining Area.......................................................................................................................92



6.3



6.4



6.2.1



Air Quality.............................................................................................................92



6.2.2



Noise ....................................................................................................................95



6.2.3



Archeology & Cultural Heritage............................................................................96



6.2.4



Ecology & Biodiversity .........................................................................................96



6.2.5



Hydrology and Hydrogeology...............................................................................97



6.2.6



Soils & Land-use................................................................................................101



6.2.7



Geology & Geomorphology................................................................................101



6.2.8



Socio-Economic & Human Health......................................................................101



Transport Corridor...........................................................................................................102

6.3.1



Air Quality...........................................................................................................102



6.3.2



Noise ..................................................................................................................103



6.3.3



Archeology & Cultural Heritage..........................................................................104



6.3.4



Ecology & Biodiversity .......................................................................................105



6.3.5



Hydrology & Hydrogeology ................................................................................106



6.3.6



Soils & Land-use................................................................................................108



6.3.7



Geology & Geomorphology................................................................................108



6.3.8



Socio-Economic & Human Health......................................................................108



Port Facilities ..................................................................................................................108



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TONKOLILI IRON ORE PROJECT



6.5



7



6.4.1



Air Quality...........................................................................................................108



6.4.2



Noise ..................................................................................................................110



6.4.3



Archeology & Cultural Heritage..........................................................................110



6.4.4



Ecology & Biodiversity .......................................................................................111



6.4.5



Hydrology & Hydrogeology ................................................................................111



6.4.6



Soils & Land-use................................................................................................112



6.4.7



Geology & Geomorphology................................................................................114



6.4.8



Socio-Economic & Human Health......................................................................114



Offshore & Coastal..........................................................................................................115

6.5.1



Marine Physical Environment ............................................................................115



6.5.2



Coastal and Marine Habitats..............................................................................119



6.5.3



Marine and avifauna ..........................................................................................120



POTENTIAL IMPACTS & MITIGATION .........................................................................122

7.1



7.2



7.3



Impact Identification & Evaluation...................................................................................122

7.1.1



Techniques for Impact Identification & Evaluation.............................................122



7.1.2



Techniques for ESHIA Risk Assessment...........................................................127



Mining Area.....................................................................................................................129

7.2.1



Air Quality...........................................................................................................129



7.2.2



Noise ..................................................................................................................133



7.2.3



Ecology & Biodiversity .......................................................................................137



7.2.4



Hydrology & Hydrogeology ................................................................................143



7.2.5



Soils & Land Use ...............................................................................................147



7.2.6



Geology & Geomorphology................................................................................151



7.2.7



Socio-Economic .................................................................................................155



7.2.8



Human Health ....................................................................................................160



Transport Corridor...........................................................................................................168

7.3.1



Air Quality...........................................................................................................168



7.3.2



Noise ..................................................................................................................172



7.3.3



Ecology & Biodiversity .......................................................................................175



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7.4



7.5



7.6



7.7



7.3.4



Hydrology & Hydrogeology ................................................................................183



7.3.5



Soils & Land Use ...............................................................................................188



7.3.6



Geology & Geomorphology................................................................................192



7.3.7



Socio-Economic .................................................................................................194



7.3.8



Human Health ....................................................................................................199



Port Facilities ..................................................................................................................206

7.4.1



Air Quality...........................................................................................................206



7.4.2



Noise ..................................................................................................................211



7.4.3



Ecology & Biodiversity .......................................................................................214



7.4.4



Hydrology & Hydrogeology ................................................................................219



7.4.5



Soils & Land Use ...............................................................................................225



7.4.6



Geology & Geomorphology................................................................................230



7.4.7



Socio-Economic .................................................................................................232



7.4.8



Human Health ....................................................................................................237



Offshore & Coastal..........................................................................................................245

7.5.1



Port Layout.........................................................................................................245



7.5.2



Port Facilities......................................................................................................247



7.5.3



Marine Structures...............................................................................................250



Operation ........................................................................................................................253

7.6.1



Presence of Marine Structures ..........................................................................253



7.6.2



Port Operations ..................................................................................................253



7.6.3



Associated Shipping Activities ...........................................................................256



7.6.4



Associated Dredging Activities...........................................................................260



Distributed Impacts from Project.....................................................................................268

7.7.1



Bulk material management ................................................................................268



7.7.2



Demand on existing infrastructure & resources.................................................268



7.7.3



Solid waste management...................................................................................268



8



ONGOING ASSESSMENT WORKS ..............................................................................270



9



MANAGEMENT ..............................................................................................................286



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9.1



Construction vs. Operational Management Plans ..........................................................286



9.2



Soil management ............................................................................................................287



9.3



Borrow Pits......................................................................................................................288



9.4



Water management ........................................................................................................288



9.5



Swamp Areas & Riverine Vegetation..............................................................................290



9.6



Work in Proximity to Communities..................................................................................291

9.6.1



Noise emissions.................................................................................................292



9.6.2



Air Quality (Air Emissions) .................................................................................292



9.6.3



Dust & Particles Generation...............................................................................293



9.7



Work near Society Bush, Thick Forests & Protected Areas ...........................................293



9.8



Waste management........................................................................................................295



9.9



Fuel & Spillages ..............................................................................................................296

9.9.1



Refueling & Maintenance Procedures ...............................................................296



9.9.2



Spill response.....................................................................................................296



9.10



Agricultural areas .......................................................................................................298



9.11



Site Selection for Camps............................................................................................299

9.11.1 Transport Activities / Equipment Use.................................................................299

9.11.2 Camp Site Decommissioning.............................................................................300



10



STAKEHOLDER ENGAGEMENT PROCESS & RESETTLEMENT PLANNING...........302

10.1



Stakeholder Engagement...........................................................................................302

10.1.1 Background ........................................................................................................302

10.1.2 Affected Chiefdoms............................................................................................302

10.1.3 Early Works Chiefdom Committee.....................................................................303

10.1.4 Community Sensitisation Meetings....................................................................304

10.1.5 Grievance Mechanism .......................................................................................304

10.1.6 Resource Requirements ....................................................................................305

10.1.7 Freetown Stakeholder Forum ............................................................................305



10.2



Resettlement Policy Framework ................................................................................308

10.2.1 Resettlement Planning Actions ..........................................................................308



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10.2.2 Minimising Resettlement....................................................................................308

10.2.3 Identifying Eligibility for Compensation ..............................................................309

11



AUDITING, MONITORING & CONTINUAL PERFORMANCE IMPROVEMENT...........313

11.1



Introduction.................................................................................................................313



11.2



Monitoring...................................................................................................................313



11.3



Incident Investigation and Reporting..........................................................................315



11.4



Non-compliance: Corrective and Preventive Actions.................................................315



11.5



Social and Environmental Management System (SEMS)..........................................316



11.6



Auditing.......................................................................................................................317



12



COMMITMENTS REGISTER .........................................................................................319



13



CONCLUSION ................................................................................................................328



14



13.1



Mine Area Impact Assessment ..................................................................................328



13.2



Transport Corridor Impact Assessment .....................................................................332



13.3



Port Impact Assessment ............................................................................................335



13.4



Offshore & Coastal Impact Assessment ....................................................................338



13.5



Distributed Impact Assessment..................................................................................342



13.6



Commitments, Management and Performance .........................................................342

REFERENCES ...............................................................................................................344



FIGURES

Figure 2-1 Tonkolili ESHIA Simplified Process Flowchart ....................................................................21

Figure 3-1 Phase 1 Mine to Port Transport Route ................................................................................27

Figure 3-2 Tonkolili Mineral Deposits....................................................................................................28

Figure 3-3 Phase 1 Mine Location ........................................................................................................29

Figure 3-4 Phase 1 Mine Detail.............................................................................................................30

Figure 3-5: Map 1 of Haul Road Alignment...........................................................................................32

Figure 3-6: Map 2 of Haul Road Alignment...........................................................................................33

Figure 3-7: Typical cross-section of the Haul Road ..............................................................................34

Figure 3-8: Road-train ...........................................................................................................................35

Figure 3-9 Lunsar Interchange..............................................................................................................37



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Figure 3-10 Rail Map.............................................................................................................................38

Figure 3-11 Schematic of Existing Pepel Port Layout...........................................................................44

Figure 3-12 Schematic diagram of material handling at Pepel .............................................................46

Figure 3-13 Example Ship-Loader Layouts for Pepel Port ...................................................................47

Figure 3-14 Example transshipment operations ...................................................................................48

Figure 3-15 Navigation Channel to Pepel Island ..................................................................................49

Figure 3-16 Proposed dredging areas - manoeuvring area and Navigation Channel ..........................50

Figure 3-17 Typical draghead (left) and suction pipe (right) from TSHD .............................................52

Figure 3-18 General layout of TSHD working at dredging site .............................................................53

Figure 3-19 Hopper wells ......................................................................................................................53

Figure 3-20 Typical overflow funnel with anti-turbidity valve ................................................................54

Figure 3-21 Bottom dumping procedures, at disposal sites..................................................................55

Figure 3-22 Proposed spoil ground.......................................................................................................57

Figure 5-1



Location of Pepel Island and Tagrin ports within the Ramsar Site ...............................86



Figure 6-1 Air Quality Monitoring Campaign Measurement Locations .................................................93

Figure 6-2 Noise Monitoring Campaign Measurement Locations.........................................................95

Figure 6-3 Water quality plot at sample location P1, February 2010..................................................116

Figure 6-4



Water quality and sediment sample locations close to Pepel .....................................117



Figure 6-5



Intertidal sediment sample locations ...........................................................................118



Figure 6-6 Mudflats located around Pepel Island. The Red shaped areas representing the location of

the Mud Flats.......................................................................................................................................119

Figure 6-7 Mangrove species distribution at Pepel Island ..................................................................120

Figure 7-1



Pepel habitat map overlaid with the early port layout .................................................245



Figure 9-1 Example of a flume pipe access........................................................................................290

Figure 11-1 The cycle of adaptive environmental monitoring .............................................................314



TABLES

Table 1-1 Prior ESHIA Deliverables......................................................................................................11

Table 2-1 Procedural Fulfilment of the ESHIA ......................................................................................20

Table 3-1 Summary of the different locations of Phase 1 .....................................................................27



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Table 3-2 Overview of Rail Specifications & Activities..........................................................................41

Table 3-3 Diesel Usage Over Construction ..........................................................................................41

Table 3-4 – Export volumes during first year of operation ....................................................................42

Table 3-5 Example TSDH vessel characteristics..................................................................................51

Table 3-6 Construction Material for Rail Refurbishment .......................................................................61

Table 6-1 Locations for Air Quality Monitoring Campaign in the Mining Area ......................................94

Table 6-2 Results of Baseline NO2 and SO2 Concentrations on Air in the Mining area .......................94

Table 6-3 Noise Monitoring Campaign in the Mining Area ...................................................................96

Table 6-4 Tonkolili River Flow Rates ....................................................................................................98

Table 6-5 Mawuru River Flow Rates.....................................................................................................98

Table 6-6 Locations for the Air Quality Monitoring Campaign along the Transport Corridor..............102

Table 6-7 Results of Baseline NO2 and SO2 Concentrations on Air in the Transport Corridor...........103

Table 6-8 Noise Monitoring Campaign in the Transport Corridor .......................................................103

Table 6-9 Locations for Air Quality Monitoring Campaign at Pepel Port ............................................109

Table 6-10 Results of Baseline Air Quality Monitoring Campaign at Pepel Port ................................109

Table 6-11: Results of Baseline Noise Monitoring Campaign at the Pepel Port Facilities .................110

Table 7-1 Valued Receptors ...............................................................................................................123

Table 7-2



Impact Significance .........................................................................................................127



Table 7-3 Mining Area - Air Quality .....................................................................................................131

Table 7-4 Mining Area - Noise Impacts...............................................................................................136

Table 7-5 Mining Area – Ecology & Biodiversity Impacts ...................................................................140

Table 7-6 Mining Area - Hydrology & Hydrogeology...........................................................................145

Table 7-7 Mining Area - Soils and Land Use .....................................................................................149

Table 7-8 – Mining Area – Geology & Geomorphology ......................................................................153

Table 7-9 Mining Area – Socio-economic Impacts .............................................................................157

Table 7-10 Mining Area – Health ........................................................................................................163

Table 7-11 Transport Corridor – Air Quality Impacts ..........................................................................170

Table 7-12 Transport Corridor – Noise Impacts..................................................................................174

Table 7-13 Transport Corridor – Ecology & Biodiversity Impacts .......................................................178



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Table 7-14 Transport Corridor - Hydrology & Hydrogeology ..............................................................186

Table 7-15 Transport Corridor - Soils & Land Use..............................................................................190

Table 7-16 Transport Corridor - Geology & Geomorphology..............................................................193

Table 7-17 Transport Corridor – Socio-Economic Impacts.................................................................196

Table 7-18 Transport Corridor – Health ..............................................................................................202

Table 7-19 Port Area – Air Quality Impacts ........................................................................................209

Table 7-20 Port Area – Noise Impacts ................................................................................................213

Table 7-21 Port Area – Ecology & Biodiversity ...................................................................................217

Table 7-22 Port Area - Hydrology & Hydrogeology.............................................................................222

Table 7-23 Port Area - Soils & Land Use............................................................................................228

Table 7-24 Port Area - Geology & Geomorphology ............................................................................231

Table 7-25 Port Area – Socio-Economic.............................................................................................234

Table 7-26 Port Area – Health ............................................................................................................240

Table 8-1 Ongoing Assessment Works Register ................................................................................277

Table 12-1 AML Commitments Register .............................................................................................320



APPENDICES

Appendix 1 Prior ESHIA Correspondence and Interim reports

Appendix 2 Environmental Aspects Register

Appendix 3 Preliminary Concepts for Solid Waste

Appendix 4 Solid Wastes Management Practice Guidelines

Appendix 5 List of Legislation Applicable to Environmental and Social Impacts from Phase 1 of the

Tonkolili Project

Appendix 6 Literature Review of Available Information and Data - Stage 1 -Prepared by the Met Office

Appendix 7 Stage 2 – Climate Assessment and Data Analysis - Prepared by the Met Office

Appendix 8 Preliminary Report on Phase 3 Vegetation Fieldwork - Prepared by SRK

Appendix 9 Tonkolili Vegetation Survey and Inventory Report - Final - Prepared by Herbarium, Royal

Botanic Gardens, Kew

Appendix 10 Report on the Vegetation Map of the Tonkolili Project Area

Appendix 11 Summary of Report, Phase 1 Study of Terrestrial Fauna at Tonkolili Mine Site, Sierra

Leone prepared by the Wildlife Conservation Society



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Appendix 12 Rapid Assessment of Aquatic Environments for the Tonkolili Project prepared by SRK

Appendix 13 Surface Water Monitoring Locations for the Mine Area

Appendix 14 Tonkolili Soils and Laterite Profile – Prepared by SRK

Appendix 15 Geological and Geomorphologic Baseline Study - Prepared by SRK

Appendix 16 Pepel Port Soil and Water Samples Locations

Appendix 17 Environmental Note on Malaria Control

Appendix 18 Environmental Management Plan (EMP)

Appendix 19 Minutes of Early Works Chiefdom Committee (EWCC) Meetings

Appendix 20 The Resettlement Policy Framework



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EXECUTIVE SUMMARY

The project has been evaluated using a rigorous impact assessment methodology comprising the

following:





A review of compliance with the Sierra Leone legislation framework;







A description of the project and review of alternatives;







Determination of the project physical and social baseline conditions at a regional and sitespecific level;







Derivation of a standardised methodology based on evaluating valued receptors and impact

index derived from assessing extent, duration and magnitude;







Assessment of the likely impacts that may arise, both positive and negative. Where impacts

are identified that could cause adverse effects, the ESHIA considers alternatives, mitigating

measures and what the likely remaining or residual impact will be after such intervention;







The environment and social impact assessment has been applied systematically to four areas

of the project: the mine, the transport corridor, the port and the off-shore and coastal zone.



The following principal issues have been determined:



Air & Noise

Air quality impacts comprising both dust and exhaust emissions arising from land clearance, mining,

stock-piles, vehicles and machinery have been identified as primary emission sources. The

implementation of standard mitigation measures involving adequate containment of loads during

haulage, dust suppression by water spraying, extractive covers at key point sources and machinery

selection should result in no major impacts.

The proximity of the proposed transport route in relation to villages and residential areas remains a

key issue. Whilst a principle of avoidance of resettlement wherever possible has been upheld, the

combination of public safety and dust and noise nuisance issues means that in some instances, even

though mitigation measures may be partially effective, it has been considered more appropriate and

responsible to pursue a resettlement solution. The maintenance of a buffer zone should be sufficient

for most residential areas, but in exceptional cases where a suitable buffer cannot be maintained and

resettlement is not feasible, additional mitigation measures (e.g. noise barriers or noise isolation) at

sensitive receptors will minimize the impacts. A buffer zone of 500m has generally been accepted for

the project, if communities lie within this zone then a review of either resettlement or mitigation is

required.

Noise sources vary, but blasting, crushing and transport noise, including aircraft, are considered to be

potentially the most significant. Assuming that occupational noise limits are maintained within



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facilities then it is predicted that appropriate environmental noise standards will be met at a distance

of 500m from the facilities.



Ecology & Biodiversity

Ecological impacts across the project have been evaluated and found to be significant primarily due to

the high level of biodiversity and conservation value of certain plant species. This is the case at a

variety of discreet habitat settings including forest and grass-lands located at the mine-site, along

riverine forests, inland valley swamp locations and in mangrove forest in the coastal areas.

Principal direct impacts will arise from the clearance of land within the footprint of the project and its

associated infrastructure. Vegetation that is not cleared or buried may be indirectly impacted by

alteration, spread of invasive species and pressure from the influx of people that will increase the

pressure on resources.

At Pepel Port, the potential release of acidity and metals from disturbed acid sulphate soils (if present)

could cause localised impacts to vegetation.

At the mine and along the transport corridor, disturbance of fauna, particularly large mammals such

as chimpanzees may further reduce natural colonisation by indigenous plant species where fauna

play a role in seed dispersal.

The impacts of habitat loss and fragmentation will affect terrestrial and aquatic ecosystems.

Avoidance of areas of ecological value is the primary tool that is applied to minimise impacts.

However, the impact of land clearance and burial in the primary mining and rock dump areas can

neither be avoided, nor mitigated because of the immovable location of the ore bodies and

practicalities governing design of the mine and waste rock areas. The project proponent (AML)

should therefore undertake a commitment to seed collection, replanting, habitat renewal and

protection at alternative selected conservation site(s). This offset or equivalence approach will not

alter the primary ecological loss and cannot realistically overcome the direct impact resulting from

clearance of forest and vegetation. However, in combination with avoidance of sensitive areas

outside of the mine footprint wherever possible, an off-set conservation programme can contribute to

lowering the overall residual impact to a moderate level.



Hydrology and Hydrogeology

The project will result in an increase in suspended sediments in rivers, alteration of river channels and

changes in catchment behaviour. Without mitigation this could lead to flooding as well as a variety of

water quality impacts. Changes of chemistry could occur with the water considered to have low

chemical buffering capacity. At the mine and transport corridor the potable and construction water

demand may lead to over-abstraction of local surface and groundwater sources leading to impacts on

downstream flows affecting both communities and dependent eco-systems.

At Pepel Port, groundwater is considered both a sensitive and vulnerable resource. Construction and

operational groundwater abstraction could lead to lowering of water levels in local wells and saline



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intrusion, while brownfield regeneration and the industrial port operations could lead to contamination

of a system that is important for sustaining potable water supplies as well as providing baseflow

discharging into the inter-tidal zone.

Residual, post mitigation impacts from the project will include some permanent loss of flow from

springs and streams as well as alteration of stream and river channels and local water levels.

However, more significant changes in local hydrology and hydrogeology are expected in Phase 3

which will require a significantly higher water demand.



Soils & Land Use

Soil impacts will arise during construction and operational phases as a consequence of land

clearance or sterilisation / burial, increased erosion or inundation due to the modification of drainage

patterns, compaction from vibration and loading under temporary stockpiles/structures. Chemical

contamination could occur from release of hydrocarbons and other chemicals including diesel and

lubricant oils and explosives residues. Some soil resource can be rehabilitated if progressive

reclamation techniques are applied. These impacts may constrain or modify existing land-uses in the

mine area. The residual (post-mitigation) impacts of land clearance and sterilisation / burial on soil

resources and land-use are likely to remain significant and extremely long-term or permanent in the

mine area. Other residual impacts should be minor if appropriate preventative and mitigation

measures are put in place.



Socio-Economic

Socio-economic effects are strongly dependent on project phase. During construction some villages

may require resettlement. Villages on the periphery of the project area will suffer loss of land resulting

in potential temporary disruption of land used for shelter, access to agriculture and natural resources.

However a compensation principle is being applied throughout the project to ensure affected people

are not disadvantaged or made worse off by the project. Some employment opportunities will be

created with associated economic benefits to the wider community.

During operations, however, there is again a mix of both economic benefit and social disturbance.

Benefits (lasting about 8 years) will mainly be in the form of wages, disbursement for the procurement

of supplies, social investments and payment of revenue to the government. Potential negative

impacts will mainly be due to disturbance to land owners and influx of workers and job seekers

bringing pressure on social infrastructure and natural resources and possible increases in social ills.

Mitigation measures are dependent on establishing transparent and effective social management

processes including harm minimisation, compensation and long-term community development

mechanisms. The following mitigation measures are expected to reduce the intensity of the residual

impacts from major to moderate/minor.





Preparation of a Resettlement Action Plan (RAP).







Preparation of a livelihood restoration plan.



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Implementation of a grievance mechanism.







Preparation of a Community Development Action Plan.



In some instances these community mitigation measures require co-opting the support of local

government and Non-governmental Organisations (NGOs).



Human Health

The major impacts identified in the preliminary health impact assessment were primarily associated

with community resettlement; impacts associated with worker in-migration (disease, food security,

substance abuse, home violence); increased burden of disease such as cholera and malaria due to

project activities and water storage facilities (drinking water tanks, waste and raw water storage

ponds); and degradation of surface and groundwater (sedimentation/erosion, contamination, changes

in drainage patterns). Moderate impacts were associated with increased road traffic, project noise and

reduction of locally produced food.

Mitigation measures have been proposed for those impacts with major or moderate significance

which, if implemented, are predicated to result in moderate, minor, or insignificant residual impacts.

Since human health is dependant on many factors such as good air, soil, water and food quality, and

stable socio-economic status, the assessment of potential impact on human health associated with

the Phase 1 project has been integrated with results of many of the other ESHIA disciplines (e.g., air,

noise, hydrology, hydrogeology, flora, fauna, soil, water quality, and social-economic assessment).

Implementation of mitigation measures recommended by these disciplines would therefore reduce the

potential for adverse human health impacts (HIA) and will be considered in the final HIA.

Positive impacts identified include access to improved healthcare facilities (for general public), health

benefits through local employment, improved access to the region and positive aspects of

resettlement.



Offshore & Coastal Impact Assessment

The baseline preliminary survey indicates that the coastal and marine habitat around Pepel Port is

healthy and contains a high level of biodiversity. There are a number of potential impacts that could

arise from reduction and clearance of habitat areas. However, the majority of the port infrastructure is

already in place, and most of what is required will be refurbished rather than constructed from new.

As a result there should be no significant increase in the existing port footprint, and therefore no

significant area of coastal habitat cleared. The currently proposed development footprint for Pepel

Port will result in reasonably minor losses of mangroves.

There is currently no evidence of any existing impact on the surrounding mangroves due to the

presence of residual hematite ore from the previous operations at Pepel, although there are elevated

levels of heavy metals in the near-shore soil samples.

The construction will increase ambient noise and light levels, and potentially result in disturbance of

sensitive coastal fauna such as birds. Due to the high density of wetland birds present in the project

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location, and its position inside a designated Ramsar site, increased light is a potentially significant

impact, especially if construction work takes place during bird migratory or breeding seasons.

Therefore a number of mitigation measures are proposed to minimise impact or better still avoid

sensitive habitat areas (eg high avifauna population, important nesting and feeding sites, and

migratory and nesting seasons).

A more detailed assessment of wastewater discharges is required to develop the necessary approach

to wastewater treatment and management. As a minimum, mitigation measures that are included

should include installation of temporary treatment plant to treat construction camp discharges,

ensuring treated water discharge is located away from sensitive locations and in areas of strong tidal

currents to increase dilution and removal; and compliance with World Bank discharge limits as

specified in the Stage 2 Environmental Basis of Design document. Improved environmental

performance has already been incorporated into the project design at Pepel to ensure there is

drainage away from the coast and incorporation of settling sumps for stormwater runoff.

During construction and refurbishment there is a risk of increased run-off due to earthworks, and a

risk of oil and chemical contamination from disturbance of existing contaminated land, and new

incidents of fuel, lubricant and coating spills used in construction machinery, and from potential oil

spills.

This will require management through run-off collection and treatment systems, waste management

planning, spill response plans (contingency planning and emergency response measures should be in

place). Industry best practice regarding refuelling activities, oil handling activities and machinery

maintenance is required considering the site’s sensitivity.

The refurbishment or replacement of mooring dolphins, to enable the mooring of transshipment

vessels will primarily impact the sub-tidal habitat through smothering, pile driving, and placement of

rock material. No mitigation measures are required other than further characterisation of the selected

mooring site.

The construction and refurbishment of marine structures could result in elevated turbidity within the

immediate vicinity of the port. However, given the natural conditions of the estuary particularly during

wet season conditions it is considered that the habitat is likely to be resilient to increased turbidity

levels over the relatively short duration of the construction programme at Pepel Port.

Construction/refurbishment activity also has the potential to disturb marine sediment. Further

characterisation of nearshore and intertidal marine sediments is recommended prior to construction.

Underwater construction activities, in particular pile driving, can generate high levels of underwater

noise. Marine mammal and the impact of underwater noise and ship collisions remain as a moderate

impact due to lack of information at this stage but surveys are underway.

The majority of marine traffic in the estuary is focussed around Freetown. Trans-shipment operations

are currently expected to involve Handymax trans-shipment vessels, which will transfer ore to a

loading on anchorage point outside the mouth of the estuary. The impact of the trans-shipment

operations on shipping in the estuary is not expected to be significant.



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The location of the trans-shipment anchorage is not currently confirmed however, two potential

anchorage locations proposed by CSL are circa 32.0 nautical miles and circa 44.0 nautical miles

offshore. If an anchorage is selected that could introduce invasive species from in-bound shipping

releasing ballast water at the destination location then the AML will need to ensure the 2004

International Convention for the Control and Management of Ships' Ballast Water and Sediments is

strictly followed.

Routine discharges from vessels may have effects on water quality similar to the effects created by

discharges from the port, such as changes in water pH, colour, temperature, smell, dissolved oxygen,

nutrient levels and bacterial contamination. Mitigation of these effects will need to be achieved

through ensuring the prevention of pollution from shipping (under the MARPOL treaty) which will

require regulation of the shipping contractors by the Port Authority.

Loading of the transshipment vessels at Pepel and offloading at the anchorage during transshipment

will lead to some inevitable overboard spillage of iron ore. Although it is assumed that the system will

be designed to be highly efficient, even minor spillage will create a cumulative impact over the life of

the project. The potential behaviour of the iron ore in the water should be evaluated by a laboratory

assessment of the proposed iron ore product and its constituents.

Capital dredging will be required to open the navigation channel to access Pepel port with subsequent

ongoing maintenance dredging required to keep the channel open. Dredging is designated as a

moderate impact in this report on the basis of what is currently known about dredge location and

ecology of the spoil disposal locations. More detailed assessment will be undertaken when details of

a work programme and contractor have been clarified. A dredging plan is included in the EMP and

will be modified on the basis of the outcome of a more detailed dredging impact assessment once the

requisite data is available.



Distributed Impacts

Provision of bulk materials such as earth and fill for ground conditioning will be controlled through

activity-specific management plans and protocols and contractors will be accountable for adherence

to the plans and protocols.

The project’s dependency on existing infrastructure will be limited. There will be initial reliance on

imported goods and contractor services for food, accommodation and camps with opportunities for

goods and services to create livelihood benefits for project communities. Adherence to prior and clear

project announcements is expected.

An impact is likely to arise from interim storage of wastes in particular pest, odour and litter control.

The AML will need ensure that its contractor’s implement a hierarchy of waste elimination at source,

recycling, reuse, recovery, and as a last resort – disposal. In addition provision for destroying or

treating hazardous waste is required to render it non-hazardous if possible, with provision for safe

storage where-ever and for as long as treatment/destruction is not an option..



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Commitments, Management and Performance

This ESHIA has been prepared for submission for approval on the understanding that elements of the

infrastructure design and ESHIA study are not yet fully developed. In recognition of this, AML has

committed to undertake completion of the various ESHIA studies, which are either ongoing or soon to

be undertaken and will be reported on in updates to the Environmental Management Plan (EMP) and

as part of the Stage 2 ESHIA. Comprehensive environmental and social (E&S) management will

continue, with the studies inputting to project design, construction and development. It is

recommended that rigorous risk review is applied in the interim ahead of final ESHIA Stage 2

submission in order to identify appropriate Environmental and Social (E&S) management measures,

which will be delivered through the ongoing EMP that will extend into the operational phase.

A significant volume of assessment work has been achieved and the impact assessment has been

completed to a sufficient level for regulatory decision making. It is recognised that further work is

required, including further project definition in order to be able to identify more specific impacts and

mitigation measures and develop effective management strategies.

Where generic construction management plans could be generated based on the currently available

information then these are have been provided. In other instances, the management plans will need

to be formulated pending further project description and or study work and all that is presented now is

an outline of the management plan purpose.

This is particularly important for the terrestrial and marine eco-systems that could be affected by the

project. To date it has been recognised that areas under the direct footprint of the project contain

either recognised high conservation value species or habitat that is of major significance. An

integrated approach involving additional assessment, avoidance wherever possible of critical areas,

mitigation, development of compensatory programmes and community development programmes is

required. Further study work is required and will be included in a Stage 2 ESHIA later in 2010 that

will provide more specific design and definition to these programmes.

It is also important that management plans take into account consequential impacts that will be

created many of which will be unintended and difficult to control. This includes the impact associated

with speculative influx of migrant workers and accelerated degradation of habitat in areas that was

hitherto relatively inaccessible and sparsely populated. Management plans need to develop a clearer

understanding of how compensation, alternative livelihood schemes, regulation and sustainable

community development can be effectively implemented to reduce secondary impacts.

Recommendations are given for ongoing monitoring, auditing and performance evaluation of the

environmental and social elements of the project so that continued improvement, adherence to

agreed standards and effective liaison with SLEPA is maintained.

Monitoring will involve both internal and external inspections and auditing of performance and

compliance to contract documents. Where a degree of capacity building is required to ensure that

inspection visits and audits by the competent authority (SLEPA) can be achieved then it is understood

and has been recorded (Appendix 1) that AML will provide provision for this. In addition inspection

visits and audits by independent consultants, appointed by AML, will produce monitoring reports that

SLEPA can access and comment on. Currently this has been done by the ESHIA consultants and



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their baseline data collection, however independent monitoring by CEMMATS is due to commence

imminently, with reporting to SLEPA.

The monitoring strategy proposed for the project can be termed "Adaptive Environmental Monitoring".

It is adaptive in the sense that the responsible party must adapt its methods and activities to the

ongoing design and implementation and prevailing environmental conditions in a continuous process.



.



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1

1.1



INTRODUCTION

Background



African Minerals Limited (AML) has identified an extensive magnetic anomaly in the Sula Mountain

range in Sierra Leone and has confirmed the presence of a world-class iron ore deposit. The Tonkolili

Project comprises the construction of a mine, ore processing and pit-to-port infrastructure to transport

materials and product in the form of iron-ore concentrate.

The Project has three phases of production. Phase 1 involves mining, beneficiation and export of a

surface hematite deposit at a maximum rate of 8 Mtpa. Transport and export will occur using a

combination of road, rail and stockpiling at the refurbished port facility at Pepel and transshipment to

waiting off-shore cargo ships. Phase 1 is due to start production in early 2011 and early enabling

works are either already underway or close to starting. This Environmental, Social and Health Impact

Assessment (ESHIA) focuses on the Phase 1 project.

Phase 2 involves the mining and processing of transition material at a rate of approximately 17 –

25Mtpa. Phase 3 comprises mining a deeper, hard-rock magnetite deposit, processing the magnetite

to a concentrate and export at a design rate of 45Mtpa. This will potentially rise to higher rates of

production depending on the confirmation of subsequent geological resource models. Phase 2 and 3

infrastructure is configured substantially differently from Phase 1 and will transition from light-rail or

road trucking progressively towards dedicated heavy-haul rail transport from the mine to a new deep

water port facility to be located at Tagrin. Phase 2 and 3 are due to commence 2014 and will be the

subject of a ‘Stage 2 ESHIA’ in 2010 that will evaluate the Phase 2 and 3 specific impacts and also

report on additional study work for the Stage 1 ESHIA project that has been developed during the

intervening period.

This ESHIA includes a review of the legislation framework associated with environmental, social and

health management and assessment. The ESHIA considers the Phase 1 project, the existing physical

conditions; that is, the environmental and human baseline and the likely impacts that may arise, both

positive and negative. Where there are impacts identified that could cause adverse effects, the ESHIA

considers alternatives, mitigating measures and what the likely remaining or residual impact will be

after such intervention. Finally, the ESHIA sets out requirements for ongoing management,

assessment, monitoring and institutional relations.



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Box 1: Project Phases

Phase 1

Steady state production: 8mtpa

Infrastructure: Road haul base case but currently undertaking engineering studies to explore

feasibility of an extended rail route

Product: Direct Shipping Ore (DSO) He (Duricrust)

FOOS: Q1 2011 if road haul, but moves to Q3 2011 if extended rail option

Full capacity: Q4 2011



Phase 2

Steady state production: 25mtpa

Infrastructure: Extended rail route with spur to Tagrin and one terminal at Tagrin. Will also need

processing plant at Tonkolili

Product: DSO He Duricrust and non DSO He Transition (a combination of the two)

FOOS: Q4 2013

Full capacity: Q1 2014



Phase 3

Steady state production: 45mtpa

Infrastructure: New heavy haul rail and new bulk port at Tagrin

Product: Magnetite

FOOS: Beyond 2014

Full capacity: 12 month ramp up



Purpose



1.2



The ESHIA report for Phase 1 of the Tonkolili Iron Ore Project has been prepared on behalf of AML to

present to the Sierra Leone Environment Protection Agency (SLEPA) for the following purpose:





To provide an understanding of the potential environmental, social and health impacts

associated with the Phase 1 project activities;







To outline the environmental, social and health commitments required for the project and the

associated management and mitigation plans identified to address these issues;







To provide a data baseline for comparison of change.



The report provides an assessment that starts with identification of relevant legislation and

institutional bodies and a summary of the project including the primary project components as well as

the supporting infrastructure and widely distributed effects that could reasonably be assumed to

occur.

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Much of the report is concerned with obtaining a representative characterisation of the existing

baseline conditions at the project area. This section has been reported as a high level summary and

makes reference to a number of supporting studies that have been completed and included as

Appendices. Following the baseline description the ESHIA presents an overview of the potential

impacts and associated mitigation measures. The impact assessment has used a standardised, semiquantitative methodology based on identifying and ranking valued receptors. The basis for this

methodology is explained.

Within the impact assessment section, there is also analysis of what is the remaining level of impact

after mitigation measures have been implemented. The ESHIA then discusses the need for ongoing

further study programmes where clearly needed as well as future management practices that AML will

have to undertake following the completion of the assessment process.

Some of these management practices are strategic in the sense that they are either not entirely

understood at the moment or may be conditional upon factors that are outside of the control of AML.

So that there is an appropriate level of accountability over future performance and commitments, the

ESHIA describes requirements for future performance monitoring and auditing as part of the

proponent’s Environmental & Social Management System.

The report builds on a series of deliverables that have already been prepared as part of an official

regulatory process in liaison with SLEPA shown in Table 1-1 below. Copies of the transcripts for these

official documents are provided in Appendix 1:

Table 1-1 Prior ESHIA Deliverables

Element



Date



ESHIA Pre-Screening Announcement Form



13th November 2009



ESHIA Screening Form



15th March 2010



ESHIA Scoping Procedures Report



22nd March 2010



Haul Road Scoping Report



15th April 2010



Haul Road Environmental Management Plan



29th April 2010



Community Development Action Plan (CDAP) for the Haul Road



29th April 2010



Public Consultation and Stakeholder Forum, convened with SLEPA in

Freetown



17th May 2010



AML Letter of intent to provide SLEPA access and support to Multipartite

Monitoring



30th March 2010



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1.3



The Project Proponents



African Minerals Limited (AML) is a mineral exploration company registered in Sierra Leone with a

contactable office in Freetown, contact details of the project proponent have been given in the project

ESHIA screening form and remain current and valid.

AML developed from a former Sierra Leone mining company (SLDC) and maintains a portfolio of

mining projects in Sierra Leone and elsewhere in Africa. AML is currently employing more than 800

Sierra Leoneans, the majority of which are associated with the exploration activities and preproduction works that are ongoing at Tonkolili.

AML has commissioned WorleyParsons to produce a Feasibility Study for the Tonkolili project and is

in the process of preparing to apply for a mine operating licence.

The team of environmental consultants that have worked on developing this Stage 1 ESHIA include

Worley Parsons as the nominated environmental consultant, SRK, CEMMATS, Wildlife Conservation

Society (WCS), the UK Meteorology Office and Kew Gardens as well as a large number of individual

specialists and experts that have contributed to sections of the report.

The main project entities in relation to the environment and social activities of the project at this stage

in its development are listed below with a brief outline of their relationship to the project. Information

that is derived from these sources is noted by a code.



Code



Project Entity



AML



African Minerals Limited -project proponent.



WP



WorleyParsons - project engineer and ESHIA consultant



Ausenco



Process plant design engineer



GoSL



Government of Sierra Leone



SLEPA



Sierra Leone EPA



SRK



SRK Consulting (UK) Ltd - project sub-consultants



1.4



Distribution and Intended Audience



The Stage 1 ESHIA report for Tonkolili Iron Ore Project is intended to inform SLEPA, district councils,

chiefdoms, community members, government and non-government organisations and other

stakeholders about the potential environmental and social impacts associated with Phase 1 of the

Tonkolili project. The ESHIA is a legislative requirement in Sierra Leone and this Stage 1 ESHIA

report is submitted on behalf of the project proponent.



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1.5



Glossary



Definitions

Phase 1 of the Project – is Phase 1 of the Tonkolili Iron Ore Project and represents the mining of

hematite ore found as a shallow capping deposit overlying the main Tonkolili deposits. This is planned

for the initial stages of the project and entails exporting the product via Pepel Port.

Phase 2 of the Project – is Phase 2 of the Tonkolili Iron Ore Project and consist of mining and

processing of transitional material.

Phase 3 of the Project – is Phase 3 of the Tonkolili Iron Ore Project and consist of the open pit mining

operation and transportation of concentrate by rail to a newly developed port at Tagrin Point from

which it is exported to global markets.



Abbreviations

ANFO



Ammonium nitrate-fuel oil



ARI



Average Recurrence Interval



BOD



Basis of Design



EHS



World Bank Environmental, Health, and Safety Guidelines (2007)



EPA



Sierra Leone Environment Protection Agency



EQS



Environmental Quality Standards



EnvID



Environmental Identification ( a screening process to identify key issues)



GOSL



Government of Sierra Leone



GVWC



Guma Valley Water Company



DFS



Definitive Feasibility Study



DfID



UK Department for International Development



EHS



Environmental, Health and Safety



EITI



Extractive Industries Transparency Initiative



ESHIA



Environmental, Social and Health Impact Assessment



HIA



Health Impact Assessment



ICMM



International Council on Mining and Metals



IFC



International Finance Corporation



ILO



International Labour Organisation



IMO



International Maritime Organisation



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IUCN



International Union for Conservation of Nature



MAFF



Ministry of Agriculture and Forestry and Food Security



MEP



Ministry of Energy and Power



MFMR



Ministry of Fisheries and Marine Resources



MLHCPE



Ministry of Lands, Housing, Country Planning and the Environment



MMR



Ministry of Mineral Resources



MoE



Ministry of the Environment



MoH



Ministry of Health



MTA



Ministry of Transport and Aviation



MTAP



Mine Technical Assistance Project



MTC



Ministry of Tourism and Culture



MWI



Ministry of Works and Infrastructure



NWRB



National Water Review Board



OP



Operational Policy



PM



Particulate Matter



SALWACO



Sierra Leone Water Company



STAT



Statutory Requirements



TQ



Technical Query



UNCTAD



United Nations Conference of Trade and Development



UNEP



United Nations Environment Program



UNESCO



United Nations Educational, Scientific and Cultural Organization



US EPA



United States Environmental Protection Agency



WBG



World Bank Guidelines



WHO



World Health Organisation



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1.6



Referenced Documents



This document has been developed from a variety of sources including some which are used

repeatedly for reference through the body of this Stage 1 ESHIA report. Listed below are the

references to these sources.



Document Title

Ndomahina E.T. 2008. Republic of Sierra Leone Mineral Sector Technical Assistance Project

Environmental and Social Impact Assessment (ESIA) Study.

SRK Consulting. June 2009, Tonkolili Iron Ore Project: Environmental and Social Initiation

Study.

Nippon Koei UK, BMT Cordah and Environmental Foundation for Africa. January 2005.

Bumbuna Hydroelectric Project Environmental Impact Assessment.

Ayibotele N. B. March 2005, National Policy Guideline and Action Plan on Water Supply and

Sanitation: Water Supply and Sanitation for Sierra Leone.

NBSAP. 2002. Convention on Biological Diversity, National Biodiversity Strategy and Action

Plan (NBSAP).

WorleyParsons. February 2010. Environmental Impact Assessment Screening Form.

The Mines and Minerals Act 2009. Government of Sierra Leone.

The Environmental Protection Act 2008. Government of Sierra Leone.



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2

2.1



ESHIA PROCESS

Relationship between Phase 1, Phase 2 and Phase 3 of the

Tonkolili Iron Ore Project



Although many aspects of Phase 1, Phase 2 and Phase 3 of the Tonkolili project are separate, the

relationship between these phases is on the whole transitional and may involve at different times

some or all of phases running concurrently.

Phase 1 mining operations will result in a product comprising Direct Shipped Ore (DSO) lump and

fines which will be mined from a surface (duri-crust) deposit. This phase represents an early, smallerscale operation that is reliant on a combination of brownfield refurbishment and mining of the

relatively easily accessible surface hematite deposits at Tonkolili. Because of these factors, the

construction stage of Phase 1 is expected to commence in 2010 and be completed within

approximately 6 months enabling a relatively rapid commencement of mining and export.

Phase 2 mining operations will be a combination of continuing the hematite duri-crust mining plus

extraction of hematite from a deeper saprolite layer. This will require some grinding and separation

probably creating a tailings waste stream. The development scenario is based on providing mine and

process plant facilities supported by a narrow gauge rail network to transfer the product to out-loading

facilities at Pepel and Tagrin Point. It is expected that Phase 2 will deliver 17 Mpta over and above

the 8 Mtpa expected from Phase 1.

Phase 3 represents a significantly larger project reliant on mining a deeper magnetite deposit and

more mineral processing, haulage and out-loading infrastructure development. Export of magnetite

concentrate is planned to commence after 2014. Phase 3 necessitates a longer construction time

than for Phase 1 and 2 and consequently there are elements of the early ‘enabling’ works of Phase 3

that are planned to commence at an earlier date. Therefore Phase 3 construction could occur whilst

the earlier phase are in construction and operation.

The Phase 1 project may create significant positive legacy factors in the form of the refurbished

former ‘Delco’ rail line and Pepel Port area when Phase 1 transitions into Phase 2. It is understood

that this has been considered in the projects lease arrangements with Government of Sierra Leone

(GoSL) and that the legacy potential for these assets may enable other mining operations to develop

in Sierra Leone. AML has also agreed to manage the port and railway, making those facilities

available to other users, including other mining companies and general freight and passenger

transport companies, at commercial rates.

It is intended that this infrastructure will in due course provide a facility servicing the West African subregion, enabling both Sierra Leone and neighbouring countries to export their goods to international

markets. The rail and port infrastructure will provide access for people in the region to a reliable and

efficient mode of transport; it will encourage the development of other businesses in the area whilst

promoting decentralisation from a densely populated Freetown. AML therefore anticipates that the

project will bring positive benefits to the local and national economies as well as improving the

standard of living for the people of Sierra Leone.

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An ESHIA that considers Phase 2 and 3 of the project will be prepared and submitted separately in

2010.



2.2

2.2.1



ESHIA Steps

Screening



The purpose of screening is to determine whether an EIA (or ESHIA) study is required. Therefore the

screening process involves a preliminary determination of the expected impact of a project on the

environment and of its relative significance.

Screening processes for the Tonkolili project have included development of an Environmental

Aspects Register and submission of a Screening Form with outline project information to SLEPA.

Environmental Aspects Register

As part of the screening process an Environmental Aspects Register was developed to gain a

preliminary understanding of the project activities and possible consequences in relation to

environmental and social aspects. The risk pathways were analysed to identify potential biophysical,

social and health impacts. This preliminary screening of environmental and social risks provided a

basis for further investigation ensuring that all the major risk pathways had been considered (See

Appendix 2 for the Environmental Aspects Register.)

Submission of Screening Form

The Screening Form for the project was submitted to the EPA in March 2010. The Screening Form

submission triggered screening of the project by SLEPA, albeit it had already been recognised at the

pre-Screening stage in November 2009 that the project was Category A. Screening also triggered the

Scoping process to obtain agreement on the terms of reference for the ESHIA study.



2.2.2



Scoping



On the basis that the project constitutes a Category A project, the next step in the ESHIA process was

agreement on the project approach, appropriate project boundary limits; the information necessary for

decision-making; and the significant effects and factors to be studied in detail. The scoping stage

clarifies the requirements of GoSL through agreed Terms of Reference for the preparation of an

ESHIA.

Accordingly a Scoping Procedure document was submitted to SLEPA in March 2010 that contained

information on the approach to the ESHIA, including scopes of work for the various specialist studies,

examples of rapid assessment surveys and information on the location and preliminary design of key

project facilities.

A Regulatory ‘Road Map’ was also produced to establish a programme of ESHIA deliverables in line

with implementation of the early components of the project.

See Appendix 1 for the Regulatory Road Map and Scoping Documents for the Tonkolili project.



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Further Scoping was completed in May 2010 when there was formal presentation with stakeholders to

describe the scope of works and methodology for the future ESHIA reports. The presentation also

included comments and feedback from interested stakeholders. A transcript of the presentation and

issues raised is included in Appendix 1.

A separate Scoping report was produced in April 2010 for the haul road component of the Phase 1

project as requested by the SLEPA. This report outlined specific environmental and social issues

related to the haul road and was produced at an early stage to reflect the early construction timeline

for this component of the project.



2.2.3



Impact Assessment



The following components have been included in this impact assessment.

Project Description & Baseline

A full project description is required to gain an understanding of the project elements and activities.

The project description presented in this ESHIA is complete to the best of our ability with the known

information about the project.

The baseline description provides an assessment of the existing environment including social, health

as well as physical aspects within the project area and in the surrounding region.

Impact Assessment

This assessment includes the projects likely effects on the existing environment including social,

health as well as physical aspects. Specific review have been completed to assess potential impacts

to air quality, noise, ecology and biodiversity, hydrology and hydrogeology, soils and land use,

geology and geomorphology, socio-economic effects, cultural heritage and human health. Impacts are

assessed by magnitude, extent and duration and their relationship to sensitive or ‘valued receptors’.

Review of Mitigation Measures

Mitigation measures aim to prevent adverse impacts from happening and to control the impacts that

do occur within an acceptable level. Opportunities for impact mitigation will occur throughout the

project cycle. The objectives of mitigation are to enhance the environmental and social benefits of the

project; avoid, minimise or remedy adverse impacts; and ensure that any residual adverse impacts

are kept within acceptable levels. The mitigation measures are discussed in the impacts section so

that the clearest analysis of what are considered to be remaining or residual impacts can be obtained.

Management Strategies

Management plans and strategies will translate recommended mitigation and monitoring measures

into specific actions that will be carried out by AML. Management plans will then form the basis for

impact management during project construction and operation.

Commitments Register

The Commitments Register presents the issues that require further management after completion of

the assessment. These issues may be residual impacts identified in the ESHIA impact assessment

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process. The register includes a description of the issue, action required to address the issue, person

responsible and date that action is required by.

Auditing, Monitoring & Continual Performance Improvement

The auditing and monitoring step provides information that will assist in impact management and to

improve understanding of cause-effect relationships and mitigation methods. Auditing is necessary to

certify that practice is in accordance with established procedures and to identify how processes or

systems can be improved. Continual improvement is central to auditing, monitoring and performance

assessment.



Terms of Reference for ESHIA



2.3

2.3.1



Terms of Reference



One of the principle functions of the scoping stage is to guide the development of appropriate terms of

reference for the ESHIA. This has been developed using a combination of consultation and

procedural techniques.

The stakeholder engagement process is broadly outlined in Section 2.4 below. Consultation

undertaken during project Scoping has enabled the development of ESHIA Terms of Reference by

engagement with stakeholders and determination of their different interests. This has taken place at

many different levels in the project as follows:





‘Phase 2b‘ survey work has involved community consultation to help define and target

specialist scientific survey work (for example botanical studies near the mine site). Local

names, use of natural resources, distribution and trends in abundance or decline have been

developed from this level of focus-group consultation;







Discussions at a community level through the Early Works Consultation Committee (EWCC)

forum about community level concerns and expectations. This has been recorded and used

to define specific issues such as proximity of project facilities. District level consultation with

affected communities near the mine site has been taking place since September 2009, with

monthly EWCC forums running from February 2010 across the entire project area;







Consultation with high level stakeholders (Ministers and GoSL Department Heads) through

2009 and into 2010 has helped align the study work according to local legislation and cultural

norms. This level of consultation has also helped clarify the expectations associated with the

level and protocol for community consultations. Ministerial consultations have helped focus

studies towards areas of concern, for example ministerial consultations have indicated

specific conservation requirements, data gaps and areas of legislation reform



SLEPA procedural guidelines associated with conducting an ESHIA for mining and on-site mineral

processing have also been used in preparing the ESHIA Terms of Reference. The following sections

have been developed (procedural guidelines are presented in Appendix 1):



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Table 2-1 Procedural Fulfilment of the ESHIA

SLEPA Procedural Requirement



ESHIA Section



ESHIA Report Content



Purpose and Physical

Characteristics of the Project



Section 3



PROJECT DESCRIPTION



Land-use Requirement of the

Proposed Project



Section 3



PROJECT DESCRIPTION



Operational Features of the

Proposed Project



Section 3



PROJECT DESCRIPTION



Alternative Sites and Processes

Considered



Section 3.4



Project Options & Alternatives



Physical Features of the Proposed

Site



Section 6



PROJECT AREA BASELINE



Legislative and Policy Framework



Section 4



Legislative and Policy

Framework (See Section 3:

‘PROJECT DESCRIPTION’);;



Impact on Human beings and the

Human-made Environment

(Construction and Operations);



Section 7



POTENTIAL IMPACTS &

MITIGATION



Impact on Land, Water Resources,

Air Quality and Climate, Flora and

Fauna



Section 7



POTENTIAL IMPACTS &

MITIGATION



Other Indirect and Secondary

Impacts



Section 7.6



Distributed Impacts from

Project



Information Gaps and

Uncertainties



Section 9



ONGOING WORKS



Significance of Impacts



Section 7.1 and

Section 8



Impact Identification &

Evaluation and RESIDUAL

IMPACTS



Mitigating Measures



Section 7



POTENTIAL IMPACTS &

MITIGATION



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Terms of Reference for the different phases of the Tonkolili project have been established together.

Screening information, stakeholder presentations and scoping materials have carefully differentiated

the two project phases while also clearly describing their inter-dependencies.

During Scoping an ESHIA flow chart was developed that provides a plan of how the ESHIA process

could be best managed. The flow-chart is presented in Figure 2-1. It was recognized that a series of

separate ESHIA covering the different phases would be necessary.

Figure 2-1 Tonkolili ESHIA Simplified Process Flowchart

SLEPA EIA Screening

Form



Scoping Documents



Early

Appraisal input

to DFS by end

of April 2010



Submitted to SLEPA in February 2010

(for Phase 1 and 2)



ESHIA

Phase 1 ESHIA



Input to FEED

by September

2010



Status



Phase 2 ESHIA



ESHIA Phase 1 (this document)

ESHIA Phase 2 (pending, in 2010

ahead of major construction)



Feedback



Stakeholder Engagement Plan



Haul Road Scoping document

submitted to SLEPA on 15th April

2010 (part of Phase 1 project)



Feedback

Public

Consultation



The Gazette and National

Newspaper

Public Hearings



Environment & Social

Management Plan (ESMP)



Construction



Operations

Community Development

Action Plan (CDAP)



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This rationale has been followed with the submission and development of the following ESHIA

components:





A series of reports that in combination represent the ESHIA for the Phase 1 Haul Road;







Stage 1 ESHIA (this document);







Stage 2 ESHIA (pending);







Specialist ESHIAs required for specific technical elements of the project (eg Dredging Impact

Assessment, Visual Impact Assessment, also pending);







Development of Risk Assessments to evaluate non-routine events such as spillages, integrity

failures, traffic and accidents;







Strategic Environmental Assessment – to evaluate potential change at national and

institutional level arising from this project (pending).



The integrity and coherence of the ESHIA program particularly with respect to determination of overall

cumulative effects whilst individual ESHIA components are being developed is achieved through the

following ongoing activities:





liaison with SLEPA throughout;







over-arching environmental and social management (auditable); and







monitoring by independent organization with reporting to SLEPA and stakeholders.



This ESHIA has been prepared for submission for approval on the understanding that elements of the

infrastructure design and ESHIA study are not yet fully developed. In recognition of this, the

proponent (AML) has committed to undertake completion of the various ESHIA studies, which are

either ongoing or soon to be undertaken and will be reported on in updates to the Environmental

Management Plan (EMP) and as part of the Stage 2 ESHIA. Comprehensive environmental and

social (E&S) management will continue, with the studies inputting to project design, construction and

development. It is recommended that rigorous risk review is applied in the interim ahead of final

ESHIA Stage 2 submission in order to identify appropriate Environmental and Social (E&S)

management measures, which will be delivered through the ongoing EMP that will extend into the

operational phase.



2.3.2



Scope



The Scope of the Stage 1 ESHIA has included the following elements:

1. Development of project information from AML and their contractors;

2. Undertaking environmental identification

environmental and social aspects register;



(EnvID)



review



and



developments



of



an



3. Site-specific studies that have been undertaken over the last 12 months using an ESHIA team

from WorleyParsons, international experts and local specialists and organizations;



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4. The scope of the survey work undertaken comprises terrestrial ecology (fauna, flora, avifauna and aquatic); marine ecology and sampling of water and sediment, air and noise

studies, surface and groundwater sampling, weather measurements, flow measurements and

well inventories, soil logging and physicochemical sampling, socio-economic baseline studies

incorporating specialist focus group including women’s groups and youth organizations and

an initial health appraisal across a small randomized population sample along with a district

level health review;

5. Repeat study work in order to evaluate seasonality;

6. The scope of the assessment work undertaken comprises biological species sample

collection and categorization, water, soil, sediment and tissue laboratory assessment and

evaluation against guideline values, numerical modelling and screening to determine air

quality, climate, marine and groundwater behaviour, processing of socio-economic

questionnaires and review of pollution sources and control measures and waste management

capacity;

7. The impact assessment has used standardized impact magnitude and valued receptors

techniques. Extent, duration and likelihood values have been standardized against

WorleyParsons risk management terms;

8. Identification of further work programs have been evaluated, critiqued and scoped based on

gap analysis by relevant specialists in the respective fields;

9. Identification of mitigation techniques, future management practices and ongoing monitoring

and performance auditing has been developed in conjunction with AML’s environmental

management office and represents a commitment from the proponent linked as a

conditionality to the ESHIA licensing process.



2.3.3



Exclusions



The Stage 1 ESHIA work has utilised over 12 months worth of survey and study work as described in

the scope above. Notwithstanding the large body of work already collected there are recognized to be

a limited number of areas that are still not well understood. Coverage of these areas in the ESHIA has

been achieved by taking a strategic view on likely impact and behaviour extrapolated from what is

currently known. The following exclusions apply to this work:





SLEPA has not provided direct comment with respect to the Terms of Reference or scope of

this Phase 1 study. Guidance on the coverage and content of this report has been taken from

comments returned by SLEPA relating to the ESHIA interim reports prepared for the Haul

Road;







There is no single feasibility study report that covers the entire Phase 1 project. Details on

project description, layout and alternatives has been derived from information obtained either

directly from AML or their nominated contractors;



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Limited to no information other than site selection has been available for the air-strip

proposed near the mine-site; a full assessment of this facility has therefore, been excluded

from the Stage 1 ESHIA;







Limited information other than basic site selection has been available for the dredge spoil

disposal sites; a full assessment of this facility has therefore, been excluded from the Stage 1

ESHIA;







Limited to no information has been available for the proposed power supply or supplies for

Phase 1; a full assessment of this facility has therefore, been excluded from the Stage 1

ESHIA;







This report has not addressed all aspects of the IFC performance standards and hence by

extension, the Equator Principles. However it is considered that a sufficient level of

assessment and ongoing environmental management is underway / pending to demonstrate

acceptable non-financial risk management and avoidance;







It has not been possible in the available time to obtain seasonal data for all of the

representative periods (wet, dry and transitional periods).



The Stakeholder Engagement Process



2.4



Consultation and disclosure about this project to the public, affected people and a wide range of other

stakeholders has been achieved through a stakeholder engagement process. This is still underway

and it can be said there will be maintenance of a forum through community committees and official

liaison throughout the life of project. Implementation of the stakeholder engagement process based

on detailed analysis and a structured approach to public consultation and disclosure in all project

phases is provided in more detail in Chapter 10.

In summary, this process is structured as follows:





Stakeholder analysis will be presented, outlining the different stakeholders involved in the

Project and their potential to influence project outcomes;







National norms followed in Sierra Leone and international requirements including the Equator

Principles (EP) and the Voluntary Principles on Security and Human Rights (VPSHR) for

stakeholder engagement;







Different types of stakeholder engagement activities will be explained and the activities

undertaken to date will be listed and reported on;







Analysis of comments from stakeholders will be presented at the outset and then updated at

various defined stages throughout the Project lifecycle;







A plan for stakeholder engagement in subsequent phases of the Project is proposed including

the human, logistical and financial resources required for the plan.



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The Structure of this Report



2.5



The structure of this report is summarised below:





Chapter 1 is the introduction to the ESHIA report;







Chatpter 2 describes the ESHIA process, the relationship between the project phases, terms

of reference, stakeholder engagement and IFC policies;







Chapter 3 is the description of the project which consists of the following project elements:

mine; transport corridor; port and offshore. The section also describes the supporting

infrastructure required by the project;







Chapter 4 presents the institutional bodies and national legislation that applies to this project;







Chapter 5 describes the existing environmental and social conditions in the overall regional

area, including the following issues climate, air & hydrology; soils land use & ecosystems;

marine and population and demographics;







Chapter 6 describes the existing environmental and social conditions in the project area. The

mine, transport corridor and port project elements are assessed against the following

categories: air quality; noise; archaeology; ecology & biodiversity; hydrology & hydrogeology;

soil & landuse; geology & geomorphology; socio-economic and human health. The offshore &

coastal environment has also been considered;







Chapter 7 outlines the potential impacts for each of project elements and provides an

evaluation and assesssment of the signifcance of the impacts. Mitigation measures have

been identified to address these significant impacts;







Chapter 8 presents the ongoing assessment works that will be undertaken as part of the

ESHIA programme;







Chapter 9 outlines the environmental and social management plans required to address

issues identified in the ESHIA studies;







Chapter 10 contains the Public Consultation and Disclosure Plan & Resettlement Policy

Framework;







Chapter 11 presents auditing, monitoring and continual performance improvement;







Chapter 12 is the Commitments Register which outlines the future commitments required for

the long term management of the project;







Chapter 13 Conclusions and Recommendations;







Chapter 14 References.



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3



PROJECT DESCRIPTION

Project Overview



3.1



‘Base-case’ engineering options for the project have been used in this report. However, it is also

recognised that further alternatives and options are being considered leading to optimisation during

successive stages of the project. More detail on engineering design and material quantities is given in

the referenced reports. The description below represents the know project description as of May 2010

and has been selected on the basis of relevance to the determination of likely environmental and

social footprint of the project that were identified during the development of the Environmental

Aspects Register (See Appendix 2).

The review of engineering, baseline conditions and preliminary impacts has been structured into four

elements comprising the Mining Area, Transport Corridor, Port Facilities and Offshore.



Proposed Development



3.2



The locations of the principal elements of Phase 1 of the Tonkolili project are described below and in

Table 3-1:





Mining Area - hematite deposits from Phase 1 are located along the crown of the Simbili

formation. Supporting mine infrastructure, accommodation facilities and mining plant will be

located in the Mawuru and Tonkolili valleys southwest of Simbili. See Figure 3-3







Transport Corridor – a haul road is under construction from the mine site to a rail interchange

at Lunsar (approximately 120 km). Ore is then transported by narrow-gauge rail to Pepel

along the original Delco rail line which is to be refurbished;







Port Facilities – ore will be exported from Pepel port using a combination of new and

refurbished facilities for rail dumper, ore handling and stockpiling and the existing wharf

interface including refurbishment of the existing jetties;







Offshore – the base-case option assumes off shore anchorage loading of ocean going bulk

carriers (Panamax or Cape size) from transshipment vessels loaded at the primary Pepel

jetty.



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Figure 3-1 Phase 1 Mine to Port Transport Route



Table 3-1 Summary of the different locations of Phase 1

Project Element



Phase 1 Location



Mine Area



A 1-2 km2 mining area that spans the crest of Simbili and with additional

areas for accommodation and beneficiation infrastructure.



Transport Corridor



New haul road and refurbished Delco rail line



Port Area



Pepel Port, occupying the southern part of Pepel Island



Offshore



Panamax shipping from transshipment anchorage offshore of Freetown



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3.2.1



Element 1 - Mining Area



The magnetite and hematite deposits that forms the basis for the full-development Tonkolili project

occurs in a north-east to south-west trending hilly outcrop. Drilling work has confirmed the magnetite

ore body reaches commercial grades of iron enrichment beneath three hills named Simbili, Marampon

and Numbara illustrated in Figure 3-2 below. Hematite occurs as a duri-crust deposit on these

deposits extending to approximately 50m depth with a further 50m depth of transitional zone. Phase 2

mining will target this transitional material. Magnetite is encountered at approximately 100m depth

below surface. Phase 3 mining will target magnetite beneath Simbili, Marampon and Numbara and

the expected pit depths extend to approximately 700m depth (SRK, May 2010).

Figure 3-2 Tonkolili Mineral Deposits



Phase 1 of the Tonkolili project targets the overlying hematite/goethite deposit in the Simbili region,

and is intended to produce 8,000,000 tonnes (8Mtpa) of saleable product per year. Exploration has

indicated an ore reserve in the order of 800 Mt. The iron content of the hematite/goethite ore can be

increased to exportable grades through beneficiation. This requires relatively lower levels of

processing and investment in order to commercialise this phase of the project than needed for Phase

2 and 3. Crushing and sorting techniques will be required during Phase 1 near the point of extraction

with limited to no chemical or processing involved. The hematite deposit extends to approximately

50m depth in some areas, although it is characterised as having a highly variable distribution and

concentration across the deposits. Between the base of the hematite deposit (-50m) and the top of

the underlying Tonkolili deposit (-100m) there is a ‘transition zone’ of heterogeneous mineral

composition. This transition zone will be mined as part of the Phase 2 works.



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Figure 3-3 Phase 1 Mine Location



Shipping of the hematite product is planned to commence in January 2011. In order to produce the

required 8 Mtpa, some 10.4 million tonnes of run-of-mine will have to be beneficiated, and a total of

34 million tonnes of material (ore and waste) will need to be mined. The strip ratio is expected to vary

between 0.5 to 1.5 during Phase 1 mining.

Mining will be undertaken with a conventional truck and shovel operation. Ore will be hauled to a

crushing and screening plant, to be located southwest of Simbili. Waste will be initially used for

construction of access and haul roads, and for various other infrastructure projects in preparation for

the commencement of Phase 3 construction. Excess waste will be dumped in areas to the west and

northwest of Simbili, outside the final magnetite pit limits so as to avoid rehandling.



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Figure 3-4 Phase 1 Mine Detail



Phase 1 mining equipment will consist of 3 hydraulic shovels (operating weight 380t each) and 21

haul trucks (payload capacity 130-140t each). Ancillary equipment will include 2 water carts (130t

capacity), three tracked dozers (Caterpillar D10 or equivalent), and 2 graders (Caterpillar 16M or

equivalent).

Mining will be conducted on a 24 hour basis, with three crews working two 12 hour shifts.

The designed pits are 50m deep and 1.3 km2. The approximate location of the mining areas on

Simbili is shown in Figure 3-4 and it is likely that the northern zone will be mined first.

Mine Layout

The proposed Pit with the Stockpiling and Park-up area is located approximately 2.5 km eastsoutheast from the main village of the area, Farangbaia, and 3.3 and 3.7 km east-southeast from the

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AML bottom and top camps, respectively. The stockpiling and parking area is approximately 3 km

southwest of Kemadugu, 2.7 km southeast of Kegbema, 2.5 km northeast of Wandugu, 5 km

northeast of Furia, and 5.3 km from other small villages in the greater area.

An airstrip will be oriented approximately north-south in the Tonkolili River valley west of the

Farangbaia forest reserve.

The main access road extends south from the contractor's workshop area to the mine haul road and

is located approximately 800 m east of the centre of the main village, Farangbaia, 850 m east of the

bottom camp and 1.3 km from the top camp.

The mine haul road is approximately 400 m east of the centre of Wandugu and Furia.

The Contractors Workshop is approximately 600 m northeast of the centre of Farangbaia, and

approximately 1.2 km northeast from the centre of the bottom camp to the centre of the top camp.

The Crushing and Loading Facility is approximately 600 m northeast from the centre of Furia and

approximately 2 km south from the centre of Wandugu.

Material from Phase 1 will be hauled down a series of ramps to the north and through a cutting on the

western side of the ridge. Ore will continue to be transported down to the crushing pad, located to the

south of the Tonkolili River, near the village of Wandugu. Waste from this phase will be taken to a

waste dump located to the northwest of the cutting (Figure 3-4) although some of the more competent

waste will be used for additional road and pad construction, in preparation for the commencement of

the second phase and the subsequent magnetite operation.



Dewatering

Major dewatering should not be required, given the elevation and drainage of the Phase 1 pits,

however, localised dewatering may be necessary from time to time. It should be noted that the

deposit lies in a tropical region, which is subject to a large amount of rainfall during the months of May

to October. The mean annual rainfall for the region is 2,542mm.

Accommodation

Camp facilities will be constructed for the development. Capacity of camps is estimated to be 600.

Blasting

Blasting activities will begin within 3-4 weeks of the project start up and will be conducted for most of

the life of the project as the excavation first progresses along the ridge to the northwest in Phase 1,

then advances to the south in Phase 3. Blasting will occur 2 times each week during the day only, and

will generally be confined to within the top 20 meters of excavation. Each blast will affect an area of

4,000 m2. Given the nature of the rock, powder factors are likely to be low; therefore vibration from

blasting activities should also be low. Some oversize blasting may be required in lower levels of the



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excavation. Blasting is likely to utilize Ammonium nitrate-fuel oil (ANFO) as a bulk explosive and nonelectric (nonel) surface and down-hole delays. Each hole will be stemmed prior to blasting.

Site Restoration

The entire Simbili hematite mining operation is contained within the larger magnetite pit shell and

therefore, rehabilitation of the pit is not deemed necessary on the assumption that Phase 3 will

continue on from Phase 1 and 2. The haul road to the ore pad will be utilised during Phase 3 as an

access road. The waste dump for Phase 1 will be enlarged as part of the Phase 3 magnetite waste

disposal facility.



3.2.2



Element 2 -Transport Corridor



Beneficiated hematite ore will be transported using a combination of road-trains on along a specially

constructed haul road followed by haulage using a light-gauge rail track. The 122 km long haul road

built from the mine site to a railhead about 8 km North-West of Lunsar where it ties in with the existing

railway which is to be refurbished.

More detailed description of the haul road design, cross-sections, waypoints, river crossings, villages,

forests and other areas of environmental and social concern have been provided in a stand-alone

Haul Road Scoping report submitted to SLEPA in April 2010 (WorleyParsons Report ref. EN-REP0014). Relevant excerpts are provided in Appendix 1. Only a brief summary is included below.

Figure 3-5: Map 1 of Haul Road Alignment



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Figure 3-6: Map 2 of Haul Road Alignment



Between Lunsar to the Rokel River crossing the topography is slightly sloping, gently undulating and

varying in elevation between about 100 and 110 masl. Here the haul road will be situated generally on

low embankments or shallow cuts. From the Rokel River to the mine site (chainage Km 110 to Km

122), the topography becomes much steeper and there are steep valley slopes and rivers and the

underlying material is hard rock. Here, significant cut and fill volumes should be expected with most of

the cut in hard rock, probably requiring the use of explosives (subject to approvals granted from the

Government of Sierra Leone).

The first part of the schedule of works for the haul road has been initiated comprising initial

reconnaissance survey and in some areas development of a scout road. The development of further

work associated with clearance, road widening, profiling and sealing (drainage etc) are subject to

confirmation from SLEPA in response to prior submissions (Haul Road Scoping, EMP and other

reports that have been generated in April 2010).

During the initial site clearance and creation of the scout road, vegetation has been cleared using

bulldozers. Further clearance will be required for the entire length and width of the route using a

heavy flail attachment on 360 excavators or similar approved fittings for a tractor. Local labour will use

machete / sickle to cut back.

The following environmental management measures are being undertaken. All decomposable

vegetation waste will be re-introduced into neighbouring vegetated areas. Trees will be logged in a

controlled manner and under direct supervision of trained competent personnel. Logging gangs will be



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operating well ahead of road construction activities. Suitable timber will be sent to saw mill for

replacement sleepers. Waste timber will be stockpiled for disposal or re-introduced into bush. All tree

roots will be removed in entirety by mechanical means / chains and shackles. Virgin bush will be

cleared with the use of CAT D6 / D8 machinery along proposed centreline of roadway. All

construction waste is anticipated to be non-hazardous. All waste to be recycled and re-used wherever

possible, and surplus to be used as haul road earth berms. Organic top soils will be stored in

managed stockpiles and reused for profiling of berms and other waste material that can be

revegetated and for rehabilitation of other areas impacted by the project.

When completed the road will comprise a compacted but unsealed surface edged with 1m high earth

berms. The road will have two lanes, with a nominal width of 12.5 m (16.5 m with berms). Drainage

from the road will be controlled by a cross-sectional road profile that drains to the edges with gaps in

the berm edging at intervals to release flows.

Figure 3-7: Typical cross-section of the Haul Road



At about Km 94 the haul road will cross the River Rokel - the major river in the area (approximate

span 90m). There will be other smaller river crossings at km 50 (River Tabai – approximate span

40m) and at around Km 110 where the haul road will cross the Tonkolili River at several locations

(approximate spans 20m).

The ore will be hauled using road train type vehicles. The road-trains will consist of a tractor unit and

five motorised trailers with a gross payload of 400 tonnes.



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Figure 3-8: Road-train



Speed limit on the road will be set at 60 km per hour. Minimum travel time for road-trains will be

approximately 2 hours. 22 vehicles will be travelling between the mine and Lunsar Interchange.

Transshipping will operate 24 hours a day.

Route Selection

The following design principles have been utilized for the haul road:











All villages to be provided a clearance of at least 500m where practicable;

Severed access tracks between villages to be maintained with 2.4m diameter corrugated

steel pipe culverts to act as an underpass beneath the haul road. Actual requirements and

locations to be site determined;

A clearance of at least 500m is to be provided to areas of sacred bush where practicable.

Site-specific requirements and locations are subject to local variability;







100m minimum clearance from any overhead power lines will be observed. All temporary

access beneath lines to be fitted with ticker tape marker poles as notification measure.

Clearance levels to be sited and clearly marked on both sides;







500m minimum clearance to any Telecom communication towers. All temporary access

beneath lines to be fitted with ticker tape marker poles as notification measure. Clearance

levels to be sited and clearly marked on both sides;







At road intersections a modular steel bridge to carry the existing road over the haul road will

be installed. Where the existing roads are minor, a manual form of traffic control will be

required (manned boom).



Construction Materials

Crushed rock and nodular ferricrete gravel will be used as construction material for the haul road. The

material will be excavated from the quarries nearest to the construction areas. Several potential

quarry sites have been identified as being economically and technically suitable. Crushed rock

potential quarries are located at the following locations:



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Makele Quarry at Makeni is an existing quarry but will require complete renovation with new

equipment;







Potential quarry site located 1km north of km 48 on the existing road requiring investigation

and development. The rock has been identified as amphibolite from 2 small surface

exposures. The overburden may be ferruginous and suitable for sub-base or selected fill

layers;

Kerfay quarry near Lunsar appears to have had minor use in the past but will need

development. The rock is granite which is exposed at the surface.







There are numerous granite exposures ranging up to significant sized granite domes. It is possible

that these will provide rock suitable for use in the base course. Investigation and development will be

required.

Borrow pits for nodular ferricrete gravel were recorded at various locations adjacent to the existing

road and adjacent to the road running north from Farandugu. Visual observations indicated that the

material has high nodular gravel content and should have a CBR (California Bearing Ration) well in

excess of 30 and possibly up to 80. Observations in cuttings indicated extensive availability of

ferricrete. It is expected that up to 40 percent of the material excavated from cuttings of more than 3m

depth may be suitable for sub-base and wearing course construction. The haul road is to be

constructed with four layers comprising Sub Grade, Sub Base a Base layer and the Surface.

Equipment

The equipment used for the haul road construction include - excavators, graders, pumps and concrete

batching as well as small plant. Equipment is listed in full in the Haul Road Scoping report

(WorleyParsons, April 2010).

Accommodation

Three camps will be constructed in order to accommodate workers:





Rogbere Camp;







Makeni Camp; and







Camp close to Tonkolili.



Construction of the camps is required as an early Phase 1 activity and the project programme

requires completion June 2010. Design, dimensions of the camps, energy sources, water and waste

management and power demand will be controlled through specific environmental management

plans.

It is assumed that water requirements will be one bore hole per camp. Water treatment plants will be

constructed at each camp. 30,000 L a day of water will be treated, while 50,000 L will be stored at

each camp. At the moment it is assumed that black water treatment plants will be placed at each

camp. Solids will be removed periodically by honey sucker.

Lunsar Interchange



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The road-trains will offload hematite ore at Lunsar Yard. The loading yard at Lunsar will consist of 3

stacking lines for stock-piling iron ore. The capacity of the combined stockpile will be around 4 million

tones. The construction of the Yard will include building of four staging lines at Lunsar yard each

approximately 1km in length to serve as the load out yard, installation of six 1:9 40kg turnouts, the

supply and installation of one 40kg stopblock. The works will also include the construction of one

office building. Fuel will be provided at the fuel yard, which will be 100 m in length. Fuel storage for

road trains and the facilities will be required. The interchange will operate on a 24 hours per day

basis. Six trains will carry ore to the Pepel Yard each day. Each train will consist of 50 wagons. Total

payload per train will be 2500 tonnes max.

Rail transport from Lunsar will be along a narrow-gauge railway line which had previously been

between Marampa and Pepel for iron ore transport operations (Delco 1933 to 1975). The ‘Delco’ line

is to undergo refurbishment along with the port and wharfing facilities at the terminus on Pepel Island,

which AML are operating under a 99 year lease agreement with the Government of Sierra Leone

(GoSL). The lease arrangement licenses AML to reconstruct, manage and operate Pepel Port and the

Pepel – Marampa Railway.



Figure 3-9 Lunsar Interchange



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Phase 1 Rail Refurbishment

Construction activities will require a number of works to be undertaken along the existing narrow

gauge (1065mm) single track rail line alignment.

The scope of work includes the repair and construction of approximately a 72km main line, two 1km

loops and a new rail loading yard at Lunsar as well as remedial work on the existing rail infrastructure

at Pepel yard.

Figure 3-10 Rail Map



Line clearance works will be performed by local workers using hand held machetes The track will be

constructed by initially lifting the existing rails and sleepers wherever they remain in position then

relaying 40kg/m rails comprising reconditioned and new sections to be laid on reconditioned steel

sleepers spaced at 650mm centers laid on 1200m³ ballast profile. One loop lines will be constructed

at approximately 20km and a former loop at 42km reinstated and a new loading yard constructed at

Lunsar.

Construction methodology:

1.



Site Preparation



The works to be performed by the contractor involves the following:





Camp Site Establishment



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Site Vegetation Clearing - grass, shrubs, bush, trees and other vegetation along rail formation

and adjacent to drainage channels will be removed by local workers with a use of hand held

machetes. Strip top soil to nominal depth of 200mm will be removed and stockpiled as

directed by the engineer.







Earthworks and Civil - the scope of works will include treatment of the existing ballast

formation throughout its length, construction of a gravel road with level crossing supply and

installation of new storm water culverts including inlet and outlet structures. The works will

also include excavation and construction of new table drains, shaping of earthworks to

facilitate drainage. Blinding and reinforcing will be installed if required. The materials camp

will be fenced.



2.



Platelaying Works



The methodology for platelaying works will comprise:



3.







Existing track upliftment and stockpiling for later reuse - existing thermite welds will be

removed by means of disc cutter or similar throughout 53km of existing track infrastructure.

Approximately 53km of existing permanent way material will be lifted and stockpiled alongside

the formation for later reuse. 11 turnouts will be lifted and moved to stockpile in the Pepel

yard. Works will be performed by a combination of local labour and front end loaders;







Track reinstatement - the works include the supply (where necessary) and construction of

approximately 72km of “new” single line track from Pepel to Lunsar. A new 1km loop will be

constructed at approximate chainage 20 km from the Pepel yard. An existing 1km loop will be

restated at Port Loko approximately 41km from the Pepel yard. 1:9 40kg turnouts will be

installed in Pepel yard and the two loops. The works will be performed by a combination of

local labour and front end loaders;







Track welding will be carried out by on track welding machine;







Alignment & tamping - 79km of track and 21 turnouts will be tamped with a heavy duty on

track mechanical and mechanical switch tamper. Replacement of sleepers on bridges and in

Pepel yard will be performed by local labour;







Supply and installation of Proposed various track signs will be installed along the rail

alignment;







Abandoned railway material will be sorted and stockpiled on the site.

Schedule



The duration of these construction works has been estimated as 229 days to complete the planned

activities.



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4.



Operation of railway



The following table provides a brief overview of the rail specifications and activities.



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Table 3-2 Overview of Rail Specifications & Activities



5.



Criteria



Value



Axle load

Rail length

Operation time

Rail Wagon payload

No of wagons per train

Total payload per train

Number of trains per year

Number of trains per day

Total train offloading time at dump station



17 t

72km

24h/day

40-47 tons (max 50t)

50

2500 tons

2190

6

2 min/wagon = 1.5h/train



Equipment



Equipment to be used during construction works includes a diesel locomotive and track mounted plant

including an axle horse and mechanical tamper. There will also be a significant amount of plant that

will access the rail track from the adjacent road including flat bed truck, dozer and smaller plant such

as welding gear. Estimates of fuel use and construction duration are given below. Overall

approximately 1 million L of fuel are expected to be used during the rail refurbishment.



Table 3-3 Diesel Usage Over Construction

Description of Plant /

Equipment



Duration

working days



Total Hrs

construction



Loco

FEL CAT IT 14

Double axle horse (Local)

1 ton LDV

8 ton flat bed Tata/4x4

Dozer D6

On Track Mechanical Tamper

Butt Welder

Generators

Sundry fuel



137

2 104

1 155

2 100

1 050

21

220

219

1 200

210



2 192

18 937

10 399

18 900

9 450

189

1 981

1 975

19 200



Fuel

Efficiency

(L.hr-1)

30

14

133

38

50

20

20

50

8

300



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6.



Employees



The workforce is estimated to comprise 19 expats supported by 165 locals involved in construction

activities. The local workforce comprises 25 skilled or semi-skilled and 140 unskilled. All staff will be

moving along the works area as the works progress.

7.



Camp locations.



The rail camp will be located in Pepel yard, while one mobile on track (on the railway line) camp will

move as the work progresses. At this stage all sources of energy will be self generating i.e. generators

varying in size from 6Kva - 25Kva however AML is responsible for the free issue of electricity at various

locations along the route.

8.



Anticipated waste types and quantities from construction



At this stage the waste related to the construction will be limited to the following:





Packaging from material – 20 to 50kg size bags and cardboard (total estimated tonnage will be

5 tonnes over the contract period of 10 months);







Paper and cardboard form locals (total estimated tonnage will be 2 tonnes a month over a

period of 10 months).



All waste will be stockpiled in the suitable area indentified by the client, where waste can be treated.



3.2.3



Element 3 - Port Facilities



Hematite ore will be taken to Pepel Port where the material handling system will be capable of either

directly loading ore from the train or stockpiling and then reclaiming depending on the timing of ship

movements. Ore will be exported via transshipment vessels (TV) to an offshore anchorage. The iron

ore will be transferred to ocean going bulk carriers (OGV) for export.

Ultimately, the total iron ore exported will be 8 million tonnes per annum (8 Mtpa). During the first year

of operation the amount of iron ore exported will ramp up as follows.

Table 3-4 – Export volumes during first year of operation



Month



Export volume (tonnes per month)



Dec-10



100,000



Jan-11



100,000



Feb-11



150,000



Mar-11



250,000



Apr-11



400,000



May-11



400,000



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Jun-11



500,000



Jul-11



666,000



Aug-11



667,000



Pepel Port is located in the Sierra Leone Estuary about 20km from the sea and 12km upriver from

Freetown. It has not operated since 1985 but infrastructure is still present in the area including housing

and office facilities, a power plant, fuel tanks, conveyer belts and a jetty / ship loader. The area of the

Pepel Port is approximately 1725 ha.

To enable operations, the Port will need to be renovated. The objective of the Pepel Port project is to

refurbish and upgrade the existing facilities to enable a maximum loading capacity of 4000 tonnes per

hour (tph). A schematic of the existing facilities is provided in Figure 3-11. The operations will be similar

to those of the existing port and therefore there is no need to expand the port footprint and no additional

land clearance is required.

The planned refurbishment and upgrade of Pepel will include the following:





Power Generation System;







Dual Train Dumping Station;







Stacker Feed System;







Reclaim Feed System;







Shiploader;







Offshore Transshipment Anchorage



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Figure 3-11 Schematic of Existing Pepel Port Layout



The iron ore will be transferred by rail to Pepel Port and offloaded at a double dump loadout station.

Total train offloading time at the dump station will be approximately 1.5 hours. The iron ore will be

transported to a double boom stacker by conveyors. The capacity of each onshore conveyor will be

2000 tph. The stacker will form 2 stockpiles with capacity of 200000 tonnes each. Four front end

loaders will excavate the ore from the stockpiles and offload it in collecting hoppers. The ore will then be

transported to the jetty by the transfer conveyor. The capacity of the transfer conveyor will be 4000

tonnes per hour.

A schematic diagram of the process flow is presented below (Figure 3-12)

Power requirements for the port are yet to be determined. At present, it is assumed that a new power

generation facility will be established, which utilises diesel generators. It is assumed that it will be a

package plant with no seawater cooling requirement. Diesel will be transported to Pepel by road and

stored within the existing storage facilities following their renovation.



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The existing liquid waste management facilities, including wastewater and run-off will be improved and

treatment provided to meet legislative requirements. An assessment of drainage facilities and

wastewater treatment and disposal options is ongoing and will be documented within the Waste

Management Plan.

Port operations will be 24 hour.



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Figure 3-12 Schematic diagram of material handling at Pepel



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3.2.4



Element 4 – Offshore (Marine engineering)



The existing terminal comprises a 140m long jetty with two quadrant ship loaders with a maximum

outreach of 25.5m. The mooring layout comprises the berthing face of the jetty head and two mooring

dolphins set back from the berthing line.

All marine structures will need to be refurbished, including the shiploader booms, stackers/reclaimers,

stockyard conveyor and berths. The two mooring dolphins are beyond refurbishment and will be

replaced. Two additional dolphins may be required to safely moor the TVs.

The detailed design of the mooring and shiploading facility is yet to be finalised a potential layout is

shown in Figure 3-13.



Figure 3-13 Example Ship-Loader Layouts for Pepel Port



Transshipment is proposed as Pepel Port is unsuitable for cape-sized vessels due to its location

within the estuary and the depth of the access channel. Transshipment results in a significant

reduction in capital and maintenance dredging requirements.

The OGV will be anchored offshore and the ore will be transported from Pepel to the anchorage by

the TV. Self unloading Handymax vessels with a cargo lift of approximately 30000 tonnes – similar in

size to the vessels previously use by the port – are proposed to be used as TVs. Two TVs will be

required and each will be doing approximately one round trip per day between Pepel and the

transshipment anchorage once the objective export volume of 8 Mtpa is reached. The OGV is

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expected to be a Cape-size vessel with a cargo capacity of approximately 170000 tonnes. Panamax

vessels with a lower capacity may be used.

The transshipment anchorage location has not been finalized and is currently being assessed but it

will be located outside the estuary some distance offshore where there is sufficient water depth for the

OGV.

TVs will transport the iron ore to the anchored OGV. The TV will transfer the ore directly into the OGV,

using its conveyor and crane system. The rate of transfer is approximately 2000 tph. Examples of

transshipment operations and storage vessels are shown in Figure 3-14.

Figure 3-14 Example transshipment operations



The proposed dredging project involves dredging a shipping channel from the disused port facility at

Pepel Island to allow navigation from the entrance of Sierra Leone River (Figure 3-15).



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Figure 3-15 Navigation Channel to Pepel Island



Dredge Channel

Preliminary design of the berthing/manoeuvring area and navigation channel from Pepel Island to the

mouth of the Bunce River comprises the following key elements:





Turning basin depth: -7.0 m chart datum (CD)







Channel depth: -10.5 m CD







Channel width (straights): 120 m







Channel width (bends): 250 m adjacent to Tasso Island; and







Channel side slopes: 1V:5H (vertical and horizontal)



The dredging works will reinstate the channel used by Pepel port when it was previously in operation.

The initial water depths for the scope of work are derived from the UK Hydrographic Office Admiralty

charts and are a minimum of -7 m CD in the main navigational channel. The estimated dredging

areas are shown in Figure 3-16. This will be dredging of material that has infilled in the Pepel channel

since Pepel port was last used and maintenance dredging took place.

The estimated volume of dredge material is approximately 1.5 million m3. However, further

bathymetry surveys are underway to confirm the dredging requirements.



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Figure 3-16 Proposed dredging areas - manoeuvring area and Navigation Channel



Additional maintenance dredging will be required on a yearly basis to maintain the navigation

channel. The frequency and volume of maintenance dredging required is currently being assessed.

However, high deposition is expected in some areas during the rainy season such as in Kakim

channel and historical information suggests that volumes of between 0.5 - 1.0 million m3 may need to

be dredged each year to restore depths.

Dredging Methodology

As infill of a previous channel is being dredged, the material is expected to be relatively soft.

Therefore a Trailing Suction Hopper Dredger (TSHD) will be used for the dredging works.

Suction dredging such as TSHD is commonly used for dredging silty, sandy or gravely soils or soft

clayey soils. Sediment grabs indicate that much of the Pepel channel has medium coarse grain

sediments, probably due to the strong tidal currents along the channel. There are some areas where

finer sediments have been deposited. This is described in more detail in the baseline section 6.5.1.

A hopper will be used to collect the dredged material in its cargo hold to transport to the dredge spoil

disposal site.

The dredging cycle starts with the dredger sailing with an empty hopper to the proposed dredging

area using its highly accurate navigation systems.



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The TSHD shall deepen the channel by removing consecutive layers of the seabed material. In

addition to the given dimensions, an average of 2 m overwidth at each side and an over-depth

between 0 m and 0.5 m is dredged as a result of positioning tolerances.

The characteristics of a typical TSHD are presented in Table 3-5.

Table 3-5 Example TSDH vessel characteristics

Approx. Specification

Hopper capacity



11 000 m³



Deadweight



18 000 ton



Length



140 m



Breadth



25 m



Draught loaded



9m



Suction pipe diameter



1m



Pump power (trailing)



3 500 kW



Pump power (discharging)



8 000 kW



Propulsion power



2 x 6 000 kW



Speed



15 kn



TSHD Working Principles

The TSHD it is a sea-going, self-propelled dredging vessel, which includes a hopper to store the

dredge material. It is commonly used.

The dredging systems of a TSHD consist of one or two suction tubes, each driven by a powerful

centrifugal pump, called the sand pump. During the dredging, and in a process, which is quite similar

to the domestic vacuum cleaner, the lower ends of the suction tubes are trailing along on the seabed,

while the sand pumps provide the suction power to lift the materials from the seabed into the hopper.

The suction pipe has a special draghead, which is designed to maximize the dredging efficiency

during the loading phase (Figure 3-17).



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Figure 3-17 Typical draghead (left) and suction pipe (right) from TSHD



The sediment is loosened and removed from the seabed by a combination of suction provided by the

sand pump, the forward motion of the vessel and the cutting and jetting characteristics of the

draghead. The materials dredged from the seabed, will be pumped into the hopper as a

sediment/water mixture. Care will be taken to minimise the water content in the mixture.

In the hopper the sand material settles due to gravity and the water flows back to the sea through the

overflows situated in the hopper.

Figure 3-18 shows the general layout of TSHD operations.



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Figure 3-18 General layout of TSHD working at dredging site



The dredge material is stored in the hopper for transport to the offshore disposal area (Figure 3-19).

Figure 3-19 Hopper wells



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In order to increase the volume of dredge material that can be stored and minimise the number of

trips to the disposal site excess water overflows from the hopper. There is a risk of increased turbidity

due to the hoper overflow.

To minimize the potential fine plume, an overflow funnel is constructed inside the hopper. It consists

of a height adjustable funnel mounted on top of a vertical cylinder which ends under the keel of the

dredge. The excess water is discharged under the dredger (see Figure 3-20), at the highest level

possible, thus minimising the concentration of suspended solids in the overflow water.

There is also an anti-turbidity valve or “green valve”, which is a hydraulically controlled valve mounted

inside the overflow funnel(s). This valve drastically reduces the turbidity generated by the overflow

water (or dredge plume) drained through the overflow funnels. It reduces the overflow funnel, which

ensures that the water level inside the overflow funnel will be maintained and the mixture will “fall”

from a lesser height. As a result less air gets mixed into the overflow and the dredge plume will not

have a tendency to rise up, next to or behind the vessel. Without the use of this green valve the finer

particles in the overflow mixture are churned up by the vessel’s propellers and hence create those

infamous turbid clouds behind the trailer dredger.

Figure 3-20 Typical overflow funnel with anti-turbidity valve



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Dredge Disposal

As soon as the hopper is fully loaded, the suction tubes will be hoisted back onboard and the dredger

will head to the dredge disposal site.

Bottom dumping is the fastest way to unload the hopper by discharging the load through the opened

bottom doors of the hopper (Figure 3-21). Water jets inside the hopper will ensure the hopper is

completely empty and free of any dredged soil prior to closing the bottom doors. Due to the draft of

the vessel the material will fall approximately ten metres through the water column to the seabed. As

part of the EMP an assessment is required to ensure that the material remains within the disposal

site.

Figure 3-21 Bottom dumping procedures, at disposal sites



The TSHD can also discharge at sea via its own suction tube, to discharge it at a greater depth. The

depth is restricted to the length of the suction tube but will be sufficient for the proposed disposal

ground.

All dredged materials will be transported to the agreed dumpsite approximately 5 km north of Cape

Sierra Leone, which is shown in



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Figure 3-22.



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Figure 3-22 Proposed spoil ground



Duration

Dredging will take place 24 hours/day for 7 days/ week. Therefore it will take up to 7.5 weeks to

remove the estimated 1.5 M m3 of sediment.

The yearly maintenance dredging will take up to 2.5 weeks, assuming a dredge volume of 500,000 m³

of sediment and a dredging capacity of 200,000 m³/wk.

Timescales for capital dredging will be confirmed once the bathymetry survey is complete and the

final dredge volume is calculated. Maintenance dredging requirements will be dependant on infilling

and estimates will be refined following modelling of sediment transport in the estuary.



3.3

3.3.1



Supporting Infrastructure

Power supply



Power requirements for Phase 1 are localized, the overall power requirements are approximately 4.5

Mw for the project (AML Stakeholder Presentation, May 2010).

Hematite Mine



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Power supply to the mine activities will be provided by diesel powered generators with a localised

distribution system within the mine area.

Power demand will be required for the contractors’ workshop, workers’ camps and crushing and

loading facilities, among others.

Haul Road

Power supply to the haul road will be only needed during the construction phase at 3 construction

camp locations (Rogbere, Makeni and Tonkolili).

Energy sources and power demand are yet to be finalised; however, it is anticipated that the demand

for general camp activities will be covered by Diesel Generators at each camp.

Lunsar Interchange

Power will be required for both, the construction and the operation phases of the Interchange Yard.

During construction, power demand will be satisfied through the use of Diesel Generators that will

supply the construction camp and any other machinery in requirement of power. During the operation

phase, the power demands for the office building will be also provided through the use of a Diesel

Generator.

The power demand is still to be finalised for both construction and operation phases.

Rail Refurbishment

Power will be needed during construction / refurbishment at both the rail camp to be located in Pepel

yard and one mobile on track (on the railway line) camp that will move as the work progresses. At this

stage all sources of energy will be self generating i.e. generators varying in size from 6Kva - 25Kva.

AML has taken responsibility for the free issue of electricity at selected locations along the route.

The Pepel Yard Generators will work on diesel and its estimated fuel demand is 8 L.hr-1, making it a

total of 168 960 L of fuel on the basis of 1 200 days for the construction.

Pepel Port

Power supply to the port area during construction will be provided by packet generation sets with a

localised distribution system within the port area. The initial port power requirements, yet to be

estimated, will be provided by 6.6 kV power generators fed by a diesel fuel source.

Pepel Operational Phase Power Requirements:

The stacker power requirements and the power requirements for the reclaimers, which will operate on

diesel, are being determined and there is a base-case assumption that refurbishment of the existing

power house at Pepel in conjunction with generator sets will be the selected model. Diesel was

previously brought into Pepel Port and stored using a dedicated fuel jetty connected to a 6Ml fuel

farm. Confirmation of renewal of this process is still underway. An alternative is that diesel will be

supplied to Pepel from Tagrin Port when Phase 3 operations commence.



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3.3.2



Water supply



Potable and construction water supply will be required at numerous locations across the project area.

Although preference has been given to utilise groundwater resources for potable use, it is likely that

due to the accelerated nature of Phase 1 a significant component of potable water will be trucked in

from Freetown, as is the current practice at the mine exploration camp. Construction water will be

sourced from nearby groundwater resources through a drilled groundwater borehole or a network of

several boreholes.

Hematite Mine

It is likely that the Phase 1 mine water will be supplied from existing springs / streams that are

currently in use for exploration activities. Currently, potable water demand is estimated as an average

of 20 L per person per day. Construction water demand is yet to be determined.

Haul Road

Haul road construction camps will require a temporary water supply in form of groundwater wells to

be drilled at each location. The latest assumption is that there will be three camp locations along the

haul road alignment, water demand for each of them is yet to be determined.

It is assumed that water requirements will be one bore hole for camp. Water treatment plants will be

constructed at each camp. 30,000 L/day of water will be treated, while 50,000 L will be stored at each

camp.

Lunsar Interchange

At the interchange there will be an office and 2 portable toilets, the location of which is also unknown.

All these facilities will require water, which is likely to come from groundwater wells drilled in the area.

Water requirement specifications for construction and operation are still pending.

Rail Refurbishment

Water supply during the rail refurbishment will be required, as a minimum, at the rail camp in Pepel

yard, and on the mobile (on the railway line) camp. It is anticipated that each location will have a

different water requirement, largely depending on the number of personnel working at each and on

the construction water requirements, yet to be determined.

It is anticipated that drinking water (bottled) will be supplied by AML from Freetown and that

construction water requirements will be sourced from drilling wells at each of the camps.

Pepel Port

During Phase 1 of work, a water supply will be required at Pepel Island. No significant fresh surface

water bodies exist on or near Pepel Island and groundwater is the primary available resource.

Average water demand for the initial construction and operation of the proposed port and related

facilities has been estimated to be about 250 m3/d (2.9 l/s), but could reach a maximum of 300 m3/d

(3.5 l/s).

It was proposed by Scott Wilson that nine production wells are located east and west of Mayela

village. On the basis of a yield of 0.5 l/s per well, seven wells will be required to meet the demand of

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3.5 l/s, and two additional wells for stand by purposes. Spacing between wells is approximately 250 m

to prevent excessive interference. It is recommended that well depths should be no more than 25

meters in depth.

At the present moment it is known that GCS Ltd is carrying out drilling works in the South-East of

Pepel Yard under the instructions from AML. There are two wells drilled, which will be pumping

approximately 2 l/s from each well. The wells extend to 32 and 42 mbgl respectively instead of

proposed 20-25 m.



3.3.3



Fuel Supply



Hematite Mine

Fuel will be required for energy generation and for the use of the mine machinery as well as for

transport purposes.

Fuel required by the mine activities will be supplied by tankers from Freetown. Currently, there is a

fuel yard in the town of Bumbuna.

Fuel storage for the mine activities and camp demands will be managed according to a specific

environmental management plan in conjunction with the fuel operations plan that is still in

development.

Haul Road

Fuel supply to the haul road will be needed during the construction phase at all 3 construction camp

locations (Rogbere, Makeni and Tonkolili).

Fuel sources, storage facilities and demand are yet to be finalised.

Lunsar Interchange

Fuel will be required for both, the construction and the operation phases of the Interchange Yard.

During construction, fuel will be probably trucked-in from Freetown. Fuel demand during construction

is yet to be determined.

During operation, fuel will be provided at the fuel yard, which will be 100 m in length. The location and

the quantity of fuel being stored are yet to be determined. Fuel will serve the operation of the trains on

a 24 hours per day basis (6 trains/day to the Pepel Yard).

Rail Refurbishment

Equipment (machinery and generators) to be used during construction works will be working on fuel

and the estimated fuel consumption for the duration of the works is 1 045 909. On the assumption

that 1 200 days will be needed for the construction phase, the daily fuel consumption is estimated as

87.1 L/day.

The trains to be used during operation will be General electric 2300HP, there will be 3 trains with 50

wagons (6 trains/day).



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Pepel Port

Fuel supply for power generation and machinery to the port area during construction and operation is

likely to be brought into Pepel by tanker via the existing jetty as per the previous (Delco) operations

which included a 6Ml fuel farm situated at Pepel. It is assumed that a similar fuel storage system will

be established to run the on-site generators, construction and operation machinery and re-fueling

vessels.

Fuel tanks will be built at Pepel Port to supply the needs of the port activities.



3.3.4



Bulk material management



Hematite Mine

Borrow material will be sourced from a new quarry to be located south of the village of Wandugu, on

the haul road alignment. Material, quantities and daily demands are yet to be determined.

Building materials and quantities are also to be determined, although it is expected that, as a

minimum, cement, steel and camp materials will be needed. Material will be stockpiled at the plant

facility.

Haul Road

See section 3.2.2 for details.

Camp construction materials will be also needed for the three camps along the haul road.

Lunsar Interchange

Building materials expected to be needed for construction include cement, steel and camp materials.

Final material and quantities are to be determined.

Rail Refurbishment

Ballast quarries will be needed although material requirements and quarry locations are yet to be

determined.

Camp materials will be needed for the camps at Pepel Yard and for the mobile camp.

A description of material to be used during rail refurbishment is given in the table below together with

an estimate of the quantities needed and the source.

Table 3-6 Construction Material for Rail Refurbishment

MATERIAL / DESCRIPTION



UNIT



QUANTITY



SOURCE



Derail Devices



ea



2



South Africa



Stop Signs



ea



18



Sierra Leone



Advance Warning Signs



ea



18



Sierra Leone



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Track Whistle Boards



ea



96



Sierra Leone



Siding Number Boards



ea



2



Sierra Leone



Transport Miscellaneous Items



ea



137



Unknown



Rails in 12 or 18 Meter Length



km rail



63.28



United Kingdom



Type Heavy Duty Steel Sleepers



no



76050



South Africa



Type Wooden Crossing Timbers



no



1974



Sierra Leone



Timber Sleepers for Bridges



no



367



Sierra Leone



Fastenings Type Pandrol to Suit



per ea



106785



South Africa



Bridge Sleeper Fastenings



per sleeper



367



South Africa



Turnout Sleeper Fastenings



per turnout



21



South Africa



Turnout Sests 1:9 40 Kg/M



set



21



South Africa



Stop Block



no



1



South Africa



Lubricators



no



20



South Africa



Varying in Length from 2.1meter to

4.2 Meter



Existing Steel Sleepers Typically

Type 1802



Pepel Port

Large amounts of construction materials will be needed in the refurbishment of Pepel Port. This will

include cement, steel, glass, brick, timber, etc.

The source of the material and the quantities are yet to be determined.



3.3.5



Demand on existing facilities/ resources



Construction and refurbishment along the Delco Rail Line and at the Pepel Port Lease will require the

support of local goods and services as well as, to a limited extent co-sharing of infrastructure such as

access roads. The interaction with existing facilities and resources will be most apparent along the 72

km of existing rail line and the upgrade of some of the existing facilities at Pepel, such as the Dual

Train Dumping Station; the Stacker Feed System;, the Reclaim Feed System; the Shiploader Feed

System and some existing buildings (offices and housing).

The Haul Road will be built in predominantly Greenfield areas with a self-sufficient contracted work

force. Some interaction with existing footpaths / minor unpaved roads is expected and has been

addressed in the Haul Road Environmental Management plan and Community Development Action

Plan (WorleyParsons, April 2010)



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The mine site and the Lunsar Interchange will be Greenfield projects that will utilise the existing mine

exploration camp infrastructure and develop a specific community development plan at Lunsar.



3.3.6



Solid Waste Management



Solid Waste from both operational and construction activities will be dealt with in a structured and

auditable manner from the commencement of the project through design, into construction and on to

operation and monitoring and beyond. Waste minimisation will be emphasised from the outset of the

project, in addition to ensuring that the waste produced is dealt with in accordance with the principles

outlined within a defined Waste Hierarchy (reduction, reuse, recovery and recycling, see

WorleyParsons Report Preliminary Concepts for Solid Waste Appendix 3). All applicable in-country

legislation and best practice will be adhered to. Where disposal or treatment is required, this should

be undertaken in accordance with the treatment recommendations included in the section below.

Hematite Mine

Solid waste will be generated at the worker camps will be dealt in accordance with the waste

hierarchy, with a significant fraction of the waste sent to an incineration unit provided specifically for

both workers and operational municipal waste generated at the mine. Currently sewage and solid

waste including putrescible is being dumped at waste pits without pre-treatment. Pits are being

managed only by intermittent cover using surface soils. Improvement and upgrading of waste

management is a priority item currently being undertaken by AML.

Haul Road

It is anticipated that the haul road will generate negligible operational waste. The primary waste

arising from the construction will be spoil potentially in the region of 800,000m3 based on preliminary

cut and fill calculations. This waste is considered to be inert and does not require an engineered

facility for disposal; however areas should be outlined at outset for stockpiling and bunding. Where

possible the road should be designed to achieve a cut and fill balance. As a minimum, land areas

should be set aside for spoil disposal; there may be an opportunity to re-use spoil in some port

reclamation works.

Rail refurbishment

It is not anticipated that the operation of the rail facility will generate significant waste issues;

however, there is a potential for waste arising from existing material that cannot be reused (especially

scrap metal). At this stage the waste related to the construction will be limited to the following:





Packaging from material – 20 to 50kg size bags and cardboard (total estimated tonnage will

be 5 tonnes over the contract period of 10 months);







Paper and cardboard from locals (total estimated tonnage will be 2 tonnes a month over a

period of 10 months).



All waste will be stockpiled in a suitable area to be identified by AML, where waste can be treated.



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Pepel Port

Construction

At Pepel port, the project development will comprise a materials handling facility, and relevant

supporting infrastructure such as power, water, access roads, accommodation facilities, workshops,

warehouses, laboratories and administration buildings, train unloading facility, stockyard and wharf.

This will comprise a combination of existing asset refurbishment and new development.

It is anticipated that the primary component of the wastes generated from Port construction will be

metals that will have a residual scrap value either locally or could be readily exported in sufficient

quantities. There is also likely to be significant quantities of hazardous waste in the form of oils and

other industrial wastes which should be disposed of either to the main incineration unit proposed for

the Port Construction Workers Camp, or to individual workshop oil burners.

Operation

Waste will be generated by the ongoing process activities at the port. Primary waste generated from

these activities will include:

-



Waste oils;



-



Metals from refurbishment of plant;



-



Packaging, plastics and pallets;



-



Lead acid batteries; and



-



Waste electrical and electronic equipment waste.



In addition the operational staff at the Port will generate a small volume of general office and

municipal waste, which should be disposed of to the incineration unit proposed for the Port

Construction Workers Camp.

All residual waste that cannot be recycled incinerated or the ash from the incineration unit should be

sent to the landfill proposed to support the development of the Port Construction Works Camp.

For further information on Phase 1 waste management refer to Appendix 4 for Solid Wastes

Management Practice Guidelines.



3.3.7



Waste Water Treatment



Suitable Black and Grey Water disposal options will be engineered throughout the project in order to

attain compliance with the project basis of design (WorleyParsons, 2010). Waste water treatment

plants will be placed at each camp. Solids will be removed periodically by honey sucker.

WorleyParsons has produced an environmental basis of design for the overall project (namely Phase

3) that will be referred to and used as a reference for good practice. A project specific waste water

management strategy and plan for the project will be developed that will address approaches to

sewage sludge disposal, implementation of secondary and tertiary level treatment and synergies

where possible with the project solid waste management strategy.

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Project Options & Alternatives



3.4



ESHIA requires an analysis of alternatives, which should provide a systematic comparison of feasible

alternatives to the proposed project and evaluation of their potential social and environmental

impacts. Alternatives to be considered should include, as appropriate, planning alternatives, site or

route locations, location of facilities, infrastructure alternatives, technology, operations, land use

alternatives, financial alternatives, and the ‘without project’ alternative.

Alternatives design, technology and site selection of the project elements has been considered

already. A significant factor that has been taken into consideration has been the attempt to minimise

adverse or negative social or environmental impacts. The project design presented above (the base

case) mostly represents the best trade-off that can be achieved, with the available information

between minimised impacts and good engineering performance.

Consideration of other alternatives is an inherent component of project design, which is ongoing at

present. Consequently the ESHIA alternatives analysis process informs project design. This ESHIA

summarises all alternatives considered, including the ‘without project’ option.

A summary of some of the high level strategic options and alternatives that have been considered to

date or are under consideration in relation to minimising environmental and social impacts is

presented below. More detailed alternatives analysis is provided for specific project elements and

facilities in the relevant impact and mitigation sections that follow:

Mining





The location of the ore bodies is fixed and there is limited available option to consider in terms

of alternative location or mining methods or scheduling as the mine plan is based on a single

optimised mining model;







However, it is important to consider that the Phase 1, 2 and 3 mining projects are interactive

in the sense that Phase 1 mining and the mining of transition material as part of Phase 2 has

a significant effect on lowering the amount of Phase 3 overburden and hence waste rock

generation;







The overall ‘without project’ alternative would involve abandoning the mining project as well

as the infrastructure aspects of the project that are conditional upon the mining operation

proceeding. The project represents a nationally significant development opportunity with

major social, environmental and governance impacts both positive and negative. This ESHIA

presents an unbiased assessment of the project so that the GoSL with respect to its

constitutional responsibilities can make an informed decision in its capacity of considering the

national interests and sustainable development.



Transport Corridor





The road and rail alignments located within the borders of the 6km wide leased transport

corridor have undergone route selection taking into account environmental and social

constraints. The route selected has avoided protected areas such as Farangbaia Forest

Reserve, riverine forest areas and areas of conservation habitat on the basis of constraints



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analysis. During the route selection assessment, all villages have been provided with a

clearance of at least 500m and a clearance of at least 500m from sacred bush areas has

been provided;





Assessment of extension of the Delco (light) rail system from Marampa (Lunsar) to the mine

site as an alternative to the haul road / road train option. This is currently under review.



Port Area





The Pepel Port project has wherever feasible looked at alternatives associated with

brownfield regeneration rather than new build so as to minimise cost, material and resourcing

requirements. This carried significant environmental and social benefit in terms of pragmatic

use of resources and limiting impacts to areas that are already have a degree of conditioning

associated with the previous operations;







The project has considered design alternatives that wherever feasible put material handling

plant; for example, conveyors and road loops underground through tunnels to limit co-sharing

of space with public amenities. This has been driven by a combination of community and

space management and public safety factors.



Offshore





The alternative of zero dredging in the Sierra Leone estuary whilst still accommodating capesize vessels has been considered by potentially using a much longer approach trestle

spanning across the estuary. This alternative is still under study;







Other alternatives currently under consideration include potential dredging. The inbound bulk

carriers would enter from sea, transit to Freetown to pick up a pilot. Transit to and from Pepel

would be timed to maximize water depth around high tide. Based on the available data there

are shallow depths at various sections along the route. In addition to the potential dredging of

the turning basin off the berth there will be a need for dredging at Tasso Island channel and

Kakim channel. There may be a need to dredge high spots in the river section; however these

areas may be passable at given heights and times of tide. The assumption is Panamax

vessels (80,000 dwt) will be used and require an estimated 6.3 million m3 of dredge material,

based on initial assessments.



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4



LEGAL, POLICY AND ADMINISTRATIVE FRAMEWORK



The GoSL’s responsibility and role in protecting the nation’s natural resources and ensuring that

sustainable development (Article 21) is pursued has been enshrined in law under the National

Environmental Policy (1994).

This policy places responsibility on the Government to secure for all Sierra Leoneans a quality of

environment adequate for their health and well being and to conserve and use the environmental and

natural resources for the benefit of present and future generations.

The policy also requires that Government manages development so as to restore, maintain and

enhance the ecosystems and ecological processes essential for the functioning of the biosphere; to

preserve biological diversity and the principle of optimum sustainable yield in the use of living natural

resources and ecosystems.

The policy outlines in general terms how these aims can be implemented using a combination of

raising public awareness, encouraging community participation and strengthening environmental

protection standards, monitoring and data use.

The policy states that ESHIA can only be effective when done prior to proposed activities which may

significantly affect the environment or use of a natural resource and to provide relevant information, in

a timely manner, to persons likely to be significantly affected by a planned activity and to grant them

equal access and due process in administrative and judicial proceedings.

The policy promotes environmental management through the creation of administrative and

infrastructural support with appropriate financial backing.

Finally there is reiteration of the need to develop good international relations by adherence to

international treaties, care with regard to transboundary issues effective prevention or abatement of

transboundary environmental protection.



Institutional Bodies



4.1



In 2008 the GoSL passed the Environment Protection Agency Act No. 11 of 2008 (EPA 2008) which

established the Environmental Protection Agency (EPA) as the competent authority for reviewing and

processing ESHIA. The EPA Board of Directors also comprises representatives from the following

Ministries:





Ministry of the Environment;







Ministry of Local Government;







Ministry of Mineral Resources;







Ministry of Marine Resources;







Ministry of Agriculture and Forestry;



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Ministry of Tourism;







Ministry of Trade and Industry;







Ministry of Transport;







Ministry of Health; and







Petroleum Unit.



The EPA has a wide range of environmental management functions including coordination of the

activities of government agencies and other agencies on matters relating to environmental protection

and management. The EPA is also responsible for ESHIA compliance and licensing (see Section

3.1.3 for further details).

At present the EPA is not fully fledged. Predecessors to the EPA include the Department of

Environment (DOE), within the Ministry of Lands, Country Planning and the Environment (MLCPE),

and the 2005 National Environmental and Forestry Commission (NACEF), which was later referred to

as the Environment Commission (SRK Consulting, 2009).



4.2



Relevant Sierra Leone Legislation



All aspects of the Project shall be designed to meet the requirements of all current relevant Acts,

Rules and Notifications, including but not limited to those listed below:

• Environmental Protection Act, 2008;

• Mines and Minerals Act 2009;

• National Lands Act, 2006;

• Forestry Act, 1988;

• Forestry Regulations, 1989;

• The Water (Control and Supply) Act (1963);

• Public Health Act, 1990;

• Labour Act, 1990;

• Wildlife Conservation Act, 1977.

See Appendix 5 for a list of legislation applicable to environmental and social impacts from Phase 1 of

the Tonkolili project.



4.2.1



Legislation Relevant to Ecological Protection



Forests

No classified forest may be cut, burned, uprooted, damaged or destroyed, except with a written

permission from the Chief Conservator of the forest (Part VI, Section 21 Subsection 2 Forestry Act,

1988). Failure to observe this is an offence punishable with a fine.

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Classified forests, which may be either national or community forest have protection or production as

their primary purpose, and are to be managed accordingly. There is a general prohibition against

logging and other activities in classified forests, except by authorized exception from the Chief

Conservator of the forest.

Granting of licences for this is conditional upon fee payments to a reforestation fund and also on

agreement of appropriate provision for replanting and undertaking reforestation/rehabilitation of

disturbed land.

Vegetation Clearance

Vegetation clearance is also controlled under Forestry Regulation, 1989 which states that removal of

vegetation has to be carried out under licence and keep to a specific land area within a stated time.

Riverine/Mangrove Vegetation

No land between the high and low water marks, nor those above the high water mark on both sides of

the bank of any waterway, covering a distance of one hundred feet (approximately 33 m), shall be

cleared of any vegetation except permitted by a clearance licence (Part XI,Section 38).

Sacred Bush

Sacred forests/bushes are common throughout rural Sierra Leone and most villages have one or

several forests within close proximity. The values of these forests to communities are many and

varied, ranging from spiritual significance to meeting places to the practical source of trees and nontimber forest products. Increasingly, within the proposed transport corridor, sacred forests/bushes are

some of the last areas of remaining natural habitat left, prominent within wider landscape of degraded

vegetation and agriculture.

The Forestry Regulations of 1989 states under article XI, paragraph 40:

“No tree or vegetation shall be removed from areas abandoned as sacred bush except under the

authority al a clearance licence issued by the Chief Conservator of Forests.”



4.3



ESHIA Legislative Requirements



On the basis of a formal application submitted to the Sierra Leone Environmental Protection Agency,

the Tonkolili Iron Ore Project has been classified under Category A (EPA letter to AML dated

4.12.09). According to the Equator Principles a Category A project requires a full environmental

impact assessment to assess the “potential significant adverse social or environmental impacts that

are diverse, irreversible or unprecedented” (Equator Principles Website, March 2010).

It is understood that the government of Sierra Leone use this categorization system to regulate the

ESHIA process and set the terms for an ESHIA licence. As part of the licensing the project’s ESHIA

needs to follow agreed terms of reference which will be established in conjunction with the EPA.



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The national legislation relevant to the preparation of the Tonkolili ESHIA and the Stage 1 ESHIA

project includes the EPA Act 2008 and the Mines and Minerals Act 2009 (MMR 2009). The following

sections outline the ESHIA requirements in each of these Acts.



ESHIA P R O C E D U R E O U T L I N E D I N T H E E N V I R O N M E N T AL P R O T E C T I O N A C T 2008

The EPA 2008 briefly charts the procedure to obtain an ESHIA licence in Sections 23-29, with

emphasis on the responsibilities of the EPA and the EPA Board, as stated below.





An application must be made to the EPA for a licence, accompanied with a description of the

proposed project;







The EPA will decide (within 14 days) whether an ESHIA is required;







If required, the applicant should then prepare an ESHIA;







On receipt of the ESHIA, the EPA will circulate it to professional bodies or associations

including Government Ministries and non-governmental organisations (NGOs) for review;







Government Ministries and non-governmental organisations (NGOs) for review;







The EPA will also open the ESHIA for public inspection and comment and will notify the

public of this in two issues of the Gazette (consecutive issues) and two issues of a newspaper

(with an interval of at least seven days between the first and second publications);







The EPA will submit the comments on the ESHIA, together with the ESHIA, to the Board for

consideration;







If the Board approves the ESHIA, it will instruct the Executive Director of the EPA to issue an

ESHIA licence;







The EPA will issue a licence to undertake the activity/ project.



The ESHIA can only be approved by a multi-department Government Board. This Board then advises

the Executive Director of the Environment Protection Agency (EPA) on its decision on whether to

issue the licence or not (see Part IV of the Environment Protection Act, 2008 for further details).

In relation to social requirements, the EPA 2008 alludes to a requirement for social impact

assessment in the Third Schedule of the Act. It states that the ESHIA should include “social,

economic and cultural effect that the project is likely to have on people and society”.



4.4



ESHIA requirements in the Mines and Minerals Act 2009



The Mines and Minerals Act 2009 sets out procedures to obtain mining licences and was approved by

the GoSL Cabinet in November 2009. Under this Act, a mining licence cannot be obtained until the

ESHIA has been prepared, submitted, reviewed and approved first. An ESHIA licence is a form of

permit which contains additional stipulations upon the holder such as abatement or remedial

measures.



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The Bill requires an applicant to have undertaken an ESHIA in consultation with the public and be

able to “‘verify possible impacts from the ‘stakeholder’s perspectives”. The licence is required in order

to commence mining operations of the nature intended by AML and will stipulate a number of

cadastral and financial technicalities. The Bill requires an eligible ‘person’ (project proponent or

company) has to present their licence application to the Ministry of Mineral Resources (MMR)

accompanied by an environmental impact assessment (ESHIA) licence (refer to Section 106 (2) (s),

GoSL 2009).

Section 133 states the applicant needs to develop an ESHIA that ”shall contain the type of information

and analysis reflecting best international mining practice” and outlines required headings from

environmental baseline through to monitoring responsibilities and an environmental management

programme.

It should also be noted that the Mines and Minerals Bill (2009) also requires the following:





S.106-2 (i-(v)): proposals for the progressive reclamation and rehabilitation of land disturbed

by mining and for the minimisation of the effects of mining on surface water and ground water

and on adjoining or neighbouring lands;







S.106-2 (i-(vi)): a statement on the effects of the mining operations on the environment and

on the local population and proposals for mitigation, compensation and resettlement

measures; and







S.106-2 (i-(vii)): a statement on any particular risks (whether to health or otherwise) involved

in mining the mineral;







S. 59 (1g & 1h), 115 & 116: promotes preferential employment of citizens of Sierra Leon, as

well as preferential procurement of goods and services from Sierra Leone;







S. 23-18: deals with restrictions on exercise of mineral rights and compensation for

disturbance of rights and for compulsory acquisition of land.



The MMR’s expectations for these documents have not yet been confirmed. It also needs to be

confirmed whether these documents could be prepared and officially validated or approved before the

ESHIA licence is obtained.



4.5



Mine Technical Assistance Project (MTAP)



The 2009 Mining Technical Assistance Project (MTAP) for Sierra Leone is a capacity building

initiative sponsored by the World Bank. The project is part of an integrated approach to extractive

industries reforms that extends the goal of sound management and transparency along the full

spectrum of the extractive industries management chain, from the awarding of licenses and contracts

to the monitoring of operations, to the collection of taxes and sound, equitable distribution of

revenues, and finally to the implementation of sustainable development projects (Ndomahina, 2008).



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The objective of MTAP is to (i) increase efficiency and transparency of the mining sector management

by the Government; and (ii) facilitate contribution of mining sector into local economic development.

The project addresses specific mining impacts in relation to climate, geology, water resource,

groundwater, noise odour and dust, traffic, and cultural and archaeological resources. Mitigation

measures outlined include dust control measures, discharge controls on tailings and sedimentation

ponds and silencers to reduce noise.



MTAP Resettlement Policy Framework



4.6



GoSL / World Bank Mining Sector Technical Assistance Project (MTAP) Resettlement Policy

Framework (RPF) suggests the resettlement and compensation principles, organisational

arrangements and criteria to be applied to meet the needs of persons affected by the project. In

accordance with World Bank OP 4.12 (see Section 7.3.7) and the established Terms of Reference,

the RPF covers the following sections:





Introduction and Project Description;







Principles and objectives governing resettlement and compensation preparation and

Implementation;







A description of the process for preparing and approving Resettlement and compensation

Plans;







Land acquisition and likely categories of impact;







Eligibility criteria for defining various categories of project affected persons;







A legal framework reviewing the relationship between the laws of Sierra Leone and

regulations and Bank policy requirements and measures proposed to bridge any gaps

between them;







Methods of valuing affected assets;







Organizational procedures for the delivery of entitlements, including, for projects involving

private sector intermediaries, the responsibilities of the financial intermediary, the

government, and the private developer;







A description of the implementation process, linking resettlement and compensation

implementation to civil works;







A description of mechanisms for redressing grievances;







A description of the arrangements for funding resettlement and compensation, including the

preparation and review of costs estimates, the flow of funds, and contingency arrangements;







A description of mechanisms for consultations with, and participation of, displaced persons in

planning, implementation, and monitoring.



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International Conventions to which Sierra Leone is signatory



4.7



In the last decade, Sierra Leone has become party to most international treaties relevant to the

environment and social issues. Lists of the relevant treaties that have been signed by Sierra Leone

are presented below (derived from SRK Consulting, 2009). Sierra Leone is receiving assistance from

various United Nations agencies to meet the requirements of the treaties, including revision of

national legislation.

Environmental conventions





United Nations Framework Convention on Climate Change 1992;







Kyoto Protocol to the United Nations Framework Convention on Climate Change 1997;







Vienna Convention for the Protection of the Ozone Layer 1985;







Montreal Protocol on Substances that Deplete the Ozone Layer 1993;







Basel Convention on the Control of Transboundary Movements of Hazardous Wastes and

their Disposal 1989;







Bamako Convention on the Ban of the Import into Africa and the Control of Transboundary

Movement and Management of Hazardous Wastes within Africa 1991;







UN Convention to Combat Desertification 1994;







Stockholm Convention on Persistent Organic Pollutants 2001;







Rotterdam Convention on the Prior Informed Consent Procedure for Certain Hazardous

Chemicals and Pesticides in International Trade 1998;







African Convention on the Conservation of Nature and Natural Resources 2003;







Convention on Biological Diversity 1992;







Cartagena Protocol on Biosafety to the Convention on Biological Diversity 2000. Convention

on International Trade in Endangered Species of Wild Fauna and Flora 1973;







Convention on Wetlands of International Importance (Ramsar Convention) 1971;







Memorandum of Understanding concerning Conservation Measures for Marine Turtles of the

Atlantic Coast of Africa;







Memorandum of Understanding concerning Conservation Measures for the West African

Populations of the African Elephant;







Convention on the Conservation of Migratory Species of Wild Animals, 1983 (Bonn

Convention) (yet be signed); and







The Convention covering the protection of the World Cultural and Natural Heritage Sites,

UNESCO 1972.



Marine conventions



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The UN Convention on the Law of the Sea (UNCLOS 1982);







The Convention of the International Maritime Organization (IMO), Geneva, 1948;







International Convention for the Prevention of Pollution from Ships 1973 and 1978 Protocol

(MARPOL);







International Convention for the Prevention of Pollution of the Sea by Oil (OILPOL, 1954);







Convention on the Prevention of Marine Pollution by Dumping of Wastes and Other Matter

1973 (London Dumping Convention) (IMO);







OSPAR Convention - Guidelines for the Management of Dredged Materials; and







HELCOM Convention - Guidelines for the Disposal of Dredged Spoils.



See Appendix 5 for additional treaties on international labour standards (ILO Conventions) and

human rights treaties.

Sierra Leone is a signatory to the Extractive Industries Transparency Initiative (EITI). This initiative

supports improved governance in resource-rich countries through the verification and full publication

of company payments and government revenues from extractive industries including oil, gas and

mining. Countries rich in natural resources have tended to under-perform economically, have a higher

incidence of conflict, and suffer from poor governance. Through the EITI, it is hoped that by

encouraging greater transparency some of these negative impacts can be mitigated. Benefits to

companies centre on mitigating political and reputational risks. Sierra Leone was accepted as an EITI

candidate country on 22 February 2008. Sierra Leone has until 9 March 2010 to undertake validation

however an extension has been requested (EITI website, Sierra Leone website, March 2010). In the

new Minerals and Mines Act a section on reporting, disclosure and dissemination of information

related to revenues and payments made by the mineral right holders and the Government provides

the legal basis to make implementation of the EITI compulsory. It is stated as the obligation of the

license holder and contravening this provision would be considered a prosecutable offence.



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5



REGIONAL BASELINE



5.1



Climate, Air & Hydrology



5.1.1 Climate

Sierra Leone has a tropical monsoon climate, modified by local influences such as a decrease in

temperature with altitude and variation in rainfall distribution induced by topography.

Characteristic of ‘monsoon’ climates are a wet season and a dry season each year - driven by the

annual cycle in the latitude at which the sun’s diurnal sky trajectory passes directly overhead. During

the northern hemisphere winter, dry northeasterly winds, originating over the Sahara desert, blow

across Sierra Leone. Conversely, in the northern hemisphere summer moist south-westerly winds

from the Gulf of Guinea are drawn across Sierra Leone. Hurricanes are not known to occur in this

region, any strong winds in the area would be related to squall lines.

Between March and November, a broad, east-west-aligned, rain-prone belt associated with the moist

air from the Gulf of Guinea advances northwards across Sierra Leone and then retreats southwards

again, drawn in the direction of the Inter-Tropical Convergence Zone (ITCZ). However, this simplistic

explanation for Sierra Leone’s wet season fails to explain all of its features. For instance, the axis of

rain-prone belt is not co-incidental with the surface position of the ITCZ, but displaced some 300-400

km to the south. In some years there is a brief lull in the rains in the middle of the wet season while

the entire rain-belt lies to the north, despite there being a plentiful supply of moist Gulf air. The

assumed direct coupling between the ITCZ and the position of main seasonal rain belt has been

questioned, and the factors involved are complex and still not fully understood. To the north of the

main monsoon rain belt is a zone where thunderstorms and line squalls develop, and move from east

to west with the tropospheric winds.

Hayward and Oguntoyinbo (1987) provide an overview of the climatology of the different weather

elements experienced in West Africa which results from the mechanisms discussed above. Sunshine

duration is greatest in the winter period, and much reduced in the rainy season as cloudy days

predominate. There is a slight increase in sunshine from the south to the north in Sierra Leone. There

is little seasonal variation in mean air temperatures, with slightly hotter conditions in April and May.

Altitude influences temperature as well as other weather variables, with temperatures generally

decreasing with altitude. Mean wind speeds are generally low, and high impact gusts are rare. The

greatest wind speeds in the dry season occur when the ‘Harmattan’ wind blows from the east or

north-east, while in the wet season higher wind speeds are associated with storms and squalls. The

prevailing wind direction is from the south-west for most of the year, especially near to the coast and

especially during the monsoon. Annual average rainfall is greatest along the coast, and decreases

with distance inland. The Met Office makes a rough estimate of mean annual potential evaporation of

1000 mm for the Sierra Leone area, with a peak in March. This is likely to be higher for inland areas

than on the coast.



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For more information on climate and weather in the project area see Literature Review of Available

Information and Data - Stage 1 -Prepared by the Met Office in Appendix 6 and Stage 2 – Climate

Assessment and Data Analysis - Prepared by the Met Office in Appendix 7.



5.1.2 Hydrology

Sierra Leone possesses a tropical and humid climate, with clearly defined dry and rainy seasons.

Annual rainfall averages about 2 526 mm.year-1, ranging from 1 900 to more than 4 000 mm.year-1,

depending on proximity to the coast. Most of the rain falls between July and September.

The hydrology of Sierra Leone comprises a fairly dense network of rivers and streams, of which the

larger ones generally flow throughout the year. Groundwater contributes baseflow to larger rivers

during the dry season, while many of the smaller tributaries feeding these larger rivers cease to flow.

About 80 percent of the rural population obtains its water from surface water sources.

The country can be divided into twelve river basins, of which five are shared with Guinea and two with

Liberia. The most important ones, from west to east are: the Kolente (Great Scarcies), Kaba, Rokel

(also known as the Seli), Pampana (Jong), Sewa, Loa, and Mona. The river catchments in Sierra

Leone are relatively small, but because of heavy rainfall, produce large flows.

There are numerous valley swamps located in the headwaters of major rivers and their tributaries.

These flat bottomed valleys are drained by slow flowing streams and are normally swamped for more

than six months of the year. These areas are very important in rice and vegetable production. In

1999, Sierra Leone signed the Ramsar Convention on Wetlands with the only confirmed Ramsar site

being the Sierra Leone Freetown Estuary area.

Sierra Leone has two major dams, both built for hydroelectricity (Guma and Bumbuna). There is

considerable potential for the development of small-scale hydroelectric schemes that could also be

designed to accommodate irrigated agriculture.

The internal renewable surface water resource is estimated at 150 km3.year-1; seasonal variations are

very important, as only 11-17 percent of the annual discharge occurs between December and April

(dry season). Internally produced groundwater is estimated to be 50 km3.year-1 of which 40 km3.year-1

are considered to be overlap between surface water and groundwater.



5.2



Geology, Hydrogeology, Soils, Land Use & Ecosystems



5.2.1 Regional Geology

Sierra Leone is predominantly underlain by rocks of Precambrian age (older than 500 million years),

with a younger coastal strip approximately 50 km wide. This strip comprises of marine and estuarine

sediments of Tertiary and Quaternary to Recent age.

The Tertiary deposits are from the Bullom Group and occupy the higher ground, while younger

Quaternary and recent deposits occupy the low lying areas. The Bullom Group comprises interlayered

silts, sands, clays and occasional lignites. Onshore, the thickness of the Bullom Group is variable but



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is known to be greater than 60 m, possibly reaching up to 120 m. The younger Quaternary deposits

comprise alluvium deposits (generally highly organic soft sandy clay).

The Precambrian rocks can be divided into two major units, the granite-greenstone complex and the

Kasila Group.

The granite-greenstone complex consists of a series of iron and magnesium rich rocks

metamorphosed to amphibolite facies (the Kambui Group, previously known as the Sula Group)

overlying the granitic basement. The grade of metamorphism in the basement generally increases

towards the Kambui Group boundary giving rise to local occurrences of granulites, known as the

Mano-Moa Formation (Birchall, et al., 1979).

The Kasila Group comprises a series of high grade basic granulites and amphibolites that developed

into a zone of shear deformation to form the southwest margin of the basement complex. During the

development of the Kasila Group, part of it was thrusted eastwards onto the basement complex

during an event known as the Rokelide Orogeny (c. 550Ma), giving rise to low grade schists,

metasediments, banded iron formation (BIF) and lavas of the Marampa Group.

The Rokel River Trough developed very late in the Precambrian and a series of sandy and clayey

sediments (quartzites, sandstones and marls) were deposited within this trough to form the Rokel

River Group. Periodic volcanic activity during this time gave rise to basic and intermediate lavas and

ashes (the Kasewe Hills Formation).

Two periods of igneous activity occurred during the break up of Gondwanaland in the early Mesozoic.

The earliest of these, associated with the initial stages of rifting resulted in the intrusion of the

Freetown Igneous Complex, a layered complex of gabbro, norite, troctolite and anorthosite located at

the peninsular of Freetown. Numerous dolerite sills and mainly east-west trending dykes were also

intruded during this time. The second period of activity was the intrusion of kimberlite dykes and pipes

(c. 90Ma) mainly in the eastern section of the country distant from the project area (Birchall, et al.,

1979).



5.2.2 Hydrogeology

Limited investigation work have been undertaken to obtain information on the hydrogeology of Sierra

Leone. With a population largely reliant on surface water, groundwater has overall received less

attention.

According to a report published by the World Bank, the aquifers of the Bullom Series are considered

the most productive aquifers in the country (World Bank/UNDP, 1991). This is supported by the high

density occurrence of hand dug wells located within the elevated terraces of the coastal strip. Pump

tests conducted on the aquifer of the upper Bullom Series (top 40 m) at Pepel Port, found that water

from the aquifer could be pumped at a rate of 5 L.s-1 from a single 150 mm diameter well.

WorleyParsons have requested and are waiting for pump test data from GCS Ltd to assess aquifer

properties.

Sierra Leone is largely underlain by igneous and metamorphic rocks, which typically have very low

primary porosity (the porosity that results from the original formation of the rock). However, their



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secondary porosity (porosity resulting from processes post formation, e.g. faulting, dissolution) could

be high, albeit, localised.



5.2.3 Soils

Sierra Leone has a total land area of approximately 7.2 million hectares, about 5.4 million of which is

cultivable. Of this, about 4.3 million hectares are low fertile arable upland and 1.1 million hectares are

of more fertile arable swamps. With nearly 80 percent of the labor force depending upon this land for

their agricultural subsistence activities (largely slash-and-burn, with rice cultivation making up the bulk

of the subsistence activity), the overall health of these lands will depend upon how well farmers are

able to maintain the soil, water, and living resources (US AID, 20007). The combined effects of poor

farming practices — shifting cultivation, recurrent bushfires and overgrazing, increasing population,

ensuing shortening of fallow periods of land — have all been identified as contributing factors to soil

erosion resulting in land degradation.



5.2.4



Land Use



Sierra Leone has a total land area of approximately 7.2 million hectares, about 5.4 million of which is

cultivable. Of this, about 4.3 million hectares are low fertile arable upland and 1.1 million hectares are

of more fertile arable swamps. With nearly 80 percent of the labor force depending upon this land for

their agricultural subsistence activities (largely slash-and-burn, with rice cultivation making up the bulk

of the subsistence activity), the overall health of these lands will depend upon how well farmers are

able to maintain the soil, water, and living resources (US AID, 2007). The combined effects of poor

farming practices — shifting cultivation, recurrent bushfires and overgrazing, increasing population,

ensuing shortening of fallow periods of land — have all been identified as contributing factors to soil

erosion resulting in land degradation.

Along the project areas, it is apparent that cultivation of land has been practiced for a number of

generations, due to evidence of extensive land working and land scars (slow recovery of cultivated

land). The local economy of the Districts affected by the project seems to be dominated by agriculture

with a traditional focus on rice.

Agriculture is generally subsistence in nature, and, according to other literature on the project affected

areas, poverty levels among the farmers are high, with 70 percent of the population falling below the

UN defined poverty line (Coastal & Environmental Services, 2009).

A wide range of food crops are grown under the shifting cultivation system; sorghum, millet, maize,

cassava, beniseed, groundnut and beans are the associated crops grown with rice. Farmers have

very rudimentary equipment and practices.

During the dry season farming is restricted to valley flood plains (SRK 2009), while hillslopes are also

used for cultivation in the rainy season. Cassava, plantain, sweet potato, cashew nut, ground nut and

sweet corn are all commonly observed growing across the project area and fruits including pineapple,

orange, papaya, banana and mango are also grown, mainly in the immediate vicinity of villages.

Mango seems to be the most important fruit tree, since trees are found in large numbers around all



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villages along the project area. In the rainy season rice is a staple crop. Palm wine tapping is evident

everywhere and fishing is also common in rivers and streams.

At present, forest resources are subjected to increasing deforestation due to the rapidly growing

population and consequent demand for more agricultural land, urban requirement for timber and

fuelwood, mining for minerals, and recurrent bush fires. With population pressure and

commercialization today, the rate of exploitation has far outstripped the rate of regeneration by natural

means. The result is deforestation and an acute threat to biodiversity, observed everywhere along the

project areas.

According to a study completed in 2004, logging, firewood collection, and mining ranked as the top

three perceptions of the actions most responsible for land degradation (US AID, 2007).



5.2.5



Ecology



Sierra Leone is divided into four major biogeographic regions: the coastal lowlands, the interior plains,

the interior plateau and scattered mountains and hills. The coastal lowlands occupy the south-western

third of the country and do not rise above 75 m above sea level (masl). They are interrupted by

inselbergs and merge into the interior plains, which reach 200 masl in the east and cover 43 percent

of the country’s land surface. The interior plains end in an abrupt escarpment which runs from northwest to south-east and marks the start of the eastern interior plateau (at 300–600 masl), which covers

22 percent of the country. Two massifs top the plateau: the Sankan Biriwa–Tingi Hills (1,709 masl)

and Mount Bintumani (1,945 masl). The latter is the highest peak in West Africa to the west of Mount

Cameroon. Ten major rivers flow roughly parallel in a southwesterly direction across the country to

estuaries and bays on the coast.

Two major biomes characterize the country’s vegetation; the Sudan–Guinea Savanna and the

Guinea–Congo Forests. The Sudan–Guinea Savanna biome occurs in the north and includes

grassland, savanna woodland and Lophira-dominated tree-savanna. A large area of forest-savanna

mosaic stretches over parts of the north and north-east and forms a zone of transition between the

savanna and forest biomes. The Guinea–Congo Forests biome occupies much of the north-east and

south-east. The vegetation typical of this zone is moist evergreen lowland forest with Afromontane

elements at higher altitudes. Local climatic conditions and human activities have, however,

particularly modified the climax forest vegetation in various parts of the country so that large areas are

now covered by secondary regrowth.

Ecoregions

Three ecoregions, as described by the World Wildlife Fund, fall within the project area.

On the coast, where the Pepel Port is to be developed, the Guinean Mangroves, an ecoregion that

stretches from Senegal to Ivory Coast, occur. These mangroves are influenced by a large tidal range

and high inputs of freshwater. The mangroves in this ecoregion contain stands that are more than 25

m in height and extend as far as 160 km inland. As the best developed mangroves in western Africa,

this ecoregion provides important habitat for migratory birds and endangered species such as the

West African manatee and the pygmy hippopotamus. The West African mangroves are relatively



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species poor containing five tree species, compared, for example, to the East African mangroves,

which host up to nine mangrove tree species.

The Guinean forest-savanna mosaic extends through the central part of the project area, which

mainly corresponds to the transport corridor to be used for haul road and railway development. This

ecoregion of West Africa consists of a band of interlaced forest, savanna, and grassland running east

to west and dividing the tropical moist forests near the coast from the West Sudanian savanna of the

interior. Constantly occurring fires keep back the growth of trees in open country. A typical species of

this ecoregion, Lophira laceolata, is a tree that is more resistant to fire. This species is widely

distributed along the project area. The interlacing forest, savanna and grassland habitats are highly

dynamic, and the proportion of forest versus other habitat components has varied greatly over time.

Savannah vegetation covers 35 percent of Sierra Leone and includes forest savannah, mixed tree

savannah and grassland savannah. This ecoregion is known to support large mammals such as

elephant, leopards, hyenas, chimpanzees, baboons and monkeys, although their densities along the

project area are likely to be very low to non-existent.

On the eastern part of the project, on the Sula Mountains, the Guinean Montane Forest ecoregion is

present. This ecoregion consists of high altitude peaks and plateaus that spread across four countries

in the Upper Guinean region of West Africa. The broad range of elevation, coupled with the

underlying geology and anthropogenic activities, have given rise to different plant associations on

several of the mountains. Although details of the number of endemic plants are not fully compiled, 35

plant species are known to be strictly endemic, with several mountains containing their own unique

plant species. Floristic diversity results from a combination of geographic isolation, varied topography

and soils, migration, speciation, climatic factors and anthropogenic activities. Studies of the Loma

Mountains have produced considerable information about the flora, with records for 1,576 species

distributed in 757 genera and 135 families. The fauna is also diverse with close to 15 strictly endemic

vertebrate species, including species found on single mountains. A number of other rare forest

mammals may also occur marginally in the mountains of this ecoregion, including Johnson’s genet

(Genetta johnstoni, DD) and a murid rat (Praomys rostratus). The western chimpanzee (Pan

troglodytes verus, EN) also occurs in this ecoregion, with high densities reported from Mt Loma. The

largest predator in the ecoregion is the leopard (Panthera pardus, EN). Avifaunal diversity is also

high, and a number of rare species occur (Collar and Stuart 1988), including two near-endemic

species, the Sierra Leone prinia (Prinia leontica, VU) and the iris glossy-starling (Coccycolius iris).

The ecoregion is also of importance for endemic amphibians. More than 10 species are believed to

be strictly endemic (WWF database), including Nimbaphrynoides occidentalis, an endemic toad

occurring in savannas on Mount Nimba (Curry-Lindahl 1966 in WWF). In terms of reptiles, the area is

of lower importance, with less than five species of near-endemic reptile being recorded. Several new

species of insects in the family Coleoptera have been reported for both the Loma and the Nimba

Mountains (Villiers 1965 in WWF). It is very likely that all the mountains of this ecoregion contain

single-site endemic invertebrates, although the data are not compiled to prove this.Mining, slash-andburn farming, and man-made fires are the major threats of this ecoregion. Grassland wildfires are

largely human caused, but natural fires due to lightning strikes also occur (Morton 1986 in WWF).



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Current status

Although once a predominant ecosystem in Sierra Leone, the forest now covers only 5 percent of the

land area and consists of evergreen and semi deciduous vegetation. Sierra Leone is one of the most

heavily deforested countries in the region (Barrie, 2002 in Walston, Hayes and Wolstencroft, 2010). A

study of vegetation-cover showed about 5 percent of the country (c. 350,000 ha) to be covered by

closed canopy evergreen forest, occurring mostly in the south-east, 3.6 percent (c. 250,000 ha) by

secondary forest and about 52 percent (c. 3,700,000 ha) by forest regrowth and bush fallow.

Distinctive fringing vegetation and gallery forests occur along the main riverbanks, while coastal

mangroves cover some 286,600 ha (Davies and Palmer, 1989 in Walston, Hayes and Wolstencroft,

2010). It is worth noting that the whole of Sierra Leone below about 09o15’ North was covered with

largely closed canopy forest 20-40m tall with lianas and epiphytes, but little ground cover or grass

(Grubb et al., 1998 in Walston, Hayes and Wolstencroft, 2010).

Moist closed evergreen lowland forests once covered the inland plains of Sierra Leone and across the

mine site though it would have included areas of moist semi-deciduous forest as well, especially in

the medium-altitude areas such as the Tama-Tonkolili Forest Reserve (Grubb et al., 1998 in Walston,

Hayes and Wolstencroft, 2010). However, farmbush, grasslands and scrub now predominate in the

region.

Lowland and submontane forest throughout West Africa has been impacted by development,

resulting in large and potentially threatening declines in the range of many species unique to this

region. The Tonkolili region is no exception, where forest, the natural climax vegetation of most of the

region, is now largely restricted to narrow strips along river valleys and on the steepest slopes, and

sacred groves and community forests (Darbyshire and van der Burgt, 2009).



5.3



Marine



5.3.1 Physical Environment

The Sierra Leone coastline is over 500 km long and includes a number of estuaries and islands

including Banana, Turtle and Sherbro islands. Generally the nearshore profile is relatively steep.

Where the Freetown estuary is located, however it is relatively shallow and rather irregular (Anthonie,

1991).

The Sierra Leone river estuary is a sheltered marine basin receiving waters from several tributaries,

including the Rokel, Seli and Bunce rivers and the Kumrabe Creek (FAO, 1986 and Ramsar, 1999).

The flow of freshwater from these rivers strongly influences the hydrographic conditions of the estuary

as demonstrated by the range of salinity recorded. This reaches a maximum during the wet season

when there is a measurable influence of freshwater extending to the continental shelf (FAO, 1986).

The estuary is bounded to the north and south by a lowland coastal plain, indented by creeks. The

Western Area Peninsular (WAP) (Freetown mountain) rises in the south. At its entrance into the

Atlantic Ocean, the estuary widens to about 11 km and suddenly deepens at its southern shore to

form a natural harbour, the third largest in the world (Ramsar, 1999).



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During the dry season from November to April, currents inside Freetown Estuary are primarily

governed by astronomical tides. Conversely, during the rainy season estuarine circulation is strongly

controlled by the enhanced river run-off currents (Lorax, 2009). The regions tides are semi-diurnal

and tidal range is variable depending on location in the estuary; the maximum tidal range at Freetown

is 2.5m, whilst within the estuary the range is greater at 3 to 4.5m. The highest currents occur in the

entrance to the estuary due to constriction of the flow around the sand banks to the north of the

estuary entrance.

Coastal processes along the Sierra Leone coast are driven by wave energy and tidal currents. The

regional wave climate consists of two long period swells (period = 7 – 16s) and locally generated wind

waves (period < 5s) from the northwest. Wave energy is low to moderate with deep-water heights of

less than 1.2 m occurring for 72 percent of the time. However, between June and October, moderate

to high energy waves (1.5 – 4m) from the south are superimposed on the north-westerly waves

(Anthonie, 1991).



5.3.2 Water and Sediment Quality

Other than at Pepel and Freetown, the lack of industry on the shores of the estuary should mean that

the estuarine waters are free of industrial contamination. However, the deficiency of appropriate

sanitary systems in the coastal and river communities may have led to bacterial contamination and

high nutrient concentrations nearshore, although there is no evidence in the water quality data

collected so far. Strong tides and high run-off volumes result in high turbidity levels in the water

column throughout the estuary.

Basic water quality parameters have been measured over a period of approximately two months

throughout the estuary and further offshore, including the Pepel Port site. Preliminary results,

covering 21 sites and 29 profiles taken between 16 February and 12 March 2010, show that the water

column appeared to be well mixed at most sites with little or no variation in temperature, salinity, pH

or DO with depth. Turbidity generally increased with depth.

Similarly, little information is available regarding the estuary’s sediment quality. Estuarine sediment is

a series of sands, clays and gravels with occasional thin beds of argillaceous limestone, calcareous

grit and additional seems of lignite (Tucker, 1973). As for water contamination of sediment is not

expected and has not been indicated by preliminary sample results that have been collected so far

around Tagrin and in the proposed dredge channel. The only exception to this is in the inter-tidal area

at Pepel Port, where there is evidence of iron ore contamination of estuary / seabed sediments due to

previous port operations.



5.3.3 Coastal and Marine Habitats

Along the northern shelf from Sherbro Island in Sierra Leone to the southern border of Guinea, the

coastline is characterized by extensive mangrove forests, sandy beaches, mudflats and isolated

areas of rocky outcrops (Fisheries and Aquaculture Department, 2010). These habitats serve as

important shelter, feeding and nesting grounds for fish, birds and marine mammals. The northern

stretch of coast, including the Sierra Leone estuary, is influenced by the Canary current, and is the



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most productive zone, with demersal, pelagic and shellfish resources (Fisheries and Aquaculture

Department, 2010).

In addition to providing a highly valuable habitat for marine and terrestrial fauna, mangrove forest also

plays a crucial role in coastal protection and reducing erosion from run-off and coastal processes.

Locally, the mangroves have an important socio-economic role as a source of wood for

firewood/charcoal and as a medium upon which shellfish anchor which provides an important food

and nutrition source.

The mangroves of Sierra Leone occupy almost half of the country’s coastline and cover a total area of

approximately 100,000 ha (FAO, 2007). Mangrove is concentrated in four major areas, one of which

is the Sierra Leone river estuary. As is the case throughout the world, the mangrove forests in Sierra

Leone have been heavily exploited due to rapid population increase and high levels of poverty. It is

estimated that nearly 40 percent of Sierra Leone’s mangroves were cleared between 1980 and 2000.

The high demand for the land and wood coupled with the lack of community participation in the

management of mangrove resources has created a de facto open-access regime. This has resulted in

mangrove cover that consists mainly of low re-growth with few larger trees, especially in the area

around Freetown.

The Freetown shoreline consists of a rocky foreshore, from the upper inter-tidal zone to deeper

subtidal areas offshore. There is an area of rocky habitat in the deeper waters between offshore

Freetown and offshore Murraytown, close to the main shipping channel. This habitat supports a

diverse community of soft corals, hydrozoans, acsidians and sponges. There are no true coral reefs

along the coast mainly due to the intrusion of the cool waters of the Benguela and Canary currents

and the high turbidity of the estuary waters (Ukwe et al. 2006). There are a number of ship wrecks

along the western coastline of Sierra Leone, which act as artificial reef and provide important habitats

for marine species such as soft corals and sponges. There is also reef habitat in shallow areas of

exposed rock.

Seagrasses are important habitat areas that provide transition ecosytems and can be influential as

marine spawning grounds. However, potential seagrass habitats in the estuary mouth were surveyed

and none was found.



5.3.4 Marine fauna

With its high rainfall, Sierra Leone has an extensive system of rivers and swamps. A variety of

mammals, birds and reptiles are found in the water, on rocks and sandy beaches or along the riparian

zone. Rivers that periodically flood and dry have a variety of migratory bird species that nest on the

exposed rocks, sandbanks and mudflats (USAID, 2007).

The Sierra Leone River Estuary is afforded some notoriety for its avifaunal abundance and is

therefore designated as a Ramsar site, under the Convention on Wetlands of International

Importance (the Ramsar convention), to which Sierra Leone is a signatory.



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Turtles are believed to inhabit the coastal waters in and around the estuary mouth1. Five marine turtle

species nest on beaches in Sierra Leone; green turtles, olive ridley, loggerhead, leatherback and

hawksbill. The primary nesting beaches are around the Sherbro and Turtle islands (IUCN, 2010),

which are a significant distance from the project site. Beaches to the north-west of Tagrin point

provide potential turtle nesting sites. However, an initial survey suggests that human presence

already deters the turtles from using these beaches. Therefore, it is believed that the turtles may use

the estuary for foraging and the offshore area as a migration route.

Scientific reports concerning marine mammals’ population dynamics are lacking for Sierra Leone;

however, small cetaceans are sighted frequently in the waters at the mouth of the estuary near

Freetown according to local specialists and observations from marine users2. Marine Mammals

known to inhabit the coastal and estuarine waters of Sierra Leone include cetaceans (for example

Humpback whale, common dolphins and Clymene dolphin) and the sirenean (African manatee). The

threatened humpback dolphin may be present in the mouth of the estuary. However, as it inhabits the

nearshore zone where there is much human activity, it may no longer be present in this area. The

African manatee is believed to inhabit smaller waterways up river, avoiding brackish water and human

presence.

Sierra Leone has abundant fish resources and as a result supports widespread fishing activity

throughout its coastal and inland waters; contributing almost 10 percent of GDP (FAO 2008). This

activity can be broadly classified into three sub-sectors:





Highly mechanized and capitalized industrial fishery,







Developing aquaculture and inland fisheries; and







Low technology but widespread artisanal fishery, which makes up the majority of the fishing in

and around the estuary.



Recent interviews with fishermen in March 2010 operating out of Tagrin confirm that Bonga

(Ethmalosa spp) is the primary fish species for local fishermen within the waters around Tagrin and

Pepel and are available for capture there throughout the year. In addition the ‘Spanish’ (Sphyraena

barracuda) is a prized fish caught offshore in the dry season. The surveys also found that fish known

locally as kutar, snapper, shinenose, bonita fish (March – May), shovelnose, longneck and grab were

landed, with most of these other species taken west of Tagrin Point and outside of the estuary.

Sierra Leone has 23 bird species with global conservation status, including the White-necked

Picathartes, Lesser Flamingo, Damara Tern, Lesser-crested Tern, Avocet, Water Dikkop, Greater

Flamingo, Northern Shoveler Terek Sandpiper, Curvew sandpiper, Great snipe and Rose-ringed

Parakeet. The Sierra Leone river estuary is regarded as one of the four most important sites for

Palaearctic migrants birds in the country as the mud/sand foreshore, intertidal mud and muddy sand

habitats provide the appropriate feeding grounds for most waders and other waterbirds; the estuary is

not only a feeding area but also a roosting area for most waterbirds in the country. A short survey was



1 Aruna, Edward. 2001. Survey of the marine turtle species and an assessment of threats that affect their survival along the

Goderich-Sussex coastline of Sierra Leone (Dissertation submitted to the department of Biological Sciences for the award of

B.Sc, Biological Sciences)

2 A number were observed by ClassDiving and in sittings during the baseline survey in March 2010



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undertaken as part of the preliminary baseline assessment and all eight of the winter wader species

listed on the Ramsar designation being observed.



5.3.5 Protected Areas

The Sierra Leone river estuary was designated a Wetland of International Importance under the

Ramsar convention in 1999. To improve the sustainable management of the Ramsar Site (including

the livelihood promotion at the local community level), the Sierra Leone Ramsar Administrative

Authority proposed the establishment of a Marine Protected Areas as a priority for implementation

(Ramsar, 2008).

The link between functional mangrove ecosystems and associated marine/estuarine ecosystem

health and fisheries production was a primary consideration in establishment of the Sierra Leone

River Estuary Ramsar site.

Pepel Island falls within one of the core areas of the Sierra Leone River Estuary Ramsar site (see

Figure 5-1).



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Figure 5-1 Location of Pepel Island and Tagrin ports within the Ramsar Site



5.4



Population & Demographics



Sierra Leone is one of the world’s poorest countries. Decades of economic decline and about ten

years of civil war have had severe consequences on the economy. Poverty is widespread with more

than 70 percent of the population living below the poverty line. The country ranks last in the Human

Development Index. Despite some economic recovery after the end of armed conflict in 2002, the

country is still considered a fragile state as it faces the challenges of poverty, corruption and

economic mismanagement.

The Republic of Sierra Leone is composed of three provinces: the Northern Province, Southern

province and the Eastern province and one other region called the Western Area.

Sierra Leone has a population of about 6 million comprising of over 20 ethnic groups. The Temne in

the north and the Mende in the South are the largest with each group representing around 30 percent

of the total population. Creole, descendants of freed Jamaican slaves who were settled in the

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Freetown area in the late-18th century, represent around 10 percent of the population. Refugees from

Liberia’s civil war also reside in the country as well as small numbers of Europeans, Lebanese,

Pakistanis and Indians. Muslim is the dominant religion in Sierra Leone followed by indigenous beliefs

systems and Christianity.

The official language of Sierra Leone is English, however regular use is limited to the literate majority,

and native languages of Mende (principal vernacular in the south) and Temne (principal vernacular in

the north) are widely spoken. The Krio language (English-base Creole) and Bengali are also spoken.

The literacy rate (defined as aged 15 and over who can read and write English, Mende, Temne, or

Arabic) is 31.4 percent.

Annual population growth rate is 2.6 percent. The life expectancy is 37 years. The infant mortality rate

is 170/1000 live births, and the under 5 mortality rate is 286/1000. In 2009 the male to female ratio

was around 0.93. About 70 percent of the population is rural and the annual rate of urbanization is

estimated to be around 2.9 percent between 2005 and 2010.



5.4.1 Health Status Summary

A desktop literature review was performed to provide a brief summary of the existing health status in

Sierra Leone, with focus on the Northern Province and project-influenced districts where possible.

The desktop study was carried out in the first quarter of 2010 and involves review of available

literature using internet sources.

In 2007, Sierra Leone ranked as the least developed country in the world (WHO 2009), with an

estimated 53 percent of people living below the international poverty line of US$1.25 per day in 2005

(UNICEF 2008). The country suffered great upheaval during the period of civil war (1991-2002) with

injury, death and displacement amongst the population. There were also consequences for many

areas of Sierra Leonean infrastructure, including the healthcare system. All levels of the system were

affected with displacement of health care professionals and destruction of basic health infrastructure

(WHO 2009).

Health Policy and Initiatives

Various health initiatives, both national, and internationally aided are in progress in Sierra Leone.

Many of these are aimed at tackling the priority health issues. The Sierra Leone National Health

Policy from the Ministry of Health and Sanitation (MoHS) (2002) cites the following as the current

national priority health problems:





Malaria;







Sexually Transmitted Infections (including HIV/AIDS);







Tuberculosis;







Unsatisfactory reproductive health including maternal and neonatal mortality;







Acute respiratory infections;







Childhood immunisable diseases;



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Nutrition-related disease;







Water, food and sanitation-borne disease;







Disability; and







Mental illness.



The WHO develops country cooperation strategies for a number of countries as a means of

intensifying its interventions within those countries. The current WHO Country Cooperation Strategy

for Sierra Leone 2008-2012 (WHO 2009) cites four strategic priorities:





Reduction of the burden of communicable and non-communicable disease with particular focus

on the prevention and control of malaria, reducing HIV/AIDS and tuberculosis and enhancing the

national vaccination programmes to prevent and control vaccine-preventable diseases;







Lowering rates of infant, child and maternal mortality and morbidity along with encouragement of

responsible and healthy sexual and reproductive health behaviour;







Improving access to and quality of health services; and







National health development through cooperation and partnerships.



Life Expectancy

As a nation, the Sierra Leonean life expectancy at birth is currently estimated by WHO at 49.4 years

(WHO 2009); however, in the past decade estimates have been as low as 37 years (WHO 2006). In

2004, the life expectancy in the Tonkolili district was estimated at 47.9 (47.3 for males and 48.6 for

females), slightly below the national estimate and below the average for the Northern Province as a

whole (49.8) (SSL 2004). Life expectancies in Port Loko and Bombali districts were slightly higher

than Tonkolili at 49.0 (males 48.1; females 50.0) and 52.5 (males 51.6; females 53.5) respectively

(SSL 2004). WHO report that the low Sierra Leonean life expectancies are due to the levels of

communicable and non-communicable disease as well as child and maternal mortality rates (WHO

2009). They cite the underlying causes as widespread poverty, limited access to safe drinking water,

poor sanitation, high levels of illiteracy (particularly amongst females), overcrowded living conditions,

poor feeding and hygiene practices and inadequate access to good quality healthcare services (WHO

2009).

Women, Children and Childbirth

At 6.3 per woman, Sierra Leone has one of the highest fertility rates in the world (WHO 2009).

However, maternal mortality rates also rank amongst the highest, with an estimated 2,100 maternal

deaths per 100,000 live births (UNICEF 2008). Contraceptive prevalence is low (5 percent) and

access to good quality care during and after childbirth is lacking, with only 43 percent of births

attended by a skilled professional (UNICEF 2008). In surveys of attitudes toward domestic violence, it

was reported that 85 percent of the population believe a husband to be justified in hitting his wife for

reasons such as burning food, arguing back, or going out without telling him (UNICEF 2008). Female

genital mutilation/cutting (FGM/C), a practice carried out for social reasons which affects the health

and well-being of both women and their babies, is extremely common in Sierra Leone. An estimated



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94 percent of women overall are affected, although rates in rural communities reach 97 percent

(UNICEF 2008).

In general, child health in Sierra Leone is poor. At close to 30 percent, the under-five child mortality

rate is the highest in the world with neonatal deaths representing 20 percent of the total under-five

mortality (WHO 2009). In the Northern Province of Sierra Leone, in which the project is to take place,

infant, child and under-five mortality rates are slightly below the national average (SSL 2004). Malaria,

diarrhoea and pneumonia are the three principal causes of child death, with malnutrition as a

common contributory factor. In 2007 it was estimated that 4,000 children (0-14 years) were living with

HIV in Sierra Leone (UNICEF). Child labour is prevalent; data gathered between 1999 and 2007

estimates that it affects 48 percent of children aged 5 to 14 years (UNICEF 2008). The target for

immunizations in Sierra Leone is 90 percent and some headway has been made in curbing diseases

such as measles (WHO 2009).

Malaria

Malaria is widespread and transmitted year-round in Sierra Leone (WHO 2004). During the past

decade, prevalence of malaria in the general population has at times been greater than 50 percent

(WHO 2009). It is the number one cause of infant mortality and accounts for a large proportion of

outpatient consultations (35 percent) (WHO 2004). In children under five years, malaria was

responsible for between 50-60 percent of all admissions (WHO 2009). Malaria also accounts for 70

percent of the anaemia reported in pregnant women (WHO 2009). Governmental malaria control

programmes and funding are in place, and a joint MoHS/WHO program for the control of malaria was

initiated in 2004. The malaria programs aim to achieve better case management, vector control,

prevention of malaria-in-pregnancy and health promotion but face challenges including changes in

environmental conditions and sales of counterfeit malarial drugs (WHO 2009).

HIV / AIDS

HIV / AIDS is increasing in Sierra Leone, with higher rates in urban areas (2.1 percent) than rural

areas (1.3 percent) (WHO 2009). HIV and AIDS impacts not only those infected, but can also have

knock-on effects in a society. For example, in 2007, an estimated 16,000 children (0-17) had been

orphaned as a result of AIDS, and school attendance amongst that group was almost 20 percent

lower than the general population (UNICEF 2008). Data gathered between 2000 and 2007 suggests

that the level of public understanding about the cause and prevention of AIDS is low; for example only

17 percent of young women (15-24 years old) had comprehensive knowledge of HIV (UNICEF 2008).

Of note is the fact that the prevalence of HIV and AIDS amongst those with tertiary education is three

times greater than those with no education (WHO 2009). In 2007, the Sierra Leone government

introduced the Prevention and Control of HIV and AIDS Act, 2007 covering areas including education

and information, safe practices, testing and access to healthcare, transmission, monitoring and

discrimination.

Other Communicable Disease

Other communicable disease of note in Sierra Leone currently include tuberculosis, leprosy,

neglected tropical diseases (soil transmitted helminthes, onchocerciasis [river blindness] and

lymphatic filariasis, dracunculiasis [guinea worm disease], yaws and schistosomiasis), lassa fever,

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yellow fever and diarrhoeal diseases (WHO 2009). Population movement counts amongst the risk

factors for increased transmission for a good number of these diseases (WHO 2004).

The burden of tuberculosis in Sierra Leone is increasing. Between 2004 and 2007, the number of

registered cases almost doubled, despite a poor case-detection rate of 50 percent (WHO 2009). Also

of concern is the rise in multi-drug resistant tuberculosis (MDR-TB) and prevalence of TB/HIV coinfection. A tuberculosis control program is in place in Sierra Leone; however it faces challenges

related to high default rates, low case-detection rates and the high percentage of patients without

sputum results (WHO 2009).

Onchocerciasis or ‘river blindness’ is a vector-borne disease which has a high infection intensity and

high resultant blindness rate in some parts of northern Sierra Leone. Risk factors for increased risk of

exposure to the infectious agent (Onchocerca volvulus, a filarial worm) include subsistence farming

fishing, bathing and mining (some areas) (WHO 2004).

Yaws disease was effectively eradicated prior to the war, but a recent re-emergence has created the

need for public health intervention (WHO 2009). In the past, this disease has been a problem in

remote communities of Bombali and Port Loko (WHO 2004), and there are currently plans for a yaws

survey in the endemic Bombali region. The survey will be a joint initiative between the Sierra Leone

Ministry of Health and Sanitation (MoHS) and WHO (WHO 2009). Portions of the proposed Phase 1

project are expected to operate in both the Bombali and Port Loko districts.

WHO rate the scale of infection with intestinal helminthiasis in Sierra Leone as ‘enormous’. These

worms cause reduction in vigour, illness, impaired intellectual development and reduced quality of life.

Programs are underway in Sierra Leone to map and better understand the types of soil transmitted

helminthes in the districts (WHO 2009).

Yellow fever has a WHO alert threshold of one case. In 2003 there were 4 confirmed cases in

Tonkolili (WHO 2004).

Schistosomiasis is a public health concern and emerging disease in six districts within Sierra Leone,

one of which is Tonkolili (WHO 2009).

Non-Communicable Diseases

There is a heavy burden of non-communicable disease including malnutrition, mental health issues

and substance abuse, disability and injury in Sierra Leone.

Malnutrition is common, especially amongst women and children. It has many direct health effects

and can also act as a contributory factor, increasing the severity of other diseases. In pregnant

women, maternal malnutrition leads to low birth weight, a causative factor in neonatal death (UNICEF

2008). In Sierra Leone, approximately 25 percent of children are born with a low birth weight, and up

to 30 percent of under fives suffer from moderate to severe underweight (UNICEF 2008).

Substance abuse is a significant problem in Sierra Leone, and the facilities to deal with mental health

issues are lacking (WHO 2009). Surveys suggest that a large proportion of the population use

alcohol, tobacco and drugs (e.g. cannabis, cocaine and heroine) (WHO 2009). A draft mental health

policy has been drawn up; however, the availability of resources to implement it remains a challenge.



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The major causes of disability in Sierra Leone are illness, congenital abnormalities, aging, accidents

(including traffic), and war (SSL 2004). Following the civil war, a sizable number of people live with

amputations (WHO 2009). In 2004, 2.2 percent of people in the Northern Province were classified as

disabled and 6 percent of these had war-related disabilities (SSL 2004). The prevalence of warrelated disability is lowest in the Northern Province of Sierra Leone.

Environmental Health

Environmental health and the provision of safe drinking water are important issues in Sierra Leone. At

present, overall, approximately 46 percent of households drink water from unimproved sources, a

number which rises to 68 percent in rural communities (UNICEF 2008, WHO 2009). Only 30.5 percent

of households dispose of excreta by sanitary means and wastewater is rarely treated before release

(WHO 2009). All of these factors increase the burden of water-borne and diarrheal disease and

impact general health.



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6



PROJECT AREA BASELINE

Baseline Study Techniques



6.1



Conducting baseline studies is an iterative process that builds on data already collected and leads to

more targeted and specific information. The aim is to gain an understanding of the existing conditions

in the project area to enables a good understanding of the sensitivity and function of the environment

prior to the project commencing. For consistency across this project we have standardised the

terminology for the baseline study phases as follows:





Phase 1a: Desktop review and planning for the studies to collate relevant information, review

legislation, identify specialists and prepare a base map for further work;







Phase 1b: Undertake reconnaissance-level field studies to ground-truth the base map

produced, identify habitats of potential conservation importance and to record significant

ecological features in the study area. This phase is termed the Rapid Assessment

Programme (RAP);







Phase 2a: Scoping consultations with key stakeholders and the general public to understand

key biodiversity issues related to local livelihoods and cultural significance;







Phase 2b: Specialist investigations to collect detailed baseline data on species and habitats

within the project area for all relevant seasons;







Phase 3a: detailed targeted study (content driven), and







Phase 3b: detailed in-fill study (coverage driven).



This terminology has been used in each of the following thematic disciplines: air and noise, hydrology,

soil and landscape, ecology, social and community and marine for all the relevant project areas.

All the thematic disciplines, to varying levels of detail depending on sensitivity have been applied to

produce a baseline for each of the project elements i.e. the mine area, the transport corridor, the port

area and the marine and coastal zone.



6.2



Mining Area



6.2.1 Air Quality

A desktop study was conducted that included a review of the available information for the study area

(Phase 1a) and a monitoring campaign was designed (Phase 1b) to assess the background air quality

levels in the study area. The campaign was carried out in February 2010.

Ambient air measurements were conducted with passive sampling monitoring devices (diffusion tubes

installed in the field for a period of 15 days), after which the devices were collected and sent to the



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laboratory for analysis. Diffusion tubes were obtained from Scientifics Laboratory in the UK. The

contaminants monitored were nitrogen dioxide (NO2) and sulphur dioxide (SO2).

The sampling scenario covered 13 positions for the air quality measurements divided between the

mine site, the port site and the transport corridor. The distribution of the sampling locations is shown

in Figure 6-1.

Figure 6-1 Air Quality Monitoring Campaign Measurement Locations



Results obtained from the monitoring campaign were analyzed and compared with relevant

guidelines.

Relevant international standards for environmental air quality include those published by the World

Bank Group (WBG) in the WBG Environmental, Health, and Safety Guidelines (known as the “EHS

Guidelines”), which are used by the WBG and the International Finance Corporation (IFC), as

described in the Pollution Prevention and Abatement Handbook (PPAH) (World Bank Group, IFC,

2007). Ambient air measurements were conducted during a period of 15 days; therefore, results are

not directly comparable with the periods given by legislation. When possible, the larger period (1 year)

with a more restrictive limit has been considered.

Existing air quality at the proposed mining area is expected to be very good, because the area is a

Greenfield site without existing industrial development or crowded populations. Dust is considered to

be the primary air pollutant, generated from vehicle movements on unpaved roads and off-road.



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The monitoring locations are listed in Table 6-1. The results obtained from the laboratory analysis for

NO2 and SO2 (PA1-PA4 locations) are shown in Table 6-2.

Table 6-1 Locations for Air Quality Monitoring Campaign in the Mining Area

Location



Coordinates



Remarks



PA1



29P 201325 991125



In crops that have been burnt down in the hamlet of Little Furia.



PA2



29P 201944 993103



In crops outside Wandugu village.



PA3



29P 207381 996691



At a tree behind the health centre in Kemadugu. Traffic more

frequent (approximately 5-10 cars / day).



PA4



29P 204163 997066



On a drill pad (abandoned). Possibility of drilling activities close to

the location. A small village (Kegbema) was observed at a short

distance.



Table 6-2 Results of Baseline NO2 and SO2 Concentrations on Air in the Mining area

Loc.



PA1



Exposure

time

(hours)

502.25



NO2 Analysis



SO2 Analysis



µg/m³



WHO limit

(µg/m³)



Comments



µg/m³



WHO limit

(µg/m³)



Comments



10.2



40



Encountered on

ground, dirt In

tube, and

discoloured upon

extraction



64.8



1253



Encountered

on ground



(1 year)



(24 hours)



PA2



501.00



5.3



-



14.5



-



PA3



498.25



6.4



-



6.4



-



PA4



498.67



6.2



Spider's web

found



4.8



-



Concentrations of NO2 and SO2 in the mining area were found to be below the levels set by the World

Bank Group (World Bank General Environmental Guidelines, IFC, 2007).

The results for PA1 are not considered reliable, as the tube was encountered on ground and could

have been contaminated by ashes present after the recent burning of the field. The results for PA2

may have been affected by nearby activities related to the creation of a scout road for the future haul

road development to the mine site.

Aside from these two locations, the monitored air quality is good and exhibits low pollutant

concentrations. As expected, the levels correspond to Greenfield values.



3



Target 1 for SO2 limit (WBG)



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6.2.2 Noise

A desktop study was conducted that included a review of the available information for the study area

(Phase 1a) and a monitoring campaign was designed (Phase 1b) to assess the background noise

levels in the study area. The campaign was carried out in February 2010.

The IFC – WBC (International Finance Corporation – World Bank Group) reference levels for ambient

noise expressed in LAeq for residential, institutional and educational receptors is 55 dB(A) during the

daytime (7:00 to 22:00) and 45 dB(A) during the night-time. For industrial areas, the reference level is

70 dB(A) any time of the day or night.

A noise survey was conducted with a Class I hand-held sound level meter and an ISO Tech sound

level calibrator. The sound level meter measured the parameter LAeq, defined as the constant sound

level that, in a given time period, would convey the same sound energy as the actual time-varying Aweighted sound level. Noise measurements were conducted during daytime hours.

The sampling scenario covered 20 locations for noise survey divided between the mine site, the port

site and the transport corridor. The distribution of the sampling locations is shown in Figure 6-2.

Figure 6-2 Noise Monitoring Campaign Measurement Locations



The ambient noise at the mine site might be generated by several naturally occurring sources and

rural human sources: wind through the vegetation, animal and cattle noises, traffic in rural and

populated areas, etc. The measurement locations at the Phase 1 mine site were selected based on

the following criteria: in the project area outside the populated areas; and where measurements could

be taken without interference from traffic or industrial noise.

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Results of the Noise Survey are listed in Table 6-3.

Table 6-3 Noise Monitoring Campaign in the Mining Area

Geographical

Location



LAeq

(dB(A))



Measurement Date



Meteorological Data



Remarks



Date



Hour



T (ºC)



Wind speed

(km/h)



40.0



14/02 2010



13:00



37.2



Light wind 1.6

– 2.4



Birds singing



29 P 201260

991116



44.8



14/02 2010



13:20



38



Light wind 1.6

– 2.4



Birds singing



N3



29 P 202017

993168 E



34.6



14/02 2010



14:00



35



3



-



N4



29 P 202067

993263



48.2



14/02 2010



14:25



35



Calm, almost

no wind



Wildlife

noise

intense



N5



29 P 204163

997066



31.7



14/02 2010



15:50



37



Calm, almost

no wind



Some birds

singing



ID



Coordinates



N1



29 P 201282

991031



N2



All measurements were conducted during the daytime; therefore, the results listed in the table above

are below the referenced Ambient Noise levels of 55 dB (A).

Results from measurements taken at locations N1, N2 and N4 are higher than at other locations, but

the field observations confirmed that they correspond to natural environmental noise.



6.2.3 Archeology & Cultural Heritage

The significance of sites of archaeological value (in-situ) and cultural heritage factors has been

initially screened by discussion with in-country ESHIA practitioners. The preliminary advice indicated

that it was likely there would be limited and in some areas negligible sensitivity. Development of an

understanding of the importance of marine and terrestrial archaeology, burial sites, Society Bush

areas and other important heritage factors has already been included in a number of baseline studies.

Integration of this information with a specialist assessment into a review of possible project impacts is

still underway.



6.2.4 Ecology & Biodiversity

Vegetation

The area encompassing the Simbili deposit has been surveyed using Phase 1a, 1b and 2b study

techniques during the wet and dry seasons in September and November 2009 and in February /

March 2010. The area is situated in a tropical moist broadleaf forest zone, but is also close to a

tropical grassland savannah zone and therefore displays some characteristics of each. The summit of

Simbili is host to degraded forest, but the sub-ridge to the north of the summit is largely covered by

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grass with scattered tree species typical of the natural wooded grassland habitat. All the grasslands

on Simbili are much disturbed with secondary grassland species dominant and with evidence of

recent farming. Heavily degraded forest patches are present on the western slope of Simbili, although

generally the species found there were characteristic of secondary forest. Only one species of

concern was identified among these patches, the tree species Cryptosepalum tetraphyllum (IUCN:

Vulnerable, VU). (See Appendix 8 for Preliminary Report on Phase 3 Vegetation Fieldwork - Prepared

by SRK, Appendix 9 for Tonkolili Vegetation Survey and Inventory Report - Final - Prepared by

Herbarium, Royal Botanic Gardens, Kew and Appendix 10 for Report on the Vegetation Map of the

Tonkolili Project Area).

Terrestrial Fauna

A Phase 1b rapid assessment of eight sites within the mining area was conducted in March 2010

during the dry season. The natural forest cover of the mining area is heavily fragmented and does not

appear to support viable populations of large mammals, with the exception of Western Chimpanzees

that may be present in the forest patches to the south of the Farangbaia Forest Reserve. The existing

habitats within the mining area support a range of bird species, including forest and non-forest

species of conservation concern. (see Appendix 11 for Summary of Report, Phase 1 Study of

Terrestrial Fauna at Tonkolili Mine Site, Sierra Leone prepared by the Wildlife Conservation Society)

Aquatic Ecosystems

A Phase 1b rapid assessment of two sites located in the vicinity of the southern boundary of the

exploration licence area (the Tonkolili and Matoine Rivers) was undertaken in March 2010 during the

dry season. Both sites have good in-stream habitat, however substantial clearing of riparian

vegetation had occurred along the right-hand bank at the Matoine River site and there was evidence

of in-stream artisanal gold mining. The waters at the sites surveyed generally had low conductivity

and were slightly acidic, which means the waters have little or no buffering capacity against changes

to pH from any acid inputs (For further information see Appendix 12 for Rapid Assessment of Aquatic

Environments for the Tonkolili Project prepared by SRK).



6.2.5 Hydrology and Hydrogeology

Phase 1 mining activities will focus on the hematite cap of the Simbili deposit which straddles the two

surface water catchments of the Tonkolili and Mawuru Rivers.

The Tonkolili catchment drains an area of approximately 165 km2 and flows for approximately 48 km

before it joins the larger Rokel River. The Tonkolili River flows throughout the year; minimum and

maximum flow rates measured at 5 gauging stations in the vicinity of the mine and eastern transport

corridor areas and corresponding to the dry and wet season of 2009 are given in Table 6-4 below. A

figure of the gauging stations is given in Appendix 13.

During the dry season, river flow rates represent the base flow component contributed by

groundwater.



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Table 6-4 Tonkolili River Flow Rates

Tonkolili River Flow Rate

3



-1



(m .sec )



Apr-09



Sep-09



RFT001



0.22



2.1



RFT002



0.95



3.2



RFT003



0.56



3.9



RFT004



0.95



5.57



RFT005



1.6



11.3



The Mawuru catchment drains an area of approximately 147 km2 as it flows south along the eastern

side of the Simbili deposit before joining the Pampana River. Maximum and minimum river flow

measurements at two gauging stations in the mine vicinity are given in Table 6-5 below. A figure of

the gauging stations is given in Appendix 13. The Mawuru River flows year-round suggesting the dry

season flows measured in April 2009 represents base flow contributed by groundwater discharge (see

Table 6-5).

Table 6-5 Mawuru River Flow Rates

Mawuru River Flow Rate

3



-1



(m .sec )



Apr-09



Sep-09



RFM001



0.979



3.48



RFM002



0.86



6.25*



Field measured water quality parameters indicate relatively stable chemical conditions with little

variation between the two catchments, and also between the wet and dry season. Electrical

conductivity (EC) of Tonkolili River and Mawuru River water was generally below 20 µS.cm-1 in both

the wet and dry season. pH was found to remain neutral, ranging from 6.2 to 7.1 pH units with slightly

lower pH values generally observed during the dry season.

Water quality samples were collected for laboratory analysis in the UK during the dry season, March

2010. In both rivers, the concentrations of iron ranged from 0.49 mg.L-1 to 1.02 mg.L-1 exceeding the

UK drinking water guideline value of 0.2 mg.L-1. Elevated concentrations of iron are suspected to be

associated with the banded iron formation (BIF) deposits and iron rich soils.

A TPH (C24-C40) concentration of 0.012 mg.L-1 was reported for a sample collected from the Mawuru

River. The presence of a heavy TPH fraction suggests a degree of anthropogenic contamination

most likely from a diesel, oil or grease source. However, the results from single sampling event



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carried out to date are not sufficient basis upon which to draw any conclusions at this time. Further

sampling has taken place and a regular monitoring programme is being implemented. Results of the

most recent sampling are awaited.

Numerous springs flowing from the upper slopes of the mountains flanking the Tonkolili and Mawuru

Rivers contribute base flow throughout the year. The flow rate of five of these spring fed streams which

discharge into the Tonkolili River have been monitored by SRK and AML using V-notch weirs for a period

of 12 months commencing in April 2009. Flow rates vary between locations and are likely to be heavily

controlled by the local geology and aquifer characteristics. A distinct pattern of peak and low flow periods

are observed in the spring hydrographs and generally mimic the rainfall records with stable, low flow

conditions existing between February and June/July at which time flows are between 0.1 and 4 L.s-1. Flow

rates increase in response to rainfall recharge during August and September to maximums of 8 to 24 L.s-1,

after which time, rates steadily decline.

Several spring-fed streams flow from the eastern flanks of Simbili discharging to the Mawuru River. Spring

flow and water quality has been measured at one location, since April 2009. The spring flow during the wet

season exceeded the capacity of the V-notch and readings could not be taken throughout August and

September. Measure flow rates ranged from 0.5 L.s-1 during the dry season to 7.7 L.s-1 during the wet



season; however maximum flow rates during August and September are likely to be much higher.

The EC value of spring water at both catchments ranged from <10 µS.cm-1 to1210 µS.cm-1. pH values

were between 6.0 and 7.42 while redox potential indicated consistently oxidizing conditions. The

chemical composition of water discharging from springs was found to contain slightly higher

concentrations of certain dissolved metals. Arsenic (0.057 mg.L-1) and selenium (0.236 mg.L-1) were

above their relevant UK drinking water guideline values while cadmium (0.0017 mg.L-1) and lead

(0.021 mg.L-1) existed at higher concentrations than reported for the Tonkolili River. It is likely that the

hematite cap overlying the BIF provides a source of various metal species which are leached by

groundwater and discharged through these springs, before being diluted in the main river systems.

The maintenance of surface water flows year round is important to both local inhabitants and the

natural environment (groundwater abstraction becomes more difficult during the dry season when

groundwater levels gradually decline). East and south east of Simbili within the Mawuru catchment,

no exploitation of groundwater has been observed and there is apparent total reliance on surface

water from Mawuru tributary streams/ springs or the Mawuru itself in some cases (at the peak of the

dry season) to meet village water demands.

Within the mine area the upper surface of the bedrock (Tonkolili Group) is thought to have weathered

to a depth of between 40 m and 60 m. The uppermost 10-20 m is completely weathered to a laterite

with rock becoming progressively fresher with depth. The weathered zone is thickest on the ridge

tops and thins towards the valley bottoms. The ridge tops are sometimes characterised by hardpan

(duricrust). The flanks of the hills are characterised by weathered material as well as transported

boulders and soils (colluvium). Alluvial deposits of sands, silts, clays and conglomerate have been

deposited in the Tonkolili and Mawuru valley bottoms, but it is not yet known how thick these deposits

are.

SRK (2010) proposed the following conceptual model for groundwater flow in the mine area:



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Recharge percolates through the laterite or duricrust into the weathered cap from

where the majority of the groundwater flows laterally, at the contact with fresh

rock, towards the ridge flanks and discharges through springs to the surface

water network. The component of groundwater flow from the weathered cap to

the colluvium is unknown but is considered low given the generally low

permeability of the colluvium, Similarly, it is thought that groundwater flow from

the weathered cap to the underlying BIF and amphibolite, which appears to be

generally competent, is also low.

The laterite / duricrust may act like a sponge, storing recharge and releasing it more slowly to the

underlying aquifer as well as buffering through-flow to springs. This is an important process for

groundwater-surface water interactions and would be seen on the Tonkolili and Mawuru river flow

hydrographs as a tailing effect.

Water levels in the deposit area monitoring wells are generally within the weathered cap. Monitoring

borehole GWM11 on the neighbouring Marampon deposit is artesian (flowing at 0.2-0.3 L.s-1),

possibly due to intersection of deeper fracture flow, which suggest local flow systems and high aquifer

heterogeneity that may also exist within the Simbili deposit.

In the lower valleys and in the wider study area it is likely that colluvial and alluvial sediments act as

aquifers of unproven thickness which discharge to the Tonkolili or Mawuru Rivers throughout the year.

A deeper, fractured basement aquifer may be present throughout the study area, and if present would

correspond with highly fractured, regional features (lineaments) mapped within the Precambrian

basement rock (Akiwumi, 1988). The existence of these lineaments and the nature of groundwater

flow in the basement rock are poorly understood. Fracturing in the upper strata was noted to reduce

to zero within 30-40 m of the surface in the valley that now contains the Bumbuna Hydroelectric Dam.

Water levels have been monitored at weekly intervals since May 2009 at eight community

groundwater wells which exploit the alluvial and colluvial aquifer. Depth to water ranges from 3.0 to

9.5 m below ground level (m bGL) during the dry season, rising to 1.0 to 6.5 m bGL during the wet

season. The highest wet season water levels and the lowest dry season water levels were both

measured in the lower Tonkolili catchment. The hydrograph response suggests that rainfall recharge

infiltrates quickly to the aquifer with very little delay between the onset of the wet season and the

initial rise in the water table.

Groundwater chemistry is expected to be fairly consistent across the study area, with the exception of

groundwater within the weathered cap overlying the BIF. In general very little water-rock interaction is

anticipated given the dominance of largely non-reactive basement rocks such as granites, schists,

and greenstones.

The conceptual understanding of groundwater occurrence and flow in the lower valleys and in the

wider study area is limited.



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6.2.6 Soils & Land-use

Soils data have been derived from drilling and interpretation of superficial material. At most drill sites

the top 2 m of material was cleared during preparation of the drill pad and therefore the baseline soil

dataset is incomplete. The uppermost surficial material is dependent on the underlying geology. For

the iron-ore protolith (quartz and silicate itabirites) a ferruginous hardcap or canga profile has

developed, consisting of predominantly angular to subrounded fragments of hematite and pisoliths

partially replaced by goethite and cemented by clays, reprecipitated silica and iron oxide. A simple

laterite profile has developed over footwall or hangingwall acid to intermediate rocks, typically red in

colour, comprising massive and colloform goethite-hematite, with common iron-oxide fragments

cemented by clays, reprecipitated silica and iron oxides. (See Appendix 14 Tonkolili Soils and Laterite

Profile - Prepared by SRK)

Preliminary qualitative information on land-use has been acquired during Phase 1b and Phase 2b

biodiversity studies (flora, fauna and freshwater) in the mining area. While some remaining forest

patches including Society Bush still exist in a mosaic land-use, in general human presence, slash and

burn farming techniques, road and communal ground clearance (including clearance by AML) has

driven a change in the area from forest and patches of grassland on the summits to primarily a

mixture of agriculture and fallow land.

Agriculture comprises a wide range of crops on hill slopes and monocultures of rice or peanuts on

periodically inundated land in the valley bottoms. Non-location specific bushmeat hunting grounds

also occur.



6.2.7 Geology & Geomorphology

The Tonkolili ore body is situated in the greenstone belts of the Sula Mountains. The license area is

dominated by rock units of the Sula Group, a greenstone belt that forms part of the Kambui Super

Group. The Sula Group is comprised of two primary formations, the Sonfon and Tonkolili formations.

The upper sequence of the Tonkolili Formation hosts the primary magnetite resource; however Phase

1 of the project is focused on the overlying hematite / goethite deposits. The iron content of the

hematite / goethite ore can be increased to exportable grades through beneficiation. The

geomorphology of the license area is characterised by smooth hill tops (that rise from 200 to 800 m in

elevation) and plateaus that trend in a north-easterly direction and are deeply incised by the Tonkolili

River drainage system which flows to the south east. (For further details see Appendix 15 for

Geological and Geomorphologic Baseline Study - Prepared by SRK)



6.2.8 Socio-Economic & Human Health

The socio-economic and human health baseline of these areas has been characterised using a range

of survey techniques at a coarse level and the results have been aggregated and described in a

generalised manner in the regional overview. Although further baseline description is underway, it is

assumed for the time being that the generalized description is an adequate characterization of the



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communities in the mine area and the baseline is not expected to be significantly different from the

regional overview.

The baseline data collected from the field studies conducted in March 2010 for other relevant

disciplines will also be considered for the health impact assessment. Water sampling program

conducted in February identified elevated heavy metals concentrations (greater than WHO

guidelines) for arsenic, barium, lead and selenium in samples from some wells in the mine area

(Section 6.2.5). The results for increased concentrations of arsenic, barium, lead and selenium

occurred in two samples (a groundwater well, and an artesian spring). The third groundwater sample

was identified to well contain barium, lead, and selenium exceedances. These results may be an

indication of elevated, naturally occurring metals in the area’s geology which may pose a human

health impact. Further assessment of the water chemistry in the mine pits and catchment areas is

required before the potential health impact can be defined. The chemical results of soil, vegetation,

fish tissue, and surface and groundwater samples collected during additional site visits will be studied

and potential concerns highlighted in the next phase of works (see Section 8).



6.3



Transport Corridor



6.3.1 Air Quality

A short-term air quality monitoring campaign was carried out between the 13th and the 17th of

February, 2010, as described in Section 6.2.1. The distribution of the sampling locations is shown in

Figure 6-1.

During the field visits, industrial sources of air contamination were not observed. The identified

contamination sources are the uncontrolled fires used in populated areas for cooking, waste burning

or vegetation clearance for agricultural purposes; the diesel generators (found only at major

settlements) used to supply electricity and the traffic.

Passive sampling diffusion tubes were used for the measurement of sulphur dioxide (SO2) and

nitrogen dioxide (NO2) in the transport corridor area and its surroundings. The sampling locations and

the diffusion tubes analysis results are listed below in Table 6-6and Table 6-7, respectively.

Table 6-6 Locations for the Air Quality Monitoring Campaign along the Transport Corridor

Location



Coordinates



Remarks



PA5



29P 196599 990523



On the proposed haul road alignment. In crops behind the health

centre of Basaia, a medium-sized village.



PA6



29P 171639 970333



Close to the transport corridor. Bashia Village, near Makeni, in

crops on the side of the road Magburaka – Makeni, northwest of

Magburaka. Near unpaved road to hamlet Makenilol.



PA7



28P 774644 967839



On rail alignment. Close to the village of Furedugu on crops on the

road to Petifu.



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Location



Coordinates



Remarks



PA8



28P 751757965580



Transport corridor. In a burned field near a small house on the

side of the Rogbere – Port Loko road.



PA9



28P 733170 970048



Transport corridor. On tall grass growing on top of the existing

railway. The surrounding grasses had been burned.



Table 6-7 Results of Baseline NO2 and SO2 Concentrations on Air in the Transport Corridor

Loc.



Exposure

time

(hours)



NO2 Analysis

µg/m³



WHO limit

(µg/m³)



SO2 Analysis

Comments



µg/m³



WHO limit

(µg/m³)



Comments



PA5



481.92



6.1



40



6.1



1254



PA6



478.25



6.0



(1 year)



4.4



(24 hours)



PA7



-



-



Missing



-



Missing



PA8



-



-



Missing



-



Missing



PA9



-



-



Missing



-



Missing



The diffusion tubes that were still present (PA5 and PA6) were collected, the chain of custody forms

were completed and the tubes were sent to the Scientifics Laboratory for analysis. Based on the

results from the analysis, air quality was found to be good.



6.3.2 Noise

A short-term noise monitoring campaign was carried out between the 13th and the 17th of February,

2010, as described in Section 6.2.2. The distribution of the sampling locations is shown in Figure 6-2.

Portions of the study area used to measure baseline sound pressure levels along the Phase 1

transport corridor are listed in Table 6-8.

Table 6-8 Noise Monitoring Campaign in the Transport Corridor

Geographical Location

ID



LAeq

(dB(A))



Measurement Date



Coordinates



Date



29 P 198355



15/02



Hour



Meteorological Data

T (ºC)



Remarks



Wind speed

(km/h)



Some wildlife noises

N6



4



987256



33.1



2010



10:00



29.4



No wind



Proximity to a road; no

vehicles / persons

observed



Target 1 for SO2 limit (WBG)



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Geographical Location

ID



LAeq

(dB(A))



Coordinates



N7



29 P 197146

987988



Measurement Date

Date



36.7



15/02

2010



Meteorological Data



Remarks



Hour



T (ºC)



Wind speed

(km/h)



11:40



34.0



Very light

wind



Crops



2–5



Crops very close to

Basaia Village



N8



29 P 196599

990523



34.8



15/02 2010



12:30



36.3



N9



29 P 171639

970333



43.6



15/02 2010



17:30



34.2



N10



28 P 795524

975669



39.4



13/02 2010



16:15



34.1



6 – 10



Measurement could

have been affected by

wind in nearby grasses



N11



28 P 794702

975569



33.1



13/02 2010



17:00



34.1



3–5



Birds singing



N12



28 P 752490

965133



41.4



16/02 2010



10:30



31.6



Wind

average

speed 3.6

km/h



Old quarry site,

surrounded by

vegetation; wildlife

noise was intense



N13



28 P 751743

965490



24.6



16/02 2010



10:00



31.2



No wind



On an unpaved road,

clear of vegetation. No

traffic



N14



28 P 733170

970048



37.5



16/02 2010



15:00



37.6



Wind speed

approx. 3.5

km/h



Birds singing



Measurement could

Strong winds

have been affected by

7 -15

wind in nearby grasses



Results at locations N9, N10 and N12 are higher than the results at other locations. In the cases of

points N10 and N12, field observations confirmed that the measurements correspond to natural

environmental noise; however, in case of location N9, the wind speed reached 15 km/h. The noise

level measured at N9 was likely due to wind through nearby grasses. For this reason, the result for

N9 is rejected as an anomaly in the present noise baseline analysis.



6.3.3 Archeology & Cultural Heritage

The significance of sites of archaeological value (in-situ) and cultural heritage factors has been

initially screened by discussion with in-country ESHIA practitioners. The preliminary advice indicated

that it was likely there would be limited and in some areas negligible sensitivity. Development of an

understanding of the importance of marine and terrestrial archaeology, burial sites, Society Bush

areas and other important heritage factors has already been included in a number of baseline studies.

Integration of this information with a specialist assessment into a review of possible project impacts is

still underway.



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6.3.4 Ecology & Biodiversity

Vegetation

A Phase 2b assessment was undertaken on the first 20 km of the haul road route, from the mine site

to Rokel River at the end of the wet season in November 2009 and complemented by a new survey in

March 2010, during the dry season. The transport corridor further west (proposed haul road route and

existing rail line up to the Pepel Port facility) was surveyed using Phase 1b techniques in March 2010

(dry season). In the vicinity of the mine site, remnants of original forest vegetation, riverine forest,

secondary forest, river channel communities and various secondary habitats are found. West of Rokel

River, vegetation is largely characterized by a patchwork of inland valley swamps, secondary forest,

farmbush, plantations, agricultural land, wild oil palm, grassland vegetation and inselbergs.

Mangroves, freshwater ecosystems and agroforestry plantations are found in the Port Loko area.

Four habitats of conservation concern are present in the transport corridor. Riverine forest and river

channel communities that have not been already highly disturbed are classified as of high

conservation concern. Inland valley swamps and mangroves that have not been highly disturbed are

classified as being of medium conservation concern. Species of conservation concern have been

found in all these habitats of conservation concern, with the exception of mangroves. The presence of

these conservation species indicates that the vegetation in these habitats is also likely to be relatively

undisturbed and these habitats may also represent the last remaining examples of the natural climax

vegetation in the study area. Although mangroves usually do not contain species of conservation

concern and do not have high plant species richness, they are of considerable ecological value in

terms of their structure and function, and are likely to harbour a wide variety of avifaunal and other

animal assemblages.

Terrestrial Fauna

A Phase 1b assessment of 16 sites along the transport corridor was conducted during the dry season.

As with the mining area, the natural forest cover is heavily fragmented, however, the continuous

riparian forests do provide an important habitat for species that require more extensive habitat areas

(such as large mammals). A diverse range of bird species exist within the remaining forest fragments,

including species of conservation concern. The Port Loko Strict Nature Reserve, located to the north

of the transport corridor does support small populations of two globally threatened mammals (the

Western Chimpanzee and Western Pied Colobus). Western Chimpanzee Populations are also found

in a forested area near the Lunsar Interchange.

Aquatic Ecosystems

The lowland areas are characterised by springs and small streams, which, based on Phase 1b

surveys (March 2010) at two freshwater swamp areas around Pepel, are low to mid quality aquatic

habitats, due to highly disturbed riparian vegetation and limited in-stream habitat types. In contrast,

the aquatic habitats of the rivers surveyed are generally in good condition, with low turbidity, intact

riparian vegetation and a range of in-stream habitat types. In particular, high quality aquatic habitats

were identified along the Port Loko and Rokel Rivers.



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Whilst no physical sampling was conducted, the Phase 1b literature review identified four freshwater

fish species of conservation interest (one critically endangered species (Pristis microdon) and three

endemic species (Leptocypris taiaensis, Marcusenius meronai, and Prolabeo batesi) that may be

present in the aquatic environments along the transport corridor.



6.3.5 Hydrology & Hydrogeology

The transport corridor covers an approximate 200km linear section cross-cutting the country in a roughly

east-west direction. The corridor crosses approximately 14 tributary catchments of the Pampana (also

known as the Jong) and Rokel (also known as the Seli) river basins. The more significant tributaries in the

project area include the Little Scaries, Bankasoka, Mabole, Pampana and Tonkolili Rivers. The upper

courses of those rivers commencing in the Sula Mountains, and the interior plateaux region generally, are

shallow during the long dry season, while the lower courses remain fuller and deeper presumably due to

progressive influx of baseflow. The interior planes are subject to flooding during the wet season due to the

relatively subdued relief of these areas. In the costal swamp area, rivers are affected by a tidal range of 2

to 3.5 m and experience severe flooding during the wet season.

The transport corridor commences at the mine-site in the Sula Mountains and loosely follows the Tonkolili

River to its confluence with the Rokel, River. Flow in the Rokel River is controlled by the release of water

from the Bumbuna hydroelectric dam, located approximately 11 km upstream from the confluence with the

Tonkolili River. After crossing north over the Rokel River, the corridor loosely follows the drainage divide

between the Rokel River to the south and the Mabole River to the north. Between the Rokel River crossing

and Makeni, the corridor runs for approximately 30 km through an undulating topography of the interior

plains. Water quality of the Tonkolili and Rokel Rivers in this region are typically fresh with neutral to

slightly acidic pH. The Mabole River flows north east away from the transport corridor where it discharges

to the Little Scarcies River.

From Makeni to Lunsar the corridor runs for 55 km through flatter topography where the major rivers,

Mabole to the north and Rokel to the south meander through areas of low-lying swamp land. Many of the

minor rivers crossing the corridor run northwards towards either the Mabole River or the Bankasoka River.

During the dry season, most of the minor tributaries to the Mabole, Bankasoka and Rokel Rivers are dry

with some of the larger tributaries containing either stagnant pools of water or very low flow. The Tabai and

Bankasoka rivers (where crossed by the existing road) contained stagnant pools of water during February

-1

2010 characterized by low EC (19 to 22 µS.cm ) and slightly acidic pH (5.76 to 6.09 pH units).



From Lunsar to Port Loko the landscape is characterised by low topographic relief and wetland areas.

The corridor runs along the catchment boundary between the Bankasoka and Rokel Rivers. A higher

occurrence of small ephemeral streams is noted in this area. On reaching Port Loko, the route crosses

north over the Bankasoka River (Port Loko Creek) which is noted to have a high flow all year round. Water

-1

quality measurements taken at this location indicated the water to be fresh with an EC value of 22 µS.cm ,

pH of 6.64.

From Port Loko to Pepel Island, the topographic relief is minimal and streams are inter-spaced with

marshes and wetlands. This subtle change in topography and vegetation cover marks the progression into

the coastal swamp and estuarine area with islands and sand bars. The corridor continues to follow the



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north-south catchment divide between the Little Scarcies River to the north, which becomes large as it

enters tidally controlled water, and Bankasoka River (Port Loko Creek) to the south. Very few flowing rivers

were observed in close proximity to the corridor during the dry season (February 2010).



The hydrogeological conditions along the transport corridor vary as the corridor crosses several of the

major geological units present in Sierra Leone. However, the hydrogeology can be divided broadly

into two main zones:

1. Basement outcrop - a weathered profile of thin Tertiary and/or Quaternary alluvial sediments

are likely to form an upper, unconfined aquifer unit. Records indicate that the basement rock

is, on average, 20 m bGL with the depth to water recorded at around 10 m bGL. The extent of

weathering and the depth to basement will be variable across the corridor area and will be

largely controlled by topography and basement geology. The majority of the transport corridor

between the mine site and Port Loko is expected to encounter this conceptual hydrogeological

setting;



2. Coastal sediments - The coastal sediments of the Bullom Group forms a belt along the entire

length of Sierra Leone shown to reach at least 60 m thick, generally comprising layers of

clays and sands. The sand layers represent either unconfined or confined freshwater

aquifers. Groundwater flow is controlled by surface topography. Groundwater discharges

either to swamp areas, freshwater streams or directly to the sea.

Within the basement outcrop zone, water levels are likely to fluctuate significantly between wet and dry

season as rainfall infiltration provides annual recharge. Groundwater flow is expected to be controlled by a

combination of surface topography and basement elevation, but will predominantly flow towards the major

rivers draining the catchments.

Aquifer parameters are largely unknown for this region. Water quality is generally fresh with EC ranging

from 100 to 200 µS.cm-1 and pH from 5.9 to 6.8 pH units. This aquifer has been observed to be widely

exploited by local communities who use hand dug wells to access a potable groundwater supply.

Within the coastal sediments zone which occupies the remaining western section of the corridor from

Port Loko to Pepel., the sediments of the Bullom Group comprises gravels, grits, sands and clays of

lacustrine, estuarine, deltaic and marine origin. This unit forms a coastal belt along the entire length of

Sierra Leone and is likely to be encountered along the corridor at some point west of Port Loko.

The Bullom Group overlies the basement rocks of the Kasila Series and has been shown to be at least

60 m thick. The basement rocks outcrop in a few places in the estuaries of the Little Scarcies and Great

Scarcies rivers and it is probable that the sediments are comparatively shallow throughout the greater part

of this area. The sediments in the northern section of the belt consist of horizontally layered, cemented grits

and sands, and recent river sands and silts. In this section of the belt, light to dark bluish-grey clays are

overlain by brown, red or magenta, angular and poorly graded sands. The sandy layers of the Bullom

Group represent either unconfined or confined freshwater aquifers. Rainfall recharge to the unconfined

water table results in large annual fluctuations in the water levels which closely follow topography.

Groundwater flow is controlled by topography with groundwater flow from higher to lower ground where

groundwater discharges either to swamp areas, freshwater streams or directly to the sea. Aquifer

properties are not well understood, however tests conducted in the Bullom Group suggest a hydraulic



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-1



conductivity value of 5 x 10-4 m.s for the sand units. Groundwater is extremely fresh (< 100 µS.cm-1) even

in close proximity to the coast line and is generally slightly acidic with an average pH of 5.1. Groundwater

of the Bullom Group is extensively used as a potable supply to local communities and is also exploited by

the national water supply company SALWACO on the Tagrin peninsula.



6.3.6 Soils & Land-use

To date, no baseline studies to characterise the physio-chemical properties of soils have been

undertaken in the transport corridor. Limited geotechnical investigation works including auguring and

trial pitting are currently being carried out along the transport corridor and some drilling is proposed at

potential river crossings. This work will allow development of soils descriptions and the Sierra Leone

Agricultural department have been approached with regard to providing input based on their past and

ongoing work as well as potential photo-interpretation of recent project imagery.

Preliminary qualitative information on land-use has been acquired during Phase 1b biodiversity

studies (flora, fauna and freshwater) in the transport corridor. While some undisturbed habitats remain

(e.g. remnant riverine primary forest), a significant proportion of land in the transport corridor is now

used for subsistence agriculture, charcoal production and settlements. Non-location specific

harvesting of medicinal plants and bushmeat hunting also occurs.



6.3.7 Geology & Geomorphology

Limited project-specific geotechnical drilling is currently being undertaken along the rail alignment

within the transport corridor and reports will be available after presentation of this ESHIA document.



6.3.8 Socio-Economic & Human Health

The socio-economic and human health baseline of these areas have been characterised using a

range of survey techniques at a coarse level and the results have been aggregated and described in

a generalised manner in the Regional Setting chapter, Section 5.4. Although further baseline

description is underway, it is assumed for the time being that the generalised description is an

adequate characterization of the communities along the transport corridor and the baseline is not

expected to be significantly different from the regional overview. The chemical results of soil,

vegetation, fish tissue, surface water and groundwater samples collected during site visits will be

studied and potential concerns highlighted in the next phase of works (see Section 8 for more

information on the next stage of work).



6.4



Port Facilities



6.4.1 Air Quality

Pepel Port is currently not in use. The large majority of remaining plant and facilities at the time of the

review were either in an abandoned state and/or disrepair. Preliminary enabling works associated

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with preparation for the refurbishment and re-engineering of the facilities is planned to commence in

mid 2010. Potential sources of air emissions identified in this area are vehicle traffic (exhaust

emissions and dust generated on unpaved roads) and fires caused by the population for different

uses (cooking, waste burning, etc.).

During the air monitoring campaign, described in Section 6.2.1, passive sampling tubes were installed

to monitor nitrogen dioxide (NO2) and sulphur dioxide (SO2). The sampling locations at Pepel Port,

shown in Figure 6-1 are listed in Table 6-9. The pollutant concentrations of NO2 and SO2 obtained

from the laboratory analysis are listed in Table 6-10.

Table 6-9 Locations for Air Quality Monitoring Campaign at Pepel Port

Location



Coordinates



Remarks



PA10



28P 713986 948893



Pepel Port. On a column of an abandoned building facing the sea.



PA11



28P 713608 948933



Pepel Port. At the meteorological Station.



PA12



28P 714432 949659



Pepel Port. In crops by a blue inhabited house on the seafront at

the main settlement on the island.



PA13



28P 713850 950828



Pepel Port. On the roadside from the Road to Pepel in a cleared

area between the palm trees.



Table 6-10 Results of Baseline Air Quality Monitoring Campaign at Pepel Port

Loc.



PA10



Exposure

time

(hours)



458.58



NO2 Analysis



SO2 Analysis



µg.m-³



WHO

limit

(µg.m-³)



Comments



µg.m-³



WHO limit

(µg.m-³)



Comments



4.2



40



Spider found

(web removed

from tube before

dispatch)



6.5



1255



-



(1 year)



(24 hours)



PA11



458.33



3.7



-



5.9



-



PA12



457.00



5.4



Spider found

(web removed

from tube before

dispatch)



8.1



-



PA13



457.33



3.1



-



6.8



-



5



Target 1 for SO2 limit (WBG)



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The observed baseline atmosphere pollutant concentrations of NO2 and SO2 in the study area are an

order of magnitude below the limits set for NOx and SO2 by the World Bank (World Bank General

Environmental Guidelines, IFC, 2007).



6.4.2 Noise

A noise baseline survey was conducted during the initial site visits using the locations N15 to N20

shown in Figure 6-2 as measurement points for the facilities at Pepel Port. The results of the baseline

survey are listed in Table 6-11.

Table 6-11: Results of Baseline Noise Monitoring Campaign at the Pepel Port Facilities

Geographical Location



LAeq

(dB(A))



ID



Coordinates



N15



28 P 714320

951474



28.2



N16



28 P 713788

950900



36.9



N17



28 P 713515

948988



28.9



N18



28 P 713608

948933



41.8



N19



28 P 713986

948893



33.7



N20



28 P 714047

948879



30.2



Measurement Date

Date



Meteorological Data



Hour



T (ºC)



Wind speed

(km/h)



10:40



36.2



No wind



13:40



36.4



No wind



17/02

2010

17/02

2010

12:40



35.2



Isolated from

background noise by

Stockpiles



12.20



35.2



3.6



Background noise

(intense) from nearby

(600 m) workers /

people



11:40



34.7



3.8



Background noise from

birds and activity at

Pepel Port



12:00



34.7



2.5



Isolated site between

Pepel buildings and

shore



17/02

2010

17/02

2010



In a forest clearing



4.3



17/02

2010



On existing railway

among mangrove

forest at Pepel Creek



Birds singing



17/02

2010



Remarks



Results at location N18 were higher than at other locations, but the field observations confirmed that

they correspond to background noise from nearby workers / people at a distance of approximately

600 m.



6.4.3 Archeology & Cultural Heritage

The significance of sites of archaeological value (in-situ) and cultural heritage factors has been

initially screened by discussion with in-country ESHIA practitioners. The preliminary advice indicated

that it was likely there would be limited and in some areas negligible sensitivity. Development of an



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understanding of the importance of marine and terrestrial archaeology, burial sites, Society Bush

areas and other important heritage factors has already been included in a number of baseline studies.

Integration of this information with a specialist assessment into a review of possible project impacts is

still underway.



6.4.4 Ecology & Biodiversity

Vegetation

The Pepel Port area is comprised of farmbush, plantations, settlements, vegetable gardens and wild

oil palm. The wider Pepel Port land lease area and the rest of Pepel Island also hosts mangroves,

mangrove / freshwater ecotone, oil palm and Acacia mangium plantations and grassland vegetation.

The conservation significance of the mangroves is medium, while all other habitats are classified as

low significance.

Terrestrial Fauna

A Phase 1b rapid assessment of six sites around the Sierra Leone River Estuary was conducted

during the dry season. The area does not appear to have significant habitat value for terrestrial large

mammals, reptiles or amphibians, however it does represent a very important (significant) wintering

area for bird species. The significance of the area for bird species is reflected in the estuaries

designation as a wetland of international importance under the Ramsar Convention (1971) and an

Important Bird Area by BirdLife International.

Aquatic Ecosystems

During the Phase 1b rapid assessment, no freshwater aquatic environments were identified on Pepel

Island.



6.4.5 Hydrology & Hydrogeology

Groundwater is the principle source of potable water supply to the inhabitant of Pepel Island. This is

in part due to the lack of a dependable fresh surface water resource, and because Pepel Island is

underlain by one of the most productive aquifers in Sierra Leone, the coastal deposits of the Tertiary

Bullom Group. The group outcrops over the high ground in the form of elevated terraces and extends

to depths of at least 60 m (SRK geotechnical investigation, 2009), possibly up to 120 m thick

(Strasser-King, 1979). The groundwater beneath Pepel Island is expected to comprise a relatively thin

lens of fresh water and become saline with depth; a common feature associated with coastal aquifers.

It is interpreted that the lens is thickest under the elevated terraces, becoming thinner towards the

coast as groundwater elevations approach mean sea level.

Groundwater samples were collected from wells on Pepel in and near the port area during a recent

site visit (March/April 2010) to assess whether historical activities at the port may have had a

detrimental effect on groundwater quality in the area. Background samples were collected from

comparison from wells further north on the island where industrial activities are very unlikely to have



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impacted on groundwater quality. Water sampling locations are shown on the map of Pepel Island in

Appendix 16.

The tests showed that at one location only (PPGW001) sulphate was elevated relative to the UK

drinking water guideline value (250 mg.L-1) south of the old stockpile area. Although arsenic

concentrations in all soil sampling locations bar one, were above the detection limit arsenic in waters

was below the guideline concentrations of 0.01 mg.L-1 at all locations. No other potential

contaminants of concern tested above concern levels.

During recent monitoring works, field parameters (electrical conductivity, pH, redox and temperature)

were recorded at sampling locations. Electrical conductivity values ranged between 70 μS.cm-1 and

200 μS.cm-1 (an outlier of 500 μS.cm-1 was measured in May 2010 at PPGW008 a recently drilled

relatively deep water well,) representative of fresh water. A significant exception was the waters

sampled from location PPGW001, located at the edge of the swamp area. The EC value for this water

sample was above the maximum detection limit of the instrument (3900 μS.cm-1), which is indicative

of saline water. The location of this well suggests that it will be impacted by influx of saline water at

high tides. The pH of the groundwater is acidic, ranging between 4.5 and 6.57 pH units.

There are no significant freshwater rivers present on Pepel Island; however, numerous ephemeral

streams are present during the rainy seasons. Runoff from the high ground during the wet drains into

the mangrove swamps. In the swamps themselves, there are a number of creeks discharging into the

sea. Estuarine swamps lie at an elevation of less than 1 m above mean sea level (m amsl) and are

subject to tidal flooding. The island is separated from the mainland by a channel, at least 100 m in

width. One surface water sample was collected from a creek adjacent to Pepel Bridge. An electrical

conductivity reading above the maximum detection limit (3900 μS.cm-1) was recorded for this sample

which is indicative of saline water.



6.4.6 Soils & Land-use

A baseline study to characterise the chemical properties of soils within the former Pepel Port facility

was recently undertaken (March-April 2010). The study included the analyses of several surface soil

samples collected from areas within the former port facility to characterise ground conditions

associated with the site’s former use as an industrial facility and hence provide the baseline reflecting

the Brownfield character of this site. The sampling and analysis were designed to test for potential

impact of historical contaminative activities associated with operation of the port (i.e. refuelling, fuel

storage, power generation). Soil samples were also collected from outside former work areas to

obtain information on the background soil characteristic of the area. Sampling locations are shown on

the map of Pepel Island in Appendix 16.

As part of an initial screening exercise, soil concentrations were compared with suitable

WorleyParsons (UK) derived generic criteria in order to identify contaminants of potential concern to

human health. As part of the screening process, each contaminant is compared to three guideline

values which were derived considering three different land use scenarios (i.e. residential land use

with vegetable uptake and without vegetable uptake and commercial land use with hard cover).



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The assessment found that none of the contaminant soil concentrations exceeded commercial land

use guideline values. However, arsenic, benzo(a)pyrene and aliphatic compounds (C16-C35)

concentrations exceeded the derived guideline values for residential land use with or without

vegetable uptake at some locations which are discussed in more detail below.

Arsenic concentrations were above the detection limit of 0.6 mg.kg-1 at all locations with exception of

sampling location PPSS004 within the port area near the rail line but remote from any area of

significant industrial activity. The highest concentration (197 mg.kg-1) was measured at location

PPSS006, which sampled soils in an historically coal tar lined gulley adjacent to the former

powerhouse. This concentration is six times greater than the residential guideline value of 35mg.kg-1

for areas with no vegetable uptake. It is possible that arsenic occurs naturally in local soils (the result

of weathering of arsenic-rich bedrock, i.e. metamorphics). However, the occurrence of significantly

higher concentrations within former port work areas indicates that these activities have contributed to

arsenic levels in soils.

Aliphatic compounds (C16-C35) exceeded the residential guideline value (9.1 mg.kg-1) at several

locations within the former working areas. The highest concentration (1830 mg.kg-1) was measured in

the soils collected from location PPSS006 which is described above.

Benzo(a)pyrene concentration exceeded the residential guideline value at two locations (PPSS001

near the refurbished AML training room and PPSS013 adjacent to rail tracks by the former fuel

storage tanks area). Benzo(a)pyrene is a contaminant often associated with coal tar. Heavily

weathered tarry material is present at Pepel Port at a number of locations where a worker confirmed

that coal tar was used to provide a seal to protect ground from being contaminated by spills of fuels in

the vicinity of the former fuel depot.

Iron concentrations ranged between 9750 mg.kg-1 (PPSS017) and 178000 mg.kg-1 (PPSS013).

These high concentrations are not considered to pose a risk to human health, as iron is not toxic to

human health. However, elevated dissolved iron in surface waters with a low pH, can impact on

aquatic life, especially in circumstance where acidic waters mix with more alkaline waters. Under

these conditions, dissolved iron would start to precipitate out of solution to form an iron oxide orange

stained sludge which will coat the river/stream bed. This coating will kill bottom dwellers, which in turn

will have a knock on effect (e.g. reduced food source) on the larger aquatic environment.

Preliminary qualitative information on land-use has been acquired during Phase 1b biodiversity

studies (flora, fauna and freshwater) in the Pepel Port facility area. In addition to remaining

mangroves, land in the Pepel Port area is used for subsistence and commercial agriculture (oil palm

and Acacia plantations), charcoal production and settlements.

Potential sources of contamination associated with the historical operation of the port remain and

include stockpiled and dispersed hematite product from the former operations, hydrocarbons and

solvents associated with fuel farms, workshops, loco sheds and the power house and transformer

stations. Asbestos containing materials were also identified and tested and demonstrated to contain

chrysotile asbestos.



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6.4.7 Geology & Geomorphology

It is understood that limited project-specific geotechnical test pitting and auguring has been

undertaken to date at the proposed port site and interpretation and reporting will be available after

issue of this ESHIA report. Published data and recent drilling for water well installations confirm the

presence of at least approximately 40m of sedimentary sequence of clay, silt and sand and consistent

with the Bullom Group which outcrops along the entire length of the Sierra Leone coastline.



6.4.8 Socio-Economic & Human Health

The socio-economic and human health baseline of these areas have been characterised using a

range of survey techniques at a coarse level and the results have been aggregated and described in

a generalised manner in the Regional Setting chapter, Section 5.4. Although further baseline

description is underway, it is assumed for the time being that the generalised description is an

adequate characterization of the communities along the port area and the baseline is not expected to

be significantly different from the regional overview.

Data collected from the field studies conducted in March 2010 for other relevant disciplines will also

be considered for the health impact assessment. In the Pepel Port area, the pH levels measured at a

number of wells and surface water sampling locations in the project area were outside of the

generally accepted drinking water range of 6.5-8.5 (WHO 2007). WHO have not established a

drinking water guideline for pH, stating that ‘values in drinking-water are well below those at which

toxic effects may occur’; they do, however, remark that pH is an important operational water quality

parameter (WHO 2008). pH can have indirect effects on water quality and health. It is known that

heavy metals and base cations can be mobilized by increasing acidity in groundwater and soil.

The number of samples collected for the baseline study was low. Better definition of the water

chemistry, is required before potential health impacts can be fully defined. Additional testing be

carried out in the next phase of works (Section 8) will more accurately define the surface and

groundwater quality in the Pepel Port catchment area to ensure that appropriate health based

guidelines are met. Testing should include metals, routine potability and microbial parameters.

The baseline soil and marine sediment programs identified elevated heavy metal concentrations

below commercial international standards (CCME) in the Pepel Port area (Sections 6.4.6 and 6.5).

Soil samples collected from the Port area contained concentrations of arsenic, benzo[a]pyrene, and

hydrocarbons C16-C35 in concentrations greater than residential guidelines with or without vegetation

uptake. Sediment samples and intertidal sediment samples were identified to contain arsenic,

chromium and lead concentrations greater than international standards.

In addition, baseline surveys and in-country visits identified materials such as asbestos sheeting,

presumably scavenged from Pepel Port and used in local communities as building materials.

The chemical results of soil, vegetation, fish tissue, surface water and groundwater samples collected

during site visits will be studied and potential concerns highlighted in the next phase of works (see

Section 8 for more information on the next stage of work).



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6.5



Offshore & Coastal



6.5.1 Marine Physical Environment

Ocean Climate

Accurate bathymetry data for Pepel is not yet available. Although UK admiralty charts do exist, there

are discrepancies between these charts and field observations. In particular, depths around the old

navigation channel have reduced following the port’s closure and discontinued maintenance dredging

(Scott Wilson, 2009).

Located further inside the estuary, tidal variations at Pepel Island are less than in Freetown. Data

from the UKHO (Admiralty Chart no. 625) shows a mean water variation of approximately 2.9m at

spring tides and 2.2m at neap tides.

A 2D hydrodynamic model (DHI MIKE) developed for this project estimated the maximum current

speeds (tides only) in the main channel at Pepel to be 0.82 m/s (WorleyParsons, 2010a). The model

utilised charted bathymetry and predicted water levels and these values are treated with caution. The

model will be improved and a more detailed analysis will be provided in the final ESHIA report based

on calibration against observed data.

The influence of waves in the Pepel part of the estuary is expected to be very low as there is

protection from the open waters of the Atlantic by Tagrin Point and sand banks and bars in the

estuary mouth.

Water and Sediment Quality

Basic water quality parameters have been measured nearshore Pepel (site P1). Figure 6-3 shows the

preliminary results from February 2010. Further data will be available for the Stage 2 ESHIA. The

results show the variability in turbidity with the tidal cycle. The waters are highly turbid during mid-ebb

flow, as expected.



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Figure 6-3 Water quality plot at sample location P1, February 2010



Depth



400



8



300



6



200



4



100



2



0



0



40

30

20

10

0



Temp (C)



pH (unit)



Depth (m)



Turbidity (NTU)



Turbidity



EC (mS/cm)



13/02 13/02 13/02 14/02 14/02 14/02 14/02 14/02 14/02 14/02 14/02 15/02 15/02

15:00 18:00 21:00 0:00 3:00 6:00 9:00 12:00 15:00 18:00 21:00 0:00 3:00



Dry season marine baseline assessment in March 2010 was undertaken around Pepel Island and the

proposed dredge channel and spoil ground. The survey was undertaken over ten days and samples

were collected from 12 sites. Sample locations around Pepel are shown in Figure 6-4.

Water and sediment samples were collected and analysed for their physical and chemical properties.



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Figure 6-4 Water quality and sediment sample locations close to Pepel



None of the water samples taken during the March 2010 environmental survey reveal concentrations

which are above international water quality guidelines for the protection of aquatic life. The baseline

conditions of estuarine water quality at Pepel are therefore good.

Results for total suspended solids (TSS) describe conditions during the ebbing tide as more turbid

than that of the flood. This is typical of surface run off carrying particulate matter into the estuary from

river channels on the ebbing tide. In contrast, less turbid marine waters enter the estuary on the flood.

Near Pepel measured TSS concentrations were < 5 mg/l around high water and approximately 40

mg/l at low water.

Sediment is well sorted in fast flowing sections of the estuary, ranging from good to moderate coarse

sand. Reduced current speeds behind Mayaba Island at sample location F result in finer particles

settling out of suspension resulting in a silt sediment.

Hydrocarbon analysis of sediments sampled close to Pepel display an increase in total hydrocarbon

concentration at location D. Location D is situated at the end of a trestle, which is part of the existing

port structure. A possible explanation for increased hydrocarbon concentrations at this location is that

vessels would have spent relatively long periods of time at the trestle whilst loading ore and fuel and

or oil could have been spilt at this time. The trestle is also an area of shelter for fish and artisanal

fishermen were observed fishing there during the survey. F fuel may have been accidentally spilt by

these fishermen. A further potential source of hydrocarbon contamination at location D is transport

from other locations, carried in the water column and deposited as the current slows at and around



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the protruding trestle – this is not supported by the sediment type however, which is indicative of a

fast flowing location.

Sediment nutrient concentrations are comparatively elevated at sample Location D. The trestle at this

location may be responsible for slowing the current and causing particulate matter to fall out of

suspension. The trestle also provides habitat for fish, which may also deposit organic matter to the

sediment.

Heavy metal concentrations in the sediment are elevated at Location F but not at Location D. Arsenic

and Chromium concentrations are above international sediment quality guidelines (Canadian CCME)

at Location F, but do not exceed the probable effects level.

Sediments were also collected from the intertidal and coastal zone in April 2010 as part of the soil

monitoring campaign (see Figure 6-5).

Figure 6-5 Intertidal sediment sample locations



Results from the baseline survey of heavy metal contamination in the intertidal zone at Pepel show

readings which indicate:





Arsenic is above sediment quality guidelines6 at location PPSS016. Arsenic is a toxin and

can reduce benthic invertebrate abundance, increase mortality, and induce behavioural

changes depending on its chemical form and resulting bioavailability (CCME, 2010).



In the absence of national or international standards the Canadian Sediment Quality Guidelines for the Protection

of Aquatic Life (Update 2002) are used, which are based upon recognised toxicological methods.



6



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Chromium is above sediment quality guidelines in both locations. Chromium is a toxin and

can decrease diversity and abundance, increase mortality, and induce behavioural changes

in benthic organisms, among others (CCME, 2010).







Lead is above sediment quality guidelines at locations PPSS015. Adverse biological effects

of Lead in the benthos include increased mortality, decreased invertebrate abundance and

diversity, and abnormal development (CCME, 2010).



Many of the contaminants are naturally associated with iron and are likely the remnants of past ore

handling operations at the port (CCME, 2010).



6.5.2 Coastal and Marine Habitats

Pepel Port lies in an area of high ecological value associated with extensive mangrove forests within

one of the core areas of the Sierra Leone Ramsar site.

The coastal habitat of Pepel Islands consists of mangroves, mudfalts and sandflats and a small sandy

beach near the community settlement. The habitats have been mapped based on high resolution

aerial and satellite imagery. The results were ground-truthed during the marine environmental site

survey.

Figure 6-6 Mudflats located around Pepel Island. The Red shaped areas representing the

location of the Mud Flats



The Mangrove forest play an important ecological and socioeconomic role, particularly in relation to

coastal fisheries for prawns and fish, as a source of wood products, as nutrient sinks, and for

shoreline protection (Rönnbäck, 1999). The mangrove communities observed near Pepel Island were

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mostly comprised of more than one species. The mangrove cover was mostly comprised of low

regrowth (up to 5 m high) with few trees of a large size (i.e. taller than 10 m). The dominant group of

mangrove species that have been identified are the Black Mangroves (Avicennia germinans

(africana)), White Mangroves (Laguncularia racemosa), Button mangroves (Conocarpus erectus) and

Red mangroves (Rhizophora racemosa, Rhizophora mangle, Rhizophora x harrisonii).

Full mangrove mapping based on high resolution aerial surveys and field surveys is ongoing to

identify the key mangrove species in Pepel Island. The preliminary results of this mapping are

provided in Figure 6-7

Figure 6-7 Mangrove species distribution at Pepel Island



6.5.3 Marine and avifauna

The shallow waters of the mud flats in the mangroves are nursery grounds for shrimp species

(Portconsult, 1996). Molluscs are found in the estuarine and mangrove creeks and include the

mangrove oyster (Crassostrea tulipa), the brackish and estuarine intertidal cockle (Senilia senilis),

and the sub-littoral rock oyster (Crassostrea denticulate) (Chaytor & Aleem 1976). The bivalves

include Iphigenia laevigatum, Tagelus angulatus and Tellina nymphalis, and the gastropods include

Cymbrium spp., Tympanotonus fuscatus and Semifusus morio (Lorax, 2009). No specific information

is available regarding fish or shelfish species in the surroundings of Pepel Island. However, artisanal

fishery, including shelfish collection activity, appears to play an important role in the local communities

as observed during the field survey. Further survey and consultation will be included in the Stage 2

ESHIA.

A survey below the Pepel trestle during the marine environmental baseline survey found the sub-sea

structures were covered with oysters (Crassostrea spp) and fish species Silver Dollar (Metynnis spp)

was also observed.



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No specific information is available on the marine mammals or sea turtles in the surroundings of

Pepel Island. However, it is unlikely that they would inhabit areas this far up the estuary. Marine

mammal and turtle studies will continue into the next phase of work.

Pepel Island is part of the core area of Sierra Leone’s only Ramsar site and there are expected to be

wading birds on the mud/sand flats. The mangroves will provide further valuable habitat for birds.

There are no specific ornithological records available that are specific to Pepel, although several bird

counts have been conducted in the Tagrin-Pepel areas, which are described in Section 5.3.4. All of

which highlighted species richness. A detailed bird survey at Pepel is underway.



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7



POTENTIAL IMPACTS & MITIGATION

Impact Identification & Evaluation



7.1

7.1.1



Techniques for Impact Identification & Evaluation



Methodology

Baseline knowledge identifies the environmental and social parameters that may be affected by the

proposed project. The potential positive and negative changes resulting from the project are predicted

for the study area over the life of the project. These predicted changes (impacts) are then evaluated

using a significance ranking process. An outline of the impact assessment procedure is as follows:





Identification of the valued receptors;







Identification of the key project activities;







Impact evaluation; and







Significance ranking.



The impact evaluation step included identification of potential activity-receptor interactions prior to the

evaluation of impact significance (Aspects Identification).

Valued Receptors

A valued receptor (VR) is any element of the environment that is considered to be important or

valuable and merits detailed consideration in the ESHIA process. In this context the broadest

definition of ‘the environment’ is applied, such that VRs may be selected according to economic,

social, aesthetic or ethical criteria, as well as by consideration of physical, ecological and biological

characteristics. The process of selecting VRs may consider legal status, scientific or cultural value,

and public perception; and may account for the views of national or local government, international,

national or local non-governmental organisations, or the general public.

The selection of VRs is dependent on the nature of the proposed project; only those environmental

components that have the potential to be affected (positively or negatively) by the project are

selected. This depends on the types of interaction with the environment that the proposed project is

expected to have, given its component activities and area of influence. VRs may include components

affected by routine project activities as well as non-routine events.

In order to aid the impact significance rating process, each VR has been categorised as being of

either low, medium or high environmental value. This is based on various factors, including the

resilience of the receptor, its vulnerability to disturbance, its current status within the region of

influence, and its value as a resource. The categorisation may also take into consideration local,

national or international designations and legal protection status, if appropriate. The categorisation is

designed to provide a broad ranking of the VRs, as follows:



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Low - a VR that is considered important but which may not be particularly sensitive to impact,

and which is not subject to legal protection;







Medium- a VR that may be sensitive to impact or of considerable local importance;







High – a VR that is highly sensitive to impact, has national or international designations and/or

legally protected features, or is otherwise regarded as being of great importance.



Based on the environmental baseline of the study area, VRs have been identified and are listed by

category below in Table 7-1. It should be appreciated that these VRs have been chosen based upon

the data available at present. A review and ranking of appropriate VRs was undertaken and the list

below represents what was considered to be the most concise selection without becoming overaggregated or simplified. The selection of a relatively limited number of VRs was made in recognition

of the potential for a significant amount of cross-over in terms of secondary impacts between different

areas. Using limited and standardised VR has helped clarify where aspects from one domain are

capable of creating an impact in another domain.

Table 7-1 Valued Receptors

VR



Importance



Categorisation



A1



Good air quality is required for local population

health, soil, water and ecological health and

quality



High



Climate changes



A2



GHG are responsible for global climate change

and the local climate is important for the local

ecology



Medium



Noise



N1



Ambient noise might disturb near residents and

affect ecosystems



Medium



Soil



S1



Soil quality is important for sustaining

ecological services including agricultural

productivity, biodiversity, water quality and

human health.



Medium



Soil



S2



Soil structure is an important aspect in

preventing geo-hazards (mass wasting,

erosion, slumping etc)



Medium



Air Quality



Code



Groundwater



GW1



Groundwater quality. Human Health.



High



Groundwater



GW2



Groundwater quantity (resource)



High



Surface water



SW1



Surface water quality. Human Health.



High



Surface water



SW2



Surface water flow (resource)



High



Forest / River Channel / Mountain Grasslands



High



Natural / Semi-natural



E1



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VR



Code



vegetation

Farmbush / Plantations

/ Degraded Grasses



Terrestrial Fauna



Importance



Categorisation



species abundance, diversity and integrity for

the maintenance of ecological services

E2



E3



Human use, Vegetation cover - stabilising soils

Terrestrial species diversity and abundance

and integrity for the maintenance of ecological

services



Low



High



Source of bushmeat

Avifauna



Aquatic Ecosystems



E4



Aquatic species richness and abundance and

integrity for the maintenance of ecological

services



High



Subsistence fishing and food availability for

local populations

Marine and Coastal

Ecosystems



E5



Marine and Coastal

Ecosystems



E6



Marine and Coastal

Ecosystems



E7



Marine and Coastal

Ecosystems



E8



Visual Impact



V1



Marine species abundance, diversity and

integrity for the maintenance of ecological

services. Human Health.

Coastal habitats – mangrove, mud-flat, beach

Subtidal habitat.

Marine fauna

Visual and aesthetics values including lighting

and changes to structures & land forms



High



High

Moderate

High

Low



Loss of access roads (-ve)

Infrastructure Changes



Human - Local

communities (e.g.

potentially sensitive

receptors such as

infants and children,

invalids)



I1



Increased facility & infrastructure investment

(e.g. major roads, rail refurbishment, port

expansion, shipping) (+ve)



High



Protection of the health of the general

population is required.

H1



High



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VR



Importance



Categorisation



H2



Protection of the persons living in work camps

as well as in local communities is required;

however, the healthy worker effect reduces

sensitivity.



Medium



Human Development

Potential



H3



Increases in well-being not related solely to

health including social cohesion, education,

participation and good governance. Fisheries



High



Employment



H4



Broader up-skilling of local workforce. Greater

employment opportunity



Medium



H5



Marine archaeology, burial sites. Society Bush

is recognised as having an important cultural

significance. Society bush is protected on the

basis of ecological principles as well and

incorporated as such also under E1 and E3



Low



Human - Employees of

the Project (e.g. young

adult and adult

workers)



Cultural Heritage



Code



Project Environmental Aspects

The Project description provided in Chapter 3 of this document has been summarised into key

environmental aspects that will occur throughout the life of the project. An environmental aspect is an

element of the project's activities that can interact with the environment. The key environmental

aspects associated with the Project activities are presented in Appendix 2 Environmental Aspect

Register.

Impact Evaluation

An environmental impact can be considered as a change to the environment due to project activity.

Such change can be positive or negative. Environmental impacts may occur where an environmental

aspect (project activity) is denoted, and may be direct or indirect. The evaluation has been conducted

using the following basic criteria for defining an impact:



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Magnitude: this is an indication of the proportion of the VR that will experience the impact in

relation to the total resource within the project area. Impacts associated with project changes

that are widely distributed by nature are considered separately;







Spatial extent: the geographical area over which the impact is experienced (for some VRs this

can be equivalent to magnitude of impact); and







Duration: the length of time over which the impact will be experienced. An impact may be

present only while a project activity is active, or it could persist long after the project activity has

ceased, in which case the duration may be regarded as the time the VR needs to recover from

the effect.



Each potential impact is evaluated by applying descriptors to each of the above criteria, based on

qualitative or, to the extent possible, quantitative evaluation, as follows.













The magnitude of impact is allocated one of the following categories:

Very Low (1)



A very small proportion of the VR is affected;



Low (2)



A small proportion of the VR is affected;



Moderate (3)



A moderate proportion of the VR is affected;



High (4)



A large proportion of the VR is affected;



Very High (5)



A very large proportion or all of the VR is affected.



The spatial extent of impact is allocated one of the following categories:

Very Low (1)



Local impact in the immediate area of the activity;



Low (2)



Local impact in the study area;



Moderate (3)



Regional scale impact;



High (4)



National scale impact;



Very High (5)



Transboundary scale impact.



Duration of impact is described by one of the following categories:

Very Low (1)



less than one year;



Low (2)



one to five years;



Moderate (3)



five to ten years;



High (4)



greater than ten years;



Very High (5)



irreversible.



Where there is any uncertainty, a higher figure is assigned to an impact criterion, so as to reduce the

chance of underestimating an impact (i.e., the precautionary principle is applied), thereby minimising

risk (Crowfoot et al. 1990).



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Each potential impact is then allocated a ‘basic impact index’ obtained by averaging the numerical

values assigned respectively for magnitude, spatial extent and duration of impact. The average is

rounded up to a whole number where necessary; thus the basic impact index is a number between 1

and 5. Potential positive effects are noted as such but are not subject to further numerical

interpretation.

Assessment of Impact Significance

The final impact significance is the result of the combination of the basic impact index and the VR

categorisation, as shown in Table 7-2. Impact significance is described as either insignificant, minor,

moderate, major or catastrophic. These categories have been standardised with an overall Risk

Matrix categorisation that has been developed in the project’s feasibility study.

Table 7-2



Impact Significance



VR Category



Basic Impact Index

Very Low



Low



Moderate



High



Very High



1



2



3



4



5



Low



Insignificant



Insignificant



Minor



Moderate



Moderate



Medium



Insignificant



Minor



Moderate



Major



Major



Minor



Moderate



Major



Major



Catastrophic



High



Those impacts rated as moderate, major or catastrophic are considered to require additional

mitigation to that contained in the project’s base case design in order to eliminate the impact or,

where this is not possible, to reduce its significance to minor or insignificant.

Summary impact evaluation and significance assessment tables have been provided for each of the

discipline areas in the following sections.



7.1.2



Techniques for ESHIA Risk Assessment



Where it is recognised that a potential impact may occur on an infrequent basis, i.e. a non-routine

unexpected event, then the magnitude of the impact will need to be evaluated through risk

assessment and the results incorporated back into the impact assessment. For example, non-routine

unexpected events might include:





Accidental spillage







Failure of impounding facilities (eg. Bunding, containment, etc)







Geo-mechanical failure







Traffic incidents







Human error



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The risk assessment takes into account the consequence of the hazard and multiples it by the

likelihood of that consequence occurring to give a risk value. The risk assessment of identified nonroutine, unexpected events will be undertaken in the next phase of the Tonkolili Project.

Impact assessments are still pending however from this assessment to date, at a qualitative level no

specific process, chemical reagent, material or activity that would result in a catastrophic

consequence due to an accidental or non-routine event occurring has been identified.



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Mining Area



7.2

7.2.1



Air Quality



Construction

The most significant impacts on air quality may arise from dust emission generated during vegetation

clearance and earth movements (e.g., creation of new access routes, extraction of borrow material at

the mine, and surface grading and leveling for buildings and facilities construction). Pollutants emitted

by these activities are mainly coarse particles that do not result in human health effects.

Nevertheless, vegetation may be affected by particle deposition on leaves. Additionally, elevated

sedimentation in streams could occur with ensuing effects on aquatic organisms. This impact can be

mitigated by spraying the affected land surfaces with water under dry conditions.

Additionally, diesel generators used for power supply, vehicles and machinery exhaust gases will

contain several air pollutants (SO2, CO, NO2 and fine particles: PM10 and PM2.5). The use of efficient

machinery (vehicles, motors and pumps) and the use of a good practices policy will avoid

unnecessary fuel consumption (e.g., limit journeys, switch-off machinery when not in use, and reduce

diesel generators use to a minimum); and therefore, will minimise the potential impacts on air quality.

Other potential sources of air pollutants are uncontrolled fires used for cooking or heating and the

associated risk of the fire propagating. This impact could be controlled by instructing and supervising

construction contractors.

Operations

Activities undertaken in the mining area that may impact air quality are as follows:





Excavation works: Operations that involve blasting, drilling, movement of soil or exposure of

erodible surfaces will generate some volumes of fugitive dust. The majority of the particles

generated during these activities will exceed 10µm in size and will not be easily respired;

therefore, the emitted particles are not expected to generate impacts on human health. These

activities may impact air quality at the project boundaries, disturbing the nearest populations

and potentially reducing the photosynthesis capacity of vegetation by deposition on leaves.

The application of the proposed mitigation measures (see below) will reduce the negative

effects on air quality;







Material processing: The Crushing and Loading facility will be located southwest of Simbili.

The material processing emissions will be dependant on the mitigation measures to be

applied; properties of the material being disturbed (e.g. particles size or moisture content);

and meteorological conditions (wind speed and direction). Efficient mitigation measures at the

point sources (filters) and at the storage areas (water, chemical foam, partial enclosure for

screen or crushers and full enclosure) may reduce the potential effects;







Power supply generation: Generators and engines will produce exhaust emissions, the

amount of which will depend on the volume of fuel consumed and its sulphur content. The

expected pollutants are SO2, NOx, CO and PM10. Since the power requirements are not



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excessive and the project might use power from external suppliers, the impact's extension

and magnitude are not expected to be high. Diesel generators should be designed to comply

with the air quality standards for compliance with occupational health conditions and

boundary sampling locations;





Stockpiles: Total dust emissions from stockpiles result from various activities within the

storage cycle: loading of aggregate onto the storage pile, wind erosion of the pile and loading

of aggregate for continuing the process stream. Fines are easily released to the atmosphere

upon exposure to air currents; however, moisture can aggregate and bond fines to the

surfaces of larger particles and greatly reduce the potential of dust emission. Total particulate

emissions can be reduced from aggregate storage operations up to 90 percent (USEPA,

AP42 methodology, ref 13.2.4-1).



Potential Mitigation Measures

Generic recommendations for reducing impacts from construction and operational phase activities are

listed below:

Reduction of air quality impacts from dust emissions:





Suppress dust during dry periods by spraying water onto potential sources for airborne

particles (e.g., unpaved roads, stockpiles, earth being moved);







Cover truck loads to avoid dust emissions during transportation;







Keep vehicle movements to a minimum and use paved areas, where possible;







Minimise discharge heights from trucks (not to exceed 1 m) for fine particles and consider the

use of dust suppression spray systems;







Design stockpiles based on the wind pattern and consider installing windscreens;







Considering the installation of filters in the design of the Crushing and Loading Facility.



Reduction of air quality impacts from engine emissions:





Review machinery permits and ensure appropriate maintenance;







Limit unnecessary journeys and adopt a policy of switching off machinery and equipment

when not in use;







Consider a choice of machinery, equipment, vehicles and materials that are fuel-efficient as

part of the purchasing procedure.



Reduction of impacts from controlled and uncontrolled fires (airborne emissions):





Avoid uncontrolled fires;







Open fires will be prohibited. To limit air emissions, avoid accidents and reduce fire risk

during the construction phase;



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Table 7-3 Mining Area - Air Quality

Aspect



VR



Impacts



VR

Category



Magnitude



Extent



Duration



Significance



1



Basic

Impact

Index

2



Moderate



Residual

Impact after

Mitigation

Minor



Land clearance



A1



Dust emissions. Particles

deposition on vegetation.

Visibility reduction.



High



2



1



Drilling, blasting and

mining activities



A1



Dust emissions. Particles

deposition on vegetation.

Visibility reduction. Health

effects.

Dust emissions. Particles

deposition on vegetation.

Visibility reduction. Health

effects.

Dust emissions (coarse and

fine particles). Particles

deposition on vegetation.

Visibility reduction. Health

effects.

Exhaust emissions (SO2, CO,

NO2, PM10 and PM2.5). Health

effects.



High



3



2



2



3



Major



Minor



Material processing



A1



High



3



2



2



3



Major



Moderate



Stockpiles



A1



High



3



2



2



3



Major



Moderate



Power supply



A1



High



3



2



4



3



Major



Moderate



Power supply



A2



Greenhouse gases emissions



Medium



1



5



4



4



Moderate



Moderate



Land clearance



A2



Local climate change due to

vegetation removal



Medium



4



1



3



3



Moderate



Minor



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Reason for

Change

Efficiency of

dust

suppression

measures

Efficiency of

dust

suppression

measures

Efficiency of

dust

suppression

measures

Moderate

Efficiency of

dust

suppression

measures

Mitigation

measures

should

ensure AQ

guidelines

compliance



Hard to

mitigate

Assumed

that

vegetation

will be

restored or



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TONKOLILI IRON ORE PROJECT

naturally

recovered

Vehicles and machinery



A1



Exhaust emission. Dust

emissions in unpaved roads.

Particles deposition on

vegetation. Visibility reduction.

Health effects.



High



2



2



2



2



Moderate



Minor



Vehicles and machinery



A2



Greenhouse gases emissions



Medium



1



5



3



3



Moderate



Moderate



Uncontrolled fires



A1



Exhaust emissions (SO2, CO,

NO2 , PM10 and PM2.5).

Health effects. Risk of fire

propagation.



Medium



2



2



2



2



Minor



Insignificant



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Efficiency of

the proposed

measures to

minimize

pollutant

emissions

Hard to

mitigate

Mitigation

measures

should avoid

uncontrolled

fires



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7.2.2



Noise



Construction

Sources of noise emissions associated with the construction phase may include noise from

machinery engines, vehicles used for transport, loading and unloading of rock and materials, chutes

and power generation. Potential impacts are not limited to the project boundaries and will propagate

beyond. Mitigation measures described in this section should be applied near the populated areas

located close to the potential noise sources. Of special interest are villages close to the roads where

traffic will be high (Farangbaia, Wandugu and Furia).

Operations

The Phase 1 Mining Area spans the crest of Simbili and includes an area that extends 4 km southeast

to southwest, as shown in the project description from which the following information can be drawn:

Potential impacts on the bottom and top camps were analysed in the same manner as for villages on

the basis that residential use is projected for both camps. It is noted that the bottom camp will also be

used for laundry, kitchen, offices and vehicle parking.

For the purposes of this ESHIA, the following qualitative analysis describes the likely impacts:

Mining Activities

Mining activities will result in an increase in sound levels due to the operation of machinery.

The equipment to be used will consist of 3 hydraulic shovels (operating weight 380 t) and 21 haul

trucks (payload capacity 130-140 t). Blasting will occur twice per week and will generally be confined

to within the top 20 m of the excavation.

Ancillary equipment will include 2 water carts (130 t capacity), three track dozers (Caterpillar D10 or

equivalent), and 2 graders (Caterpillar 16 M or equivalent).

Machinery movements and motors will generate noise, but the potential impacts on ambient noise will

be limited to within 500 m of the sources. Assuming that occupational health limits are maintained for

noise power limits at the facility boundaries (85 dB(A)) then it is predicted that appropriate

environmental noise standards will be met at a distance of 500m from the facilities.

The noise from a blasting explosion in a canyon between mountains can be propagated over large

distances from the source, but as the blasting noise frequencies are low (2 to 25 Hz) the equivalent

dB(A) will be much lower than the ambient noise values. Audible frequencies are above 20 Hz. If AML

maintain blasting operation standards then the noise power and sound pressure at receptors should

be limited to within acceptable environmental noise standards within a distance of 500m from the

facilities.

If the expected safety measures are in place, the generated sound pressure levels dB(A) should not

generate impacts at the nearest receptors located several kilometres from the site.



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Noise impacts generated from blasting will be dependent on the following:

-



Blasting conditions (e.g., amount of explosive, hole size and depth and rock type);



-



Noise propagation conditions defined by the terrain.



Contractors Workshop

No specific information was available regarding the equipment that will be used in the workshop;

however, the close proximity of this facility to the camps and to Farangbaia village will necessitate

further layout planning to avoid noise impacts. Depending on the outcome of the lay-out planning

further mitigation measures such as attenuation screens may be required.

The nearest residential areas are located approximately 600 m from the facility, so it is not expected

that the populations will be significantly affected. Assuming that occupational health limits are

maintained for noise power limits at the facility boundaries (85 dB(A)) then it is predicted that

appropriate environmental noise standards will be met at a distance of 500m from the facilities.

Crushing and Loading Facility

No specific information was available regarding the acoustical emission of the equipment that will

produce noise in the facility; however, the proximity to Furia and the cumulative effect expected from

truck traffic indicate that mitigation measures should be applied or the village should be resettled.

The Aircraft Stand

Due to the proximity of the Aircraft Stand to villages and the camps, possible noise impacts, though

limited, must be studied. The air strip is only expected to be used for transporting mine workers and

hence aircraft movements will be scheduled according to staff mobilisation, as opposed to freight

movement.

The Aircraft Stand will likely be used for urgent shipments and light-aircraft, and a noise buffer around

the Stand and into the Farangbaia village should be considered. Aircraft noise is expected to be

directed primarily in concert with the take-off direction, and to a lesser extent in the landing direction.

Aircraft take-off routes should avoid populated or sensitive areas within 2 to 6 km, depending on the

aircraft to be used and the take-off routes. A more detailed assessment should be conducted before

the airstrip operations begin when the types and schedule of aircraft are known.

Roads

Both of the camps and the villages, Farangbaia, Wandugu and Furia, are located near unpaved roads

on which the volume of vehicle and truck traffic will be high. Due to the high noise levels expected

from these roads, noise at the camp accommodation buildings might exceed the Environmental,

Health, and Safety (EHS) IFC Guidelines for residential areas (45 dB(A) at night and 55 dB(A) during

the day). The camp design shall avoid locating the accommodation buildings and medical centres

near the road.

Potential Mitigation Measures

Noise emissions may occur during each stage of the mine cycle, in particular during construction and

operational activities.

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Generic recommendations for reducing impacts from activities to be conducted during the

construction phase of the project are listed below:





Use machinery and generators with ‘quiet’, ‘muffled’ or ‘silenced’ settings, when available;







Consider choices of machinery and equipment that guarantee low noise emissions;







As long as hoppers and dumper boxes are more than 500m from residential areas there is no

need for any special mitigation measure. If this machinery is within 500m then it is

recommended that elastic coatings are used;







Limit unnecessary journeys and adopt a policy of switching off machinery and equipment

when not in use;







Optimise internal-traffic routing to reduce the need to reverse vehicles (avoiding noise from

the reversing alarm) and to allow the maximum distances possible between traffic and the

nearest sensitive receptors;







Conduct regular inspections and maintenance of construction vehicles and equipment to

maintain smooth operation; and







Limit vehicle speeds in the vicinity of populated areas.



The preventive and corrective measures to reduce the impact on noise pressure during the

operational activities are defined below:





Correct blast design and charging is essential and should include a survey of the face profile

prior to design and continuous review of charge requirements.







The setting-out and drilling of blasts should be as accurate as possible, the drilled holes

should be surveyed for deviation along their lengths, and the blast design should be adjusted,

if necessary.







Particular care is necessary with a first blast. It may otherwise give rise to abnormally high

overpressure and vibration because there is no free face to give relief to the forces produced.

Blast noise is usually controlled by limiting the amount of explosive and employing staggered

detonation. Problems may occur if there are faults in the strata and other forms of

heterogeneity; blasting in tight corners; blasting near made ground; excessive charge and

non-compliance with manufacturers' tolerances/errors in explosives or detonators.

It is

assumed that expert computerised firing sequence control would remove most risk

associated with operator's error resulting in simultaneous detonation of more than one

charge/hole/deck.







Noise levels will need to be monitored under normal and blasting conditions considering the

day and night noise limits. If cumulative noise levels are exceeding criteria for sensitive

receptors, additional mitigation measures should be defined, such as sound barriers. If the

source of noise will not bee effectively mitigated by these barriers (e.g. due to aircraft noise),

then additional measures should be considered, such as noise isolation at the sensitive

receptors.



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Table 7-4 Mining Area - Noise Impacts

Aspect



VR



Impacts



VR

Category



Magnitude



Extent



Duration



Significance



1



Basic

Impact

Index

2



Land clearance



Noise



Blasting and earth

movement



Reason for

Change



Minor



Residual

Impact after

Mitigation

Minor



Increase in noise levels due to

machinery operations



Medium



2



1



Noise



Increase in noise levels due to

blasting activities



Medium



3



2



2



3



Moderate



Minor



2



2



Minor



Insignificant



1



2



2



Minor



Minor



3



2



2



3



Moderate



Minor



4



3



2



3



Moderate



Moderate



Appropriate

blasting

management

should

minimize the

impact

Efficiency of

noise

isolation

Power

generation

noise is hard

to attenuate

Efficiency of

noise

barriers

Aviation

noise is hard

to attenuate



Material processing



Noise



Increase in noise levels due to

the mining process



Medium



2



2



Power supply



Noise



Increase in noise levels.



Medium



2



Vehicles and machinery



Noise



Increase in noise levels.



Medium



Airstrip



Noise



Increase in noise levels



Medium



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Land

clearance



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7.2.3



Ecology & Biodiversity



Construction

It is noted that impacts associated with Phase 1 mining activities overlap with likely impacts from the

other phases and may become more significant as the scale of the mining operations increases in the

course of the next project phases.

Vegetation



Conservation importance



The principal direct impacts will arise from the clearance of land within the footprint of the open pit

and associated infrastructure and the burial of vegetation in waste dump areas which will have a longterm to permanent impact on the current vegetation coverage. Vegetation that is not cleared or buried

may be indirectly impacted by alteration of drainage patterns and exposure to contaminated surface

runoff (contaminants may include petroleum products from operations and also mobilised trace

metals present in the hematite ore deposit). Further impacts may arise through the spread of invasive

species. These may also spread to undisturbed land following natural colonisation or deliberate

introduction in disturbed areas (where such species tend to thrive). An influx of people to the area will

increase the pressure on resources (e.g. clearance of land for agricultural use, subsistence and

commercial logging of timber). Impacts on fauna may further reduce natural colonisation by

indigenous plant species where fauna play a role in seed dispersal. The impact classification of these

impacts is influenced by the nature of the vegetation present in the area being impacted (defined as

high and low conservation importance for semi-natural or degraded vegetation respectively):



High



Low



Major

Land clearance;

burial; drainage

alteration;

exposure to

contaminated runoff; spread of alien

invasive species

-



Impact classification

Moderate

Minor

Increased local

human population;

reduced

dispersion of

seeds by fauna



Land clearance;

burial; drainage

alteration; spread

of alien invasive

species



Exposure to

contaminated runoff



Insignificant

-



Increased local

human population;

reduced

dispersion of

seeds by fauna



Terrestrial Fauna

The most significant potential impact is a change in species diversity and abundance (and potentially

a loss of species of conservation concern) through habitat loss and fragmentation directly associated

with the mining activities (such as vegetation removal) and indirectly through increased pressure due

to population influx on the resources in the area (such as increased vegetation removal for timber

supply and use as agricultural land). Displacement of terrestrial fauna may also occur through

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increased sensory disturbance as a result of the mining activities. Increases in local human

populations may increase hunting and bushmeat consumption. Bushmeat is an important source of

protein for local villages around the mining area. Food shortage has been identified in the social

surveys as an issue facing many villages, and therefore any significant ecological impacts (such as

ongoing displacement of fauna) as a result of the project-related activities may have indirect social

impacts. The impact classification of these impacts is as follows:





Major: habitat loss, habitat fragmentation, habitat disturbance and increase in hunting.







Moderate: displacement of fauna.



Aquatic Ecosystems

The most significant potential impact is a decrease in species richness and abundance through

deterioration of water quality in the area. Deterioration of water quality may occur through increased

sedimentation in aquatic environments as a result of sediment mobilisation during construction and

operation and / or changes in water chemistry that may arise from sediment runoff or acid rock

drainage from the mining activities (depending on the geochemical characteristics of the overburden /

ore). Direct modification of the aquatic environments within the vicinity of the Simbili deposit may also

occur during Phase 1 (for example diversion or obstruction of surface waters), which may cause the

loss of locally endemic species and concomitant impacts on subsistence fishing and food availability

for local populations. All of these impacts are classified as major.

Operations

The primary impact during the operations phase will be caused by the increase in population. This will

have regional significance for biodiversity and ecology receptors. This could create unintended

consequential impacts associated with increase in access and demand for natural resources.

Potential Mitigation Measures

The following mitigation measures have been identified for significant ecology and biodiversity issues:





Forest on hillslopes and Riverine forest are the most important habitats of conservation

concern in the wider Simbili pit area. Mining infrastructure should be planned outside the

forest patches and if this is not possible, a botanist should survey the affected forest well in

advance of the construction work to allow possible adjustments to be made.







Roads should be kept to the minimum width possible, commensurate with relevant design

and safety standards.







Minor in-stream infrastructure can constitute barriers to fish migration. Where possible, these

should be designed to be compatible with the passage of migratory stream organisms, and

crossings of any drainage lines or water bodies should have appropriate culverts built to

international environmental standards.







Plants belonging to species with conservation status Endangered (EN) or of Conservation

Importance (CR) should at all times be left undisturbed. Plants belonging to species with

conservation status Vulnerable (VU) should be left undisturbed as much as possible.



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STAGE 1 ENVIRONMENTAL, SOCIAL AND HEALTH IMPACT ASSESSMENT

TONKOLILI IRON ORE PROJECT







Species of conservation concern which were found on the deposits or near proposed

infrastructure should be relocated to suitable localities outside the project area, by way of

seed collection and / or translocation of specimens.







Replanting of vegetation should use indigenous species and should be based on silvicultural

systems that promote natural ecosystem functions and that increase the probability that

native species and ecological processes will be maintained. Planting of exotic species in

natural forest areas should not be permitted.







Establish and enforce a total ban on the hunting and capture of wildlife by company

employees and contractors.







Recognizing the importance of wildlife as a protein source to indigenous peoples, government

and the company should cooperate with local communities in the development of sustainable,

community-based wildlife management programs.







Project affected communities should be supported in the development of improved animal

husbandry techniques and provided with starter stocks. This would be a positive contribution

to the livelihoods of people and also reduce demand for bushmeat and limit the impact of

hunting restrictions on local communities.







The project should investigate the potential for supporting local plantations, which would be

beneficial to the project, local livelihoods and the remaining natural forests (and therefore,

also for fauna).







Work with government to explore opportunities to control and minimise the uncontrolled inmigration of people into areas newly opened-up by road construction, especially along the

roads themselves. Uncontrolled in-migration will lead to further forest and wildlife losses and

compound pressures on existing human communities.







Consider biodiversity offsets to compensate for the unavoidable habitat loss (including

vegetation and fauna).







Increased sedimentation in the aquatic environments due to mobilization of sediments may

subsequently result in a change in fish distribution, with more turbid-tolerant species

becoming prevalent. Best practice erosion and sediment control measures should be

implemented during construction to minimise the significance of this impact.



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AFRICAN MINERALS LIMITED

STAGE 1 ENVIRONMENTAL, SOCIAL AND HEALTH IMPACT ASSESSMENT

TONKOLILI IRON ORE PROJECT



Table 7-5 Mining Area – Ecology & Biodiversity Impacts

VR



Impacts



VR Category



Magnitude



Extent



Duration



Significance



5



Basic

Impact

Index

4



Major



Residual

Impact after

Mitigation

Major



5



3



4



3



5



4



Moderate



Moderate



3



3



5



4



Major



Major



3



3



4



3



Major



Moderate



4



3



5



4



Major



Major



4



3



5



4



Moderate



Moderate



3



3



5



4



Major



Major



3



3



4



3



Major



Moderate



3



3



5



4



Major



Major



Aspect

E1



Loss of biodiversity and sensitive habitat



E2



Loss of biodiversity and habitat



E3



Change in species richness and

abundance

habitat loss / disturbance / fragmentation

Decrease in species richness and

abundance through deterioration of

water quality in the area through

increased sedimentation



Land clearance

E4



High



Low



High



Blasting and Earth

Movement



Changes in drainage

pattern



High



E2



Loss of biodiversity and habitat



E3



Change in species richness and

abundance

habitat loss / disturbance / fragmentation

Decrease in species richness and

abundance through deterioration of

water quality in the area through

increased sedimentation or from runoff

of excess nitrates (used in blasting)



E4



Low



Best

international

practice to

be followed,

pending

further

evaluation

Area will be

affected

permanently



High



High



Loss of biodiversity and sensitive habitat

E1



Area will be

affected

permanently



High



Loss of biodiversity and sensitive habitat

E1



Reason for

Change



High



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Best

international

practice to

be followed,

pending

further

evaluation

Area will be

affected

permanently



AFRICAN MINERALS LIMITED

STAGE 1 ENVIRONMENTAL, SOCIAL AND HEALTH IMPACT ASSESSMENT

TONKOLILI IRON ORE PROJECT

VR



Significance



5



Moderate



Residual

Impact after

Mitigation

Moderate



3



5



4



Major



Major



3



3



5



4



Major



Major



Burial will be

permanent



2



1



4



2



Moderate



Minor



Burial of vegetation



3



2



4



3



Major



Major



Loss of biodiversity through exposure to

contaminated run-off



2



2



4



3



Minor



Insignificant



Burial of vegetation



4



3



4



4



Moderate



Moderate



Decrease in species richness and

abundance through changes in water

chemistry from runoff of excess nitrates

(used in blasting) or acid rock drainage

from the mining activities

Increased pressure on timber



3



4



4



4



Major



Minor



Adherence

to

international

best practice

Burial is

irreversible

Adherence

to

international

best practice

Burial is

irreversible

Adherence

to

international

best practice



3



4



4



4



Major



Major



3



3



4



3



Major



Major



E2



Loss of biodiversity and sensitive habitat



E3



Change in species richness and

abundance

habitat loss / disturbance / fragmentation

Direct modification of the aquatic

environments - loss of locally endemic

species

Loss of biodiversity through exposure to

contaminated run-off



E4



E1



E2



VR Category



Magnitude



Extent



Duration



Project induced influx

of workers and job

seekers



Low



4



3



3

High



High



High



Waste generation



Low



E4



Reason for

Change



Basic

Impact

Index

4



Impacts



Aspect



E1



High



High



Spread of alien invasive species



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Mitigation

will require

co-operation

between

AML and

local

partners –

pending

further

evaluation

Presently

unknown



AFRICAN MINERALS LIMITED

STAGE 1 ENVIRONMENTAL, SOCIAL AND HEALTH IMPACT ASSESSMENT

TONKOLILI IRON ORE PROJECT

VR



Impacts



VR Category



Magnitude



Extent



Duration



Aspect



Basic

Impact

Index



Significance



Residual

Impact after

Mitigation



Reason for

Change

pending

further

evaluation



E2



Increased pressure on timber

Spread of alien invasive species



E3



Increase in hunting

Displacement of fauna



2

Low

High



3



2



2



Insignificant



Insignificant



4



3



4



4



Moderate



Moderate



4

2



3

2



4

3



4

2



Major

Moderate



Major

Moderate



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AFRICAN MINERALS LIMITED

STAGE 1 ENVIRONMENTAL, SOCIAL AND HEALTH IMPACT ASSESSMENT

TONKOLILI IRON ORE PROJECT



7.2.4



Hydrology & Hydrogeology



Construction

Assessment of potential impacts on the hydrological and hydrogeological setting have been

conducted based on a Phase 2B – Reconnaissance Level baseline assessment carried out during

February March and April 2010. The following potential impacts have been identified during the

construction phase:





Erosion of exposed surfaces and loose material by wind, water and construction activities

generating higher sediment loads in surface runoff entering the Tonkolili and Mawuru Rivers

and their tributaries.







Increased potable and construction water demand may lead to over-abstraction of surface

water from nearby rivers leading to impacts on environmental flows and/or downstream users.







Uncontrolled discharge of sewage and other waste water to groundwater or directly to surface

water contaminating freshwater aquifers, waterways and impacting on human health and/or

aquatic ecosystems.







Uncontrolled release of drilling fluids associated with ongoing exploration, geotechnical or

hydrogeological drilling works. Potential impacts on aquatic ecosystems and downstream

potable water supply.



Operations





Modification and interruption of the existing hydrological regime of the Tonkolili and Mawuru

catchments. Excavation of the weathered cap of Simbili will interrupt the flow of several

springs discharging from the flanks of the deposit providing base flow to both rivers.







Alteration to the natural hydrologic regime of both catchments as excess water produced

during dewatering of the weathered cap is discharged.







Increased flood risk and/or increased flow rates in rivers following storm events due to the

loss of the buffering capacity of the Simbili weathered cap aquifer.







Increased water demand on site may lead to over abstraction from surface water bodies

leading to reduced environmental flows and impacts on downstream users.







Generation of contaminated runoff where rainfall infiltration comes in contact with stockpiled

waste rock. Rainfall infiltrating through the Phase 1 waste rock dump may become acidic

and/or leach metals from the waste rock before entering groundwater and surface water. Low

natural chemical buffering potential of groundwater and surface water exacerbates this risk.







The use of specific units of waste rock that may potentially be acid generating for construction

purposes could lead to surface and groundwater contamination.



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STAGE 1 ENVIRONMENTAL, SOCIAL AND HEALTH IMPACT ASSESSMENT

TONKOLILI IRON ORE PROJECT







Increased recharge of rainfall to groundwater beneath waste rock dumps. The porous waste

rock dump may promote greater rainfall recharge and create a localised groundwater mound

beneath the dump potentially water-logging surrounding soils.







Uncontrolled release of toxic chemicals to the environment. A range of chemicals will be

stored and used during construction and mining activities. The most common chemicals

likely to be used are hydrocarbons (diesel fuel, oil and grease) and solvents. Where toxic

chemicals are present, the potential for spillages will exist.



Potential Mitigation Measures

The following mitigation measures have been identified for hydrology and hydrogeology issues that

are considered to have a significant impact:





Robust surface and groundwater monitoring programmes in order to establish comprehensive

baseline and identify any impacts to flows, turbidity and chemistry.







Treatment of all potentially contaminated wastewater sources prior to discharge to ground or

surface.







Acid Mine Drainage (AMD) study to assess likelihood of formation of acid waters from waste

rock dumps or areas where waste rock may be used as a fill or construction material.







Acid-base accounting of waste rock material to be applied in assessment of optimal dump

locations.







Appropriate engineering design measures to contain and capture potentially contaminated

water escaping rock dumps.







Detailed hydrological study to determine minimum required environmental flows in rivers

which may be affected by construction and mining operations.







Hydrochemical environmental study to determine potential sensitivity of local receptors to

changes in surface water and groundwater chemistry.



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AFRICAN MINERALS LIMITED

STAGE 1 ENVIRONMENTAL, SOCIAL AND HEALTH IMPACT ASSESSMENT

TONKOLILI IRON ORE PROJECT



Table 7-6 Mining Area - Hydrology & Hydrogeology

Aspect



VR



Impacts



VR Category



Magnitude



Extent



Duration



Basic

Impact

Index



Significance



Residual

Impact after

Mitigation



Land clearance



SW1



Higher sediment loads in surface runoff

entering the Tonkolili and Mawuru rivers

and their tributaries (construction)



High



3



2



3



3



Major



Moderate



Blasting and

earthworks



SW2



Reduced surface water resources

(construction and operation)



High



2



2



5



3



Major



Major



SW2



Flooding (operational)



High



3



3



5



4



Major



Moderate



High



2



2



4



2



Moderate



Insignificant



High



2



2



4



2



Moderate



Insignificant



SW1



GW1



Surface water contamination from

uncontrolled use of acid generating

waste rock for construction purposes

(operational)

groundwater contamination from

uncontrolled use of acid generating

waste rock for construction purposes

(operational)



GW1



Contamination of water resources from

uncontrolled release of sewage and

other waste waters (construction)



High



3



3



2



4



Major



Insignificant



SW1



Contamination of water resources from

uncontrolled release of sewage and

other waste waters (construction)



High



3



3



2



4



Major



Insignificant



SW1



Contamination of surface waters from

uncontrolled release of drilling fluids

(construction)



High



2



2



2



2



Moderate



insignificant



SW1



Contamination of surface water



High



3



3



4



4



Major



Moderate



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Page 145

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Reason for

Change

Adherence

to

international

best practice

Impact will

be

permanent

Appropriate

design and

international

best practice

Detailed

studies,

adherence to

international

best practice

Detailed

studies,

adherence to

international

best practice

Adherence

to

international

best practice

Adherence

to

international

best practice

Adherence

to

international

best practice

Detailed



AFRICAN MINERALS LIMITED

STAGE 1 ENVIRONMENTAL, SOCIAL AND HEALTH IMPACT ASSESSMENT

TONKOLILI IRON ORE PROJECT



Aspect



VR



Impacts



VR Category



Magnitude



Extent



Duration



Basic

Impact

Index



Significance



Residual

Impact after

Mitigation



resources from contaminated runoff

(acidic and/or high metal concentrations)

(operational)



Resource utilisation



GW1



Contamination of groundwater resources

from contaminated runoff (acidic and/or

high metal concentrations) (operational)



High



3



2



4



4



Major



Moderate



GW2



Water logging of soils around waste rock

dump (operational)



High



1



1



4



2



Moderate



Insignificant



GW2



Reduced groundwater resources in

vicinity of camps where water may be

derived from groundwater (construction

and operation).



High



2



2



4



4



Major



Insignificant



SW1



Uncontrolled release of fuels and toxic

chemicals (construction and operational)



High



3



3



2



4



Major



Moderate



GW1



Uncontrolled release of fuels and toxic

chemicals (construction and operational)



High



2



2



4



4



Major



Minor



Chemical / fuels

storage and

utilisation



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Reason for

Change

studies,

adherence to

international

best practice

Detailed

studies,

adherence to

international

best practice

Engineering

design and

adherence to

international

best practice

Detailed

studies,

appropriate

design and

location of

abstractions

and water

resources

management

plan

Engineering

design and

adherence to

international

best practice

Engineering

design and

adherence to

international

best practice



AFRICAN MINERALS LIMITED

STAGE 1 ENVIRONMENTAL, SOCIAL AND HEALTH IMPACT ASSESSMENT

TONKOLILI IRON ORE PROJECT



7.2.5



Soils & Land Use



Construction

The principal direct impact will arise from land clearance or sterilisation / burial, leading to long-term

or permanent loss of soil resources and existing land-use capabilities at Simbili. Additional impacts

on soils that are not cleared or sterilised include contamination by windblown dusts (from bare

ground, blasting activities and plant movements), increased erosion or inundation due to the

modification of drainage patterns, compaction from vibration and loading under temporary

stockpiles/structures, contamination with hydrocarbons and other chemicals including diesel and

lubricant oils and explosives residues. Invasive species may also spread to undisturbed land following

natural colonisation or deliberate introduction in disturbed areas (where such species tend to thrive).

Operations

Operational stage works in the mine area will primarily result in ongoing impacts for soil and land use

as defined for the construction stage. Land clearance or sterilisation will increase with development

of the resource strip and associated infrastructure and expansion of waste dumps and access routes.

Potential Mitigation Measures

The following mitigation measures have been identified for soils and land use issues that are

considered to have a significant impact:





Minimise land / soil to be cleared or buried and concentrate such activities in areas with

limited soil quality and land-use capability.







Consider biodiversity offsets for unavoidable long-term and permanent soil / land clearance

and soil / land burial. Integrate livelihoods components as necessary with offsets to replace

lost land-use capability.







Prior to commencement of mining, prepare a waste rock management plan and rehabilitation

programme to include designs for progressive rehabilitation/re-vegetation of suitable areas

throughout the mining lifecycle in order to minimise cleared / buried areas. Inspect and

monitor rehabilitated surfaces to establish success of revegetation and soils recovery.







Implement appropriate conservation and preservation of stripped top-soils and sub-soils from

all areas to retain physical and chemical characteristics and seed-bank for subsequent use

for rehabilitation activities.







Implement required storm water drainage and control prior to prevent erosion of exposed

areas and inundation of down-slope areas.







Minimise access by vehicles to essential areas to reduce compaction of soils.







Isolate and manage potential soil contaminants (including wind blown dusts and water-borne

contaminants).



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TONKOLILI IRON ORE PROJECT







Avoid disturbance / exposure of acid sulphate soils if present.







Avoid deliberate introduction of alien invasive species during rehabilitation activities.







Manage pathways by which alien invasive species can enter a disturbed area (including

avoidance of non-indigenous plant species in rehabilitation activities).







Undertake studies to determine appropriate recolonisation programme for impacted areas.



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STAGE 1 ENVIRONMENTAL, SOCIAL AND HEALTH IMPACT ASSESSMENT

TONKOLILI IRON ORE PROJECT



Table 7-7 Mining Area - Soils and Land Use

Aspect



VR



Impacts



S1



Changes in quality/available land due to

invasive species colonising disturbed

areas



Land clearance

S2



S2



Stripping of vegetation and surface soils

overlying hematite may lead to

increased soil erosion



Loss of soils/land available for other

uses



VR Category



Magnitude



Extent



Duration



Basic

Impact

Index



Significance



Residual

Impact after

Mitigation



Medium



2



3



4



4



Major



Moderate



Medium



2



2



4



3



Moderate



Insignificant



Medium



2



2



4



3



Moderate



Insignificant



Medium



2



2



4



3



Moderate



Moderate



Medium



2



2



3



2



Minor



Insignificant



Compaction associated with vibration,

loading

S2

Blasting and

earthworks

S1



Chemical / fuels

storage and

utilisation



Areas in and around the mine may be

impacted by wind blown dust from bare

ground, earth moving, stockpiles and

plant movements on unsurfaced roads.



S2



Flooding (operational)



Medium



2



2



4



3



Moderate



Insignificant



S1



Uncontrolled release of fuels and toxic

chemicals (construction and operational)



Medium



2



2



4



3



Moderate



Insignificant



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Reason for

Change

Appropriate

design and

international

best practice

Appropriate

site

management

and

international

best practice

Long term

rehabilitation

and

international

best practice

Appropriate

site

management

and

international

best practice

Appropriate

site

management

and

international

best practice

Appropriate

design and

international

best practice

Engineering

design and

adherence to



AFRICAN MINERALS LIMITED

STAGE 1 ENVIRONMENTAL, SOCIAL AND HEALTH IMPACT ASSESSMENT

TONKOLILI IRON ORE PROJECT



Aspect



VR



Impacts



VR Category



Magnitude



Extent



Duration



Basic

Impact

Index



Significance



Residual

Impact after

Mitigation



Reason for

Change

international

best practice



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AFRICAN MINERALS LIMITED

STAGE 1 ENVIRONMENTAL, SOCIAL AND HEALTH IMPACT ASSESSMENT

TONKOLILI IRON ORE PROJECT



7.2.6



Geology & Geomorphology



Construction

The impacts associated with major mine construction such as stripping of surface vegetation, soils,

and deposits include changes in slope stability and topography and local drainage and spring flow.

Operations

Impact of the mining inevitably includes loss of the non renewable resource itself. Mining in general

can commonly sterilise associated deposits of lower value or undiscovered resources making them

effectively inaccessible beneath waste rock and tailings. Some of the low value ‘sterilised’ deposits

may become economically viable in the future with increase in market value of the commodity.

There will be major changes to the landscape with the top of Simbili hill being effectively removed

while substantial overburden and rock waste dumps will be formed nearby.

Stripping of overburden will be followed by mining of the hematite which will lead to further impacts on

topography and drainage as it forms the upper Simbili hill outcrop. However the hematite also

overlies BIF deposits that are to be mined under Phase 3 and ultimately the entire hill will be mined

out and an opencast pit extend beneath ground level. Phase 3 and associated cumulative impacts

will be addressed in a Stage 2 ESHIA report.

Mining of the upper hematite deposit will initiate changes in runoff patterns and erosion and

sedimentation rates potentially impacting permanently on local geomorphology. Construction of mine

infrastructure may have similar but lower level impacts.

Blasting of hard rock layers throughout the mining may destabilize soils and trigger landslides with

very localized impacts on geomorphology.



Potential Mitigation Measures

The following mitigation measures have been identified for geology and geomorphology issues that

are considered to have a significant impact:





Although a major impact, the loss of the exploitable ore body is the purpose of the mining

activity. The impact can be outweighed by the opportunity presented by exploitation of the

resource though adherence to a resource management and mine plan which maximises the

efficiency of resource extraction and ensures that stakeholders derive the maximum potential

benefit. Without appropriate considered management through processes such as ESHIA and

good governance, potential long term detrimental impacts on the local and national economy

and community can outweigh the short term gains.







Risk of sterilising future resources can be mitigated in part by ensuring adequate exploration

has been completed both for definition of the ore body to be exploited and areas that will be



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TONKOLILI IRON ORE PROJECT



covered by waste rock, tailings and other major structures such as the raw water supply dam

and associated inundation zone. However there is a limit to mitigation that can be applied to

prevent sterilisation of low grade deposits that may become economically viable in the future.

Such deposits may inevitably be lost as potential future resources due to burial beneath

waste materials or further to flooding of mined out pits.





Geomorphological mitigation measures include the preservation of watercourses (where

possible) and diversion of watercourses around infrastructure to maintain downstream

drainage patterns, rehabilitation and revegetation of disturbed areas, and re-contouring

disturbed areas to original topography (to the extent possible).







Appropriate management measures need to be addressed (see Commitments Register ,

section 12) to avoid instabilities include appropriate mine design (so that slopes do not fail),

adopting the correct slope angle, benching of slopes, including appropriate drainage around

the slopes (and the toe and crest of the slopes) and incorporating stand offs at the base of the

slopes to prevent impacts on people if instabilities do occur.







Reclaim and rehabilitate land disturbed during construction and operation by re-grading, recontouring and replacing topsoil following closure and decommissioning.







Reuse excavated material, where possible, for further construction and earth works, in order

to minimise the necessity for construction-associated quarrying in the area.







Reduce harmful effects on the shape of the landscape (scars) through minimising the

development of potential geotechnical failure surfaces. Well-designed blasting programmes

and mining techniques should be followed to minimise the creation of these geotechnical

issues.



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Table 7-8 – Mining Area – Geology & Geomorphology

Aspect



VR



Impacts



V1



Mining and associated dumping of waste

rock may sterilise areas of resources

making them non economically viable for

future exploitation.



V1



Changes to profile of Simbili and runoff

may lead to increased sedimentation in

some areas and changes in drainage

patterns



VR Category



Magnitude



Extent



Duration



Basic

Impact

Index



Significance



Residual

Impact after

Mitigation



Low



2



2



5



4



Moderate



Moderate



Low



2



2



5



4



Moderate



Insignificant



V1



Stripping of vegetation and surface soils

overlying hematite and construction of

mining roads may destabilise slopes and

change soil water pressure regime

leading to increased risk of landslides



Low



2



2



5



5



Moderate



Insignificant



V1



Stripping and mining will change the

landform and impact on the visual

landscape. The hill which forms the

hematite outcrop will ultimately be

removed



Low



3



3



5



5



Moderate



Moderate



V1



Mining and associated dumping of waste

rock may sterilise areas of resources

making them non economically viable for

future exploitation.



Low



2



2



5



4



Moderate



Insignificant



V1



Blasting may destabilise soils and trigger

landslides with risk enhanced by

changes in topography and groundwater

regime caused by other mining activities.

Lidar data indicates the presence of past



Low



2



2



5



5



Moderate



Insignificant



Land clearance



Blasting and

earthworks



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Reason for

Change

Long term

rehabilitation

and

international

best practice

Engineering

design and

adherence to

international

best practice

Engineering

design and

adherence to

international

best practice

Irreversible.

Long term

rehabilitation

and

international

best practice

Long term

rehabilitation

and

international

best practice

Engineering

design and

adherence to

international

best practice



AFRICAN MINERALS LIMITED

STAGE 1 ENVIRONMENTAL, SOCIAL AND HEALTH IMPACT ASSESSMENT

TONKOLILI IRON ORE PROJECT



Aspect



VR



Impacts



VR Category



Magnitude



Extent



Duration



Basic

Impact

Index



Significance



Residual

Impact after

Mitigation



Reason for

Change



Insignificant



Long term

rehabilitation

and

international

best practice



landslides in the area probably

associated with relatively loose

sediments / weathered material

overlying solid bedrock on hill slopes

and episodes of high rainfall



Waste Generation



V1



Waste rock dumps will change the

landform and impact on the visible

landscape.



Low



2



2



4



4



Moderate



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7.2.7



Socio-Economic



Construction

Land acquisition

Depending on the final footprint area for hematite mining, some villages may require resettlement.

Villages on the periphery of mining area will suffer loss of land resulting in loss of shelter, loss of

access to agricultural land, artisanal mining sites and natural resources leading to decrease in

economic stability. There are also likely to be graves and sacred sites within the footprint area that will

require relocation.

Land acquisition related impacts can result in long-term and severe impacts on social and economic

well being of affected populations.



Operations

The socio-economic benefits of hematite mining (lasting about 8 years) will mainly be in the form of

wages, disbursement for the procurement of supplies, social investments and payment of revenue to

the government. The negative impacts will mainly be due to disturbance to land owners and influx of

workers and job seekers.

Economic aspects

The economic impacts are mainly beneficial in nature:





Mining will generate employment during both construction and operation phases. It will

mainly benefit Kalansogia and neighbouring chiefdoms, although skilled manpower will

also be sourced from other districts.







Business opportunities for suppliers and contractors at the district and national levels.







Payment to Government of Sierra Leone in the form of taxes, royalties and duties.



Project induced influx of workers and job seekers

The economic opportunities created by the Project are expected to lead to an influx of workers and

job seekers (as has already happened in Farangbaia Village). This can result in the following

negative impacts:





Pressure on social infrastructure and natural resources.







Increases in social ills such as crime, alcoholism, drug abuse and prostitution.







Increases in communicable diseases due to intermingling of the local population with

outsiders.







Increases in the cost of living and potential for conflict with migrants.



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Community investment

The social investment programme of AML developed in consultation with local stakeholders is

expected to result in the following benefits to the community:





Increases in education and skills levels.







Improvement in social infrastructure such as water supply, schools and health centres.







Development of livelihood opportunities, independent of the mine.







Other initiatives to address community needs.



Mine closure

Closure impacts have not been assessed for the Phase 1 project as completion of hematite mining

will lead into the larger magnetite mining project.



Potential Mitigation Measures

Construction

The following mitigation measures are expected to reduce the intensity of the residual impacts from

major to moderate/minor.





Preparation of a Resettlement Action Plan (RAP).







Preparation of a livelihood restoration plan.







Implementation of a grievance mechanism.







Preparation and implementation of a Community Development Plan.



Operations

Project induced influx of workers and job seekers

The following mitigation measures are expected to minimise the impacts from major to

moderate/minor:





Planning with relevant stakeholders to minimise speculative migration.







Providing assistance to local government to increase (and improve) infrastructure

services.







Communication to minimise tensions associated with non-local recruitments.







Providing assistance to local health department (and NGOs) to strengthen programmes

for control of communicable diseases and educational programmes



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Table 7-9 Mining Area – Socio-economic Impacts

VR



Impacts



VR Category



Magnitude



Exten

t



Duration



Significance



2



Basic

Impact

Index

2.3



Moderate



Residual

Impact after

Mitigation

Moderate (+)



2



3



1



3



3



2.3



Moderate



Major (+)



1



3



3



2.3



Moderate



Major (+)



2



4



2



2.7



Major



Moderate (+)



1



4



3



2.7



Major



Major (+)



1



4



3



2.7



Major



Major (+)



3



1



4



2.7



Major



Low



Aspect

employment creation (construction)

High



employment creation (operation)

High

Economic aspects

(employment,

procurement of

services and supplies,

and payment of taxes

and revenue to

government)



Training of workers

High

H1



Increase in business for suppliers

(construction)



Increase in business for suppliers

(operation)



High



High



Increase in government income

High



Land acquisition



H1



Loss of land



High



Loss of shelter



High



2



1



4



2.3



Moderate



Moderate (+)



Loss of income



High



3



2



4



3



Major



Minor



Loss of access route



High



3



2



4



3



Major



Moderate



Reason for Change



Priority given to locals

during recruitment

process although skills

availability is expected to

be limited

Priority given to locals

during recruitment

process

Considerable skills

enhancement injected

into the area

Priority given to locals

during tender process

although availability is

expected to be limited

Priority given to locals

during tender process

although availability is

expected to be limited

Revenue from project

taxes, royalties, etc

expected to be major

contributor to GoSL GDP

Provision of alternative

land

Provision of replacement

housing of superior

quality in most

circumstances

Implement livelihood

restoration plan

Identify and provide

alternative routes or

crossing methods



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VR



Impacts



Significance



4



Basic

Impact

Index

3



Major



Residual

Impact after

Mitigation

Minor



2



4



2.7



Major



Minor



2



2



3



2.3



Moderate



Minor



VR Category



Magnitude



Exten

t



Duration



Reduced food security



High



3



2



Breakdown social support



High



2



Aspect



Increase in stress

High



H1



Project induced influx

of workers and job

seekers



Project induced



Communit



Community investment



y



Reduced access to services



High



2



2



2



2



Moderate



Moderate (+)



Community conflict



High



2



1



2



1.7



Moderate



Minor



Pressure on social infrastructure

due to increase in population

Pressure on natural resources due

to increase in population

Increase in social ills (crime,

alcoholism and prostitution)



High



4



2



3



3



Major



Moderate (+)



High



4



2



3



3



Major



Moderate



High



4



2



3



3



Major



Moderate



Increase in communicable

diseases



High



4



2



3



3



Major



Moderate



Increase in cost of living

Tensions between locals and

outsiders due to real or perceived

unequal access to project benefits

Social infrastructure



High

High



3

2



2

2



3

3



2.7

2.3



Major

Moderate



Moderate

Minor



3



2



4



3



Major



Moderate (+)



Education and skills



High



3



2



4



3



Major



Major(+)



High



Reason for Change



Provision of alternative

land and transitional

support mechanisms

Relocate all villagers to

the same host site

village.

Regular consultation and

publicising grievance

mechanism with PAPs

Provision of replacement

social infrastructure likely

to provide increased

access to service

Effective and broad

stakeholder engagement

Provision of replacement

social infrastructure

Effective and broad

stakeholder engagement

Effective and broad

stakeholder engagement

together with support

from appropriately

positioned NGOs

Effective and broad

stakeholder engagement

together with support

from appropriately

positioned NGOs

Influx management.

Influx management and

regular consultation

Provision of replacement

social infrastructure

Training programs



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VR



Impacts



VR Category



Magnitude



Exten

t



Duration



3



2



4



Aspect

Livelihoods



Significance



Major



Residual

Impact after

Mitigation

Major(+)



-



-



-



Increased income from

direct and indirect

employment

-



-



-



-



-



-



-



-



-



-



-



-



-



High

H1



Mine closure



Loss of income for workers,



High



Loss of businesses



High



Loss of revenue to government



High



Psychological impacts



High



Closure impacts have not been

assessed for the Phase 1 project

as completion of hematite mining

will lead onto the larger magnetite

mining project.



Reason for Change



Basic

Impact

Index

3



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TONKOLILI IRON ORE PROJECT



7.2.8



Human Health



Construction & Operations

Based on the current available project and existing health information, preliminary impacts at Phase 1

have been identified for the mine area. It is important to note, that the Project description has not

been finalized, nor has all the baseline data been analysed, therefore, the qualitative impact

designations and significance may change as the Phase 1 details are finalized.

The preliminary health impacts associated with Phase 1 mine area are described below. Impacts

relate to both phases of the project (construction and operation) unless otherwise stated.

Potential negative impacts of major significance:





Community resettlement;







In-migration related impacts (disease, food security, substance abuse, home violence);







Increased burden of disease due project activities and water storage facilities (drinking water

tanks, waste and raw water storage ponds);







Degradation and/or reduction of surface water (sedimentation/erosion, contamination, changes in

drainage patterns); and







Degradation of groundwater quality.



Potential negative impacts of moderate significance:





Increased road traffic accident rate (during operation phase);







Impacts of noise on health and well-being (blasting and heavy vehicle activity); and







Reduction in quality or quantity of locally produced foods.



Potential negative impacts of minor or insignificant significance:





Increased road traffic accident rate (during construction phase);







Exposure to increased levels of particulate matter (PM) (diesel power generators, crushers,

blasting, vehicles, road dust; assuming no thermal power generation requirements); and







Acute exposure to elevated SO2 and NO2 in air (diesel power generators, heavy vehicle

emissions) (assuming no thermal power generation requirements).



Potential positive impacts:





Access to improved healthcare facilities (for general public);







Health benefits to AML employees and through local employment;







AML financed community development initiatives;



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Improved access to the region; and







Positive aspects of resettlement.



A number of assumptions were made for the preliminary impact assessment specific to the Phase 1

mine area. It was assumed that all communities on or within 500 m of the Project area were resettled

to a distance greater than 500 m before construction associated with each pit area is begun. Thus,

the Health VR used in the preliminary impact assessment for exposure to particulate matter (PM),

SO2, and NO2 was categorized as Medium (an AML employee, or HR2 see Table 7-1).

Also, with respect to PM, SO2, and NO2 emissions, it was assumed that a thermal power generating

facility (a potentially significant generator of these types of emissions) will not be built at the mine site.

If power generation arrangements are altered significantly from those described in Section 3, this

preliminary impact will require re-assessment. Should a thermal power generator be implemented, the

significance of the impact and the sensitivity of the VR would be expected to increase.

The positive class impacts associated with access to healthcare facilities only apply if AML undertake

to provide these facilities.

Where there was uncertainty in significance designation, the more conservative assumption was

selected so as to ensure that the preliminary potential impact of the Project was not underestimated.



Potential Mitigation Measures

Potential mitigation measures have been identified in association with each headline health impact as

listed below. The headline impacts were identified with the assumption that no mitigating measures

were applied. Thus, implementation of the recommended mitigating measures is expected to reduce

the significance of the headline health issues and thus avoid potentially major health issues for

persons living in the vicinity of the Phase 1 mine area.

Health related mitigation measures are listed below, however, it is important to note that mitigation

recommended by the other disciplines, particularly socio-economic as well as other environmental

assessments (e.g., air, surface and groundwater, flora and fauna) can also affect human health.

Alteration of the current project description and further monitoring results may result in the

recommendation of additional mitigation measures, or modification of those currently recommended.

Community resettlement





Social mitigation measures regarding loss of land and re-settlement (see social assessment

results and mitigation measures).



In-migration related impacts (disease, food security, substance abuse, home violence)





Adherence to the requirements of the Prevention and Control of HIV and AIDS Act.







Appropriate education of workforce regarding transmittable diseases.







Employing local labour where appropriate.



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Providing suitable healthcare facilities.







See social assessment results and mitigation measures.



Increased burden of disease due to project activities, and water storage facilities (drinking water

tanks, waste and raw water ponds).





Awareness and control of mosquito breeding sites to prevent malaria incidence.







Appropriate treatment of drinking water.







Providing suitable healthcare facilities.







Appropriate management of waste water ponds, including odour controls.



Degradation and/or reduction of surface water (sedimentation/erosion, contamination, changes in

drainage patterns, dam construction)





Management and remediation of any contamination associated with storage of fuels, waste

water and other hazardous materials.







Management of surface and storm water run-off.







Implementation of surface water management practices to prevent/reduce sedimentation,

contamination, and changes in drainage patterns of local rivers and streams.



Degradation of groundwater quality





Mining and deposition of the products of the mining operations are required to be conducted

in such a way that the possibility of groundwater disruption or contamination is avoided.







Remediation of pits, and waste piles.







Monitoring of water quality in groundwater wells used for drinking water.



Dug out pits (standing water, falling hazard, land slides, impede access to agricultural or fishing

locations).





Implementation of controls to keep local persons and animals out of potentially dangerous

areas during remediation of mined areas.







Remediation of mined pits.



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Table 7-10 Mining Area – Health

Aspect



VR



Impacts

Increased road traffic accident rate



Construction



H2



Exposure (inhalation) to increased

levels of dust and particulate

matter (PM) (potential emissions

from diesel power generators,

crushers and vehicles)

Exposure (inhalation) to elevated

sulphur dioxide (SO2) and nitrogen

dioxide (NO2) in air emissions

(from power generator, crushers

and vehicles).

Health benefits through local

3

employment

2

Community resettlement



H1



VR

Category

Medium



Medium



Residual

Impact

after

4

Mitigation



Magnitude



Extent



Duration



Basic

Impact

Index



Significance



2



1



1



1.3



Minor



2



1



1



1.3



Insignificant



2



1



1



1.3



Insignificant



4



3



4



3.7



Major



Moderate



3



3



3



3.0



Major



Moderate



1



Medium



1



Medium



1



High



In-migration related impacts

(disease, food security, substance

abuse, home violence)



High



4



Reason for change



• Compliance with

recommended mitigation

measures.

• Resettlement is

permanent.

• Level of public concern

unknown.

• Moderate confidence in

data (requires interpretation

of social assessment with

respect to Human health

impacts)

• Compliance with

recommended mitigation

measures.

• Level of public concern

unknown.



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Aspect



VR



Impacts



VR

Category



Magnitude



Extent



Duration



Basic

Impact

Index



Significance



Residual

Impact

after

4

Mitigation



4



Reason for change



• Low confidence in data.

Increased burden of disease due

to project activities (drinking water

tanks, waste and raw water ponds)



High



Impacts of noise on health and well

being (blasting and heavy vehicle

activity)



High



Degradation and/or reduction of

surface water

(sedimentation/erosion,

contamination, changes in

drainage)

Degradation of groundwater

quality.



Reduction in quantity or quality of

locally produced foods through

land appropriation and clearance,

potential siltation of rivers/streams)



Operation



H2



Access to improved healthcare

3

facilities

Increased road traffic accident rate



3



3



3



3.0



Major



Moderate/

Minor



3



2



1



2.0



Moderate



Minor



4



3



3



3.3



Major



Moderate



2



3



4



3.0



Major



Moderate



3



1



3



2.3



Moderate



Moderate/

Minor



2



1



2



1.7



Moderate



Minor



High



High



High



• Compliance with

recommended mitigation

measures.

• Level of public concern

unknown.

• Low confidence in data.

• Compliance with

recommended mitigation

measures.

• Level of public concern

unknown.

• Low confidence in data.

• Compliance with

recommended mitigation

measures.

• Level of public concern

unknown.

• Low confidence in data.

• Compliance with

recommended mitigation

measures.

• Level of public concern

unknown.

• Low confidence in data.

• Compliance with

recommended mitigation

measures.

• Level of public concern

unknown.

• Low confidence in data.



High

Medium



1



• Compliance with

recommended mitigation



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TONKOLILI IRON ORE PROJECT



Aspect



VR



Impacts



VR

Category



Magnitude



Extent



Duration



Basic

Impact

Index



Significance



Residual

Impact

after

4

Mitigation



4



Reason for change



measures.

• Level of public concern

unknown.

• Low confidence in data

(no traffic study).

Exposure (inhalation) to increased

levels of dust and particulate

matter (PM) (potential emissions

from diesel power generators,

crushers and vehicles)

Exposure (inhalation) to elevated

sulphur dioxide (SO2) and nitrogen

dioxide (NO2) in air emissions

(from power generator, crushers

and vehicles).

Health benefits through local

3

employment

2

Community resettlement



2



2



2



2.0



Minor



2



2



2



2.0



Minor



High



4



3



4



3.7



Major



Moderate



High



3



3



3



3.0



Major



Moderate



Medium



1



Medium



1



Medium



1



H1



In-migration related impacts

(disease, food security, substance

abuse, home violence)



• Compliance with

recommended mitigation

measures.

• Resettlement is

permanent.

• Level of public concern

unknown.

• Moderate confidence in

data (requires interpretation

of social assessment with

respect to Human health

impacts)

• Compliance with

recommended mitigation

measures.

• Level of public concern

unknown.

• Low confidence in data.



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Aspect



VR



Impacts



VR

Category



Increased burden of disease due

to project activities (drinking water

tanks, waste and raw water ponds)



High



Impacts of noise on health and well

being (blasting and heavy vehicle

activity)



High



Degradation and/or reduction of

surface water

(sedimentation/erosion,

contamination, changes in

drainage)

Degradation of groundwater

quality.



Reduction in quantity or quality of

locally produced foods through

land appropriation and clearance,

potential siltation of rivers/streams)



Residual

Impact

after

4

Mitigation

Moderate/

Minor



Magnitude



Extent



Duration



Basic

Impact

Index



3



3



3



3.0



Major



3



2



2



2.3



Moderate



Minor



4



3



3



3.3



Major



Moderate



2



3



4



3.0



Major



Moderate



3



1



3



2.3



Moderate



Moderate/

Minor



Significance



High



High



High



4



Reason for change



• Implementation of

recommended malarial

control measures and

odour control measures for

standing water.

• Compliance with

recommended mitigation

measures.

• Level of public concern

unknown.

• Moderate confidence in

data.

• Compliance with

recommended mitigation

measures.

• Level of public concern

unknown.

• Low confidence in data.

• Compliance with

recommended mitigation

measures.

• Level of public concern

unknown.

• Low confidence in data.

• Compliance with

recommended mitigation

measures.

• Level of public concern

unknown.

• Low confidence in data.

• Compliance with

recommended mitigation

measures including those

associated with

resettlement.



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Aspect



VR



Impacts



VR

Category



Magnitude



Extent



Duration



Basic

Impact

Index



Significance



Residual

Impact

after

4

Mitigation



4



Reason for change



• Level of public concern

unknown.

• Low confidence in data.

Access to improved healthcare

3

facilities



High



1



Assuming all communities are >500m away.

2

Could be a positive impact if well compensated and/or moved to a better location.

3

Positive impacts.

4

Estimated for Impacts with Moderate or Major Significant only.



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Transport Corridor



7.3

7.3.1



Air Quality



Construction

The air quality impacts produced during the haul road construction and rail refurbishment are

common to the other project construction activities:





Dust emissions during vegetation clearance along the haul road route and temporal access

routes for the construction phase.







Particles emissions caused by earth movements: creation of temporary access routes and

grading and levelling of the haul road route.







Material and waste management: dust emissions during loading and unloading activities and

wind erosion of the stockpiles.







Vehicles transport and operation of heavy equipment will generate exhaust emissions and

increase dust due to movements over unpaved roads.



It should be noted that some sections of the transport corridor are close to populated areas. At these

locations, mitigation measures described below should be implemented.

Operations

Air emissions will depend on the frequency and the fuel consumption of vehicles that travel the haul

road (approximately 120 km long) and the train emissions between Marampa and Pepel. The

contaminants of potential concern are listed below:





Exhaust emissions from the vehicles and the train (NOx, SO2, PM10 and CO)







Dust from the material transport and the haul road traffic. These emissions will be mainly

coarse particulate matter larger than 10 µm with little effect on human health, but with

potential effects on vegetation and on near residents due to disturbance.



Exhaust gas emissions can be controlled by minimising fuel consumption and maintaining train and

truck motors. Dust emissions can be controlled by covering wagons and trucks to avoid airborne

particulate matter.

The potential impact on air quality will be restricted to a buffer zone along the haul road and the

railway. As detailed in the project description, all villages were provided with a clearance of at least

500 m during the route selection assessment. Topographical constraints do not allow for avoiding all

of the residential areas along the haul road and the train corridor. For those populated areas located

close to the transport corridor, additional mitigation measures should be implemented



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Additionally, a stockpile with an approximate capacity of 4 million tonnes will be located at Lunsar

Interchange. Storage piles may be sources of dust emissions during loading and unloading activities

and due to wind erosion of the pile.

The potential for particles emissions will depend on the stored material size, the total stockpile

surface and the wind speeds. Emissions can be reduced by up to 90 percent with appropriate

mitigation measures (USEPA, AP42, ref 13.2.4-1).

Loading mining product onto the train wagons should be conducted using a Car Dumper Dust

Collector to minimise dust emissions. The Car Dumper Dust Collector will filter dust emissions with an

efficiency of 99%.

Potential Mitigation Measures

The following recommendations for reducing impacts on air quality from activities associated with

transport corridor construction are generic mitigation measures that should be applied during the

entire construction phase.





Dust suppression measures should be applied, such as spraying water during dry seasons on

unpaved roads and stockpiles. Vehicle movements should be minimised, truck loads should

be covered with mesh to avoid dust emissions, and discharge heights from trucks should not

typically exceed 1 m.







Exhaust emissions should be minimised through the use of fuel efficient machinery and

appropriate machinery maintenance. Unnecessary journeys should be avoided, and a policy

of switching off machinery when not in use should be implemented. Uncontrolled fires will be

prohibited.



The negative impacts on air quality during the operation of the transport corridor can be minimised

through the following measures:





Avoid unnecessary journeys and optimise transport traffic







Regular maintenance of vehicles and machinery







Avoid airborne dust during transport by covering the truck and train loads, and/or select

closed wagons for transport by train







Minimise discharge heights (not to exceed 1 m) for fine particles and consider the use of dust

suppression spray systems







Spray trailer boxes, wheels and undersides with water before leaving the mine site







Suppress dust emissions from the stockpiles during dry periods by spraying the surface with

water.



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Table 7-11 Transport Corridor – Air Quality Impacts

Aspect



VR



Impacts



Land clearance, earth movements

and construction



A1



Material transportation

A1



Stockpiles

A1



Power supply at Lunsar

A1



Traffic (road train, rail train and other

vehicles)



A1



Uncontrolled fires



A1



VR

Category



Magnitude



Extent



Duration



Basic

Impact

Index



Significance



Dust emissions. Particle

deposition on vegetation.

Visibility reduction



High



2



2



1



2



Moderate



Residual

Impact

after

Mitigation

Minor



Dust emissions. Particle

deposition on vegetation.

Visibility reduction. Health

effects



High



3



2



4



3



Major



Minor



Dust emissions (coarse and

fine particles). Particle

deposition on vegetation.

Visibility reduction. Health

effects

Exhaust emissions (SO2, CO,

NO2, PM10 and PM2.5). Health

effects



High



3



2



4



3



Major



Moderate



High



2



2



4



3



Major



Minor



High



1



2



4



3



Major



Minor



High



1



1



1



1



Minor



Insignificant



Exhaust emissions from

combustion. Dust emissions in

unpaved roads. Particle

deposition on vegetation.

Visibility reduction. Health

effects

Exhaust emissions (SO2, CO,

NO2 , PM10 and PM2.5). Health

effects. Risk of fire propagation



Reason for

Change



Efficiency of

dust

suppression

measures

High

efficiency of

dust

suppression

measures

Moderate

efficiency of

dust

suppression

measures

Mitigation

measures

should

ensure AQ

guidelines

compliance

Efficiency of

emissions

control

measures



Mitigation

measures

should

avoid

uncontrolled

fires



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Land clearance



A2



Power supply at Lunsar

A2

Vehicles and machinery

A2



Changes in the microclimatic

conditions



Medium



2



1



4



3



Moderate



Minor



Global warming due to

Greenhouse gases emissions

from fuel consumption

Global warming due to

Greenhouse gases emissions

from fuel consumption



Medium



1



1



4



2



Minor



Minor



Medium



1



1



4



2



Minor



Minor



Assumed

that

vegetation

will be

restored or

naturally

recovered

Hard to

mitigate

Low

magnitude

but hard to

mitigate



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7.3.2



Noise



Construction

The following noise emission sources during the transport corridor construction are common to almost

all construction activities:





Machinery engines used during construction activities, e.g., clearance, road widening,

profiling and sealing







Vehicles used for transport







Loading and unloading rock, construction materials and waste







Motors and other construction equipment (compressors, dozers, etc.)







Diesel engines used for energy supply



It should be noted that some sections of the transport corridor are close to populated areas. At these

locations, mitigation measures described below should be implemented.

Operations

Noise sources along the transport corridor will arise from road trains and railway stock that will use

the existing railway line between Lunsar (Marampa) and Pepel.

The potential impact will be restricted to a buffer zone along the haul road and the railway. During the

route selection assessment, all villages were provided a clearance of at least 500 m. Topographical

constraints do not allow for avoiding all of the residential areas along the haul road and the train

corridor. For those populated areas located close to the transport corridor, additional mitigation

measures should be implemented where the sound levels might exceed the Environmental, Health,

and Safety (EHS) IFC Guidelines for residential areas (45 dB(A) at night and 55 dB(A) during the

day).

The design of the mitigation measures will require study before the beginning of the haul road and

train operations considering the distance of the nearest buildings within the villages to the transport

corridor.

Additionally, the loading and offloading of ore in the Lunsar Interchange area will constitute an

important noise source, and mitigation measures should be applied.

Community safety regarding noise emissions as one of the environmental aspects will be addressed

through a Community Safety Plan to be developed by AML and rolled out in conjunction with the

EWCC.

Potential Mitigation Measures

Noise prevention measures for the construction phase include the use of machinery and equipment

that guarantee low noise emissions and the regular inspections and maintenance of construction

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vehicles and equipment. Journeys will be limited to only those necessary and a policy of switching off

machinery and equipment when not in use will be implemented. Vehicle speeds will be limited in the

vicinity of populated areas.

Recommendations for reducing impacts on noise levels from the transport activities are listed below:





Select vehicles and equipment that guarantee low noise emissions







Avoid unnecessary journeys and optimise transport traffic







Conduct regular inspections and maintenance of vehicles and equipment to maintain smooth

operation.







Limit vehicle speeds in the vicinity of populated areas



Mitigations measures, such as sound barriers, should be installed where ambient noise levels

may be exceeded. When these barriers are not effective, additional measures should be

considered, such as noise isolation at sensitive receptors.



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Table 7-12 Transport Corridor – Noise Impacts

Aspect



VR



Impacts



Land clearance, earth movements and

construction



N1



Material transportation and traffic



N1



Increase in noise levels due to

machinery operations. Noise at

near residential areas. Fauna

disturbance

Increase in noise levels due to

traffic activity. Noise at near

residential areas. Fauna

disturbance



Reason

for

Change



Minor



Residual

Impact

after

Mitigation

Minor



Moderate



Minor



Efficiency

of noise

barriers



VR

Category



Magnitude



Extent



Duration



Basic

Impact

Index



Significance



Medium



2



1



1



2



Medium



3



2



4



3



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Hard to

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7.3.3



Ecology & Biodiversity



Construction and Operations

Vegetation

The principal impact will arise from the land clearance required for road construction, leading to the

removal of vegetation. Fragmentation of habitats may also occur. Outside the direct footprint of the

road, localised clearance of vegetation may occur in borrow areas (potential sources for bridge

construction materials). Invasive species may also spread to undisturbed land following natural

colonisation or deliberate introduction in disturbed areas (where such species tend to thrive).

Localised erosion or inundation of vegetated areas due to the modification of drainage patterns may

occur. Impacts on vegetation may occur due to disturbance during the refurbishment of the Delco rail

line. Impacts on rheophytes (aquatic plants) may occur at and downstream of river crossings as a

result of changes in fluvial geomorphology. Impacts on fauna may further reduce natural colonisation

by indigenous plant species where fauna play a role in seed dispersal. The classification of these

impacts is influenced by the nature of the vegetation present in the area being impacted (defined as

high, medium and low conservation importance):



Conservation importance



High



Low



Major

Land clearance;

spread of alien

invasive species;

downstream

impacts of river

crossings

-



Impact classification

Moderate

Minor

Habitat

Borrow pits;

fragmentation;

disturbance

drainage

alteration; reduced

dispersion of

seeds by fauna

Land clearance;

Habitat

spread of alien

fragmentation;

invasive species

downstream

impacts of river

crossings



Insignificant

-



Borrow pits;

drainage

alteration;

disturbance;

reduced

dispersion of

seeds by fauna



Terrestrial Fauna

The most significant potential impact is a change in species diversity and abundance (and potentially

a loss of species of conservation concern) through habitat loss and fragmentation directly associated

with the construction of the transport corridor. Habitat alteration may occur through vegetation

removal and the construction of physical barriers within the habitat range of species (for example the

frequent train / vehicle movements may prevent migration across the transport corridor).

Displacement of terrestrial fauna may also occur through increased sensory disturbance as a result of

haul road traffic. The impact classification of these impacts is as follows:



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Major: habitat loss, habitat fragmentation, habitat disturbance and increase in hunting.







Moderate: displacement of fauna.



Aquatic Ecosystems

The aquatic environments along the transport corridor could potentially be impacted by the

construction of new road crossings and the re-development of existing rail crossings. The most

significant impacts associated with the construction and redevelopment of crossings is uncontrolled

sedimentation (and increased turbidity) in aquatic environments from in-stream (such as piling) and

land disturbance activities (such as removal of riparian vegetation, construction of bridge foundations,

sourcing borrow material), changes to fluvial geomorphology and the introduction of physical barriers

to fish migration. Riparian vegetation can reduce runoff and trap potential water contaminants prior to

entering the watercourse. The direct removal of riparian vegetation for the construction of the

transport corridor may increase diffuse pollutant transport from the adjoining areas. The impact

classification of these impacts is as follows:





Major: changes to fluvial geomorphology, physical barriers.







Moderate: sedimentation / increased turbidity, entry of diffuse pollutants.



The aquatic environments along the transport corridor are relied upon by local villagers for

subsistence fishing. Food shortage has been identified in the social surveys as an issue facing many

villages, and therefore fishing is undertaken to supplement diets. As such, any significant ecological

impacts as a result of the project-related activities may have indirect social impacts.

Potential Mitigation Measures

The following mitigation measures have been identified for ecology and biodiversity issues that are

considered to have a significant impact:





Mining infrastructure should be planned outside the forest patches and if this is not possible,

a botanist should survey the affected forest well in advance of the construction work to allow

all possible adjustments to be made.







Minimise tree felling at river crossings. The project should source all timber from certified

plantations (i.e. not local sources of timber, which come only from the last remaining natural

forests, which now require the highest level of protection).







All roads should avoid sacred forests / bushes by at least 200 m.







Roads should be kept to the minimum width possible, commensurate with relevant design

and safety standards.







Implement best practice sediment control measures during construction of river crossings.







Where bridges are built, ensure they are designed in a manner that does not confine the river;







Minor in-stream infrastructure can constitute barriers to fish migration. Where possible, these

should be designed to be compatible with the passage of migratory stream organisms, and



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crossings of any drainage lines or water bodies should have appropriate culverts built to

appropriate environmental standards.





Plants belonging to species with conservation status Endangered (EN) or Critically

Endangered (CR) should at all times be left undisturbed. Plants belonging to species with

conservation status Vulnerable (VU) should be left undisturbed as much as possible.







Species of conservation concern which were found on the deposits or near proposed

infrastructure should be relocated to suitable localities outside the project area, by way of

seed collection and / or translocation of specimens.







Replanting of vegetation for any purpose should use indigenous species and should be based

on silvicultural systems that promote natural ecosystem functions and that increase the

probability that native species and ecological processes will be maintained. Planting of exotic

species in natural forest areas should not be permitted, with the possible exception of erosion

control activities utilising species that are proven to be short-lived and non-invasive.







Establish and enforce a total ban on the hunting and capture of wildlife by company

employees and contractors.







Recognizing the importance of wildlife as a protein source to indigenous peoples, government

and the company should cooperate with local communities in the development of sustainable,

community-based wildlife management programs.







Project affected communities should be supported in the development of improved animal

husbandry techniques and provided with starter stocks. This would be a positive contribution

to the livelihoods of people and also reduce demand for bushmeat and limit the impact of

hunting restrictions on local communities.







The project should investigate the potential for supporting local plantations, which would be

beneficial to the project, local livelihoods and the remaining natural forests (and therefore,

also for fauna).







Work with government to explore opportunities to control and minimise the uncontrolled inmigration of people into areas newly opened-up by road construction, especially along the

roads themselves. Uncontrolled in-migration will lead to further forest and wildlife losses and

compound pressures on existing human communities.







Consider biodiversity offsets to compensate for the unavoidable habitat loss (including

vegetation and fauna).







The risk of injury to endangered species and other fauna from vehicle movements will be

minimised by adopting safe speed limits, reducing night driving to the minimum possible, and

restricting driving to marked access routes.







The project should consider establishing a relationship with the Tacugama Chimpanzee

Sanctuary and to work through it to enhance conservation of chimpanzees in the project area

and more widely in Sierra Leone.



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Table 7-13 Transport Corridor – Ecology & Biodiversity Impacts

VR



Impacts



Aspect



E1



E2



Loss of biodiversity through removal of

vegetation

Fragmentation of habitat



VR

Category



Magnitude



Extent



Duration



Significance



4



Basic

Impact

Index

4



Major



Residual

Impact after

Mitigation

Moderate



4



4



4



4



4



4



Moderate



Minor



3



4



4



4



Major



Major



2



3



2



2



Moderate



Moderate



1



1



2



1



Minor



Insignificant



2



1



2



2



Insignificant



Insignificant



2



2



3



2



Moderate



Major



High



Loss of biodiversity and Fragmentation of

habitat

Low



Land Clearance

E3



Change in species richness and abundance

habitat loss / disturbance / fragmentation

High



E4



Borrow /

construction

Materials



Decrease in species richness and

abundance derived from uncontrolled

sedimentation through land disturbance

activities



E1



Localised clearance of vegetation – habitat

loss



E2



Habitat loss



E3



Habitat loss / disturbance



High



High

Low



High



Reason for

Change

Careful

planning to

avoid

damage to

valuable

vegetation

Avoidance of

clearance

through

forest

remains

Presently

unknown

pending

further

evaluation'

Presently

unknown

pending

further

evaluation

Avoid borrow

areas on key

habitats



Presently

unknown

pending

further

evaluation'



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VR



Impacts



Aspect

E4



VR

Category



Sedimentation / increased turbidity through

land clearance



Significance



2



Basic

Impact

Index

2



Moderate



Residual

Impact after

Mitigation

Minor



4



4



4



Major



Minor



4



4



4



4



Moderate



Minor



3



4



4



4



Major



Major



2



3



2



2



Moderate



Minor



2



2



3



2



Moderate



Moderate



2



2



3



2



Insignificant



Insignificant



3



2



3



3



Major



Major



3



3



4



3



Major



Major



Magnitude



Extent



Duration



2



2



3



High



Loss of biodiversity and sensitive habitat

E1

E2



High

Loss of biodiversity and habitat

Low



Earth Movements



E3



Change in species richness and abundance

habitat loss / disturbance / fragmentation

High



E4



Sedimentation / increased turbidity through

land clearance

High



E1



Changes in drainage

patterns



E2

E3



Impacts on rheophytes (aquatic plants) at

and downstream of river crossings as a

result of changes in fluvial geomorphology

Localised erosion or inundation of

vegetated areas

Localised erosion or inundation of

vegetated areas

Change in species richness and abundance

habitat loss / disturbance / fragmentation



High



Low



Medium



E4



Decrease in species richness and

abundance through changes to fluvial



High



Reason for

Change

Use of best

practice

sediment

control

measures

Avoid areas

of valuable

vegetation

Avoidance of

clearance

through

forest

patches

Presently

unknown

pending

further

evaluation'

Use of best

practice

sediment

control

measures

Presently

unknown

pending

further

evaluation



Presently

unknown

pending

further

evaluation

Presently

unknown



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VR



Impacts



Aspect



VR

Category



Magnitude



Extent



Duration



Basic

Impact

Index



Significance



Residual

Impact after

Mitigation



geomorphology



Vegetation disturbance



E1



Waste Generation

E2

E4



1



1



2



1



Minor



Insignificant



1



1



2



1



Insignificant



Insignificant



2



2



3



2



Moderate



Minor



4



3



4



4



Major



Minor



3



3



4



3



Minor



Insignificant



3



3



4



3



Major



Minor



Low



Vegetation disturbance



Medium



Decrease in habitat quality through entry of

diffuse pollutants

High



Loss of riparian forests

Impacts on rheophytes (aquatic plants at

and downstream of river crossings as a

result of changes in fluvial geomorphology

High



E1



Bridges / Culverts

Construction



Loss of habitat

E2



E4



Low



Changes to fluvial geomorphology and the

introduction of physical barriers to fish

migration



High



Reason for

Change

pending

further

evaluation

Adherence

to

international

best

practices for

waste

management



Use of best

practice

sediment

control

measures

Minimisation

of

construction

work in

riparian

forests.

Supervision

by a

botanist.

Minimisation

of

construction

works in

riparian

habitats

Bridges to be

designed in

a manner

that does not

confine the



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AFRICAN MINERALS LIMITED

STAGE 1 ENVIRONMENTAL, SOCIAL AND HEALTH IMPACT ASSESSMENT

TONKOLILI IRON ORE PROJECT

VR



Impacts



Aspect



E3



VR

Category



Habitat fragmentation



Presence of the

transport

infrastructure



Extent



Duration



Basic

Impact

Index



Significance



Residual

Impact after

Mitigation



3



4



4



4



Major



Major



3



4



4



4



Major



Major



3



3



4



3



Major



Major



2

4

4

2

3



3

3

3

2

4



2

4

4

3

4



2

4

4

2

4



Insignificant

Moderate

Major

Moderate

Major



Insignificant

Moderate

Major

Moderate

Major



High



Increased pressure on timber



E1

Project induced

influx of workers and

job seekers



High



Spread of alien invasive species



E2

E3

E3

Haul Road Traffic /

Train Traffic



Magnitude



Increased pressure on timber

Spread of alien invasive species

Increase in hunting

Displacement of fauna

Loss of biodiversity

Habitat fragmentation



Low

High



High



Reason for

Change

River.

Selection of

open box

culverts with

natural

substrata

rather than

enclosed

Culverts

Presently

unknown

pending

further

evaluation

Mitigation

will require

co-operation

between

AML and

local

partners –

pending

further

evaluation

Presently

unknown

pending

further

evaluation



Presently

unknown

pending

further



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AFRICAN MINERALS LIMITED

STAGE 1 ENVIRONMENTAL, SOCIAL AND HEALTH IMPACT ASSESSMENT

TONKOLILI IRON ORE PROJECT

VR

Aspect



Impacts



VR

Category



Magnitude



Extent



Duration



Basic

Impact

Index



Significance



Residual

Impact after

Mitigation



Reason for

Change

evaluation



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AFRICAN MINERALS LIMITED

STAGE 1 ENVIRONMENTAL, SOCIAL AND HEALTH IMPACT ASSESSMENT

TONKOLILI IRON ORE PROJECT



7.3.4



Hydrology & Hydrogeology



Potential impacts pertaining to local surface and groundwater have been determined based on the

partial project descriptions available and field observation of early haul road construction and rail

refurbishment activities.

Construction





Construction works at or near watercourses may lead to increased runoff and erosion with

increase in turbidity and reduction in water quality impacting aquatic environment and

downstream users.







Construction of temporary stream and river crossings includes creation of river bed crossings

and infill with rock, soil and organic debris arising from the route clearance and stripping

works. Construction process of these crossings and vehicles passing through river bed

crossings disturb river bank and river bed sediments raising downstream turbidity, impacting

on water quality and potentially increasing long term erosion in the vicinity of the crossing.







Infill crossings lead to increased downstream turbidity impacting on water quality as fines are

washed downstream by increasing flows with onset of the wet season.







High rainfall events will carry larger infill material and similar materials deposited in general on

road alignment adjacent to river banks and flood areas downstream - including rocks and

trees which can destroy community foot crossing. High organic content in water courses may

impact on water quality.







Dewatering of aquifers leading to impacts on surface water hydrology and local communities.

Groundwater will be abstracted to supply potable and construction water at various locations

along the haul road and existing rail alignment. Surface water may also be abstracted for

construction use. Over-exploitation of aquifers could locally reduce the water table and

potentially dry nearby community wells, surface water streams and/or wetland habitats.







Modification and interruption to the existing hydrological regime of the bounding catchments

may occur. The raised haul road and diversion of storm water runoff may alter the natural

drainage patterns of the various catchments.







Erosion of exposed surfaces by wind, water and construction activities generating higher

sediment loads in surface runoff entering the surrounding river catchments. This will be of

particular concern in the vicinity of river crossing and wetlands.







Alterations to the natural course of rivers may be required where major river crossing are

planned. Deepening of river channels and alterations to the surrounding topography could

alter the natural course or flow rates of rivers as well as the flood plain dynamics during the

wet season.



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Page 183



AFRICAN MINERALS LIMITED

STAGE 1 ENVIRONMENTAL, SOCIAL AND HEALTH IMPACT ASSESSMENT

TONKOLILI IRON ORE PROJECT







Potentially contaminated soil waste may be generated during the re-development of the

existing rail alignment. Contaminants could be mobilised from excavated soils and migrate to

surface or groundwater.



Operations

Assessment of potential impacts on the hydrological and hydrogeological setting have been

conducted based primarily on a Phase 1B – Walkover baseline assessment supplemented with

limited reconnaissance level assessment conducted during February 2010. Potential impacts

associated with the project will be accurately quantified during the impact assessment but may

include the following:





Uncontrolled release of toxic chemicals to the environment. Diesel fuel, oil, grease and

solvents will all be used during the operation and maintenance of vehicles using the haul road

and rail. Accidental spillage and contact with rainfall runoff may lead to the pollution of

groundwater and/or surface water bodies.







Lack of hard surfacing of the haul road may lead to dusting and erosion and runoff carrying

material into water courses where the road is nearby or at crossings. This may impact on

turbidity and other water quality parameters. Groundwater and or surface water abstraction at

permanent camps/facilities along the transport corridor may locally reduce the water table and

potentially dry nearby community wells, surface water streams and/or wetland habitats.







Dust and spillage of ore from haul road and rail wagons may enter water courses or leach into

groundwater impacting water quality



Potential Mitigation Measures

The following mitigation measures have been identified for hydrology and hydrogeology issues that

are considered to have a significant impact:





Robust surface and groundwater monitoring programmes to establish baseline and ensure

early identification of impacts.







Treatment of all potentially contaminated wastewater sources prior to discharge to ground or

surface.







Rapid replacement of riverbed crossings and infill crossings with appropriately designed

culverted/bridged crossings. Prohibit construction of similar crossings and ensure culvert and

bridge crossings commence only when suitable plant and materials available on site.







Strict adherence to Environmental Management Plans prepared in line with industry and

international best practice.







Appropriate hydrogeological/hydrological assessment of water resources and careful design

of water abstraction points so as to minimise impacts on other users.







Strict load level and moisture control of materials to be transported in open rail/road wagons



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AFRICAN MINERALS LIMITED

STAGE 1 ENVIRONMENTAL, SOCIAL AND HEALTH IMPACT ASSESSMENT

TONKOLILI IRON ORE PROJECT







Design to ensure potentially contaminating materials are not stored in proximity to surface

water courses and adequate bunding for spill control. Prepare spill response plans and

materials handling management plans. Avoid storage over potentially sensitive/important

shallow aquifers and prepare engineered low permeability surfaces with drainage/runoff

controls for storage and handling areas.



.



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AFRICAN MINERALS LIMITED

STAGE 1 ENVIRONMENTAL, SOCIAL AND HEALTH IMPACT ASSESSMENT

TONKOLILI IRON ORE PROJECT



Table 7-14 Transport Corridor - Hydrology & Hydrogeology

Aspect



Land Clearance



VR



VR Category



Magnitude



Extent



Duration



Basic

Impact

Index



Significance



Residual

Impact

after

Mitigation



SW1



Higher sediment loads in surface

runoff entering rivers and their

tributaries (construction)



High



3



2



3



3



Major



Moderate



SW1



Construction phase river bed

crossings and infill crossings may lead

to increased turbidity and other

changes in water quality.



High



3



2



3



3



Major



Moderate



SW2



Reduced surface water resources

(construction and operation)



High



2



2



5



3



Major



Major



SW2



Modification and interruption of

existing hydrological regimes

(construction and operation)



High



3



3



4



4



Major



Insignificant



SW2



Flooding (operational)



High



3



3



5



4



Major



Moderate



High



3



3



2



4



Major



Insignificant



High



3



3



2



4



Major



Insignificant



High



2



2



2



2



Moderate



Insignificant



Blasting and

earthworks



SW1



Waste generation



Impacts



GW1



SW1



Contamination of surface water

resources from uncontrolled release of

sewage and other waste waters

(construction and operation)

Contamination of groundwater

resources from uncontrolled release of

sewage and other waste waters

(construction)

Contamination of surface waters from

uncontrolled release of drilling fluids

(camp construction)



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Reason for

Change

Adherence

to

international

best practice

Adherence

to

international

best practice

Impact will

be

permanent

Appropriate

design and

international

best practice

Appropriate

design and

international

best practice

Adherence

to

international

best practice

Adherence

to

international

best practice

Adherence

to

international

best practice



AFRICAN MINERALS LIMITED

STAGE 1 ENVIRONMENTAL, SOCIAL AND HEALTH IMPACT ASSESSMENT

TONKOLILI IRON ORE PROJECT



Aspect



Resource utilisation



VR



Impacts



VR Category



Magnitude



Extent



Duration



Basic

Impact

Index



Significance



Residual

Impact

after

Mitigation



GW2



Reduced groundwater resources in

vicinity of camps where water may be

derived from groundwater

(construction and operation).



High



2



2



4



4



Major



Insignificant



SW1



Uncontrolled release of fuels and toxic

chemicals (construction and

operational)



High



3



3



2



4



Major



Moderate



GW1



Uncontrolled release of fuels and toxic

chemicals (construction and

operational)



High



2



2



4



4



Major



Minor



SW1



Turbidity and other water quality

impacts due to dusting and erosion

from the operational haul road



High



3



3



4



3



Major



Insignificant



SW1



Turbidity and water quality impacts

from dust and spillage of ore from

open rail and road wagons



High



3



3



4



3



Major



Insignificant



Chemical and fuels

storage and utilisation



Vehicle movements



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Reason for

Change

Detailed

studies,

appropriate

design and

location of

abstractions

and water

resources

management

plan

Engineering

design and

adherence

to

international

best practice

Engineering

design and

adherence

to

international

best practice

Engineering

design and

adherence

to

international

best practice

Engineering

design and

adherence

to

international

best practice



AFRICAN MINERALS LIMITED

STAGE 1 ENVIRONMENTAL, SOCIAL AND HEALTH IMPACT ASSESSMENT

TONKOLILI IRON ORE PROJECT



7.3.5



Soils & Land Use



Construction

While there are no baseline soil data currently available for the transport corridor, the preliminary

identification and evaluation of impacts is possible based on field observations of baseline conditions

as well as current haul road construction activities, qualitative land-use information and an

understanding of Phase 1-related activities in this area.





Land clearance including slash and burn of vegetation and surface soils strip being carried

out for scout road construction and subsequent widening may lead to significant erosion.







Temporary stream and river crossings include river bed crossings or ‘infill’ crossings where

earth/rocks and vegetation have been pushed into the watercourse restricting the natural flow

of water. Onset of the wet season will lead to severe erosion of river bank soils in the vicinity

of these crossings and flooding associated with infill type crossings may lead to deposition of

sediment on surrounding areas impacting on soils and land use.







The construction of the road may constrain certain land-uses and / or access to land and

leads to permanent loss of some land to former land use..







Localised impacts may occur associated with borrow pit areas and quarries (potential sources

for road and bridge construction materials).







Invasive species may also spread to undisturbed land following natural colonisation or

deliberate introduction in disturbed areas (where such species tend to thrive).







Localised erosion or inundation may occur due to the modification of drainage patterns.







Stripping of soils and shallow deposits has been carried out over much of the haul road scout

route and to date the stripped material has been pushed to the sides of the road to form

bunds mixed with cleared vegetation and subsoil and non-organic sediments. Unmanaged

storage of soils can lead to a loss of the soils structure as well as wash out and erosion

during high rainfall events leading to permanent loss of the soil.



• Temporary and minor impacts on soil resources and land-use during the refurbishment of the

Delco rail line may also occur. Historical soil quality impacts are highly likely to have occurred

during operation of the rail line and there are visible deposits of ore spillage in many areas

along and immediately adjacent to the line. Renovation/construction works could lead to the

spread or redistribution of this material.





Soil resources and land-use in areas adjacent to the road may experience localised dustrelated impacts from truck movements and earth moving activities during road construction.







Compaction and permanent loss of soil structure may occur in the vicinity of the road

construction due to the movement of plant and vehicles beyond the necessary work areas.



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AFRICAN MINERALS LIMITED

STAGE 1 ENVIRONMENTAL, SOCIAL AND HEALTH IMPACT ASSESSMENT

TONKOLILI IRON ORE PROJECT



Operations

Road haulage and renewed operation of the rail line is likely to result in spillage of some ore product

for which detailed chemistry is not yet known. However the very narrow, linear form of the transport

lines means that any impacts on soils are likely to be localised and limited.

Although the product grain sizes are not anticipated to lead to dusting in their own right, the heavily

weathered nature of some of the material means that some abrasion and dust formation may occur.

Dust may be blown from road and rail wagons and accumulate on local soils. Again, potential

chemistry of any dust is not yet known. For now, limited impacts are assumed.

Potential Mitigation Measures

The following mitigation measures have been identified for soils and land use issues that are

considered to have a significant impact:





Minimise land / soil to be cleared or buried and concentrate such activities in areas with

limited soil quality and land-use capability. Given the advanced stage of design and

construction the opportunity to apply this mitigation may not apply.







Consider biodiversity offsets for unavoidable long-term and permanent soil / land clearance

and soil / land burial. Integrate livelihoods components as necessary with offsets to replace

lost land-use capability.







Identify suitable storage locations and implement appropriate conservation and preservation

of stripped top-soils and sub-soils from all areas to retain physical and chemical

characteristics and seed-bank for subsequent use for rehabilitation activities. Where

practical, soils can be formed as roadside bunds or caps to roadside bunds and be planted in

order to maintain soil structure and quality. This mitigation can be retrospectively applied for

road sections that have already been partially cleared where extensive mixing with unsuitable

materials has not occurred.







Implement required storm water drainage, culvert and bridge construction and flow control

prior to construction and during the dry season to prevent erosion of exposed areas and

inundation of low lying and down-stream areas. For crossings which have already been

breached and either have river bed crossings or temporary infill crossings, install engineered

crossings as soon as possible ahead of increasing rainfall and runoff.







Restrict access by vehicles to essential areas only, in order to reduce compaction of soils.







Isolate and manage potential soil contaminants (including wind blown dusts and water-borne

contaminants) through careful selection of storage sites and moisture control prior to transport

and during storage.







Avoid deliberate introduction of alien invasive species during rehabilitation activities.







Manage pathways by which alien invasive species can enter a disturbed area (including

avoidance of non-indigenous plant species in rehabilitation activities).



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AFRICAN MINERALS LIMITED

STAGE 1 ENVIRONMENTAL, SOCIAL AND HEALTH IMPACT ASSESSMENT

TONKOLILI IRON ORE PROJECT



Table 7-15 Transport Corridor - Soils & Land Use

Aspect



VR



Impacts



S1



Changes in quality/available land due to

invasive species colonising disturbed

areas



Land clearance

S2



Earthworks



Exposure of soils and stripping of

vegetation in the vicinity of the road

construction may lead to increased soil

erosion



S2



Change in land use leading to loss of

farming land and some access

restrictions may constrain some land use



S2



Compaction and destruction of soils may

occur due to plant movements and

earthworks in the vicinity of the road



S1



S2



Soils bounding the alignment may be

impacted by spillage of ore, accumulated

dust blown from rail and road wagons

and generated by vehicle movements

over the unsurfaced roads.

Construction of temporary river

crossings may lead to increased erosion

and loss of soils



VR Category



Magnitude



Extent



Duration



Basic

Impact

Index



Significance



Residual

Impact after

Mitigation



Medium



2



3



4



4



Major



Insignificant



Medium



3



3



4



4



Major



Insignificant



Medium



3



3



4



4



Major



Moderate



Medium



2



2



4



3



Moderate



Insignificant



Medium



2



2



4



3



Moderate



Insignificant



Medium



2



2



3



3



Moderate



Insignificant



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Page 190

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Reason for

Change

Appropriate

design and

international

best practice

Appropriate

site

management

and

international

best practice

Long term

rehabilitation

and

international

best practice

Appropriate

site

management

and

international

best practice

Appropriate

site

management

and

international

best practice



Appropriate

site

management

and



AFRICAN MINERALS LIMITED

STAGE 1 ENVIRONMENTAL, SOCIAL AND HEALTH IMPACT ASSESSMENT

TONKOLILI IRON ORE PROJECT



Aspect



VR



S2



Chemical / fuels

storage and

utilisation



Impacts



Failure to separately strip and stockpile

and manage soils in an appropriate

manner can lead to loss of structure as

well as wash out and erosion.



S2



Construction of temporary infill river

crossings or inadequately drained

permanent crossings may lead to

flooding and deposition of flood

sediments over farmland



S1



Uncontrolled release of fuels and toxic

chemicals (construction and operational)



VR Category



Magnitude



Extent



Duration



Basic

Impact

Index



Significance



Residual

Impact after

Mitigation



Medium



2



2



4



3



Moderate



Insignificant



Medium



2



2



4



3



Moderate



Insignificant



Medium



2



2



4



3



Moderate



Insignificant



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Reason for

Change

international

best practice

Appropriate

site

management

and

international

best practice

Appropriate

design, site

management

and

international

best practice

Engineering

design and

adherence to

international

best practice



AFRICAN MINERALS LIMITED

STAGE 1 ENVIRONMENTAL, SOCIAL AND HEALTH IMPACT ASSESSMENT

TONKOLILI IRON ORE PROJECT



7.3.6



Geology & Geomorphology



Construction

No project-specific baseline geological or geotechnical drilling or mapping has been undertaken to

date along the rail route or haul road however limited information is available in published regional

geological descriptions and from observations during field visits. Since the rail line is already

established and was operated for many years, no further significant impacts on geology or

geomorphology are anticipated. Construction of the haul road and re-instatement of the rail line will

require quarrying of some construction materials for ballast, bridges and road base. Potential

changes to watercourses and runoff and erosion patterns crossed by the road alignment may impact

on local geomorphology. The eastern 20km stretch of road passes through the very hilly Sula range

which are locally deeply incised by streams and rivers. Cut and fill requirements in this region will be

much more significant than for the western road sections and will result in localised significant

changes in geomorphology. However, overall, at this stage and based on limited design data

reviewed to date, no major impacts to geology and geomorphology along the transport corridor are

anticipated.

Operations

Operation of the transport corridor is not anticipated to have any significant impact on geology or

geomorphology.

Potential Mitigation Measures

The following mitigation measures have been identified for geology and geomorphology issues that

are considered to have a significant impact:





Geomorphological mitigation measures include the preservation of watercourses (where

possible) and diversion of watercourses around infrastructure to maintain downstream

drainage patterns, rehabilitation and revegetation of disturbed areas, and re-contouring

disturbed areas to original topography (to the extent possible).







Design of the road should be optimised so as to minimise unnecessary cut and fill. It is

understood that this is anyway consistent with one of the primary design aims for the road.



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AFRICAN MINERALS LIMITED

STAGE 1 ENVIRONMENTAL, SOCIAL AND HEALTH IMPACT ASSESSMENT

TONKOLILI IRON ORE PROJECT



Table 7-16 Transport Corridor - Geology & Geomorphology

Aspect



VR



V1



Impacts

Potential changes to watercourses and

valley swamps drainage and

erosion/deposition patterns may alter

local geomorphology.



VR Category



Magnitude



Extent



Duration



Basic

Impact

Index



Significance



Residual

Impact after

Mitigation



Low



3



3



5



4



Moderate



Moderate



Low



3



3



4



4



Moderate



Moderate



Low



2



2



5



4



Moderate



Insignificant



Land clearance

V1



Blasting and

earthworks



V1



Stripping of land surface will change the

landform and impact on the visual

landscape.

Cut and fill requirements for road

construction in the Sula mountains area

may result in localised changes in

geomorphology.



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Reason for

Change

Irreversible.

Long term

rehabilitation

and

international

best practice

Long term

rehabilitation

and

international

best practice

Irreversible.

Long term

rehabilitation

and

international

best practice



AFRICAN MINERALS LIMITED

STAGE 1 ENVIRONMENTAL, SOCIAL AND HEALTH IMPACT ASSESSMENT

TONKOLILI IRON ORE PROJECT



7.3.7



Socio-Economic



Construction

Land acquisition

The impacts due to land acquisition for construction of the haul road (rail refurbishment will take place

on the existing rail embankment) will range from loss of access to land-based resources to loss of

shelter, all of which may potentially lead to a decrease in economic stability. These can include (but

may not be limited to):





Loss of income.







Impact on dwelling units.







Impact on community structures.







Increases in physical and mental stress.



The haul road may pass through the sugar plantations to be developed as part of the Addax Biofuel

Project. The compensation for potential impacts on the sugarcane plantations may require separate

negotiations with relevant stakeholders. The mitigation measures given below are expected to reduce

the impacts from major to moderate/minor.





Preparation of a Resettlement Action Plan (RAP).







Preparation of a livelihood restoration plan.







Implementation of a grievance mechanism.







Preparation and implementation of the CDAP.



Project induced influx of workers and job seekers

An influx of population will result from the arrival of workers and job seekers to the construction sites

along the transport corridor. This influx is likely to lead to the following impacts:





Pressure on social infrastructure, natural resources.







Increases in social ills such as crime, alcoholism, drug abuse and prostitution.







Increases in communicable diseases.







Potential for conflict between the local community and outsiders.



Given the high level of unemployment in Sierra Leone, it will be difficult to control the influx of job

seekers to villages and towns along the transport corridor. The following measures can reduce

impacts from moderate to minor.





Planning for self sufficient and closed workers camps to minimise intermingling of

workers with local population.



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Providing assistance for the control of communicable diseases and for educational

campaigns for prevention of social ills.







Planning jointly with local Paramount Chief and other stakeholders to minimise

speculative migration.



In the long term, the improved transport infrastructure may also lead to growth of industry and other

economic activities along the corridor (more likely along the haul road), which may contribute to

general economic development. The above benefit will be independent of the project and hence has

not been evaluated.

Operations

The social impacts of the transport corridor are likely to occur mainly during the construction phase

due to disturbance to the existing land users. The impacts on land are expected to occur during

construction of a new 120 km haul road between Farangbaia and Lunsar and refurbishment of the

existing rail line between Lunsar and Pepel Port.

Economic aspects

The economic impacts are expected to be mainly beneficial in nature as described below:





Employment of workers for the construction and operation phases (with additional

indirect and induced jobs with contractors and suppliers).







Initial investment and sustaining capital for maintenance and operation of the railway

line translated into business opportunities for contractors.







Government income in the form of excise duties on imports (mainly during construction)

and taxes.



Community investment

As part of its social investment programme, AML is expected to contribute towards development of

social infrastructure in communities along the transport corridor. These could include safe drinking

water, support to schools, construction of roads and other social infrastructure within the settlements

along the rail line. No mitigation measures are suggested for these positive impacts.

Closure of transport operations

The use of the haul road and a refurbished rail line from Lunsar to Pepel Port is planned to be used

for an initial period (at most 8 years). After this the transport activities will take place through a new

rail corridor from the mine site to Tagrin Port as part of Phase 2 and 3. However it is not expected that

there will be large scale retrenchment and consequent impacts as much of the workforce can be

deployed at the new transport corridor or other project operations.



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Table 7-17 Transport Corridor – Socio-Economic Impacts

VR



Impacts



VR Category



Magnitude



Extent



Duration



Significance



2



Basic

Impact

Index

1.7



Moderate



Residual

Impact after

Mitigation

Moderate (+)



1



2



1



2



3



2



Moderate



Major (+)



1



3



3



2.3



Moderate



Major (+)



1



4



2



2.3



Moderate



Moderate (+)



1



4



3



2.7



Major



Major (+)



1



4



3



2.7



Major



Major (+)



1



1



4



1.7



Moderate



Low



Aspect

employment creation

(construction)

High



employment creation (operation)

High

Economic aspects

(employment,

procurement of

services and supplies,

and payment of taxes

and revenue to

government)



Training of workers

High

H1



Increase in business for suppliers

(construction)



Increase in business for suppliers

(operation)



High



High



Increase in government income

High



Land acquisition



H1



Loss of land



High



Loss of shelter



High



1



1



4



2



Moderate



Moderate (+)



Loss of income



High



1



2



4



2.3



Moderate



Minor



Loss of access route



High



1



2



4



2.3



Moderate



Moderate



Reason for Change



Priority given to locals

during recruitment

process although skills

availability is expected to

be limited

Priority given to locals

during recruitment

process

Inject considerable skills

enhancement into the

area

Priority given to locals

during tender process

although availability is

expected to be limited

Priority given to locals

during tender process

although availability is

expected to be limited

Revenue from project

taxes, royalties, etc

expected to be major

contributor to GoSL GDP

Provision of alternative

land

Provision of replacement

housing of superior

quality in most

circumstances

Implement livelihood

restoration plan

Identify and provide

alternative routes or

crossing methods



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VR



Impacts



Significance



4



Basic

Impact

Index

2.3



Moderate



Residual

Impact after

Mitigation

Minor



1



1



1



Insignificant



Insignificant



1



2



3



2



Moderate



Minor



VR Category



Magnitude



Extent



Duration



Reduced food security



High



1



2



Breakdown in social support



High



1



Aspect



Increase in stress

High



H1



Project induced influx



Reduced access to services



High



1



2



3



2



Moderate



Moderate (+)



Community conflict



High



1



1



1



1



Insignificant



Insignificant



Pressure on social infrastructure

due to increase in population

Pressure on natural resources due

to increase in population

Increase in social ills (crime,

alcoholism and prostitution)



High



1



2



3



2



Moderate



Moderate (+)



High



1



2



3



2



Moderate



Minor



High



1



2



3



1.7



Moderate



Minor



Increase in communicable

diseases



High



1



3



3



2.3



Moderate



Minor



Increase in cost of living

Tensions between locals and

outsiders due to real or perceived



High

High



1

1



2

2



3

3



1

2



Moderate

Moderate



Minor

Minor



of workers and job

seekers



Reason for Change



Provision of alternative

land and transitional

support mechanisms

Villagers moved to other

locations within existing

village therefore not

likely to suffer loss of

cohesion

Regular consultation and

publicising grievance

mechanism with PAPs

Provision of replacement

social infrastructure likely

to provide increased

access to service

Villagers moved to other

locations within existing

village therefore not

likely to suffer loss of

cohesion

Provision of replacement

social infrastructure

Effective and broad

stakeholder engagement

Effective and broad

stakeholder engagement

together with support

from appropriately

positioned NGOs

Effective and broad

stakeholder engagement

together with support

from appropriately

positioned NGOs

Influx management

Influx management and

regular consultation



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VR



Impacts



VR Category



Magnitude



Extent



Duration



Basic

Impact

Index



Significance



Residual

Impact after

Mitigation



Reason for Change



2



3



3



2.7



Major



Moderate (+)



Provision of replacement

social infrastructure

Training programs



Aspect

unequal access to project benefits

Social infrastructure

H1

Project induced

Community investment



H1



Mine closure



High



Education and skills



High



2



3



3



2.7



Major



Major(+)



Livelihoods



High



2



3



3



2.7



Major



Major(+)



Loss of income for workers,



High



-



-



-



Increased income from

direct and indirect

employment

-



Loss of businesses



High



-



-



-



-



Loss of revenue to government



High



-



-



-



-



Psychological impacts



High



-



-



-



-



It is anticipated that much of the

workforce working on the transport

corridor for the Phase 1 can be

deployed at the new corridor or

other project operations.

Consequently, large scale

retrenchment and associated

impacts are not expected.



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7.3.8



Human Health



Construction & Operations

Based on the current available project and existing health information, preliminary impacts for Phase

1 of the Tonkolili project have been identified for the transport corridor. It is important to note that the

Project has not been finalized, nor has all the baseline data been analysed, therefore, the qualitative

impact designations and significance may change as the Phase 1 details are finalized.

The preliminary health impacts associated with the Phase 1 transport corridor are described below.

Impacts relate to both construction and operation of the transport corridor unless otherwise stated.

Potential negative impacts of major significance:





Community resettlement (during construction);







In-migration related impacts (disease, food security, substance abuse, home violence) (during

construction); and







Degradation and/or reduction of surface water (sedimentation/erosion, contamination, changes in

drainage patterns).



Potential negative impacts of moderate significance:





Increased road traffic accident rate; and







Reduction in quality or quantity of locally produced foods.



Potential negative impacts of minor or insignificant significance:





Impacts of noise on health and well-being (heavy vehicle activity);







Exposure to increased levels of particulate matter (PM) (diesel power generators vehicle

emissions, and road dust); and







Acute exposure to elevated SO2 and NO2 in air (diesel power generators, heavy vehicle

emissions).



Potential positive impacts:





Access to improved healthcare facilities (for general public);







Health benefits to AML employees and through local employment;







AML financed community development initiatives;







Improved access to the region; and







Positive aspects of resettlement.



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A number of assumptions were made for the preliminary impact assessment specific to the Phase1

transport corridor. It was assumed that all communities on or within 500 m were to be resettled to a

distance greater than 500 m. Thus, the Health VR used in the preliminary impact assessment for

impacts associated with PM, SO2, and NO2 was categorized as Medium (an AML employee or HR2

see Table 7-1).

Also, with respect to PM, SO2, and NO2 emissions, it was assumed that a thermal power generating

facility (a potentially significant generator of these types of emissions) will not be built in this area.

Should the arrangements for power supply be altered from those described in Section 3, this

preliminary impact will require re-assessment. Should a thermal power generator be implemented, the

significance of the impact and the sensitivity of the VR would be expected to increase.

It was assumed that activities associated with the haul road construction and railway up-grade would

be superficial and not impact groundwater along the transport corridor. Thus, an impact to

groundwater was not included in preliminary impact assessment of the Phase 1 transport corridor.

The positive class impacts associated with access to medical facilities only apply if AML undertake to

provide these facilities.

Where there was uncertainty in significance designation, the more conservative assumption was

selected so as to ensure that the preliminary potential impact of the Project was not underestimated.

Potential Mitigation Measures

Potential mitigation measures have been identified in association with each headline health impact as

listed below. The headline impacts were identified with the assumption that no mitigation measures

were applied. Thus, implementation of the recommended mitigation measures is expected to reduce

the significance of the headline health issues and thus avoid potentially major health issues for

persons living in the vicinity of the Projects.

Health related mitigation measures are listed below, however, it is important to note that mitigation

recommended by the other disciplines, particularly socio-economic as well as other environmental

assessments (e.g., air, surface and groundwater, flora and fauna) can also affect human health.

Alteration of project descriptions and monitoring results may result in the recommendation of

additional mitigation measures, or modification of those currently recommended.

Increased road traffic accident rate





Implementation of sound health and safety measures during the construction phase, including

safe driving practices.







Road Health and Safety and awareness training for all employees.







Assigned crossing areas for pedestrians.







Lighting along dangerous sections of the road and busy intersections.







Building good quality roads with adequate signage.







Keeping Project-related night time traffic to a minimum.



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Protection fences on rail line to restrict movement of fauna.



Also see traffic assessment results and mitigation measures

Community resettlement





Social mitigation measures regarding loss of land and re-settlement (see social assessment

results and mitigation measures).



In-migration related impacts (disease, food security, substance abuse, home violence)





Adherence to the requirements of the Prevention and Control of HIV and AIDS Act.







Appropriate education of workforce regarding transmittable diseases.







Employing local labour where appropriate.







Providing suitable healthcare facilities.







See social assessment results and mitigation measures.



Increased burden of disease due to project activities, and water storage facilities (drinking water

tanks, waste and raw water ponds).





Awareness and control of mosquito breeding sites to prevent increased malaria incidence.







Appropriate treatment of drinking water.







Providing suitable healthcare facilities.







Appropriate management of waste water ponds, including odour controls.



Degradation and/or reduction of surface water (sedimentation/erosion, contamination, changes in

drainage patterns, dam construction)





Management and remediation of any contamination associated with storage of fuels, waste

water and other hazardous materials.







Management of surface and storm water run-off.



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Table 7-18 Transport Corridor – Health

VR



Impacts



VR

Category



Aspect



Construction



H2



Impacts of noise on health and

well being (train and road activity)

Exposure (inhalation) to increased

levels of dust and particulate

matter (PM) (potential emissions

from diesel power generators and

vehicles)

Exposure (inhalation) to elevated

sulphur dioxide (SO2) and nitrogen

dioxide (NO2) in air emissions

(from power generator and

vehicles).



Medium



1



Medium



1



Medium



1



Health benefits through local

3

employment

Increased road traffic accident rate



H1



Reason for Change



Moderate



Minor



Major



Moderate



• Compliance with

recommended mitigation

measures.

• Level of public concern

unknown.

• Low confidence in data (no

traffic study).

• Compliance with

recommended mitigation

measures.

• Resettlement is permanent.

• Level of public concern

unknown.

• Moderate confidence in

data (requires interpretation



Extent



Duration



Basic

Impact

Index



Significance



2



2



1



1.7



Minor



2



1



1



1.3



Insignificant



2



1



1



1.3



Insignificant



3



1



1



1.7



4



3



4



3.7



High



Community resettlement



2



High



4



Residual

Impact

after

4

Mitigation



Magnitude



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VR



Impacts



Aspect



In-migration related impacts

(disease, food security, substance

abuse, home violence)



VR

Category



Magnitude



Extent



Duration



Basic

Impact

Index



Significance



4



2



4



3.3



Major



Minor



3



3



1



2.3



Moderate



Minor



5



3



4



4



Major



Moderate



2



2



1



1.7



Moderate



Minor



High



Increased burden of disease due

to project activities (drinking water

tanks, waste and raw water

ponds)

High



Degradation and/or reduction of

surface water

(sedimentation/erosion,

contamination, changes in

drainage)



H1



Reduction in quantity or quality of

locally produced foods through

land appropriation and clearance,

potential siltation of

rivers/streams)



Access to improved healthcare

3

facilities



High



High



4



Residual

Impact

after

4

Mitigation



Reason for Change



of social assessment with

respect to Human health

impacts)

• Compliance with

recommended mitigation

measures.

• Level of public concern

unknown.

• Low confidence in data.

• Implementation of

recommended malarial

control measures and odour

control measures for standing

water.

• Compliance with

recommended mitigation

measures.

• Level of public concern

unknown.

• Moderate confidence in

data.

• Compliance with

recommended mitigation

measures.

• Level of public concern

unknown.

• Low confidence in data.

• Land appropriation and

clearance, and siltation or

diversion of surface water will

have a permanent impact.

• Level of public concern

unknown.

• Low confidence in data.



High



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VR



Impacts



Aspect



Operation



H2



Increase road and rail access to

3

the region .

Impacts of noise on health and

well being (train and road activity)

Exposure (inhalation) to increased

levels of dust and particulate

matter (PM) (road dust and road

train emissions)

Exposure (inhalation) to elevated

sulphur dioxide (SO2) and nitrogen

dioxide (NO2) in air emissions

(emissions from road trains).

Health benefits through local

3

employment

Increased road traffic accident rate



VR

Category



Magnitude



Extent



Duration



Basic

Impact

Index



Significance



2



2



1



1.7



Minor



2



1



2



1.7



Minor



2



1



2



1.7



Minor



3



1



1



1.7



Reason for Change



Moderate



Minor



4.0



Major



Moderate



2.0



Moderate



Minor



• Compliance with

recommended mitigation

measures.

• Level of public concern

unknown.

• Low confidence in data (no

traffic study).

• Compliance with

recommended mitigation

measures.

• Level of public concern

unknown.

• Low confidence in data.

• Land appropriation and

clearance, and siltation or

diversion of surface water will

have a permanent impact.

• Level of public concern

unknown.

• Low confidence in data.



5



3



4



2



2



2



High

Medium



1



Medium



1



Medium



1



H1

High



Degradation and/or reduction of

surface water

(sedimentation/erosion,

contamination, changes in

drainage)

Reduction in quantity or quality of

locally produced foods through

land appropriation and clearance,

potential siltation of

rivers/streams)



Access to improved healthcare

3

facilities



4



Residual

Impact

after

4

Mitigation



High



High



High



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VR



Impacts



Aspect

Increase road and rail access to

3

the region .



VR

Category



Magnitude



Extent



Duration



Basic

Impact

Index



Significance



Residual

Impact

after

4

Mitigation



High



1



Assuming all communities are >500m away.

2

Could be a positive impact if well compensated and/or moved to a better location.

3

Positive impacts.

4

Estimated for Impacts with Moderate or Major Significant only.



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4



Reason for Change



AFRICAN MINERALS LIMITED

STAGE 1 ENVIRONMENTAL, SOCIAL AND HEALTH IMPACT ASSESSMENT

TONKOLILI IRON ORE PROJECT



Port Facilities



7.4

7.4.1



Air Quality



Construction

Construction activities at Pepel Port will comprise a combination of existing asset refurbishment and

new development.

Contaminants of potential concern are dust emissions and exhaust gases that will contain several

pollutants (SO2, CO, NO2, PM10 and PM2.5).

Dust will be generated during vegetation clearance and earth movements (creation of new access

routes, and surface grading and levelling for buildings and facilities construction). Pollutants emitted

by these activities are mainly coarse particles (above 10 µm) without health effects. Nevertheless,

vegetation in this area (mangrove ecosystems) may be affected by the deposition of particles on the

leaves.

Dust (coarse particles) dispersion might travel up to 1 km depending on the wind characteristics,

believed to be prevailing westerly.

Additionally, diesel generators used for power supply, vehicles and machinery will generate exhaust

emissions. The use of efficient machinery (vehicles, motors and pumps) and a good practices policy

(e.g., minimise journeys, switch-off machinery when not in use, and reduce diesel generators use to a

minimum) will avoid unnecessary fuel consumption, minimising the potential impacts on air quality.

Operations

The most significant potential impacts may arise from two stockpiles located in the Port Facilities

area, with a capacity of 200,000 tonnes each, and the diesel generators used for the power supply.

Total dust emissions from aggregate storage piles will result from the following distinct source

activities during the storage cycle:





Loading of aggregate onto storage piles (batch or continuous drop operations).







Equipment traffic in the storage area.







Wind erosion of the fines within the pile and ground surfaces around the piles.







Loadout of aggregate for shipment or for return to the process stream (batch or continuous

drop operations).



The quantity of dust emissions from aggregate storage operations will vary with the volume of

aggregate passing through the storage cycle, the size of the particles, the surface of the stockpiles,

the moisture content (moisture aggregates and bonds fines to the surfaces of larger particles) and the

wind conditions.



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Suspended particle emissions could be controlled with great efficiency if measures are applied (e.g.,

humidification or protection from wind). When the appropriate measures are not taken, negative

effects will likely increase considerably.

Other potential sources of pollutant emissions (NOx, SO2 and PM) are the transport ships, periodically

present close to the port.

The project power requirements at the port will be supplied by small diesel generators. The installed

power (currently undefined) and the fuel characteristics will define the pollutant emissions. The power

generators should be specified to comply with the International Finance Corporation / World Bank

Group HSE Ambient Air Quality guidelines.

Potential Mitigation Measures

Generic recommendations for reducing impacts from activities to be conducted during the

construction phase of the project are listed below:

Decrease air quality impacts due to dust emissions:





Suppress dust during dry periods by spraying with water the potential sources that could

release airborne particles (unpaved roads, earth being moved)







Cover truck loads to avoid dust emissions during the transport of excavated earth







Keep vehicle movements to a minimum and use paved areas, where possible







Minimise discharge heights from trucks (not to exceed 1 m) for fine particles and consider the

use of dust suppression spray systems



Decrease air quality impacts due to combustion emissions:





Review machinery permits and ensure appropriate maintenance







Limit unnecessary journeys and adopt a policy of switching off machinery and equipment

when not in use







Consider a choice of machinery, equipment, vehicles and materials that are fuel-efficient as

part of the purchasing procedure



Controlled and uncontrolled fires (airborne emissions):





Open fires will be prohibited. To limit air emissions, avoid accidents and reduce fire risk

during the construction phase.



The negative impacts on air quality during the operation of the Pepel Port facilities can be minimised

through the following measures:





Design stockpiles based on wind patterns and consider the installation of windscreen if dust

emissions are observed.







Suppress dust emissions from the stockpiles during dry periods by spraying the surface with

water.



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Minimise discharge heights for fine particles and consider the use of dust suppression spray

systems.







Power generator emissions should be assessed to comply with Ambient Air Quality

Standards. If a combustion power plant is constructed to supply power for the project, the

pollutant emissions will affect the background air quality; and therefore, the emissions should

be assessed and incorporated as part of the background.



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Table 7-19 Port Area – Air Quality Impacts

Aspect



VR



Impacts



Earth movements,

grading and

construction



A1



Material processing

(unloading, loading)



A1



Stockpiles

A1



Power supply at Pepel

A1



Traffic (rail train and

other vehicles)



A1



Uncontrolled fires

A1



Power supply at Pepel



A2



VR

Category



Magnitude



Extent



Duration



Significance



1



Basic

Impact

Index

2



Moderate



Residual

Impact after

Mitigation

Minor



Dust emissions. Particle deposition on vegetation.

Visibility reduction.



High



2



2



Dust emissions. Particle deposition on vegetation.

Visibility reduction. Health effects.



High



3



2



4



3



Major



Minor



Dust emissions (coarse and fine particles).

Particle deposition on vegetation. Visibility

reduction. Health effects.



High



3



2



4



3



Major



Moderate



Exhaust emissions (SO2, CO, NO2 , PM10 and

PM2.5). Health effects.



High



3



2



4



3



Major



Minor /

moderate



Exhaust emissions from combustion. Dust

emissions in unpaved roads. Particle deposition

on vegetation. Visibility reduction. Health effects.



High



1



2



4



3



Major



Minor



Exhaust emissions (SO2, CO, NO2 , PM10 and

PM2.5). Health effects. Risk of fire propagation.



High



1



1



1



1



Minor



Insignificant



Medium



1



5



4



4



Major



Moderate



Global warming due to Greenhouse gases

emissions from fuel consumption



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Reason for

Change

Efficiency of

dust

suppression

measures

Efficiency of

dust

suppression

measures

Moderate

Efficiency of

dust

suppression

measures

Mitigation

measures

should

ensure AQ

guidelines

compliance

Efficiency of

emissions

control

measures

Mitigation

measures

should avoid

uncontrolled

fires

Hard to

mitigate



AFRICAN MINERALS LIMITED

STAGE 1 ENVIRONMENTAL, SOCIAL AND HEALTH IMPACT ASSESSMENT

TONKOLILI IRON ORE PROJECT

Vehicles and

machinery



A2



Global warming due to Greenhouse gases

emissions from fuel consumption



Medium



1



5



4



4



Major



Moderate



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Low

magnitude

but hard to

mitigate



AFRICAN MINERALS LIMITED

STAGE 1 ENVIRONMENTAL, SOCIAL AND HEALTH IMPACT ASSESSMENT

TONKOLILI IRON ORE PROJECT



7.4.2



Noise



Construction

An increase in noise levels may be generated by machinery, engines, vehicles used for transport,

loading and unloading of rock, materials and waste and power generation. Preventive and corrective

measures for construction phase are described below.

Operations

Identified noise sources are ship traffic (motors, sirens, etc.), machinery movement, conveyors,

loading and unloading activities at Dual Train Dumping Station, the Stacker Feed System, the

Reclaim Feed System and the Shiploader Feed System.

Noise can affect receptors far from the sources, depending on the noise power and frequency.

Industrial noise is typically reduced at 500 m to 1 km from the source as a consequence of the noise

power attenuation, soil absorption and the elements affecting the noise propagation. Noise generated

by offshore vessels might reach greater distances before being attenuated due to the low noise

absorption capacity of the sea and the absence of barriers to the noise propagation.

The potentially sensitive areas near the port are the nearest villages, Kalangba and Mapota, and the

Sierra Leone estuary fauna.

No specific information was available regarding the acoustical emission (noise power) of the

equipment that will produce noise in the port facilities. The proximity to Kalangba, located adjacent to

the facilities boundary, and the cumulative effect expected from truck traffic and railway corridor,

suggests that noise emissions will require mitigation measures.

Potential Mitigation Measures

Generic recommendations for the construction phase include the use of machinery and equipment

that guarantee low noise emissions and the regular inspections and maintenance of construction

vehicles and equipment. Journeys will be limited to only those necessary and a policy of switching off

machinery and equipment when not in use will be implemented. Vehicle speeds will be limited in the

vicinity of populated areas.

The preventive and corrective measures to reduce the impact on noise pressure during the

operational activities are defined below:





Select vehicles and equipment that guarantee low noise emissions







Conduct regular inspections and maintenance of vehicles and equipment







Mitigations measures, such as sound barriers, should be installed where ambient noise levels

may be exceeded. When these barriers are not effective, additional measures should be

considered, such as noise isolation at the sensitive receptors.



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Noise impacts at nearest receptors (Kalangba) should be minimised through an appropriate

layout plan. Community safety regarding noise as one of the environmental aspects will be

addressed through a Community Safety Plan to be developed by AML and rolled out in

conjunction with the EWCC.



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Table 7-20 Port Area – Noise Impacts

Aspect



VR



Impacts



VR

Category



Magnitude



Extent



Duration



Earth movements,

grading and construction



N1



Significance



4



Basic

Impact

Index

2



Increase in noise levels due to machinery

operations. Noise at near residential areas.

Fauna disturbance



Medium



5



4



Reason for

Change



Minor



Residual

Impact after

Mitigation

Minor



Hard to

mitigate



Material processing

(unloading, loading)



Increase in noise levels due traffic activity.

Noise at near residential areas. Fauna

disturbance



Medium



3



2



4



3



Moderate



Minor



N1



Hard to

mitigate



Traffic (rail train and

other vehicles)



Increase in noise levels due traffic activity.

Noise at near residential areas. Fauna

disturbance



Medium



3



2



4



3



Moderate



Minor



N1



Efficiency of

noise

barriers



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TONKOLILI IRON ORE PROJECT



7.4.3



Ecology & Biodiversity



Construction & Operations

Vegetation



Conservation importance



The principal impacts will arise from the potential clearance of mangrove during installation or

refurbishment of infrastructure. Invasive species may also spread to undisturbed land following

natural colonisation or deliberate introduction in disturbed areas (where such species tend to thrive).

The release of acidity and metals from disturbed acid sulphate soils (if present) can cause the die

back of vegetation in the localised area and hydraulically connected areas. Impacts on fauna may

further reduce natural colonisation by indigenous plant species where fauna play a role in seed

dispersal. The impact classification of these impacts is influenced by the nature of the vegetation

present in the area being impacted (defined as high and low conservation importance).



High



Low



Major

Land clearance;

contamination;

spread of alien

invasive species;

contamination;

exposure to

acidity / heavy

metals

-



Impact classification

Moderate

Minor

Reduced

dispersion of

seeds by fauna



Land clearance;

spread of alien

invasive species



Contamination;

exposure to

acidity / heavy

metals



Insignificant

-



Reduced

dispersion of

seeds by fauna



Terrestrial Fauna

The most significant potential impact is a change in species diversity and abundance (and potentially

a loss of species of conservation concern) through habitat loss and fragmentation directly associated

with land clearance and the refurbishment / construction of the port infrastructure. Although the area

may not be significant for terrestrial mammals, reptiles and amphibians, the area is an important

wintering spot for migratory bird species and therefore unnecessary habitat alteration should be

avoided. Displacement of terrestrial fauna may also occur through increased sensory disturbance as

a result of the mining activities. The impact classifications for these impacts are:





Major: habitat fragmentation and habitat disturbance.







Moderate: displacement of fauna.



Aquatic Ecosystems



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During the Phase 1b rapid assessment, no freshwater aquatic environments were identified on Pepel

Island (the location of the port infrastructure for Phase 1); therefore no impacts have been identified.

Potential Mitigation Measures

The following mitigation measures have been identified for ecology and biodiversity issues that are

considered to have a significant impact:





Mining infrastructure should be planned outside the forest patches and if this is not possible,

a botanist should survey the affected forest well in advance of the construction work to allow

all possible adjustments to be made.







Roads should be kept to the minimum width possible, commensurate with relevant design

and safety standards.







Plants belonging to species with conservation status Endangered (EN) or Critically

Endangered (CR) should at all times be left undisturbed. Plants belonging to species with

conservation status Vulnerable (VU) should be left undisturbed as much as possible.







Species of conservation concern which were found on the deposits or near proposed

infrastructure should be relocated to suitable localities outside the project area, by way of

seed collection and / or translocation of specimens.







Replanting of vegetation for any purpose should use indigenous species and should be based

on silvicultural systems that promote natural ecosystem functions and that increase the

probability that native species and ecological processes will be maintained. Planting of exotic

species in natural forest areas should not be permitted, with the possible exception of erosion

control activities utilising species that are proven to be short-lived and non-invasive.







In the localities with extensive areas of mangrove, such as at the Pepel Port lease areas,

construction activities should be planned outside the mangroves as much as possible, and

mangrove disturbance kept to a minimum where construction is unavoidable.







Establish and enforce a total ban on the hunting and capture of wildlife by company

employees and contractors.







Recognizing the importance of wildlife as a protein source to indigenous peoples, government

and the company should cooperate with local communities in the development of sustainable,

community-based wildlife management programs.







Project affected communities should be supported in the development of improved animal

husbandry techniques and provided with starter stocks. This would be a positive contribution

to the livelihoods of people and also reduce demand for bushmeat and limit the impact of

hunting restrictions on local communities.







The project should investigate the potential for supporting local plantations, which would be

beneficial to the project, local livelihoods and the remaining natural forests (and therefore,

also for fauna).



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Work with government to explore opportunities to control and minimise the uncontrolled inmigration of people into areas newly opened-up by road construction, especially along the

roads themselves. Uncontrolled in-migration will lead to further forest and wildlife losses and

compound pressures on existing human communities.







Consider biodiversity offsets to compensate for the unavoidable habitat loss (including

vegetation and fauna).



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Table 7-21 Port Area – Ecology & Biodiversity

VR



Impacts



Aspect



VR

Category



Loss of biodiversity and sensitive habitat

E1



Land

Clearance



Extent



Duration



Significance



4



Basic

Impact

Index

3



Major



Residual

Impact after

Mitigation

Moderate



3



3



4



3



4



4



Moderate



Minor



3



3



4



3



Major



Major



3



3



4



3



Major



Minor



4



3



4



4



Moderate



Minor



2



2



3



2



Moderate



Major



3



2



4



3



Major



Major



High



Loss of biodiversity and habitat

E2

E3



Magnitude



Low

Change in species richness and abundance

habitat loss / disturbance / fragmentation

High



E1



Localised clearance of vegetation – habitat

loss



High



Habitat loss

Port

Infrastructure

Rehabilitation



E2

E3



Low

Habitat loss / disturbance

High



Waste

Generation



die back of vegetation through exposure to

acidity and heavy metals

E1



High



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Reason for

Change

Careful

planning to

avoid

damage to

valuable

vegetation

Avoidance of

clearance

through forest

remains

Presently

unknown

pending

further

evaluation'

Avoid areas

of valuable

vegetation

Avoidance of

clearance

through forest

patches

Presently

unknown

pending

further

evaluation'

presently

unknown

pending

further

evaluation'



AFRICAN MINERALS LIMITED

STAGE 1 ENVIRONMENTAL, SOCIAL AND HEALTH IMPACT ASSESSMENT

TONKOLILI IRON ORE PROJECT

VR



Impacts



Aspect



VR

Category



die back of vegetation through exposure to

acidity and heavy metals

E2



E1



E3



3



3



3



Major



Major



3



3



4



3



Major



Major



2

4

2



3

3

2



2

4

3



2

4

2



Insignificant

Moderate

Moderate



Insignificant

Moderate

Moderate



Duration



4



3



3



High

Spread of alien invasive species



E2



Moderate



Residual

Impact after

Mitigation

Moderate



Extent



Low



Increased pressure on timber



Project induced

influx of

workers and

job seekers



Significance



4



Basic

Impact

Index

4



Magnitude



Increased pressure on timber

Spread of alien invasive species

Displacement of fauna



Low

High



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Reason for

Change

presently

unknown

pending

further

evaluation

Mitigation will

require cooperation

between AML

and local

partners –

pending

further

evaluation

Presently

unknown

pending

further

evaluation



AFRICAN MINERALS LIMITED

STAGE 1 ENVIRONMENTAL, SOCIAL AND HEALTH IMPACT ASSESSMENT

TONKOLILI IRON ORE PROJECT



7.4.4



Hydrology & Hydrogeology



Assessment of potential impacts on the hydrological and hydrogeological setting at Pepel Island has

been conducted based on a Phase 2B – Reconnaissance Level baseline assessment conducted

during February, March and April 2010 as well as observations on early works construction activities.

Construction





Construction and pumping of new water wells may lead to salt water intrusion and permanent

loss of water quality impacting other site and community wells if locations, depths or pumping

rates are not appropriate to the local aquifer morphology. Scott Wilson (March 2010) have

carried out a detailed non intrusive site study at Pepel that recommended installation of water

wells only in the northern part of the Island where current groundwater utilisation is negligible.

They also recommend a maximum installation depth of 25m and a pumping rate of 0.5 l/s in

order to minimise saline intrusion. Two well have recently (April 2010) been installed in the

Port Area to meet current construction and potable water demand. The wells extend to 32

and 42 mbgl and will be pumping approximately 2 l/s per well. Recently recorded electrical

conductivity values which are higher than in any other groundwater wells.







Modification and interruption to the existing hydrological regime may occur, particularly where

new raised roads or railway alter the path of the natural surface water drainage network.







Contamination of surface and / or groundwater due to loss of containment of fuels and other

chemicals associated with mobile and static plant and vehicle maintenance.







Mobilisation/solution of historical contaminants in soils including arsenic, oils and tars further

to disturbance of soils and structures and ground cover on site may impact on groundwater

and surface water runoff quality.







Demolition/renovation of historical plant and structures may lead to loss of containment of

historically present sources which include significant volumes of liquid hydrocarbons

(fuels/insulating oils/lubricants) in storage tanks, transformers and sumps may impact on

groundwater and surface water quality.



Operations





Groundwater abstraction leading to reduced community access to potable water supplies.

Groundwater will be abstracted at a rate of between 2.9 and 3.5 L.sec-1 across a proposed

network of nine groundwater bores. Over exploitation of the aquifer could locally reduce the

water table and potentially dry nearby community wells.







Induced salt water intrusion into freshwater aquifer through unsustainable groundwater

pumping. Saline water may be drawn into the aquifer either horizontally from the coast or

vertically from depth (if present) causing degradation of the freshwater resource.



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Contaminated runoff from stockpiled ore may cause sedimentation or heavy metal pollution to

local groundwater and surface water resources.







Loss of containment of fuel, solvents, lubricants and chemicals during transport or storage

could lead to contamination of surface water and groundwater.



Potential Mitigation Measures

The following mitigation measures have been identified for hydrology and hydrogeology issues that

are considered to have a significant impact:





Robust surface and groundwater monitoring programmes to establish baseline and ensure

early identification of impacts. Groundwater at Pepel Island is considered to be a highly

sensitive receptor both to contamination through construction and operational activities and

over exploitation. Failure to rigorously implement appropriate resource and environmental

management and protective measures could readily lead to very long term damage to the

aquifer beneath Pepel Port. The monitoring will allow mitigation measures to be refined and

ensure they are appropriate and effective.







Waste water treatment and testing to confirm compliance with relevant discharge standards.







Strict adherence to Environmental Management Plans prepared in line with industry and

international best practice.







Appropriate hydrogeological/hydrological assessment and field testing of water resources and

careful design of water abstraction points so as to minimise impacts on other users. This

process has been initiated by Scott Wilson (March 2010)







Detailed study and testing to determine whether recently drilled construction phase water

supply wells pose a risk of saline intrusion and long term or permanent damage to the aquifer.

In the event that a risk is established, carry out repair works to seal the base of the well/s with

cement/bentonite or abandon the risk wells and redrill in line with recommendations of the

Scott Wilson report or any subsequent study as per bullet point above.







Design to ensure potentially contaminating materials are not stored in proximity to surface

water courses and adequate bunding for spill control. Prepare spill response plans and

materials handling management plans. Avoid storage of materials at locations overlying

potentially sensitive/important shallow aquifers and prepare engineered low permeability

surfaces with drainage/runoff controls for storage and handling areas.







Perform leachate tests on ore to be stockpiled at the port to determine risks to groundwater

from stockpiles and allow for design of suitable storage area.







As part of routine baseline ESHIA studies, testing of surface soil scrapes, groundwater from

available water supply wells and inspection of readily accessible historical plant and

structures was carried out. Determination of mitigation measures to prevent potential impact

on groundwater due to disturbance of and leaching from potential existing historically

contaminated soils requires completion of more detailed understanding through site



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investigation including intrusive investigation techniques to assess subsurface soils in any

areas to be cleared or excavated as part of the proposed port development works.





A detailed audit of potential point sources of contamination should be carried out by a suitable

contractor and a site register prepared recording details of all risk areas such as location and

condition of structures and plant containing oils and tars for example. All transformer oils

should be tested for PCB’s. All existing leaks of oils and tars or other potential contaminants

to be repaired. All potential contaminating liquids currently within plant/structures with no

secondary containment to be drained of and disposed of in a safe manner or provided with

secondary containment or alternative storage facilities.







All current and future development works should be permitted only after reference to the

contamination register so that works can either avoid contaminated areas or go ahead after

appropriate remedial measures have been implemented.







Dependent on results of further sampling and testing, if appropriate, ensure that scraped

surface soils and excavation arisings are disposed of in a safe, suitable manner or stockpiled

in a suitable secure engineered location within the site boundary.







Ensure stockpiles of any potentially contaminative materials including ore stockpiles are

located in engineered low permeability bunded areas with surface drainage guided to catch

pits and settling areas to prevent runoff of rainwaters and leachate from dispersing dissolved

contaminants.







Minimise land / soil to be cleared or excavated and concentrate such activities in areas of low

soil quality and land-use potential.







Implement required storm water drainage and controls prior to earthworks and construction

activities to prevent release of potentially contaminated waters.



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Table 7-22 Port Area - Hydrology & Hydrogeology

VR Category



Magnitude



Extent



Duration



Basic

Impact

Index



Significance



Residual

Impact after

Mitigation



Higher sediment loads in surface runoff

entering watercourses and mangrove

swamps (construction)



High



3



2



3



3



Major



Insignificant



SW1



Higher sediment loads in surface runoff

entering watercourses and mangrove

swamps (construction)



High



3



2



3



3



Major



Insignificant



SW2



Modification and interruption to the

existing hydrological regime

(construction)



High



1



1



4



1



Minor



Insignificant



SW1



Contamination of surface water

resources (construction and operation)



High



3



3



2



4



Major



Insignificant



GW1



Contamination of groundwater resources

(construction and operation)



High



2



2



4



4



Major



Insignificant



SW1



Contamination of surface water

resources from uncontrolled release of

sewage and other waste waters

(construction and operation)



High



2



2



2



4



Major



Insignificant



GW1



Contamination of groundwater resources

from uncontrolled release of sewage and

other waste waters (construction)



High



2



2



4



4



Major



Insignificant



SW1



Contamination of surface waters from

uncontrolled release of drilling fluids

(construction)



High



2



2



1



2



Moderate



Insignificant



High



2



2



4



4



Major



Moderate



Aspect



VR



Land Clearance



SW1



Impacts



Earthworks



Waste generation



Resource utilisation



GW2



Reduced groundwater resources in port

area where water will be derived from



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Reason for

Change

Appropriate

design and

international

best practice

Appropriate

design and

international

best practice

Appropriate

design and

international

best practice

Appropriate

design and

international

best practice

Appropriate

design and

international

best practice

Adherence

to

international

best practice

Adherence

to

international

best practice

Adherence

to

international

best practice

Detailed

studies,



AFRICAN MINERALS LIMITED

STAGE 1 ENVIRONMENTAL, SOCIAL AND HEALTH IMPACT ASSESSMENT

TONKOLILI IRON ORE PROJECT



Aspect



VR



Impacts



VR Category



Magnitude



Extent



Duration



Basic

Impact

Index



Significance



Residual

Impact after

Mitigation



groundwater (construction and

operation).



GW1



Degradation of fresh groundwater

resource due to saline intrusion

(operations)



High



2



2



5



4



Major



Moderate



SW1



Uncontrolled release of fuels and toxic

chemicals including residual historical

sources (construction and operational)



High



3



3



2



4



Major



Moderate



GW1



Uncontrolled release of fuels and toxic

chemicals including residual historical

sources (construction and operational)



High



2



2



4



4



Major



Moderate



SW1



Turbidity and other water quality impacts

due to dusting and erosion from plant

movements on site



High



3



3



4



3



Major



Insignificant



SW1



Turbidity and water quality impacts from

dust and spillage of ore from open rail

wagons and conveyors



High



3



3



4



3



Major



Insignificant



Chemical and fuels

storage and utilisation



Vehicle/plant

movements



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Reason for

Change

appropriate

design and

location of

abstractions

and water

resources

management

plan

Detailed

studies,

appropriate

design and

location of

abstractions

and water

resources

management

plan

Engineering

design and

adherence to

international

best practice

Engineering

design and

adherence to

international

best practice

Engineering

design and

adherence to

international

best practice

Engineering

design and

adherence to

international



AFRICAN MINERALS LIMITED

STAGE 1 ENVIRONMENTAL, SOCIAL AND HEALTH IMPACT ASSESSMENT

TONKOLILI IRON ORE PROJECT



Aspect



VR



Impacts



VR Category



Magnitude



Extent



Duration



Basic

Impact

Index



Significance



Residual

Impact after

Mitigation



Reason for

Change

best practice



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TONKOLILI IRON ORE PROJECT



7.4.5



Soils & Land Use



Construction

Baseline soil data for the historical industrial Pepel Port area has been collected for a few indicative

surface samples only and indicates a probably relatively low level historical impact on quality,

principally with some elevated levels of arsenic and some localised leakage or spillage of fuels and

oils as well as coal tar related contamination. On the whole, the reinstatement of the Port is not

considered likely to have a significant impact on the soils at or outside the port if works are designed

and managed with due consideration given to current conditions.

Stripping of surface soils and other earthworks associated with preparation of new stockpile areas

and foundations for new port infrastructure could potentially mobilise or expose historically present

contaminants such as arsenic, asbestos and coal tar constituents. Full details of the proposed layout

of the port are not yet available but there will be a requirement for some foundation construction

activities. Working and disposal of excavated soils could potentially spread contamination to

uncontaminated soils including areas of the port and surrounds where farming and grazing is still

carried out.

Several sources of potential contamination remain on site since it was last operated as a port. These

sources include significant volumes of liquid hydrocarbons (fuels/insulating oils/lubricants) in storage

tanks, transformers and sumps. Coal tars are also present where they were used as sealants to

reduce infiltration of spillage/leakage of fuels along pipe runs and around the fuel farm tanks area.

Demolition and salvage and recycling works associated with development could lead to spillage and

spread of contaminants which could significantly reduce soil quality in the vicinity.

Asbestos containing materials (ACM) have been identified on the site. Construction board and

cement bound asbestos board and cement bound asbestos piping were used in buildings and

underground infrastructure (wastewater piping). Some of the piping has also been used as bollards –

placed in the ground as posts and filled with cement as observed on the boat jetty. Demolition and

salvage and recycling works associated with development could lead to disturbance / break up of

ACM and spread of asbestos fibres which could significantly reduce soil quality in the vicinity.

Operations

Operation of Pepel Port will include a number of activities with potential to impact on soils and land

use at and near the Port. Transport, storage and handling of fuel, solvents, lubricants and chemicals

as well as the ore itself could all impact on local soil quality including at residential areas adjacent to

the port and cultivation and mangrove areas at and near the port.

Potential Mitigation Measures

The following mitigation measures have been identified for soils and land use issues that are

considered to have a significant impact:



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Only sampling of surface soils, groundwater in available water supply wells and inspection of

readily accessible historical plant and structures was carried out during ESHIA field studies.

Mitigation measures to prevent potential impact on soils due to disturbance of potential

existing historically contaminated soils requires completion of more detailed understanding

through site investigation including intrusive investigation techniques to assess subsurface

soils in areas to be cleared or excavated as part of the proposed port development works.







A detailed audit of potential point sources of contamination should be carried out by a suitable

contractor and a site register prepared recording details of all risk areas such as location and

condition of structures and plant containing oils and tars for example. All transformer oils

should be tested for PCB’s.







An asbestos survey should be carried out by a qualified contractor and professional guidance

followed with regard to removal and safe disposal to ensure no spread of fibres. Asbestos

survey should screen for free fibres in and near all areas where ACM has already been

removed or is known or likely to have been located.







Identify areas of ACM disposal from recent development/renovation works on site on the

contamination register. Include these areas in the asbestos survey and seek surveyor

recommendations for future management of disposed materials.







Materials that pose a risk to soils and land use in their current condition (oil and tar leaks

known to be present) should be removed and disposed of in a safe manner or secured and

isolated.







All current and future development works should be permitted only after reference to the

contamination register so that works can either avoid contaminated areas or go ahead after

appropriate remedial measures have been implemented.







Dependent on results of further sampling and testing, if appropriate, ensure that scraped

surface soils and excavation arisings are disposed of in a safe, suitable manner or stockpiled

in a suitable secure engineered location within the site boundary.







Ensure stockpiles of any potentially contaminative materials including ore stockpiles are

located in engineered bunded areas with surface drainage guided to catch pits and settling

areas to prevent runoff of rainwaters from dispersing soils/sediment loading.







Minimise land / soil to be cleared or excavated and concentrate such activities in areas of low

soil quality and land-use potential.







Consider biodiversity offsets for unavoidable long-term and permanent soil / land clearance

and soil / land burial. Integrate livelihoods components as necessary with offsets to replace

lost land-use capability.







Implement appropriate conservation and preservation of any good quality stripped top-soils

and sub-soils from all areas to retain physical and chemical characteristics and seed-bank for

subsequent use for rehabilitation activities.



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Implement required storm water drainage and controls prior to earthworks and construction

activities to prevent erosion of soils or spread of potentially contaminated soils.







Restrict access by vehicles and construction plant to essential areas to minimise erosion and

compaction of soils.







Isolate and manage potential soil contaminants (including wind blown dusts and water-borne

contaminants).







Avoid deliberate introduction of alien invasive species during rehabilitation activities.







Manage pathways by which alien invasive species can enter a disturbed area (including

avoidance of non-indigenous plant species in rehabilitation activities).



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TONKOLILI IRON ORE PROJECT



Table 7-23 Port Area - Soils & Land Use

Aspect



Land clearance



Demolition and

Earthworks



VR



S2



Impacts

Exposure of soils and stripping of

vegetation in the port area may lead to

increased soil erosion



S1



Demolition / removal of structures and

equipment and earthworks may mobilise

(leaching/dusting) historically

contaminated surrounding soils and

impact on clean areas.



S1



Demolition / removal / renovation of

buildings with ACM may lead to release

of asbestos fibres and contamination of

soils.



S1



Earthworks may expose / damage

buried pipes composed of ACM leading

to release of asbestos fibres

contaminating soils.



VR Category



Magnitude



Extent



Duration



Basic

Impact

Index



Significance



Residual

Impact after

Mitigation



Medium



1



1



1



2



Minor



Insignificant



Medium



2



2



3



3



Moderate



Insignificant



Medium



1



1



4



3



Moderate



Insignificant



Medium



1



1



4



3



Moderate



Insignificant



Medium



2



2



4



3



Moderate



Insignificant



Medium



2



2



4



3



Moderate



Insignificant



spillage of ore, accumulated dust blown

from rail wagons and stockpile.

S1

Ore transport and

storage

S1



Surface water runoff from stockpiles and

stockpile areas may lead to

contamination of surrounding soils.



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Reason for

Change

Appropriate

site

management

and

international

best practice

Appropriate

site

management

and

international

best practice

Asbestos

survey and

qualified

contractor to

remove ACM

Asbestos

survey and

qualified

contractor to

remove ACM

Appropriate

site

management

and

international

best practice

Engineering

design and

adherence to

international

best practice



AFRICAN MINERALS LIMITED

STAGE 1 ENVIRONMENTAL, SOCIAL AND HEALTH IMPACT ASSESSMENT

TONKOLILI IRON ORE PROJECT



Aspect



VR



Impacts



S1



Demolition / removal of historical

structures containing fuels and oils

could result in loss of

containment/spillage and contamination

of soils.



S1



Uncontrolled release of fuels and toxic

chemicals (construction and

operational)



Chemical / fuels



VR Category



Magnitude



Extent



Duration



Basic

Impact

Index



Significance



Residual

Impact after

Mitigation



Medium



1



1



4



3



Moderate



Insignificant



Medium



1



1



4



3



Moderate



Insignificant



storage and

utilisation



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Reason for

Change

Contamination

survey and

register,

appropriate

site

management

Engineering

design and

adherence to

international

best practice



AFRICAN MINERALS LIMITED

STAGE 1 ENVIRONMENTAL, SOCIAL AND HEALTH IMPACT ASSESSMENT

TONKOLILI IRON ORE PROJECT



7.4.6



Geology & Geomorphology



Construction

The impact on geology and geomorphology within the Pepel Port area is expected to be minor as the

site has operated as a dedicated port facility servicing to a mine site in the past. Impacts on the

geology and geomorphology would already have occurred. All details of the Port design are not yet

known and there is potential for construction of new port facilities to impact on coastal geomorphology

but given the significant historical development and operation of the port, additional facilities are not

considered likely to greatly increase these impacts.

Operations

As with the construction phase, no operational activities are anticipated to impact significantly on

geology or geomorphology.

Potential Mitigation Measures





No significant impacts are considered likely based on current information with regard to

construction and operation of Pepel Port and therefore no mitigation measures are proposed

at this stage.



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TONKOLILI IRON ORE PROJECT



Table 7-24 Port Area - Geology & Geomorphology

Aspect



Earthworks



Stockpiling of iron

ore



VR



Impacts



VR Category



Magnitude



Extent



Duration



Basic

Impact

Index



Significance



Residual

Impact after

Mitigation



V1



Construction of new structures may

impact on local Pepel Island

geomorphology.



Low



2



2



4



3



Minor



Insignificant



V1



Iron ore stockpiles will change the

landform and impact on the visible

landscape.



Low



2



2



3



3



Minor



Insignificant



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Reason for

Change

Long term

rehabilitation

and

international

best practice

Long term

rehabilitation

and

international

best practice



AFRICAN MINERALS LIMITED

STAGE 1 ENVIRONMENTAL, SOCIAL AND HEALTH IMPACT ASSESSMENT

TONKOLILI IRON ORE PROJECT



7.4.7



Socio-Economic



Construction

Land acquisition

The refurbishment of the Pepel Port may require additional land in its vicinity for construction and

operational activities and facilities. The land near the port is currently used for dwellings, trading,

agriculture and grazing. Potential impacts include impacts on the land base as well as sea based

activities such as fishing.

The following mitigation measures are expected to reduce the intensity of the residual impacts from

major to moderate/minor.





Preparation of a Resettlement Action Plan (RAP).







Preparation of a livelihood restoration plan.







Implementation of a grievance mechanism.







Preparation and implementation of the CDAP.



Project induced influx of workers and job seekers

The economic opportunities created at the Pepel Port are expected to lead to an influx of workers and

job seekers mainly during the construction phase. This is likely to lead to:





Pressure on social infrastructure and natural resources.







Increases in social ills such as crime, alcoholism, drug abuse and prostitution.







Increases in communicable diseases.







Increases in the cost of living.



The following measures are expected to reduce the impacts from major to moderate/minor.





Planning jointly with local government, Paramount Chief and other stakeholders to

minimise speculative migration.







Providing assistance to local government to increase (and improve) infrastructure

services.







Support for strengthening of programmes for control of communicable diseases and

educational campaigns for prevention of social ills.



Operations

The refurbishment of the Pepel Port is expected to have predominantly beneficial socio-economic

impacts during its construction and operation phase (up to 8 years).



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Economic aspects





The employment generation within Port Loko District and at national level.







The investment for refurbishment of the port.







Skill building of people employed at the port.







Revenue earnings for the government.



No mitigation measures are required for these positive impacts.

Community investment

In line with its corporate policy, AML is expected to initiate a social investment programme in the

Pepel Port area with the start of construction work. This is expected to mitigate to some extent the

negative impacts on the affected communities. Potential benefits to the community are expected to

include:





Increases in education and skills levels.







Improvement in social infrastructure such as water supply, schools and health centres.







Development of livelihood opportunities, independent of the port.







Other initiatives to address community needs.



Closure of the port activities

Once the Tagrin Port is constructed, operations at Pepel Port will be transferred to the new port. It is

expected that the workers and contractors at Pepel Port may either be transferred and engaged at

Tagrin Port or continue working at Pepel if it continues to operate as a facility under lease to another

operator and therefore the negative socio-economic impacts associated with closure are expected to

be avoidable.



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Table 7-25 Port Area – Socio-Economic

VR



Impacts



Aspect



VR

Category



employment creation

(construction)



Magnitude



Extent



Duration



Significance



2



Basic

Impact

Index

3



Major



Residual

Impact after

Mitigation

Moderate (+)



3



4



2



3



3



2.7



Major



Major (+)



2



3



3



2.7



Major



Major (+)



3



4



2



3



Major



Moderate (+)



2



4



3



3



Major



Major (+)



3



4



3



3.3



Major



Major (+)



2



1



4



2.3



Moderate



Low



High



employment creation (operation)

High

Economic aspects

(employment,

procurement of

services and supplies,

and payment of taxes

and revenue to

government)



Training of workers

High

H1



Increase in business for suppliers

(construction)



Increase in business for suppliers

(operation)



High



High



Increase in government income

High



Land acquisition



H1



Loss of land



High



Loss of shelter



High



1



1



4



2



Moderate



Moderate (+)



Loss of income



High



2



2



4



2.7



Major



Minor



Loss of access route



High



2



2



4



2.7



Major



Moderate



Reason for Change



Priority given to locals

during recruitment

process although skills

availability is expected to

be limited

Priority given to locals

during recruitment

process

Considerable skills

enhancement injected

into the area

Priority given to locals

during tender process

although availability is

expected to be limited

Priority given to locals

during tender process

although availability is

expected to be limited

Revenue from project

taxes, royalties, etc

expected to be major

contributor to GoSL

GDP

Provision of alternative

land

Provision of replacement

housing of superior

quality in most

circumstances

Implement livelihood

restoration plan

Identify and provide

alternative routes or



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TONKOLILI IRON ORE PROJECT

VR



Impacts



Aspect



VR

Category



Magnitude



Extent



Duration



Basic

Impact

Index



Significance



Residual

Impact after

Mitigation



Reduced food security



High



2



2



4



2.7



Major



Minor



Breakdown social support



High



1



2



4



2.3



Moderate



Minor



2



2



3



2.3



Moderate



Minor



Increase in stress

High



H1



Project induced influx

of workers and job

seekers



Project induced

Community



H1



Reduced access to services



High



2



2



3



2.3



Moderate



Moderate (+)



Community conflict



High



2



2



2



2



Moderate



Minor



Pressure on social infrastructure

due to increase in population

Pressure on natural resources

due to increase in population

Increase in social ills (crime,

alcoholism and prostitution)



High



3



2



3



2.7



Major



Moderate (+)



High



2



3



3



2.7



Major



Moderate



High



3



3



3



3



Major



Moderate



Increase in communicable

diseases



High



3



3



3



3



Major



Moderate



Increase in cost of living

Tensions between locals and

outsiders due to real or perceived

unequal access to project benefits

Social infrastructure



High

High



3



3

2



3

3



3

1.7



Major

Moderate



Moderate

Minor



3



2



3



2.7



Major



Moderate (+)



High



Reason for Change



crossing methods

Provision of alternative

land and transitional

support mechanisms

Relocate all villagers to

the same host site

village.

Regular consultation and

publicising grievance

mechanism with PAPs

Provision of replacement

social infrastructure

likely to provide

increased access to

service

Effective and broad

stakeholder engagement

Provision of replacement

social infrastructure

Effective and broad

stakeholder engagement

Effective and broad

stakeholder engagement

together with support

from appropriately

positioned NGOs

Effective and broad

stakeholder engagement

together with support

from appropriately

positioned NGOs

Influx management.

Influx management and

regular consultation

Provision of replacement

social infrastructure



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TONKOLILI IRON ORE PROJECT

VR



Impacts



Aspect

investment



Education and skills



VR

Category

High



Livelihoods



Reason for Change



Major



Residual

Impact after

Mitigation

Major(+)



2.7



Major



Major(+)



-



-



-



Increased income from

direct and indirect

employment

-



-



-



-



-



-



-



-



-



-



-



-



-



Significance



3



Basic

Impact

Index

9



3



Magnitude



Extent



Duration



3



3



3



2



High

H1



Mine closure



Loss of income for workers,



High



Loss of businesses



High



Loss of revenue to government



High



Psychological impacts



High



It is planned to use Pepel Port for

the export of hematite for a limited

period, until a new port is built at

Tagrin. Once the Tagrin port is

ready the operations at Pepel Port

will be transferred to the new port.

Pepel Port may continue to be

used for the import of materials

required for the mining operation

for the duration of the mine’s life or

other non-project

related activity in accordance with

the terms of the Pepel Port and

infrastructure lease agreement.

Consequently, as for the transport

component, it is expected that

workers and contractors at Pepel

Port will largely be transferred and

engaged at Tagrin Port or remain

at

Pepel port to avoid the negative

socio-economic impacts

associated with closure.



Training programs



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TONKOLILI IRON ORE PROJECT



7.4.8



Human Health



Construction & Operations

Based on the current available project and existing health information, preliminary impacts for the

construction and operation of Phase 1 have been identified for the Pepel Port facilities. It is important

to note, that the Project description has not been finalized, nor has all the baseline data been

analysed, therefore, the qualitative impact designations and significance may change as the Phase 1

details are finalised. In addition, the implications of incineration of waste at the Pepel Port site have

not been assessed at this point in time. Assessment of this issue will be undertaken for the Stage 2

ESHIA.

The preliminary health impacts associated with the Pepel port facilities are described below. Impacts

relate to both the construction and operation of the port unless otherwise stated.

Potential impacts of major significance:





Community resettlement (during construction);







In-migration related impacts (disease, food security, substance abuse, home violence) (during

operation phase);







Increased burden of disease due project activities and water storage facilities (drinking water

tanks, waste and raw water storage ponds);







Degradation and/or reduction of surface water (sedimentation/erosion, contamination, changes in

drainage patterns); and







Degradation of groundwater quality.



Potential impacts of moderate significance:





In-migration related impacts (disease, food security, substance abuse, home violence) (during

construction phase);







Increased burden of disease due project activities and water storage facilities (drinking water

tanks, waste and raw water storage ponds)(for construction phase);







Impacts of noise on health and well-being (port and heavy vehicle activity); and







Reduction in quality or quantity of locally produced foods.



Potential impacts of minor or insignificant significance:





Increased road traffic accident rate;







Exposure to increased levels of road dust and particulate matter (PM) (diesel power generators,

crushers, blasting, vehicles, road dust)(assuming no thermal power generation requirements);



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Acute exposure to elevated SO2 and NO2 in air (diesel power generators, heavy vehicle

emissions)(assuming no thermal power generation station); and







Exposure to hazardous materials removed from the exiting port facilities to the local villages (e.g.,

materials containing asbestos).



Potential positive impacts:





Access to improved healthcare facilities (for general public); and







Health benefits through local employment.



A number of assumptions were made for the preliminary impact assessment specific to the Phase 1

port area. It was assumed that all communities on or within 500 m of the Project area were to be

resettled to a distance greater than 500 m before the construction phase begins. Thus, the Health VR

used in the preliminary impact assessment for exposure to PM, SO2, and NO2 was categorized as

Medium (Human HR2 see Table 7-1 in Section 7).

With respect to PM, SO2, and NO2 emissions, it was assumed that a thermal power generating facility

(a potentially significant generator of these types of emissions) will not be built at the Pepel port. As

the precise method of power generation has not yet been determined, this preliminary impact will

require re-assessment once the Phase 1 project details have been finalized. Should a thermal power

generator be implemented, the significance of the impact and the sensitivity of the VR would be

expected to increase.

The positive class impacts associated with access to medical facilities only apply if AML undertake to

provide these facilities.

Where there was uncertainty in significance designation, the more conservative assumption was

selected so as to ensure that the preliminary potential impact of the Project was not underestimated.

Potential Mitigation Measures

Potential mitigation measures have been identified in association with each headline health impact as

listed below. The headline impacts were identified with the assumption that no mitigation measures

were applied. Thus, implementation of the recommended mitigation measures is expected to reduce

the significance of the headline health issues and thus avoid potentially major health issues for

persons living in the vicinity of the Projects.

Health related mitigation measures are listed below, however, it is important to note that mitigation

recommended by the other disciplines, particularly socio-economic as well as other environmental

assessments (e.g., air, surface and groundwater, flora and fauna) can also affect human health.

Alteration of project descriptions and monitoring results may result in the recommendation of

additional mitigation measures, or modification of those currently recommended.

Community resettlement





Social mitigation measures regarding loss of land and re-settlement (see social assessment

results and mitigation measures).



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In-migration related impacts (disease, food security, substance abuse, home violence)





Adherence to the requirements of the Prevention and Control of HIV and AIDS Act.







Appropriate education of workforce regarding transmittable diseases.







Employing local labour where appropriate.







Providing suitable healthcare facilities.







See social assessment results and mitigation measures.



Increased burden of disease due to project activities, and water storage facilities (drinking water

tanks, waste and raw water ponds).





Awareness and control of mosquito breeding sites to prevent increased malaria incidence

(See Appendix 17 – Environmental Note of Malaria Control).







Appropriate treatment of drinking water.







Providing suitable healthcare facilities.







Appropriate management of waste water ponds, including odour controls.



Degradation and/or reduction of surface water (sedimentation/erosion, contamination, changes in

drainage patterns, dam construction)





Management and remediation of any contamination associated with storage of fuels, waste

water and other hazardous materials.







Management of surface and storm water run-off.



Degradation of groundwater quality





Monitoring of water quality in groundwater wells used for drinking water.



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Table 7-26 Port Area – Health

VR



Impacts



Aspect

Increased road traffic



Construction



H2



Exposure (inhalation) to

increased levels of dust and

particulate matter (PM) (potential

emissions from diesel power

generators and vehicles)

Exposure (inhalation) to elevated

sulphur dioxide (SO2) and

nitrogen dioxide (NO2) in air

emissions (from power generator

and vehicles).

Health benefits through local

3

employment

2

Community resettlement



VR

Category

Medium



Medium



Medium



1



Magnitude



Extent



Duration



1



1



2



Reason for Change



Major



Moderate



Moderate



Minor



• Compliance with

recommended mitigation

measures.

• Resettlement is permanent.

• Level of public concern

unknown.

• Moderate confidence in data

(requires interpretation of

social assessment with

respect to Human health

impacts)

• Compliance with

recommended mitigation

measures.

• Resettlement is permanent.

• Level of public concern

unknown.

• Moderate confidence in data



Significance



1



1



1



1.3



Insignificant



2



1



1



1.3



Insignificant



4



3



4



3.7



3



2



1



2.0



Insignificant



1



1



High



H1



In-migration related impacts

(disease, food security,

substance abuse, home

violence)



High



4



Residual

Impact after

4

Mitigation



Basic

Impact

Index

1.0



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VR



Impacts



Aspect



VR

Category



Increased burden of disease due

to project activities (drinking

water tanks, waste and raw

water ponds)



Magnitude



Extent



Duration



Basic

Impact

Index



Significance



4



2



3



3.0



Major



Moderate/

Minor



3



2



1



2.0



Moderate



Minor



4



2



3



3.0



Major



Moderate



2



3



4



3.0



Major



Moderate



High



Impact of noise on health and

well being



High



Degradation and/or reduction of

surface water

(sedimentation/erosion,

contamination, changes in

drainage)

Degradation of groundwater

quality/quantity



High



High



4



Residual

Impact after

4

Mitigation



Reason for Change



(requires interpretation of

social assessment with

respect to Human health

impacts)

• Implementation of

recommended malarial

control measures and odour

control measures for standing

water.

• Compliant will applicable

legislation and guidelines for

water storage and treatment

of drinking and waste waters.

• Provision of publicly

accessible health care

facilities.

• Level of public concern

unknown.

• Moderate confidence in

data.

• Compliant with applicable

legislation and guidelines.

• Implement quieter

operations time (e.g., at night,

during important

public/religious holidays).

• Level of public concern

unknown. Moderate

confidence in data.

• Compliance with

recommended mitigation

measures.

• Level of public concern

unknown.

• Low confidence in data.

• Compliance with

recommended mitigation



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VR



Impacts



Aspect



Reduction in quantity or quality

of locally produced foods through

land appropriation and

clearance, potential siltation of

rivers/streams)



Access to improved healthcare

3

facilities

Increase road and rail access to

3

the region



Increased road traffic

Operation



H2



H1



Exposure (inhalation) to

increased levels of dust and

particulate matter (PM) (potential

emissions from diesel power

generators and vehicles)

Exposure (inhalation) to elevated

sulphur dioxide (SO2) and

nitrogen dioxide (NO2) in air

emissions (from power

generators and vehicles).

Health benefits through local

3

employment

In-migration related impacts

(disease, food security,



VR

Category



Magnitude



Extent



Duration



Basic

Impact

Index



Significance



3



1



3



2.3



Moderate



1



1



1



1.0



Insignificant



2



1



1



1.3



Insignificant



2



1



1



1.3



Insignificant



3



2



4



3.0



Major



4



Residual

Impact after

4

Mitigation



Moderate/

Minor



High



Reason for Change



measures.

• Level of public concern

unknown.

• Low confidence in data.

• Compliance with

recommended mitigation

measures including those

associated with resettlement.

• Level of public concern

unknown.

• Low confidence in data.



High

High



Medium



1



Medium



1



Medium



1



High



Minor



• Compliance with

recommended mitigation



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VR



Impacts



Aspect



VR

Category



Magnitude



Extent



Duration



Basic

Impact

Index



Significance



substance abuse, home

violence)



Increased burden of disease due

to project activities (drinking

water tanks, waste and raw

water ponds)



4



2



3



3.0



Major



Moderate/

Minor



3



2



2



2.3



Moderate



Minor



4



2



3



3.0



Major



Moderate



High



Impact of noise on health and

well being



High



Degradation and/or reduction of

surface water

(sedimentation/erosion,



High



4



Residual

Impact after

4

Mitigation



Reason for Change



measures.

• Resettlement is permanent.

• Level of public concern

unknown.

• Moderate confidence in data

(still needs interpretation of

social assessment with

respect to Human health

impacts)

• Implementation of

recommended malarial

control measures and odour

control measures for standing

water.

• Compliant will applicable

legislation and guidelines for

water storage and treatment

of drinking and waste waters.

• Provision of publicly

accessible health care

facilities.

• Level of public concern

unknown.

• Moderate confidence in

data.

• Compliant with applicable

legislation and guidelines.

• Implement quieter

operations time (e.g., at night,

during important

public/religious holidays).

• Level of public concern

unknown. Moderate

confidence in data.

• Compliance with

recommended mitigation

measures.



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VR



Impacts



Aspect



VR

Category



Magnitude



Extent



Duration



Basic

Impact

Index



Significance



contamination, changes in

drainage)

Degradation of groundwater

quality/quantity



2



3



4



3.0



Major



Moderate



3



1



3



2.3



Moderate



Moderate/

Minor



High



Reduction in quantity or quality

of locally produced foods through

land appropriation and

clearance, potential siltation of

rivers/streams)



Access to improved healthcare

3

facilities

Increase road and rail access to

3

the region .



High



4



Residual

Impact after

4

Mitigation



Reason for Change



• Level of public concern

unknown.

• Low confidence in data.

• Compliance with

recommended mitigation

measures.

• Level of public concern

unknown.

• Low confidence in data.

• Compliance with

recommended mitigation

measures including those

associated with resettlement.

• Level of public concern

unknown.

• Low confidence in data.



High

High



1



Assuming all communities are >500m away.

Could be a positive impact if well compensated and/or moved to a better location.

3

Positive impacts.

4

Estimated for Impacts with Moderate or Major Significant only.

2



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7.5



Offshore & Coastal



7.5.1 Port Layout

Land Clearance and Earthworks

The port will sit within the existing footprint and no land clearance is planned.

The proposed port infrastructure is located on a wetland within the Sierra Leone Estuary Ramsar site.

The Ramsar site covers the majority of the estuary, and Pepel sits within one of the core areas.

Coastal habitat includes mangrove and mudflats which provide important nesting and feeding

grounds for marine fauna and avifauna, and serve as a nursery for marine fish and shellfish.

Mangroves stabilise soils and marine sediment, and clearance can lead to increases in erosion and

run-off. Any disturbance to these habitats may therefore have significant consequences on marine

and coastal fauna and flora, as well as on the local communities that depend on them for food and

resources. Figure 7-1 is a habitat map of the Pepel Island area; the proposed port layout is overlaid to

give an initial indication of the potential impacts of any clearance of habitat.



Figure 7-1 Pepel habitat map overlaid with the early port layout



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The baseline preliminary survey indicates that the coastal and marine habitat around Pepel is healthy

and contains a high level of biodiversity. Land clearance and significant earthworks are not required

but there are a number of potential impacts to the coastal habitat and mangrove in particular including

altered hydrology and spill over of development effects to surrounding habitat.

The majority of the port infrastructure is already in place, and most of what is required is expected to

be refurbished rather than constructed. As a result there should be no significant increase in the

existing port footprint and no area of coastal habitat will have to be cleared. However, changes to

hydrology and its affect on coastal habitat requires further investigation and the layout of the port

must be finalised before the impact rating can be reduced to the minor that is expected..

The potential impact on the VR coastal habitat of clearance of the port footprint could be major if the

existing port footprint is not maintained.

Mitigation measures:

• Ensure that the port remains within the existing footprint to avoid mangrove clearance and

disruption; and

• Mangrove protection and management should be considered as compensatory measures

within the next phase of the Tonkolili project.

Pressure on the Use of Resources due to Population Increase

The construction camp could increase pressure on local resources if all workers are not fully catered

for, potentially affecting marine coastal habitat and fauna, including mangroves (used as a primary

source for fuel) and fisheries. Currently the mangroves located in and around the island are in a

healthy and diverse state, therefore the potential impact on mangroves is considered to be significant.

The local fish populations are already subject to a high degree of exploitation from the local villages,

so any increase in fishing activity is also viewed as significant.

Before mitigation the potential impact on VR coastal habitat is considered to be of major significance.

Before mitigation the potential impact on VR human development potential i.e. fisheries is considered

to be of moderate significance.

Mitigation measures:

• Construction Management Plans must ensure that construction workers have access to

appropriate facilities to avoid the need to use local resources, in particular relating to

mangrove.

Clearance of Existing Port including Stockpiles

The current Port development plans do not require removal of old stockpiles that remain on site.

Given that the two stockpiles located at the south west area of the former facility have been in place

for a matter of decades, it is assumed that any significant dusting, washout of fines and leaching has

already occurred and they do not pose a significant risk while they remain undisturbed. In the event

that at some future point the existing ore stockpiles are to be removed this operation has the potential

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to lose material through dust dispersion and rainwater run-off, leading to direct impacts in estuarine

water quality, and secondary impacts to coastal and subtidal habitats and fauna. Considering the

large volume of old ore currently present at Pepel, these could potentially be significant, depending on

the clearance and transport procedures put in place.

Whilst it has been shown that slight positive impacts associated with increased rates of growth

(particularly in younger mangrove plants) have been associated with iron contamination, toxicity limits

are not known and the potential for synergistic negative responses remain.

Alongi (2010) found that growth of five mangrove species from seedling to sapling stage were

enhanced by increasing iron supply, although some species showed iron toxicity at higher supply

rates. Paling et al., (2001) note that iron ore dust does not enter or damage the stomatal cells in

leaves of the white mangrove (Avicennia marina). The authors concluded that if iron ore dust affects

mangroves, “it must do so by some other mechanism, such as either increased temperature, shading

or a restriction of transportation by the thickness of the dust on the abaxial surface”.

Over the past 24 years rain and wind activity has subjected the old stockpiles to leaching, and there is

a chance that the percentage of leachable material remaining is now very low. Results of leachate

tests on a single sample comprising principally ore filings from the stockpile support this assumption.

This would substantially diminish the potential impact, and further assessment on the nature of the

residual material is required before a full conclusion can be made. There is currently no evidence of

any existing impact on the surrounding mangroves due to the presence of the residual hematite ore,

although there are elevated levels of heavy metals in the nearshore soil samples (Hydrological

baseline survey, April 2010).

Before mitigation the impact on VR marine fauna is considered to be of moderate significance.

Before mitigation the impact on VR coastal habitat is considered to be of moderate significance.

Mitigation measures:

• Undertake physical and chemical analysis of the residual iron ore prior to removal;

• Ensure appropriate collection and treatment of run-off during construction; and

• Implement an appropriate Waste Management Plan to guarantee minimal loss of material to

the coastal and marine environment during removal.



7.5.2 Port Facilities

In general, port construction or refurbishment activities tend to disturb coastal and marine flora and

fauna due to the generation of noise and dust, the continuous use of electric lighting, and changes in

water quality from runoff and discharges of contaminants.

Increased Noise



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The use of heavy machinery during construction tends to temporarily increase ambient noise levels,

which can potentially result in disturbance of sensitive coastal fauna such as birds. The Ramsar site

covers the majority of the estuary, and Pepel sits within one of the core areas. The current level of

noise in Pepel is relatively low, due to the low human population and lack of any significant port

activity. As a result, higher noise levels may result in significant impacts on birds. Further information

is provided on the impacts to avifauna and terrestrial fauna in the terrestrial noise assessment.

Before mitigation the potential impact on VR avifauna is considered to be major

Mitigation measures:





Adapt construction activities to avoid areas of high avifauna population, important nesting and

feeding sites, and migratory and nesting seasons; and







Avoid the most sensitive times of the day e.g. extended night operations.



Increased Light Levels

Persistent man-made light can be a major issue for a range of marine fauna, with birds in particular

sensitive to increased and extended levels. Non-natural light can deter them from feeding, breeding

and nesting, and can generally confuse their natural behaviour (Longcore and Rich, 2004, Lorne &

Salmon, 2007, Witherington, 1992).

Due to the high density of wetland birds present in the project location, and its position inside a

designated Ramsar site, increased light is a potentially significant impact, especially if construction

work would take place during bird migratory or breeding seasons. The low levels of current manmade light at Pepel also contribute to this impact.

Before mitigation the potential impact on VR avifauna is considered to be major

Mitigation measures:

• Avoid strong lighting on any sensitive habitat areas, use shading methods wherever possible;

and

• Evaluate the use of low-pressure sodium vapour lamps, as this wavelength does not disorient

fauna as much as regular full spectrum lighting.

Wastewater Discharge

If appropriate collection and treatment systems are not in place, the presence of construction camps

pose a threat to estuarine water quality due to wastewater discharge. Discharge of untreated

wastewater into the estuary has the potential to affect water pH, colour, temperature, smell, dissolved

oxygen, nutrient levels and bacterial contamination. This can create indirect impacts on the estuary

ecosystem, as well as posing a health risk to local communities; especially if the discharge point is

located near to beaches used by locals for fishing or bathing.

The significance of the impact of waste water discharge is highly dependant on the treatment system

implemented in the project design, and the location of the discharge point in the estuary.

Before mitigation the impact on VR marine fauna is considered to be of moderate significance.

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Before mitigation the impact on VR coastal habitat and VR subtidal habitat is considered to be of

moderate significance.

Before mitigation the impact on VR human development potential (i.e. fisheries) is considered to be of

moderate significance.

Mitigation measures:





Design an appropriate wastewater collection and treatment system utilising the best available

techniques;







Install a temporary treatment plant to treat construction camp discharges;







The treated water discharge point should be located away from sensitive locations such as

mudflats, mangroves and areas of community use; in an area with strong tidal currents to

increase dilution and removal; and







In the absence of national legislation, the treatment system should meet World Bank

discharge limits, to ensure the receiving water quality is within appropriate international

standards.



A more detailed assessment of wastewater discharges is required to develop the mitigation methods

further.

Spills and Run-off of Oil and Chemical contaminants

During construction and refurbishment there is a risk of increased run-off due to earthworks, and the

use of heavy machinery, including the disturbance of contamination from the previous port operations.

There is also a risk of oil and chemical contamination from fuel, lubricants and coatings used in

construction machinery, and from potential oil spills.

The significance of this impact will depend upon the level of increased run off and/or spills, and their

location and proximity to coastal habitat such as mangroves or mudflats; mangroves are particularly

sensitive to oil spills.

Before mitigation the impact on VR marine fauna is considered to be of moderate significance.

Before mitigation the impact on VR coastal habitat and VR subtidal habitat is considered to be of

moderate significance.

Before mitigation the impact on VR human development potential (i.e. fisheries) is considered to be of

moderate significance.

Mitigation measures:





Design an appropriate run-off collection and treatment system using the best available

techniques prior to discharge. Coatings (e.g. anti-fouling) should be selected to minimize

contamination risk;







Develop and implement an appropriate Waste Management Plan that would define the best

ways of dealing with waste oils, following the industry best practices;



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Management plans should ensure that the risk of accidental spillage is minimised, and

contingency planning and emergency response measures should be in place. Follow industry

best practices regarding refuelling activities, oil handling activities and machinery

maintenance; and







In the absence of national legislation, treatment systems to be implemented should be

designed to meet World Bank discharge limits, to ensure the receiving water quality is within

appropriate international standards.



The ESHIA process to date has already been influential in modifying the Pepel Port design so that

earthworks at Pepel are designed to slope away from water and include a settling sump to collect

sediment in run-off. This is subject to ongoing assessment and drainage design to manage run-off

during construction stage. As such further modifications and improvement will be controlled through

a management process in order to implement mitigation methods.



7.5.3 Marine Structures

In addition to the terrestrial port infrastructure, the refurbishment of marine structures has the potential

to cause a range of additional effects on the marine environment. These include disturbance of

coastal and subtidal habitat, changes in water quality and associated underwater noise.

Refurbishment of Mooring Dolphins

The refurbishment and potential construction of mooring dolphins, to enable the mooring of

transshipment vessels will primarily impact on the sub-tidal habitat. The sub-tidal habitat directly

beneath could be impacted through smothering, pile driving, and placement of rock material. At the

time of writing, detailed information on the precise nature of sub-tidal habitat at the proposed locations

of the dolphins had not been collected but is believed to be soft sediment, with no sensitive habitat.

As the structures are relatively small, disturbance will be localised and restricted. No other major

structures will be added to the existing loading jetties during port operations.

The impact on VR sub-tidal habitat without mitigation is considered to be minor.

No mitigation measures are required other than further characterisation of the subtidal habitat.

Increased Turbidity

The construction and refurbishment of marine structures could result in elevated turbidity within the

immediate vicinity of the port. Activities such as piling can significantly disturb bottom sediments,

introducing material into the water column. Increased turbidity can result in a number of direct and

indirect impacts on coastal and marine ecosystems; for example, levels of photosynthesis can fall due

to a drop in light penetration down through the water column. This can impact on marine flora, and on

up through the marine fauna food chain, limiting the ability of organisms to grow, reproduce and

survive.

The degree to which turbidity and smothering affects benthic species is dependent on pre-existing

ambient water quality conditions and the tolerances of local species (ABP Research, 1999; Ellison,



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1999). Coastal habitats such as mangroves can also be affected by high levels of turbidity, but

specific tolerances vary with species (Ellison, 1999).

During the wet season, the Sierra Leone River Estuary is characterized by high rainfall, and

associated run-off and riverine input. The estuarine water flowing through the project area

experiences high levels of turbidity all year round and particularly during the wet season and on the

ebb tide. This has been confirmed by a specific monitoring campaign. Therefore marine fauna and

habitats in the Pepel area are likely to be resilient to increased turbidity, particularly over short

durations such as that required for construction.

Before mitigation the impact on VR marine fauna is considered to be of minor significance.

Before mitigation the impact on VR coastal habitat and VR subtidal habitat is considered to be of

minor significance.

Before mitigation the impact on VR human development potential (i.e. fisheries) is considered to be of

minor significance.

Although the impact is expected to be minor the following mitigation measures should be considered:





Use of floating turbidity barriers and/or silt curtains to contain turbidity plumes during marine

construction activities; and







Design construction activity to occur in periods of high dispersion (e.g. ebb tide).



Disturbance of Contaminated Sediments

Construction/refurbishment activity has the potential to disturb marine sediment. If the sediment

retains any pre-existing contamination (e.g. hydrocarbons or metals) water quality may be impacted

through the re-introduction of these contaminants into the water column. If these released

contaminants are assimilated by marine flora or fauna (e.g. mangroves, fish and shellfish) they can

accumulate in the food chain, impacting on many areas of the marine ecosystem and the local human

population dependant on these resources.

Whilst showing elevated levels of hydrocarbons directly opposite the main loading jetty the sediment

analysis from the preliminary marine baseline survey (March 2010) showed little signs of major

contamination. However, the hydrological baseline survey (April 2010) sampled several onshore

areas close to the high water mark, and showed high levels of arsenic, chromium, copper, lead and

zinc7; potentially a result of the leached materials from the pre-existing port infrastructure. The area

where the mooring dolphins are to be constructed lies between these two areas. At the time of writing,

no detailed study has been completed on intertidal sediment quality and around the proposed dolphin

locations but a survey covering this area is underway and will be reported in the Stage 2 report.

Undertake a detailed characterization of nearshore and intertidal marine sediments (Physical,

Chemical and Biological) to assess the risk of contamination prior to construction; and



7



Based on the values from Canadian Sediment Quality Guidelines



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Before mitigation the potential impact on VR marine fauna is considered to be of moderate

significance.

Before mitigation the potential impact on VR coastal habitat and VR subtidal habitat is considered to

be of moderate significance.

Before mitigation the potential impact on VR human development potential (i.e. fisheries) is

considered to be of moderate significance.

Mitigation measures:





Undertake a detailed characterisation of nearshore and intertidal marine sediments (physical,

chemical and biological) to assess the risk of contamination prior to construction;







Avoid disturbance of contaminated areas; and







Conduct construction activities in a manner that minimises re-suspension of sediment.



Increased Underwater Noise

Underwater construction activities, in particular pile driving, can generate high levels of underwater

noise with the frequency, intensity and persistence of underwater noise dictating its potential effects

on different marine species. Whilst temporary, these levels of noise can disturb sensitive marine

fauna.

Many marine organisms such as marine mammals, fish, and even some invertebrates use sound for

a variety of purposes; for example in communication, to locate mates, to search for prey, to avoid

predators and hazards, and for short- and long-range navigation (OSPAR, 2009). All these species

and others such as turtles may alter their behaviour if subject to high noise levels. It is generally

accepted that exposure to anthropogenic sound can induce a range of adverse effects on marine life,

from insignificant impacts to significant behavioural changes, to in some cases stranding and death

(OSPAR, 2009; Southall et al. 2007).

No evidence exists showing that cetaceans are present in the immediate project area, although heavy

piling can affect whales and dolphins many kilometres away from the source. Manatees generally

remain higher up the estuary, and do not venture as far down as Pepel, and no significant turtle

presence is expected at Pepel. All these statements are subject to review following dedicated marine

mammal and turtle surveys.

Heavy underwater noise could be expected to impact on small pelagic fish, particularly during

spawning season, leading to indirect effects in fisheries. However, considering that the impact would

be localized and temporary, impacts are not considered to be significant.

Before mitigation the impact on VR marine fauna is considered to be of moderate significance.

Before mitigation the impact on VR human development potential (i.e. fisheries) is considered to be of

moderate significance.

Mitigation measures:





Design the construction activities to avoid critical spawning and breeding seasons; and



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7.6



Construction teams to understand the significance of marine mammal/turtle sightings during

heavy construction e.g. piling, and to restrict activity wherever possible until the animals leave

the area.



Operation



Many of the impacts associated with port operations are very similar to the ones predicted for the

refurbishment\construction phase e.g. noise, light, wastewater discharges, run-off and spills.



7.6.1 Presence of Marine Structures

The coast is a dynamic environment and is subject to constant change; with natural processes such

as tidal currents and wave action leading to coastal erosion, accretion and reshaping. Any changes to

or construction of marine structures has the potential to alter these established physical processes.

Over time changes in the sediment transport regime may result, leading to alterations in general

coastal morphology. These changes may have secondary impacts on marine ecology and human

users of the sea e.g. fisheries nursery grounds.

However, this project is primarily a refurbishment of existing marine structures at Pepel. The marine

structures have been in place for decades. The current coastal morphology has therefore developed

to account for their presence. In addition, the two extra, if required, mooring dolphins are relatively

small, and the degree of any disturbance to physical transport processes will be localised and

restricted. No other major marine structures will be added to the existing loading jetties.

Before mitigation, the impact on VR coastal morphology is considered to be insignificant.

No mitigation measures are required



7.6.2 Port Operations

Wastewater Discharges

Impacts of operational wastewater discharges are as described in the section above. Only the flow

rate and the duration of discharge differs.

The impact of the wastewater discharge is highly dependent on the treatment system implemented in

the project design and the location of the discharge point in the estuary. Further assessment is

required.

Before mitigation the impact on VR marine fauna is considered to be of moderate significance.

Before mitigation the impact on VR coastal habitat and VR subtidal habitat is considered to be of

moderate significance.

Before mitigation the impact on VR human development potential (i.e. fisheries) is considered to be of

moderate significance.

Mitigation measures:



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Design an appropriate wastewater collection and treatment system utilising the best available

techniques;







The treated water discharge point should be located away from sensitive locations such as

mudflats, mangroves and areas of community use; in an area with strong tidal currents to

increase advection and dispersion; and







In the absence of national legislation, the treatment system should meet World Bank

discharge limits, to ensure the receiving water quality is within appropriate international

standards.



A more detailed assessment of wastewater discharges is required to develop the mitigation methods

further.

Handling of Iron Ore

During bulk handling operations such as stockpiling, processing and transport, the potential exists for

iron ore dust to enter the coastal and marine environment through wind and/or surface run-off. Iron is

an essential trace element required by most organisms, but it can be toxic at extreme concentrations.

There is little information currently available on toxicity for marine species, but iron forms colloidal

suspensions of ferric hydroxide in the presence of oxygen, which can remain suspended in water or

settle into sediment, causing problems with turbidity, light penetration and smothering of benthic

organisms.

If not treated correctly, large volumes of dust and/or run-off have the potential to directly affect

mangroves, by reducing photosynthesis and chemical impacting their root structures. Most mangrove

species breathe via their surface roots, and wind and surface water-borne pollutants can easily affect

this process. Additionally, iron supply often limits production in marine environments and can exert

controls on the dynamics of plankton blooms (Boyd et al., (2007); a secondary impact on fish might

be the occasional local increase in food availability for Bonga (Ethmalosa fimbriata) which feed on

plankton. Inputs of iron to the marine environment can also create a visual impact, as the presence of

high concentrations8 can turn the water an ochre (red) colour.

Pepel Island is located in a core area of the Sierra Leone Estuary Ramsar site, and is considered an

area of high ecological value. The potential impact of metal contamination on coastal and subtidal

habitats, marine fauna and human users of the estuary i.e. fisheries is considered to be highly

significant. Iron ore can possibly render fish to a higher risk of toxic effects from potentially harmful

algal exudates. Bury and Grosell (2003) note that whilst iron is a vital micronutrient for teleost fish, in

excess it can be toxic. Fish in SLRE may be exposed to increased iron levels in both dissolved and

dietary phases (Bu-Olayan and Thomas, 2008). Mudskippers are prey for many predators and hence

a path for bioaccumulation.

Bury et al., (2003) note that iron is an essential nutrient to almost all organisms. One of irons key

cellular functions is to confer redox activity to the cytochromes involved in respiration, due to its ability



8



Maximum concentrations for iron in marine waters in the US are 0.3 mg/l and in the UK 0.1 mg/l. These are believed to be

primarily for aesthetic reasons.



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to exchange electrons in aerobic conditions. A negative consequence of irons redox flexibility is that

it produces oxygen free radicals that are toxic to the cell. Consequently, in excess, iron can be

detrimental to health. In addition, excess waterborne iron may be toxic to fish, due to the formation of

iron flocs on the gills, resulting in gill clogging and respiratory perturbations.

The current existence of a diverse and healthy mangrove environment at Pepel demonstrates that the

coastal habitat can adapt in the long term to a certain level of metal contamination. Fish and shellfish

sampling is ongoing and will yield information on iron contamination in fish.

Before mitigation the impact on VR marine fauna is considered to be of moderate significance.

Before mitigation the impact on VR coastal habitat and VR subtidal habitat is considered to be of

moderate significance.

Before mitigation the impact on VR human development potential (i.e. fisheries) is considered to be of

moderate significance.

Mitigation measures:





Undertake a chemical assay of the proposed iron ore product to understand its constituents;







Install a treatment plant to collect and treat possible discharges; and







Design and implement an appropriate Transport Management Plan to guarantee minimal loss

of material to the coastal and marine environment.



Fuel Handling Operations

Fuel for power generation will be transported by road and vessels will not refuel at Pepel, therefore no

fuel handling operations are planned within the marine area of the port.

The movement and use of fuel oils for power generation is a potentially significant source of

hydrocarbon contamination to local coastal and subtidal habitats. Mangroves are particularly

susceptible to hydrocarbon pollution, which manifests itself in the intertidal and particularly affects the

ability of pneumatophores (in particular) and prop roots to regulate salt content and for the mangrove

to breathe. Therefore, if there are any fuel handling operations a detailed environmental management

and contingency plans must be in place.

Any spills within the port facility have the potential to contaminate the coastal habitats via run-off or

groundwater.

Before mitigation the impact on VR marine fauna is considered to be minor.

Before mitigation the impact on VR coastal habitat is considered to be moderate.

Before mitigation the impact on VR subtidal habitat is considered to be minor.

Before mitigation the impact on VR human development potential i.e. fisheries is considered to be

minor.

Mitigation measures:





Undertake a Quantitative Risk Assessment (QRA) of fuel handling operations; and



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Implement management and contingency / response plans to ensure any fuel spills within the

land-side of the port do not enter the marine environment.



7.6.3 Associated Shipping Activities

As Pepel Port has been out of use for several years, its regeneration will increase marine traffic

between Pepel Port and Freetown, creating disturbance to other marine users such as fishing boats.

Ports may have a role in terms of appropriate reception facilities, guidance to port users and

inspection of documentation.

Navigation and Fishing

The majority of marine traffic in the estuary is focussed around Freetown. Numbers from 2008

indicate that 368 vessels used the main commercial port, 352 of which were cargo ships, whilst the

rest were industrial fishing, military and research vessels. In the wider estuary shipping is believed to

be limited to small artisanal fishing boats and passenger vessels, and the Freetown to Tagrin ferry.

Transshipment operations are currently expected to involve Handymax transshipment vessels, which

will transfer ore to a loading on anchorage point outside the mouth of the estuary. These vessels will

be of a similar size to those previously using Pepel port. As the port has been inactive for some time,

vessels of this size have not been used as far up the estuary as Pepel for a number of years.

However, only two transshipment vessels will be in operation and each will make one round trip per

day. Although relatively large, the volume of movement of these vessels up and down the estuary will

be low. Considering the amount of other commercial traffic and large cargo vessels using Freetown

port, the impact of the transshipment operations on shipping in the estuary is not expected to be

significant.

Consultation with the fishing community is ongoing and further assessment will be undertaken. The

transshipment anchorage location is also yet to be finalised. Therefore it is considered to be a

moderate impact within this assessment.

The impact on VR Infrastructure Changes – shipping is considered to be of minor significance.

The impact on VR Infrastructure Changes – shipping is considered to be of minor significance.

Mitigation measures:





Further consultation with the fishing community (already underway).







Navigation Guidance must be provided to vessels using the port and other shipping and

fishing vessels in the area.



Risk to Marine Fauna – Underwater Noise and Collisions

As discussed in Section 7.5.2, underwater noise can impact on marine mammals, sea turtles and fish.

Marine vessels, in particularly large bulk carriers are relatively loud sources of underwater noise.

Their continued presence in the estuary, and the offshore area outside of the mouth, has the potential

to affect the behavioural ecology of local marine fauna. In addition, many species of whales and



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dolphins may be vulnerable to collisions with vessels. Most reports of collisions involve large whales

but collisions with smaller species also occur (IWC, 2009).

Very little published information currently exists on the abundance and distribution of marine

mammals and turtles in the estuary and immediately offshore. As such it is difficult to estimate the

likely significance of increased vessel traffic. An ongoing study is currently collecting information,

which will be incorporated into the Stage 2 assessment. Potential species of concern include turtles,

humpback dolphins and humpback whales.

Freetown port is a busy commercial marine environment and therefore the increase in noise and

vessel collision risk from the TV and OGV may be of minor significance. A greater understanding of

the abundance of marine mammals and turtles in the estuary and further assessment of potential

transshipment anchorage locations is required before the potential impacts can be fully evaluated.

Before mitigation the impact on VR marine fauna is considered to be of moderate significance.

Mitigation measures:





If initial surveys indicate abundance of species of conservation concern, further mitigation and

monitoring will be required.



Increased Light Levels

Persistent man-made light from vessels, an operational port, and navigation aids throughout the

channel could impact significantly on marine fauna; with birds in particular sensitive to increased and

extended levels. Non-natural light can deter them from feeding, breeding and nesting, and can

generally confuse their natural behaviour (Longcore and Rich, 2004, Lorne & Salmon, 2007,

Witherington, 1992).

Due to the high density of wetland birds present in the project location, and its position inside a

designated RAMSAR site, increased light is a potentially significant impact, especially as year round

operations will continue during bird migratory and breeding seasons. The current low levels of manmade light at Pepel exacerbate this potential impact, particularly if bright navigation aids are to be

placed in the approach channel to the port.

With respect to vessels moving up and down the estuary, there is already a large degree of light

pollution at Tagrin and Freetown, and transshipment vessels are not expected to significantly

increase the level of light at the mouth of the estuary. Closer to the port however, this impact may

become significant.

Before mitigation the potential impact on VR avifauna is considered to be moderate

Before mitigation the potential impact on VR marine fauna is considered to be moderate.

Mitigation measures:





During port operations, avoid strong lighting on any sensitive habitat areas, use shading

tactics wherever possible;







Consider use low-pressure sodium vapour lamps, as this wavelength does not disorient fauna

as much as regular full spectrum lighting; and



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Use navigation aid lighting only when strictly necessary.



Ballast Water and Marine Pests

The introduction of invasive species is of concern during the operational phase with the increase in

shipping activities. Before a voyage when they are not laden with cargo, ships take in a certain

amount of water for stability. Once the ship arrives at its destination it may release the ballast water

at the destination location. Ballast water can contain large amounts of sediment and microscopic

organisms, eggs and larvae. International shipping is responsible for the majority of these alien

species invading foreign waters. The effects of introducing new animals and plants can be almost

undetectable, or conversely they can completely displace native communities.

The 2004 International Convention for the Control and Management of Ships' Ballast Water and

Sediments (from which Sierra Leone is signatory) establishes that all ships using ballast water

exchange should whenever possible, conduct ballast water exchange at least 200 nautical miles from

the nearest land and in water at least 200 metres in depth. The transshipment vessels to be used in

the estuary will only have to release foreign ballast water once on arrival, and as all bulk carriers

arriving for ore loading will not be entering the estuary, this impact is considered to be minor as long

as correct exchange procedures are followed.

Before mitigation the impact on VR marine fauna is considered to be of moderate significance.

Before mitigation the impact on VR coastal habitat is considered to be of minor significance.

Before mitigation the impact on VR subtidal habitat is considered to be of moderate significance.

Before mitigation the impact on VR human development potential – fisheries is considered to be of

minor significance.

Mitigation measures:





Ensure the 2004 International Convention for the Control and Management of Ships' Ballast

Water and Sediments is strictly followed by all ships approaching the anchorage loading

point; and







A monitoring program to check for the presence of invasive species, and to undertake regular

assessment of sensitive habitat areas.



Vessel Waste Management and Discharges

Routine discharges from vessels include uncontaminated deck drainage, potentially contaminated

drainage from machinery spaces, engine cooling water and treated sewage / grey water. The

potential effects on water quality are similar to the effects created by discharges from the port, such

as changes in water pH, colour, temperature, smell, dissolved oxygen, nutrient levels and bacterial

contamination.

The source of pollution in the case of barges/tugs is a moving source, with a potentially larger area of

impact but a higher dilution rate, and therefore the impact is not considered to be significant.

Before mitigation the impact on VR marine fauna is considered to be of moderate significance.



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Before mitigation the impact on VR coastal habitat and VR subtidal habitat is considered to be of

moderate significance.

Before mitigation the impact on VR human development potential – fisheries is considered to be of

moderate significance.

Mitigation measures:





Ensure that the International Convention for the Prevention of Pollution from Ships

(MARPOL) is strictly followed by all ships operating within the project area, estuary and the

anchorage loading point;



Transshipment Anchorage

Loading on anchorage impacts during transshipment are generally associated with material spillages

and dust dispersion, leading to impacts on water quality, coastal and subtidal habitats and marine

fauna. Although the system is designed to be highly efficient, the cumulative impact over the life of the

project could be significant.

The potential behaviour of the iron ore in the water will depend on the spillage particle size and its

chemical composition. Generally, iron often forms colloidal suspensions of ferric hydroxide in the

presence of oxygen, which can remain suspended in water or settle into the sediment. Potential

impacts include increased turbidity, reduced light penetration, smothering of benthic organisms and

aesthetic impacts (water discolouration). Iron is not generally toxic to marine fauna. A full chemical

assay is required to understand if there are any other contaminants of concern within the hematite,

although this is considered unlikely. Modelling can be used to assess concentrations within the water

column for comparison to toxicity thresholds.

There is also a risk non-routine events such as a vessel collision leading to much larger spills into the

estuary. It is considered pertinent to conduct a QRA to ascertain the level of risk associated with

accidental spills at sea or within the Pepel Port area once details concerning shipping are confirmed.

Before mitigation the impact on VR marine fauna is considered to be of moderate significance.

Before mitigation the impact on VR coastal habitat and VR subtidal habitat is considered to be of

moderate significance.

Before mitigation the impact on VR human development potential (i.e. fisheries) is considered to be of

moderate significance.

Mitigation measures:





Undertake a full assessment of the proposed iron ore product to understand its constituents;

and







Design and implement an appropriate Transport Management Plan to guarantee minimal loss

of material to the coastal and marine environment.







Undertake a QRA of port and shipping activities.



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7.6.4 Associated Dredging Activities

Capital dredging will be required to open the navigation channel to access Pepel port. The capital

dredging is expected to only remove infill that has occurred since the closure of Pepel Port to

reinstate the previous channel. Ongoing maintenance dredging will then be required to keep the

channel open but the volume required will be smaller. The total predicted dredging volume is

approximately 1.5 million m3 based on UKHO admiralty charts. As explained in the Project Description

the dredging volume will be finalised following bathymetric and geotechnical surveys.

Key potential impacts from dredging activities include changes in water quality due to increased

turbidity and disturbance of potentially contaminated sediments; removal and smothering of the

benthos. There are also potential impacts from light and noise, particularly as 24 hour operations will

take place. Secondary impacts can include changes in waves and currents due to changes in

bathymetry. There is also a potential impact on fishing.

Sediment grabs from the dredge channel indicate that most of the channel is medium to coarse sand,

which is expected given the strong tidal currents through the channel. Coarse silt was found at one

location to the north-west of Tasso Island, this may be due to the slowing of the tidal currents around

the bend in the channel. There is no evidence of any areas of reef in and around the channel and as

the channel is being reinstated these sand and silt sediments are expected to exist throughout.

Macrofaunal communities are typical of such sediments in an estuarine environment and are not of

high biodiversity value.

The estuary is turbid in the area around the dredge channel due to the high sediment load from the

tributaries and wetlands inputting to the estuary and the strong tidal currents. Suspended solids

concentrations of up to 40 mg/l were measured in the lower part of the water column in the dredge

channel. Turbidity of up to 350 NTU was measured in the channel close to Pepel, for comparison 25

NTU is considered murky. Although the dredging methodology has not been finalised there are

mitigation measures inherent in the design to reduce the concentration and extent of any dredge

plumes, in particular from the hopper overflow though the use of the adjustable overflow funnel and

green valve described in the Project Description. Therefore the impact is expected to be minor.

However, within the EMP any dredge plumes will be modelled and compared to background turbidity

and suspended solids data.

The dredging will take place over a relatively short period and due to the type of dredger proposed

underwater noise levels are expected to be comparable with those created by shipping.

As the dredging will involve only the reinstatement of the previous channel no significant changes in

currents, sediment transport or morphology are expected. As the dredge channel is within the estuary

waves are not an issue.

Consultation with local fishing communities is underway. There is some fishing activity in the vicinity

of the channel and potential setting of nets. Further information is being collected through the

consultation process. The period of dredging is relatively short but it will still be necessary to ensure

that the fisherman and communities close to the dredge channel are informed of activities and

procedures. This will be facilitated through the consultation process, which will be within the EMP.



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The effects of dredged spoil disposal will be site specific and dependent on the characteristics of the

dredged material and the hydrodynamic conditions in the area. The primary issues are the smothering

and changing of the benthos and the risk of contamination of the disposal site. In addition, there is a

risk of increased suspended sediment and turbidity. The finer the material and the greater the energy

at the disposal site, the greater the possibility of increased suspended sediments and turbidity.

A video survey of spoil ground was undertaken during the marine environmental baseline survey. This

found that the area was dominated by soft bottom sediments with no areas of reef. There are reef

areas, such as Carpenter’s rocks, to the south of the dredge spoil disposal ground but these are

some distance away. Therefore an initial assessment indicates that the impact will be minor. Once the

dredging methodology is finalised an assessment of the deposition of the dredge material will be

undertaken including modelling of the dredge material to ensure that it is deposited within the spoil

ground and any dredge plume does not impact the reef habitats that have been identified within the

vicinity of the dredge spoil disposal ground.

There is evidence of sediment contamination around the existing Pepel port above sediment quality

guidelines9. However, initial samples within the dredge channel indicate that the area of

contamination does not extend that far from the port land-side. As part of the EMP cores will be taken

and sub-sampled for environmental analysis to confirm whether there are any seabed sediment

contamination issues and, if found appropriate action will be taken.

There is also a risk of dredging impacting on shipwrecks which may have Cultural Heritage. A review

of the UK Hydrographic Office wrecks database does not indicate that there are any wrecks in the

dredge channel or at the disposal site. The geophysical survey of the channel will confirm this.

Before mitigation the impact on VR marine fauna is considered to be of moderate significance.

Before mitigation the impact on VR coastal habitat and VR subtidal habitat is considered to be of

moderate significance.

Before mitigation the impact on VR human development potential i.e. fisheries is considered to be of

moderate significance.

Before mitigation the impact on VR cultural heritage (marine archaeology) is considered to be

insignificant.

Mitigation measures:





The primary mitigation measure is to follow the London Convention of 1972 and subsequent

protocol of 1976, to which Sierra Leone is a signatory (see Legislation and Guidance section).

This includes guidance on the sampling of sediments for contamination and the selection of a

dredged disposal site.







Mitigation measures will be included within the dredging equipment and methods to minimise

the extent of any dredge plumes.



In the absence of national or international standards the Canadian Sediment Quality Guidelines for the Protection

of Aquatic Life (Update 2002) are used, which are based upon recognised toxicological methods.



9



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Within the EMP dredge plumes will be modelled and analysis and assessment undertaken to

ensure that there is no risk of contamination from the dredge material.







Consultation with the local fishing communities is underway and will continue via the EMP.



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Table 7-5 Port Area – Offshore & Coastal

VR



Impacts



Aspect

Land clearance and

earthworks



E6

E6



Pressure increase in

natural resources



H3



Clearance of coastal habitat during

construction activities

Increased pressure on the uses of

mangrove due to increased

population during construction

Increased pressure on fish resources

due to increased population during

construction

Impacts on marine fauna



E8



Clearance of old

stockpiles and port site



Increased noise during

construction works

Increased light levels

during construction

works

Waste water discharge

during construction



E6



E3



VR Category



Magnitude



Extent



Duration



Basic

Impact

Index



Significance



Residual

Impact after

Mitigation



Reason for

Change



High



2



2



3



2



Major



Minor



Ensure no

clearance



High



4



2



4



3



Major



Moderate



Best practices



High



2



2



2



2



Moderate



Minor



Best practices



Moderate



High



1



2



2



2



Moderate



High



2



2



2



2



Moderate



High



2



1



2



2



Major



High



2



1



2



2



Major



Moderate



Management

Plan



High



1



2



2



2



Moderate



Minor



Appropriate

collection and

treatment



Impacts on coastal habitat



Disturbance of avifauna



Moderate



Moderate



Disturbance of avifauna

E3



E8



Disturbance to marine fauna due to

potential changes in water quality



Construction

Best Practice to

ensure

contaminants do

not enter the

marine

environment

Construction

Best Practice to

ensure

contaminants do

not enter the

marine

environment

Management

Plan



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VR



Impacts

VR Category



Magnitude



Extent



Duration



Basic

Impact

Index



Significance



Residual

Impact after

Mitigation



Impacts on coastal habitat due to

potential changes in water quality



High



3



2



1



2



Moderate



Minor



Impacts on subtidal habitat due to

potential changes in water quality



Moderate



3



2



2



3



Moderate



Minor



High



1



2



2



2



Moderate



Minor



High



1



2



2



2



Moderate



Minor



High



3



2



1



2



Moderate



Minor



3



2



2



3



Moderate



Minor



High



1



2



2



2



Moderate



Minor



Moderate



2



2



1



2



Minor



Minor



High



1



1



1



1



Minor



Minor



High



1



1



1



1



Minor



Minor



2



2



1



2



Minor



Minor



High



1



1



1



1



Minor



Minor



High



2



1



1



2



Moderate



Moderate



Aspect

E6



E7



H3



Impacts on fish stock due to potential

changes in water quality

Disturbance to marine fauna due to

potential changes in water quality



E8



Spills and run-off of oil

and chemical

contaminants during

construction



Refurbishment of

mooring dolphins



E6



Impacts on coastal habitat due to

potential changes in water quality



E7



Impacts on subtidal habitat due to

potential changes in water quality



H3



Impacts on fish stock due to potential

changes in water quality



E7

E8



Increased turbidity due

to underwater

construction



E6

E7



H3

Disturbance of

contaminated sediments



E8



Impacts on subtidal habitat due to

underwater construction

Disturbance to marine fauna due to

changes in water quality

Impacts on coastal habitat due to

changes in water quality

Impacts on subtidal habitat due to

changes in water quality

Impacts on fish stock due to changes

in water quality

Disturbance to marine fauna due to

water contamination



Moderate



Moderate



Reason for

Change

Appropriate

collection and

treatment

Appropriate

collection and

treatment

Appropriate

collection and

treatment

Appropriate

collection and

treatment



Appropriate

collection and

treatment

Appropriate

collection and

treatment

Appropriate

collection and

treatment



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VR



Impacts



Aspect

during underwater

construction



Increased underwater

noise during underwater

construction

Presence of marine

structures



Duration



Basic

Impact

Index



Significance



3



2



1



2



Moderate



3



2



2



3



Moderate



Residual

Impact after

Mitigation



High



E7



Impacts on subtidal habitat due to

water contamination



Moderate



H3



Contamination of fish stock due to

changes in water quality



High



1



2



2



2



Moderate



E8

H3



Disturbance to marine fauna

Disturbance to fish stock



High



2



1



1



2



Moderate



Moderate

Moderate



High



2



1



1



2



Moderate



Moderate



S2



Changes in coastal morphology due

to changes in estuary dynamics

Disturbance to marine fauna due to

potential changes in water quality



Medium



1



1



2



1



Insignificant



Insignificant



High



2



1



1



2



Moderate



Minor



Impacts on coastal habitat due to

potential changes in water quality



High



3



2



1



2



Moderate



Minor



Impacts on subtidal habitat due to

potential changes in water quality



Moderate



3



2



1



3



Moderate



Minor



Impacts on fish stock due to potential

changes in water quality



High



2



2



2



2



Moderate



Minor



Disturbance to marine fauna due to

changes in water quality



High



1



2



3



2



Moderate



E7



H3



E8

E6



E7

H3



Fuel handling operation spillages



Extent



Impacts on coastal habitat due to

water contamination



E6



Handling of Iron Ore –

dust dispersion and

surface run-off



Magnitude



E6



E8



Wastewater discharge

during port activities



VR Category



E8

E6



Moderate

Moderate



Appropriate

collection and

treatment

Appropriate

collection and

treatment

Appropriate

collection and

treatment

Appropriate

collection and

treatment



Moderate



Disturbance due coastal habitat due

to potential changes in water quality

and dust settlement

Impacts on subtidal habitat due to

potential changes in water quality



High



1



2



3



2



Moderate



Moderate



2



2



3



3



Moderate



Impacts on fish stock due to potential

changes in water quality



High



1



2



3



2



Moderate



High



2



1



1



2



Moderate



Minor



High



2



2



1



2



Moderate



Minor



Disturbance to marine fauna due to

changes in water quality

Disturbance due coastal habitat due



Reason for

Change



Moderate



Moderate

Moderate

No marine fuel

handling

No marine fuel



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VR



Impacts



Aspect



VR Category



E7

H3

I1

Navigation and shipping

H3

Underwater noise and

collisions with marine

fauna



E8



E3

Increased light levels



E8



E8

Ballast Water and

Marine Pests



E6

E7

H3

E8

E6



Vessel Waste

Management and

Discharges



E7



H3



to potential changes in water quality

Impacts on subtidal habitat due to

potential changes in water quality

Impacts on fish stock due to potential

changes in water quality

Impacts on marine users and existing

navigation patterns due to vessel

movements

Disturbance to fishing vessels due to

increase marine traffic

Impacts on Marine Fauna due to

increase in marine traffic



Magnitude



Extent



Duration



Basic

Impact

Index



Significance



Residual

Impact after

Mitigation



Reason for

Change

handling

No marine fuel

handling

No marine fuel

handling



Moderate



3



2



2



3



Moderate



Minor



High



3



2



2



2



Moderate



Minor



High



1



1



2



1



Minor



Minor



High



1



1



2



1



Moderate



Moderate



High



2



2



1



2



Moderate



Moderate



High



2



1



2



2



Moderate



Moderate



Project design



High



2



1



2



2



Moderate



Minor



Project design



High



1



1



3



2



Moderate



Minor



Follow MARPOL



High

Moderate

High



1



1



2



1



3

2



2

1



2

1



3

1



Minor

Minor

Minor



Insignificant

Insignificant

Insignificant



High



1



2



1



2



Moderate



Minor



Impacts on coastal habitat due to

potential changes in water quality



High



2



2



1



2



Moderate



Minor



Impacts on subtidal habitat due to

potential changes in water quality



Moderate



2



3



2



3



Moderate



Minor



High



2



2



1



2



Moderate



Minor



Follow MARPOL

Follow MARPOL

Follow MARPOL

Appropriate

collection and

treatment

Appropriate

collection and

treatment

Appropriate

collection and

treatment

Appropriate

collection and

treatment



Impacts on Avifauna at port, in the

surroundings of vessels and

navigation aids

Impacts on Marine fauna in the

surroundings of vessels and

navigation aids

Disturbance to marine fauna due to

potential competition

Impact on to coastal habitat

Impact on due to subtidal habitat

Impact on of fish stock

Impact on marine fauna due to

potential changes in water quality



Impacts on fish stock due to potential

changes in water quality



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VR



Impacts



Aspect



E8

E6

Transshipment

Anchorage



E7



H3

E8



Dredging Activities



Disturbance to marine fauna due to

changes in water quality and

potential toxicity

Disturbance due coastal habitat due

to potential changes in water quality

and potential toxicity

Impacts on subtidal habitat due to

potential changes in water quality

and potential toxicity

Contamination of fish stock due to

potential changes in water quality

Impact on marine fauna



E6



Impact on coastal habitat



E7



Impact on subtidal habitat



H3



Impact on fish stocks



H5



Impact on cultural heritage (marine

archaeology)



VR Category



Magnitude



Extent



Duration



Basic

Impact

Index



Significance



Residual

Impact after

Mitigation



High



2



2



1



2



Moderate



Moderate



High



3



2



1



2



Moderate



Moderate



Moderate



2



3



2



3



Moderate



Moderate



High



2



2



1



2



Moderate



High



2



3



1



2



Moderate



Moderate



High



3



2



1



2



Moderate



Moderate



Moderate



3



2



4



3



Moderate



Moderate



High



2



2



2



2



Moderate



Moderate



Low



2



1



2



2



Insignificant



Insignificant



Reason for

Change



Moderate

Dredging impact

assessment

Dredging impact

assessment

Dredging impact

assessment

Dredging impact

assessment



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7.7

7.7.1



Distributed Impacts from Project

Bulk material management



Material required for ground improvement across the project will need to be sourced locally from

multiple quarry sites and borrow pit. This has the potential for significantly broadening the impacts

from the project. Consequently all bulk material activities will need to be managed through specific

environmental management and be accountable through contract terms to a single, best-practice

source of guidelines.



7.7.2



Demand on existing infrastructure & resources



The provision of goods and services to maintain the project, co-use of infrastructure such as roads,

power and telecoms networks and the effect of a large logistics operation and mobilization throughout

the project footprint has the potential to create significant impact and over-demand on the existing,

fragile and undeveloped infrastructure and resources.

Logistics, programming, procurement and the provision and expectations for good and services are

dealt with under a project’s feasibility study and execution plan which is outside of the scope of this

study.

Due to the broad scope of these activities it is not considered meaningful to suggest a single source

of management to regulate this. Instead the project consultation and disclosure system coupled with

a grievance system, established by the proponent will be utilized to ensure that project activities are

announced publicly and that a response system is in place should problems arise. This has been

described under the social management section.



7.7.3



Solid waste management



It is anticipated that sound waste management practice will have limited impact on the existing

infrastructure within the region. Waste management proposals have been determined based on the

proximity principle, locating facilities as close as possible to major waste generation sources.

Delivery of the proposed incineration units should consider the existing road infrastructure.

The greatest impact is likely to arise from interim storage of wastes in particular pest, odour and litter

control. During storage organic waste will decay and generate small volumes of methane gas which

should be allowed to vent to the atmosphere.

Consideration should be made in waste storage areas for adequate drainage, particular during the

rainy season. Run off from waste storage should be minimised and treated as leachate rather than

being discharged into the conventional drainage system. Provision should be made for storage and

evaporation ponds where existing infrastructure is inadequate.



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Potential Mitigation Measures





Implement a hierarchy of waste elimination at source, recycling, reuse, recovery, and – as a

last resort - disposal;







Destruct or treat hazardous waste to render it non-hazardous if possible;







If the hazard cannot be eliminated, contain waste in a secure manner and monitor to ensure it

cannot damage the environment;







Segregate and quantify waste for effective management;







Use a system of waste manifests to track generation, transportation, receipt and disposal;







Audit waste transport or disposal companies prior to contracting.



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8



ONGOING ASSESSMENT WORKS



Further ESHIA works required for this project (Stage 1) which will be reported in the Stage 2

assessment are set out in the Environmental Management Plan (EMP) in Appendix 18.

Air & Noise

Spot sampling of air quality parameters and baseline noise have been conducted to date. Detailed

impact assessment requires a more accurate knowledge of the background air quality and a refined

estimate of the project contribution to the existing background levels. For this purpose a second round

of baseline data collection is currently being undertaken at the start of June 2010 and further

seasonal coverage will be required which will involve works that extend into and beyond the Stage 2

ESHIA reporting period. Some targeted baseline data collection, interpretation and assessment can

only be carried out after detailed Phase 1 designs are available including major power source

designs/locations and airfield/aircraft details. Air assessment and design feedback to ensure

compliance with air quality standards will be presented in the Stage 2 report. Based on the currently

advised programme it is also assumed that some Tonkolili Phase 1 construction works will be

underway and therefore monitoring data will be available to support the assessment. An air

dispersion model will be developed in order to predict the expected air quality contributions from the

routine operations of the project with assessment standards based on national and international

guidelines.

Sampling to date has indicated (subject to verification) a predominantly non-industrial baseline for the

project area. It is therefore reasonable to assume that there will not be additional significant air

quality impact sources (i.e. from other industry) that could lead to a cumulative air quality loading in

addition to project contributions. Therefore assuming that mitigation and management applied by

AML is effective in mitigating air and noise sources this should mean that project contributions will not

lead to excessive levels.

The impacts from the proposed development on noise quality will be assessed following a quantitative

approach. Due to the large project area potentially affected by noise emissions, the target zones to

be modelled will be limited to the surroundings with the predicted highest noise emissions: the

perimeter of the mine facilities, the transport corridor (railway and roads) nearby populated areas and

the Phase 1 power plant/plants. Where significant potential noise impacts are identified, specific

mitigation measures will be suggested (e.g. construction of barrier panels) and tested in the noise

model to ensure that the predicted noise impacts will be mitigated.

Noise modelling will be conducted with SoundPLAN, an industry standard noise prediction software

used to calculate sound pressure levels and to generate noise mappings, considering reflections and

diffractions of sound, the geometry of buildings at the site, topography and climatic conditions. The

pressure levels calculated or interpolated for each point within the defined calculation area will be

shown as a grid of sound pressure values, from which a contour map will be generated showing

isophones (lines of equal sound pressure). The noise maps will show only the project contributions

and the cumulative effects will be assessed adding the existing noise background conditions at

sensitive receptors.

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Ecology & Biodiversity

Vegetation

Further work will concentrate on the assessment of species and habitats of conservation concern in

the project area as well as on the study of habitats and localities that are not yet well documented or

understood and that are likely to be impacted by the mining activities. Requisite works include:





Detailed aerial image interpretation to determine whether there is additional riverine system of

interest along the transport corridor that has not been previously identified or surveyed and

may deserve consideration.







Inland valley swamps have not yet been studied in detail and further surveys of selected inland

valley swamps are required to assess the presence/absence of species of conservation

concern.







The freshwater river areas and saline / freshwater transition zone of Port Loko Creek will be

surveyed in more detail, especially for rheophytes.







Survey of Farangbaia Forest Reserve to determine the presence of species of conservation

concern found on project affected areas and the potential as an offsetting area.







Surveys outside the anticipated impacted project footprint aimed at confirming presence of

species already identified as of conservation concern and so far found only on the Simbili

deposit or near proposed infrastructure. This will allow reassessment and potential lowering of

the conservation status of these species. This survey will also identify potential areas to be

protected and used as offsetting zones or relocation zones if required.







Inselbergs will be visited to assess remnant forest patches.







Other localities and habitats of potential conservation concern that have not yet been studied in

detail will be explored further. The most important localities and habitats are some parts of the

Tonkolili River (focusing mainly on the western valley, where some infrastructure related to rail

development may be located), the river channel community of the Tonkolili River near

Farangbaia, Pepel Port land lease, Port Loko freshwater ecosystems, the Toka River, and

some of the inland valley swamps along the rail / road corridor.



Fauna

In order to establish and validate pre-project baseline and trends the following supplementary Phase

2a and Phase 2b baseline studies are required and will be reported in the Tonkolili Stage 2 ESHIA or

follow up study reporting where seasonal constraints entail later works:





Assess potential conservation strategies for Western Chimpanzee populations.







Assess the conservation value of extensive semi-natural seasonal wetlands and scattered

forest patches along the Toka river valley, essentially those between Makeni and Lunsar, and

the gallery evergreen forest along the Rokel upstream from Makeni to its confluence with the

Tonkolili River. These investigations will be most productive if undertaken in May and

November-December.



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Assess faunal-groups where observations and literature suggest that species of global

importance may occur.







Assess the transport corridor in detail. Surveys to be undertaken at both the beginning and the

end of the wet season (June and November-December) when migrant intra-African birds,

amphibian and insect populations would be at a much higher level.







Assess mangrove vegetation along the Bankasoka River.







Assess the significance of sacred forests / bush areas for fauna. This will require careful

planning and early consultation and engagement with relevant local communities.







Assess fauna present in the Pepel Railway area and adjacent mangroves.



Freshwater

The Phase 1b aquatic ecosystem studies to date are high-level, rapid assessments that represent a

‘snapshot’ of conditions at the site. Pre-project trends as seasonal variations (such as water levels,

migration and breeding patterns) have not been investigated and defined. To establish pre-project

trends the following supplementary Phase 2a and Phase 2b baseline studies are required:





Wet and dry season aquatic surveys to describe the aquatic biota in the mining lease area and

transport corridor.







Aquatic fauna tissue metal survey to assess existing metal concentrations (that are likely to be

influenced by activities of artisanal miners and natural mineralisation in the area).







A comprehensive baseline water quality sampling programme will be undertaken in conjunction

with the hydrology and hydrogeology studies and monitoring programme.







Seasonal hydrological flow data collection, particularly for the downstream reaches of the

Mawuru and Tonkolili Rivers (where dams are proposed) is required and will be collected in

conjunction with the hydrology and hydrogeology studies and monitoring programme. Aquatic

surveys have not yet been undertaken in this area which contains many small streams and

brooks that may house endemic species and an aquatic fauna survey will describe establish

baseline conditions. A long term monitoring survey programme will be implemented in order to

assess effectiveness of any mitigation measures and allow remedial action in the event that

negative impacts are detected.



Hydrology and Hydrogeology

Further to Stage 1 reporting, works required for completion of environmental studies include





Ongoing monitoring of surface and groundwater quality to establish baseline and long term

trends







Ongoing flow monitoring of surface water to establish baseline, long term trends and surface

and groundwater relationships including baseflow index and recharge estimates. Requires

stream profile surveys and LIDAR interpretation to establish calibration / ratings curves for

gauging points.



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Refine quality and flow monitoring programmes further to analysis of initial trends and

improved understanding of baseline and development designs.







Data interpretation to characterise water resources – quality and quantity, including seasonal

variations, based on existing reports and monitoring data.







Refine mass water balance. Assess whether there may be significant net change in the water

balance of the various river systems in the project footprint due to stripping, mining, waste

dumps, valley crossings etc.







Calculate stream flow deficit durations







Peak flood estimations







Input to storm water management plan and surface water management plan







Recurrent stream stability monitoring







Potential Sediment Transport model.







Input/interact with Acid Mine Drainage study to assess likelihood and impact of acid waters

draining from waste dumps or areas of construction using waste rock.







Input to solid waste management plan, surface water management plan, waste water

management plan, waste rock management plan (potential acid waters and flooding/water

logging issues) and spill response plan.







Input to outline EMPs for future works including mining, drilling, waste storage, haulage,

transfer and export where potential for impacts on surface and groundwater exist.







Review and interpretation/inclusion of geotechnical pitting and drilling data as is becomes

available.







Review and analytical assessment and interpretation of water well drilling and testing data as

it becomes available.







Review and assessment of drainage designs.







Identify significant impacts that may result either directly or indirectly from the use of surface

or groundwater when detailed water demands and abstraction designs are available.







Determine whether there will be any cumulative impacts on river and groundwater systems.







Assess risk of polluting ground and surface water resources throughout the various project

areas.







Provide practical design recommendations/remedial measures where possible to avoid any of

the identified impacts.



Soils and Land Use

Ongoing works involve preparation of a soils and land use mapping based on recently acquired full

detailed aerial photo coverage of the proposed development. This will include input from Agricultural

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Department, Sierra Leone, on soil types and agricultural areas and any mitigation or offsetting

recommendations where loss of land use and erosion impacts have been identified in particular.

Ongoing geotechnical field investigations may allow some site specific descriptions and assessment

of soils for localised areas. Full Stage 1 and Stage 2 ESHIA information will be presented in the

Stage 2 preliminary ESHIA and where relevant in the EMP.



Geology and Geomorphology

Ongoing works including detailed literature review and summary of local geology are to be finalised.

Detailed mine planning will optimise resource utilisation and minimal requirement for further ESHIA

works are foreseen for Phase 1



Human Health

Human health impact assessment is an iterative process that requires input from a number of other

disciplines. The work presented in this Stage 1 document represents a preliminary screening

assessment based on baseline information and project description available at this point in time. The

Human impact assessment will be developed as more definitive project information and field data

becomes available. Ongoing ESHIA work will refine and build upon the findings of Stage 1,

incorporating new data and information to be presented in the Stage 2 ESHIA. Further works

will involve:





Detailed definition of baseline pertaining to human health. This will include incorporation of

the results of chemical analysis of environmental media (soils, air, surface and groundwater),

food (plant and fish tissue) as well as other factors (noise, traffic etc) that have the potential to

impact human health;







In-country data collection. A site visit will be conducted by a senior health assessor for field

survey/overview and meetings with government officials and medical representatives in order

to facilitate completion of medical and governmental health questionnaires;







Definition of chemicals of potential concern (COPCs). COPCs for the project will be

generated and undergo preliminary screening. This will involve data collection and

implementation of selection processes, including discussion with project engineers.







Health impact assessment. The list of health impacts developed during Stage 1 will be reevaluated and refined in light of the most up-to-date project details and the healthrelated inputs received from other assessment disciplines; and







Reporting in the Tonkolili Preliminary/Stage2 ESHIA document.



Socio-Economic

The SIA for Stage 2 is considered to be an evolution of the Stage 1 report with some additional

geographic scope based on the larger footprint. As such, the following work will be conducted

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primarily for the purposes of the Stage 2 ESHIA but at the same time providing an opportunity to

review and, if required, enhance Stage 1 ESHIA:





Further socio-economic baseline studies are planned for the next phases of the Tonkolili

project which will provide additional detail to the present understanding of socio-economic

conditions in the project area including the Phase 1 footprint which shares many of the same

attributes.







Use the RPF as the foundation for developing a RAP including a detailed household asset

survey which will provide an opportunity to better understand the full extent of resettlement

impacts. This process will incorporate direct consultation with PAPs and other stakeholders

throughout implementation. There may be circumstances that require retroactive execution of

the RAP to ensure that benefits for PAPs are delivered fairly and equitably.







Work with local NGO’s and GoSL to initiate livelihood restoration programs.







Implement the measures set out in the CDAP through consultation with local communities

and GoSL stakeholders. This consultation process will itself evolve to encompass

communities across both Stage 1 and Stage 2 footprints so that community development

strategies can be prepared that address broader community requirements whilst at the same

time focusing on implementing viable and cost-effective building projects and social

programs.







Through an overall AML management policy initiative, develop a Community Safety Plan to

address safety issues that may result from project activities interacting with local communities

such as public access across rail tracks and haul roads.



Offshore & Coastal

Based on the key environmental issues identified in the preparation of this report, further data

collection and analysis is required to fully assess the severity of each impact and to finalise

appropriate mitigation measures that will provide input to the Environmental Management Plan.

Additional studies required in order to support impact assessment include the following:





Hydrodynamics, sedimentary transport and coastal morphology - Development of higher

resolution hydrodynamic and sediment transport model, based on the results from metocean

data collection and geotechnical survey (including bathymetry survey);







Sediment quality - Laboratory analysis of samples already collected; additional sediment

sampling; sub-sampling and analysis of sediment vibrocores to assess contamination and

acid sulphate soil risk; modelling of fate of sediments from dredging and construction

activities;







Water quality - Laboratory analysis of samples already collected; Longer term in-situ water

quality monitoring as part of the MetOcean survey; Additional targeted surveys around

potential discharge locations; MIKE 21 model development and water quality modelling of

wastewater discharges, run-off and dredging activities;



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Marine habitat studies - More detailed mapping of subtidal and mangrove habitats using

quantitative techniques and assessment of mangrove health; Quantification of habitat

clearance; Identification of habitat conservation status and growth patterns; Additional survey

of inter-tidal areas (mudflats), spoil ground #1 and transshipment anchorage.







Benthic fauna studies - Laboratory analysis of samples already collected; In-situ chlorophyll

measurement as part of MetOcean survey; Wet season measurements;







Plankton studies - Laboratory analysis of water samples;







Cetaceans studies - incidental MMO during other marine activities; information gathering

through consultation; additional MMO or acoustic monitoring, dependant on initial findings;







West African manatee studies - Consultation with villagers and fishermen in key areas;







Avifauna studies - Consultation of local specialists; birds survey (observation) in the study

area and analysis of field results;







Fish and shellfish studies - Consultation with fisherman around key landing sites and markets;

Consultation and collation of data from Ministry of Fisheries; Ecological assessment of the

affect of habitats impacts on fish stocks; Collection of fish and shellfish samples to support

health assessment.







Marine Archaeology study - Expert review of geophysical datasets and wrecks database to

assess impact; and







Shipping and navigation - Collation of data from Freetown Port Authority; Consultation with

key stakeholders and marine users; Mapping of existing and projected shipping.



Outcome of these detailed studies will be reported within the Stage 2 ESHIA



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Table 8-1 Ongoing Assessment Works Register

Discipline



Component

Complete /

Available



Component

proposed before

Stage 2 ESHIA



Timing



Component post

Stage 2 ESHIA (i.e.

go into EMP)



Timing



Responsibility



Air Quality



Spot sampling for

NOx, SOx



Systematic baseline

sampling (passive,

active, extended

time) & dust.



Full baseline

prepared for

Stage 2 ESHIA



Further air quality

monitoring and

modelling to refine

management

practices.



As required



ESHIA Consultant



Air Quality



Assess air

emissions from

mining activities,

stockpiles and

power generation.



Air Assessment to

ensure compliance

with Air Quality

standards (including

background) using

dispersion models.



Preliminary

models in Stage 2

ESHIA



Project monitoring,

modeling residual

impacts to go into

EMS.



Refined models

throughout

operations.



ESHIA Consultant

with Project owners

team



Air Quality



Assess noise from

Airstrip at the mine

once defined

location and

aircrafts are

defined.



Noise assessment

and Action plan for

conflict areas.



Before Airstrip

operation start up.



Project monitoring,

modeling residual

impacts to go into

EMS.



Ongoing.



ESHIA Consultant

with Project owners

team



Noise



Assess noise from

traffic (train and



Noise assessment

and noise barrier



Before mineral

transport start up.



Project monitoring,

modeling residual



Ongoing



ESHIA Consultant

with Project owners



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Discipline



Component

Complete /

Available

haul road), material

processing at the

mine site and port

activities at

populated areas.



Component

proposed before

Stage 2 ESHIA

design.



Timing



Component post

Stage 2 ESHIA (i.e.

go into EMP)

impacts to go into

EMS.



Timing



Marine



Extensive

hydrodynamics,

water quality,

sediment quality,

mangrove

mapping,

ecological work &

sub-tidal video

already

undertaken.



More detailed

habitat mapping and

surveys where

residual impacts

identified including

avifauna survey,

marine mammals

observation,

manatees and

fisheries

consultation.



Marine



Initial

hydrodynamic and

sediment transport

model built.



Refinement of

hydrodynamic and

sediment transport

model. Set up of

water quality model.

Wet season



Responsibility



Full baseline

prepared for

Stage 2 ESHIA



Project monitoring,

residual impacts to go

into EMS.



Ongoing



ESHIA Consultant

with Project owners

team



Preliminary

models in Stage 2

ESHIA.



Refinement and

updates to the models

due to additional data

availability and any

changes to project

description.



Refined models

before operations

start up.



ESHIA consultant

and marine and

coastal engineering

team with Project

owners team



team



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Discipline



Component

Complete /

Available



Component

proposed before

Stage 2 ESHIA

metocean data to be

collected. Use of

model to assess

water and sediment

quality and sediment

transport including

wastewater,

dredging plumes

and accidental

discharges.



Timing



Component post

Stage 2 ESHIA (i.e.

go into EMP)



Timing



Responsibility



Marine



Preliminary

dredging

assessment

complete



Specific dredging

impact assessment

in development,

including

contamination

analysis of cores

and modeling of

dredge plumes.



Timely completion

of dredging impact

assessment once

required data

becomes

available, Stage 2.



Project monitoring

and residual impacts

to go into EMS.



Ongoing



ESHIA Consultant

with Project owners

team



Marine



Preliminary

assessment of

transshipment

complete



Survey and

assessment of

transshipment

anchorage once



Survey and

assessment for

inclusion in Stage

2 report.



Project monitoring

and residual impacts

to go into EMS.



Ongoing



ESHIA Consultant

with Project owners

team



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Discipline



Component

Complete /

Available



Component

proposed before

Stage 2 ESHIA

options are

identified



Timing



Component post

Stage 2 ESHIA (i.e.

go into EMP)



Timing



Responsibility



Waste



Practice guidelines

drafted.



Review and update

waste model based

on Contractors

estimates.



Before

construction

begins



Develop standalone

Phase 1 waste

infrastructure during

construction and

operations.



Before

construction

begins



ESHIA Consultant

with Project owners

team and requires

detailed contactor

management

plans.



Ecology Flora



Partially completed

the study work

predominantly at

the mine area only

and sections of the

haul road.



Specialists

scheduled to

complete a program

in June addressing

Inland valley

swamps along

transport corridor)

and target further

areas.



To complete by

Stage 2 ESHIA.



Conservation

measures, set asides,

capacity programmes

etc – all need to be

developed in

conjunction with

Stage 2.



To complete by

Stage 2 ESHIA.



ESHIA Consultant

with Project owners

team



Ecology Fauna



Dry season survey

only.



Transitional wet-dry

season survey and

supporting study

work with others



To complete by

Stage 2 ESHIA.



Conservation

measures, set asides,

capacity programmes

etc – all need to be



To complete by

Stage 2 ESHIA.



ESHIA Consultant

with Project owners

team



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Discipline



Component

Complete /

Available



Component

proposed before

Stage 2 ESHIA

(Tacugama)



Timing



Component post

Stage 2 ESHIA (i.e.

go into EMP)

developed in

conjunction with

Stage 2.



Timing



Responsibility



Ecology Aquatic



Walk over surveys

in transitional drywet season only.



Dry season survey

required



To complete after

Stage 2 ESHIA supplementary

studies during the

next dry season.



Project monitoring.

There has been no

opportunity for full dry

season survey (which

is regarded as critical

for some phyla).



To complete after

Stage 2 ESHIA supplementary

studies during the

next dry season.



Seasonal

differences in

spawning

behaviour,

breeding habits,

fish migration etc.



Soil and landuse



Collected samples

from soils in

targeted locations

at mine, none from

rail corridor, and at

Pepel. Not yet

assessed.

Preliminary landuse cover

information

available



Future stock-pile

materials

(leachability)

pending AMD study.

Review of transport

corridor aerial

photography for

land-use

classification on

transport corridor.



To complete by

Stage 2 ESHIA.



Land-use

management plans.



To complete by

Stage 2 ESHIA.



ESHIA Consultant

with Project owners

team



Hydrology /



2 rounds of



Completion of



Preliminary



Water management



Refined models



ESHIA Consultant



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Discipline



Component

Complete /

Available

groundwater and

surface water

sampling and

review across

Phase 1 project.

Sampling from

available bores and

community wells

and streams (dryseason).



Component

proposed before

Stage 2 ESHIA

analysis and

modeling for impact

assessment.

Further pump test

results and logs

from AML supply

bores and further

impact assessment.



Timing



Human Health



Desk top study of

human health

baseline for Sierra

Leone



Baseline health for

regional populations



Human Health



Evaluation of other

discipline baseline

results as they

apply to human

health impacts air,

soil, water and food

quality/quality,

socio-economic



Further Baseline

health and animal

and plant tissue

sampling.

Contingent



Hydrogeology



on other studies

such air & noise,



Component post

Stage 2 ESHIA (i.e.

go into EMP)

plans required.

Project monitoring,

modeling residual

impacts to go into

EMS.



Timing



Responsibility



throughout

operations.



with Project

owner’s team.



For Phase 1

ESHIA



Continued support of

health and social

mitigation measures

(e.g., health clinics)



On-going



AML with social

and health

consultation.



Phase 2



Project monitoring,

residual impacts to go

into EMS.



On-going



AML with ESHIA

team experts

relevant to human

health.



models in Stage 2

ESHIA



ESHIA



Reviewing

dependencies and

determining health



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Discipline



Component

Complete /

Available

status.)



Component

proposed before

Stage 2 ESHIA



Timing



Component post

Stage 2 ESHIA (i.e.

go into EMP)

impact strategy.



Timing



Responsibility



land and sampling.



Human Health



Establish air

baseline



Evaluation Phase 1

construction and

operation activities

effects through

evaluation of the air

dispersion model

results.



Phase 2 ESHIA



Confirmation of

predicted dispersion

air modelling results

with monitored air

data.



On-going.



AML consultation

with air and noise

and human health

teams.



Social

(Baseline)



S-E baseline

initiated (limited to

100 randomised,

aggregated

results),



Further baseline

required. Prepare

livelihood restoration

plan.



To complete by

Stage 2 ESHIA.



Project monitoring,

modeling residual

impacts to go into

EMS. Maintaining

living standards of

PAPs at the same

level or preferably

higher than before

relocation.



Ongoing



ESHIA Consultant

with Project

owner’s team.



Social

(Engagement)



Stakeholder

Engagement Plan

is ready



Allow PAPs to

present their

grievances in an

open and



To complete by

Stage 2 ESHIA

and prior to

relocation of



Project monitoring,

modeling residual

impacts to go into

EMS. Maintain



Ongoing



Project owner’s

team.



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Discipline



Component

Complete /

Available

Consultative

Committees

operational.



Component

proposed before

Stage 2 ESHIA

unintimidating

manner with

predefined response

timing explained to

them in advance.

Prepare grievance

redress mechanism

in consultation with

local stakeholders.



Timing



PAPs. When

resettlement

committee is

established.



Component post

Stage 2 ESHIA (i.e.

go into EMP)

grievance mechanism



Timing



Responsibility



Social

(Resettlement)



RPF drafted.



Prepare RAP in

consultation with

local stakeholders



Prior to relocation

of PAPs



Addressing impacts

resulting from the

resettlement process



Ongoing



Project owner’s

team/local

stakeholders.



Community

Development



CDAP for Haul

Road already

submitted.Loss of

community

infrastructure and

meeting legislated

community

development

requirements.



Prepare and

implement CDAP.



Ongoing



Project monitoring,

modeling residual

impacts to go into

EMS.



Ongoing



Project owner’s

team/local

stakeholders.



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Discipline



Component

Complete /

Available



Component

proposed before

Stage 2 ESHIA



Timing



Component post

Stage 2 ESHIA (i.e.

go into EMP)



Timing



Responsibility



Community

safety



Outline issues

identified



Prepare and

implement

community safety

plan for construction

phase of the Project.



Ongoing



Prepare and

implement community

safety plan for

operational phase of

the Project



Ongoing



Project owner’s

team/local

stakeholders.



Cultural /

Heritage



Pending

consultations



Part of Social

Commitment



Ongoing



Local – in country

specialists to carry out



Ongoing



Project owner’s

team/local

stakeholders.



EMPs



Haul Road EMP

completed



In some areas will

have to be

addressed through

risk register instead.



Ongoing



Specific EMPs for

Mining, Pepel &

Marine required



Ongoing



Project owner’s

team/local

stakeholders.



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9



MANAGEMENT



An Environmental Management Plan (EMP) has been developed for the project (Appendix 18). The

EMP will interact with the project feasibility study and the ongoing ESHIA. The EMP includes

provisions for the control, mitigation, monitoring, reporting and auditing necessary to prevent or limit

potentially adverse environmental, social and health effects from the construction and operation of the

Project.

The EMP has been developed in parallel to the Stage 1 ESHIA. The intention is that the ongoing

ESHIA process will inform the EMP as requisite monitoring data becomes available. The EMP

provides a combination of environmental management practices as well as guidance on the principles

and elements to be included as the EMP develops over time and becomes more substantive with the

inclusion of further impact assessment information and data.

It is critical that an EMP is developed with the full participation of the owner/operators of the Project in

order that appropriate management and monitoring responsibility is embedded and communicated to

those who will be responsible for implementing these plans. AML have contributed significantly to the

development of this EMP document in terms of fully endorsing the intent of the EMP and its content

and structure. AML will be using the EMP as their environmental management reference for the

project.

The EMP should be treated as a ‘live’ document that requires updating and ongoing development

during all stages of the project. It is envisaged that the EMP would also in part be defined by, and

implemented through, the Environmental Management System (EMS) adopted by AML.

In addition, the EMP at this stage aims to provide a basis for the development of component-specific

(thematic) environmental management plans, which may be developed according to the requirements

of the project schedule giving priority to early works.



9.1



Construction vs. Operational Management Plans



Construction management plans have already been developed as part of the current ESHIA works

program. This includes the materials prepared for the haul road which were presented to SLEPA at

an early stage to ensure the fast-tracked elements of the project are managed correctly. A Solid

Wastes Management Practice Guidelines has also been produced for Phase 1 of the Tonkolili project.

Further management plans will be required for the construction, operations and closure of specific

project components and facilities. An over-arching Environmental Management Plan (see Appendix

18) is needed to set out common approaches to standardise the specific plans. As the project

progresses management plans will be developed to address potential issues during the construction,

operations and closure phases and may include some of the following examples:



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Site Specific Social & Environmental Management plan (Site specific EMPs could be

developed for numerous elements within the project, for example, processing plant, mine,

tailings facilities, waste rock dumps, etc) (construction phase)







Integrated Waste Management Plan (operational phase)







Emergency Preparedness Management Plan (operational phase)







Environmental & Social Monitoring Programme (operational phase)







Security Management Plan (operational phase)







Community Development Action Plan (operational phase)







Closure and Decommissioning Plan (closure phase)



The following sections provide an overview of the management procedures, predominantly

construction orientated that are being considered during the Phase 1 project activities. The

operational stage management plans listed above are referenced in the Commitments Register and

will need to be further defined and scoped as part of the Stage 2 ESHIA.



9.2



Soil management



Introduction

Many of the construction activities associated with the Phase 1 project will require some land

clearance however this will depend on features that materialize such as community land use,

environmental or community assets and/or ground conditions.

The haul road construction will involve clearance of a scout track for survey, ca. 6m width, followed by

widening, either symmetrically or asymmetrically depending on environmental and social

considerations. The scout track, but particularly the widening process will involve clearing of scrub

predominantly (as routing through well wooded areas has been minimised wherever possible) and

non-woody vegetation, followed by topsoil stripping. Topsoil is an important environmental and social

resource, as it is key to supporting natural vegetation and farming processes. In addition, where

vegetation is reasonably diverse, it contains the seeds and other propagules that under the right

circumstances can allow recolonisation of the original vegetation assemblage, hence reducing the

adverse effects on ecological resources.

There are other reasons for promoting rapid revegetation of disturbed areas not required for

trafficking, such as reducing erosion and preventing washout and scouring of cuts and embankments,

minimising fugitive dust emissions and contributing to landscape and noise screening.

Procedure

In all areas where depths permit, topsoil will be stripped to a minimum depth of 300mm and stored in

a berm (or two berms) parallel to the alignment, for later use. Topsoil shall not be stored where it

would result in blockage of formalized and agreed accesses or encroach onto farmland or where it

impedes water flow. It will not be stored where it can readily be washed into streams and rivers and

cause pollution.

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Following finalization of works the intention will be to cover non trafficked surfaces and in particular

cuts and embankments with topsoil to allow natural vegetation colonization.

In the case of the haul road construction, the height of the road train vehicles and the large diameter

of the curved bends, it is unlikely that vegetation will become a safety hazard due to reducing sight

lines. However, vegetation growth will be monitored by AML and the appropriate maintenance will be

introduced.



9.3



Borrow Pits



Borrow pits and quarries to be used for this project will be managed with due consideration to social

and environmental concerns and after appropriate permits, where required, are in place. The

contractor will:

• Obtain AML approval before sourcing material from quarries, not opening borrow pits without

informing AML

• Not open borrow pits within 100m of riverbanks or well forested areas, where a risk to water

quality or forest resources is foreseen

For any new borrow pits, topsoil has to be managed carefully to allow for restoration of some

temporarily affected areas. Where possible topsoil will be stripped off to a typical depth of 300mm and

stored in windrow or berm for later use (e.g. landscaping embankments to reduce erosion during wet

season). Topsoil will not be mixed with low fertility subsoil to facilitate its use for restoration needs.

In the case of the haul road construction, where hills or hummocks along the transport route contain

suitable material, the relevant permissions will be obtained from local authorities, such as the

Paramount Chief, if applicable.



9.4



Water management



Introduction

Water is of considerable importance throughout the project area, from surface water resources used

for irrigation, fishing, washing, bathing and in some cases potable supply. It is therefore necessary to

manage the construction works in such a manner that they forecast potential adverse effects and

either design them out or apply mitigation to minimize negative effects.

• Disturbance to river banks will be minimised by limiting the movement of machinery close to the

river’s edge;

• The areas to be cleared will be clearly defined before the start of works and no works/clearance

will be conducted outside this. If bridges are to be build, only higher trees will be removed,

leaving the low growth vegetation on site to avoid erosion issues and surface run-off.

• Clearing near to water courses will be conducted to minimise any materials or plant entering or

damaging the water course.



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• Wherever possible, free-spanning bridge structures will be used with piled / trestle bridges as a

secondary option; solid embankment / causeway structures will not be used;

• Consideration will be given to wet season flow in designing watercourse crossings including

potential for blockage by trees and debris etc

• Flume pipes or pre-fabricated culverts will be used for crossings in areas with lower flow

• Machinery and other construction materials will be stockpiled no less than 50m back from the

river banks or otherwise to prevent pollution;

• A pre-construction photographic record will be recorded to establish a benchmark against

which post construction site rehabilitation can be monitored, where applicable;

• Sampling of water quality upstream, at work locations and downstream; locations and

parameters to be determined at a later date in the design of the haul road and subject to

agreement with environmental regulators as may be appropriate.

• Each river crossing will be surveyed to ascertain whether the river course is used as a transport

route by locals and / or a water source;

• The river bank either side of the crossing will be protected with sand bagging or other means

as may be necessary.

• Drainage control/ runoff protection including settling areas to prevent sudden influx of high

sediment from earthworks, will be implemented.

In view of the impending wet season, early identification of wet areas such as inland valley swamps

will be undertaken and where feasible, consideration will be given to early installation of flume pipes.

This will reduce potential pollution of water courses and damage to agricultural areas, as many of

these low lying areas are farmed by communities with dry season crops prior to the wet season crops.

These measures will also enable contractors to access their portion of the haul road without being

hindered by wet ground conditions following the onset of rains. An example of a flume pipe installed

on a haul road is presented below in Figure 9-1.



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Figure 9-1 Example of a flume pipe access



9.5



Swamp Areas & Riverine Vegetation



The swamp areas and riverine ecosystems are considered to have a high fragility and often a high

agricultural value and, therefore, impacts will be limited to the maximum extent possible.

Project activities will be limited to the maximum extent possible in close proximity to seasonally

flooded areas (swamps), rivers and associated vegetation; advice will be sought from a local ecologist

where necessary.

Mitigation measures to keep impacts within acceptable limits include the following:

• Keep earth movements to the minimum required near riverine vegetation areas

• Avoid excavating material (borrow pits) or landfills near watercourses or inundated areas, and

especially through riverine forest areas

• Where a river is not to be crossed a minimum of 50 m buffer zone from the riverine area will be

respected (100 m in case of the Rokel River), wherever feasible

• Where disturbance is necessary, clear only the minimum to facilitate safe access and work

• Ensure workforce is aware of environmental and/or community sensitivities

• It is recommended that the haul road is diverted if an area with higher trees density is found.

Rivers and seasonally flooded areas will preferentially be crossed through locations where

vegetation coverage is less dense and/or valuable



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• Clearly define and mark the construction locations before activities begin and avoid

construction outside the defined area

• Control vehicle movements and plan to minimise journeys

• Plan subsequent restoration requirements. Make photographic records of areas to be disturbed

before development, to assist in after-use site restoration, as applicable

• Practice progressive site clean-up through the life of the project

The risk of contamination of permanent and temporary surface water bodies will be minimised by the

adoption of appropriate operating procedures as follows:

• Potentially contaminating liquids, such as fuel, oil and chemicals, will be stored and handled

according to manufacturers’ recommendations/MSDS, good industry practice and HSE plan

stipulations (this also applies to subcontractors delivering supplies)

• Such liquids will be stored away from seasonally flooded areas and rivers

• Spill response equipment and procedures will be in place in all areas where the potential for

spills exists

• Settlement pits excavated for the treatment of liquid waste will not be located near permanent

or temporary surface water bodies and the pits will be appropriately lined; and

• To preserve surface water bodies from accidental spills or leakages, no temporary camps will

be located within a preferential radius of 500m of the nearest river / water body; ground

conditions to determine distance.



9.6



Work in Proximity to Communities



Introduction

The most important mitigation for potential negative impacts to the local community is to ensure that

people are aware of the start of the activities and ensure their protection. This will be achieved in

consultation with local authorities in all affected communities before construction starts.

Appropriate authorities will be consulted with regard to access creation, temporary camp locations,

and advice for dealing with any particular sensitivities including the existing infrastructure (community

water wells, schools and roads), agricultural and grazing areas and society bush.

With the construction of the haul road there will be an increase in vehicle traffic in the area that will

lead to potential increases in vehicle-related incidents or accidents. The health and safety of the local

population is a primary concern throughout the project.

Mitigation measures designed to minimise the risks include the following:

• The adoption of driving regulations to be adhered to by all personnel including subcontractors

• Strict enforcement of speed limits



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• Careful planning of all journeys, particularly in areas where members of the public may be

encountered

• No night driving except in an emergency or with specific management measures

• Implement a journey management system



9.6.1



Noise emissions



Impacts on local air quality (noise) resulting from the use of heavy machinery and equipment and

transport activities can be minimised by carefully planning vehicle movement and using machinery

that has been certified and appropriately maintained.

Recommendations for minimising noise include the following:

• Carefully plan mobilisation of personnel and equipment to limit transport to essential travel;

• Noise-efficient vehicles and equipment will be used and serviced regularly (in accordance with

the manufacturers’ recommendations) to ensure efficient operation and minimal emissions;

• Keep operations as distant from populated areas as possible and limit operations during

morning and evening times to avoid causing nuisance. Restrict the number of engines working

at night;

• In general, plan the project so that equipment and vehicle use are minimised (e.g. in terms of

staff movements and the delivery of supplies);

• Switch off generators and engines whenever equipment or vehicles are not in use; and

• Avoid running engines at excessive speed.



9.6.2



Air Quality (Air Emissions)



Local reductions in air quality will result from a number of factors, including the use of diesel powered

equipment, dust generation during civil works and potential vapour emissions during fuel transfer or

maintenance activities or from hazardous material handling and storage.

Air quality may be reduced by waste incineration. In order to minimise the impact on air quality from

waste incineration, these activity will be reduced when conditions are such that impacts could be

exacerbated (e.g., during calm and high pressures situations that might help accumulate air pollutants

at one area). In addition, the general aim will be to minimise the quantity of waste to be incinerated.

General procedures for minimising impact to air quality from vehicle emissions will be in place for the

duration of the programme, including the following:

• Consider fuel efficiency when selecting equipment and vehicles;

• Many of the items listed in the noise section above.



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9.6.3



Dust & Particles Generation



Dust generation (from heavy vehicle use, line clearance, earth movement, etc), may also contribute to

a degradation of local air quality. Dust and particulate emissions will be mitigated by observing the

following dust suppression measures, as appropriate:

• Use of water trucks for regular watering of unsealed roads

• Operator awareness training on the causes of dust and how it can be minimised (in particular to

unpaved surfaces and stockpiles)

• Use of surface binding/sealing agents on high-traffic surfaces

• Minimise traffic on unsealed roads

• Strictly enforce speed limits when driving on unpaved roads

• Limit civil works involving earth movements during periods of high winds

• Cover truck loads of earth or excavated materials

• Minimise dust generating activities when conditions could exacerbate the impacts (e.g., during

high winds)

• Avoid off-track driving

• Minimise vehicle use



9.7



Work near Society Bush, Thick Forests & Protected Areas



Society bush areas are important both for local communities, due to the use of these areas, and for

conservation purposes, since these areas host important flora and fauna.

The importance of vegetation in the area will be clearly communicated to all project personnel. Other

remaining thick forest areas are also important in terms of conservational values since they represent

the last remnants of what used to be the main habitat in the project areas. Protected areas,

independent of their state of conservation, are safeguarded by Sierra Leone laws and works will not

be undertaken in these areas unless appropriate permits issued by the Ministry of Lands, Country

Planning and the Environment are in place, as applicable. The general rule is that no Society Bushes

(or large trees in any areas) are to be disturbed except in exceptional circumstances.

A local ecologist and a local community representative will view the proposed haul road locations

where a Society Bush / thick forest is located or flora of particular interest has been observed.

General recommendations for vegetation clearance include:

• Avoid clearance through thick forests

• If clearance is required, consult with AML to ensure appropriate permits have been obtained in

advance



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• Consult with communities and AML community liaison to identify “no-go” areas (e.g. Society

Bush)

• Do not cut trees for firewood

• Cut large trees with chainsaw rather than bulldozing, to avoid unnecessary soil disturbance

Fires will be strictly prohibited outside temporary camp sites, and fires within the camps will be

appropriately controlled. Local wood will not preferentially be used as fuel for temporary camp

activities.

Recommendations to prevent deterioration of habitats may be provided by a local ecologist / zoologist

(or an ecology survey team) and will be followed.

Furthermore, the following measures will be considered:

• Inform personnel that hunting during their time in the area will be prohibited.

• Raise and maintain personnel awareness of the importance of not damaging plants and

animals. For example, most of the monkeys that could be encountered are likely to face

conservation threats.

• Control personnel movements. Restrict personnel from the most sensitive areas.

• Create and implement a site restoration plan to mitigate impacts on Society Bushes or any

other forest areas with significant tree growth to the greatest extent possible.

• Access roads locations will be selected in a way that minimises effects on sensitive fauna.

Block access routes that could lead poachers to areas where endangered species might roam.

The risk of injury to fauna from vehicle movements will be minimised by the adoption of safe speed

limits and a ban on night driving, except in emergency situations.

Neither temporary camps nor waste disposal areas will be established near society bush / thick

forests / protected areas (100 metres buffer zone). Mature trees stands will be avoided as far as

possible, except if the main trees in the stands are palm trees.

Noise, air pollutant emissions and dust generation may also impact forested areas.

Impacts on local fauna likely to inhabit Society Bush areas and other forested strips resulting from

noise generation produced through the use of heavy machinery and equipment and transport

activities can be minimised by carefully planning vehicle movement and using machinery that has

been certified by international standards and appropriately maintained.

Dust generation (from heavy vehicle use, line clearance, earth movement, etc), may also contribute to

a degradation of the floral community. To avoid impact on flora from dust and particulate emissions

the dust suppression measures previously presented will be applied.



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9.8



Waste management



The development of construction and mine workers camps will generate significant quantities of

typical household solid waste, at varying times throughout the project. It is recommended that an

approach to dealing with waste is developed prior to the construction of the camps and that the

following high level principles are adopted:

• Where possible waste will be managed in accordance with the waste hierarchy;

• Potential disposal sites will be identified at the outset and an assessment made of the most

appropriate treatment / disposal method, based on the availability and of fit for purpose

disposal sites;

• Waste will be separated at source, the extent of which to be determined by the availability of

local recycling markets and final disposal options;

• Local community will be engaged to develop a mechanism for recycling materials back into the

local area;

• Liaise with AML CLO to identify suitable locations for temporary waste facilities and identify

existing waste facilities in project areas that can be used for waste disposal

• Waste storage and collection provision will make consideration for local climate, and in

particular for pest and odour control;

• Locate waste collection areas at least 1km from populated areas and 500m from agricultural

areas

• Do not discharge any waste into rivers; grey and black waters to be disposed in lined pits sited

close to workers’ camp(s) or otherwise as appropriate so as to avoid contamination

• Do not leave any waste on site: workers must carry bags to collect all wastes for return to camp

waste storage facility

• Consideration will be made for composting of organic fractions;

• It is understood that burning of waste is widespread practice through the region, this will not be

undertaken without due consideration for the appropriate air quality standards;

• The local waste regulatory body will be engaged at the earliest opportunity with respect to any

waste management proposals;

• Ultimately an integrated approach will be adopted with respect to all worker camps waste

management.

• Litter and waste collection systems are to be implemented and litter bins covered at all sites.

Hard waste at site has to be removed to the central camp for sorting and burying/ burning/ reuse as appropriate.

Vegetation clearance will generate almost exclusively organic wastes that will be suitable for self

biodegradation in the surrounding forest.



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• Set down areas for any useful timber will be identified at the outset, including engagement with

the local community as to suitability of location;

• The vegetation may contain elements of valuable hardwood, where possible this will be

separated at source by machine and procedures set in place in order that the local community

can safely recover elements of hardwood;

• Small fractions of vegetation may become contaminated with diesels, hydraulic oils etc. these

will be stockpiled separately and disposed to an appropriately facility to be determined in liaison

with AML;

• Given the volume of organic waste likely to be generated the potential for composting will be

considered and additional proposals may be developed accordingly.



Fuel & Spillages



9.9

9.9.1



Refueling & Maintenance Procedures



Oil and fuel storage and refuelling activities will be guided by the following principles:





Store all fuels and oils within secondary containment (double skinned tanks, impermeable

bunds, drip trays or plastic sheeting on sand bags)







Provide a sealed surface refuelling (or spill prevention) and machinery maintenance area at

the workers’ camp(s)







Do not carry out refuelling or maintenance works outside designated area







Carry spill response and clean-up materials to deal with any accidental spills of fuels and

lubricants







Train designated workers in fuels storage and handling and spill clean up







Do not store quantities of fuels and oils within 100m of water courses, swamps or drainage

ditches



It is envisaged that some refuelling and maintenance requirements will generate hazardous wastes

such as hydraulic oils, heavy metals, lubricants etc. These will be identified, removed and kept

separate from other waste materials to avoid further contamination and be disposed of in accordance

with all relevant legislation and best practice guidelines at point of origin or at an alternative suitable

site.



9.9.2



Spill response



Accidental events have the potential to cause major impacts. Mitigation will include the following

guiding principles and are discussed further below:



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• Prevention: Following standard protocols and procedures adhering to best practice will help

avoid accidental event occurrence. Best practice includes personnel training and setting

adequate health, safety and security measures.

• Quick response: Preparing an Emergency Response Plan (ERP) for implementing

countermeasures against non-routine events.

Spill Prevention Control and Countermeasure

Vehicles and equipment shall be serviced regularly in a manner which minimises spills and leaks.

Service areas will be designated and shall be used for vehicle maintenance. Heavy equipment (e.g.,

large trucks) will produce large quantities of waste oils and lubricants that need to be stored in

labelled containers and removed from the site. Use drip pans, or trays, for protection from leaks

during vehicle maintenance. Machinery maintenance and refuelling will only take place at

designated, preferably lined areas; the construction of dykes and berms may be appropriate at the

site in a manner that will contain any fluid spills that might occur during camp operations.





A written procedure for inspecting and testing pollution prevention equipment and systems

will be prepared and maintained at the worker’s camp. The procedures will form part of the

overall spill prevention control and countermeasure plans.







All tanks to be subject to periodic integrity testing (visual inspection), taking into account tank

design and use.







Spill cleanup and emergency response equipment to be centrally located and staff trained in

its proper use.







Personal protection equipment to be located at all fluid handling points, i.e. in vehicle yard,

generators and workshops







Relevant emergency response equipment to be located at working points, equipment to

include as a minimum: First aid - including eyewash; Fire extinguishers; Sorbents; and

Personal protection equipment (hardhats, visors, gloves, aprons, face mask)



Contingency and Emergency Response Plan

Contractors shall develop an Emergency Response Plan (ERP) to deal with incidents that occur

during the construction programme.

Facilities and procedures to prevent spills shall be in place during operations, including:





Provide safe oil and chemical packaging and storage;







Provide containment around oil-containing areas and equipment;







Use efficient oil/water separators where necessary; and







Operate safe fuel transfer procedures.



Emergency response plans that address spill incidents shall be prepared during the planning phase

for specific locations. Plans shall include the following:



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Identification of sensitive resources and priority protection areas;







Identification of internal emergency organisations, responsibilities and resources (human and

equipment and materials) for spill response. A clear chain of communication to ensure a rapid

emergency response will be established. Periodic refreshers will be conducted;







Training of personnel at the beginning of the construction programme on health, safety and

security requirements with clear guidance on emergency responses; and







Spill response and cleanup strategies.



In case of a spill, contaminated soil materials will be identified, removed and kept separate from other

construction waste materials in order to avoid further contamination and will be disposed of in

accordance with all relevant legislation and best practice guidelines at point of origin or at an

alternative suitable site.

A chemicals and hazardous materials management plan shall be adopted, taking into account

relevant regulatory requirements and environmental considerations that include the following:





Provision of Material Safety Data Sheets (MSDS) and handling procedures for hazardous

chemicals and materials;







Carry spill clean-up material on large vehicles in case of fuel and hydraulic fluid leaks;







Provision of segregated and contained storage areas; and







Use of low impact chemicals and materials as far as practicable.



9.10



Agricultural areas



• The details of the haul road construction activities will be discussed with local authorities prior

to construction start and this process in currently ongoing concomitant with the design. The

discussions will include concerns regarding disturbance to agricultural and grazing areas and

activities planned near human settlements.

• AML CLOs are in ongoing contact with relevant local residents prior to commencing works in

an area

• Agricultural land is to be avoided to the maximum extent possible; and contractors/AML are

and will continue to document and photographically recorded agricultural activity prior to

commencing work in or near agricultural land

• Agricultural and grazing areas will be avoided unless adequate compensation or alternative

land schemes are agreed; this is an ongoing initiative with the EWCC mechanism.

• Residents will be allowed to recover material and private property prior to commencing works, if

applicable

• Land inventories will be developed and agreed with local authorities. These will include records

of location, land area, crops grown and allocated owner. Photographic records will be

employed.

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• Temporary workers’ camps construction and borrow pits will avoid agricultural areas.

• No waste disposal will be permitted in the vicinity of agriculture areas (within a 50m radius).



9.11



Site Selection for Camps



Introduction

This section is included here to address the issues associated with establishment of any temporary

camps and facilities required during construction. Currently contractors are accommodated in existing

hotels, such as in Makeni or AML guest houses or at the mine camp, however as staff numbers ramp

up there will be a need to establish camps along the route local to the work site.

Procedure

Site selection for temporary workers’ camps will be guided by the following principles:

• Camps must, as far as possible be located on previously cleared or sparsely vegetated, flat

areas along road alignment

• Agree location of workers’ camps with local chiefs; liaise with AML Community Liaison

Officer(s) (CLO) designated to the area

• Camps must be located at least 500m from villages and well outside active agriculture areas

where feasible

• Camps must be located at least 100m from densely forested areas and 100m from rivers /

swamps

• Personnel movement outside camps will be restricted

• Hunting will be prohibited

• A photographic record of camp(s) area(s) will be made prior to site clearance

Access roads to be opened for accessing temporary working facilities and infrastructure will follow

these principles:

• Use existing roads as access roads wherever possible taking into account health and safety of

other (community) users

• Align new access roads, to the maximum extent possible, along the haul road alignment to

avoid excessive vegetation clearance

• Access roads must avoid forest and riverine vegetation wherever possible

• Minimise width of access roads and give attention to potential wash-out and offsite pollution



9.11.1 Transport Activities / Equipment Use

Transport activities will be regulated by the following principles:



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• Restrict vehicle movement to marked tracks only

• Avoid night time driving wherever possible or implement measures to reduce accidents, such

as flagmen and signage

• Enforce speed limits (30km/h maximum near villages); lower through villages

• Track and road crossings:

- Ensure advance liaison via CLO; activities must not start without prior notification of proposed

works to local communities

- Ensure safety of road users via use of flagmen and signage

Furthermore, to avoid nuisances to local communities and impacts to fauna and flora, the following

will be adhered to:

• Always cover trucks carrying material likely to generate dust or otherwise ensure dust is not an

issue

• Turn engines off when machinery is not in use / stationary

• Limit illumination sources and generator use at night

Carrying out construction operations during the night is potentially dangerous and will only be

undertaken if the contractor