NOTICE: The text below was created automatically and may contain errors and differences from the contract's original PDF file. Learn more here

MARAMPA IRON ORE PROJECT

ENVIRONMENTAL AND SOCIAL

IMPACT STATEMENT - VOLUME 2



Prepared For



MARAMPA IRON ORE (S.L.) LIMITED



Report Prepared by



SRK Consulting (UK) Limited

UK3823



SRK Consulting



Marampa Iron Ore Project ESIS



COPYRIGHT AND DISCLAIMER

Copyright (and any other applicable intellectual property rights) in this document and any

accompanying data or models is reserved by SRK Consulting (UK) Limited ("SRK") and is

protected by international copyright and other laws.

This document may not be utilised or relied upon for any purpose other than that for which it is

stated within and SRK shall not be liable for any loss or damage caused by such use or

reliance. In the event that the recipient of this document wishes to use the content of this

document in support of any purpose beyond or outside that which it is expressly stated or for

the raising of any finance from a third party where the document is not being utilised in its full

form for this purpose, the recipient shall always in each and every circumstance ensure that the

incorporated content presented is in a manner which accurately and reasonably reflects any

results or conclusions produced by SRK.

Further, the recipient agrees not to use this document or any of its content in any such way as

to prejudice the context and integrity of SRK’s work which is integral to SRK's professional

reputation and the recipient assumes all risk from its use of this document and SRK’s reports,

analysis, opinion or similar that have been edited, abridged or otherwise amended by the

recipient or any other person on behalf of the recipient without first obtaining the consent in

writing of SRK. SRK shall not be liable for any loss caused by any use or reliance placed upon

any versions of this document, its content or any of SRK’s reports, analysis, opinion or similar

modified other than by or on behalf of SRK.

The use of this document is strictly subject to terms licensed by SRK to its client as the

recipient of this document and unless otherwise agreed by SRK, this does not grant rights to

any third party. This document shall only be distributed to any third party in full as provided by

SRK and may not be reproduced or circulated in the public domain (in whole or in part) or in

any edited, abridged or otherwise amended form unless expressly agreed in writing by SRK. In

the event that this document is disclosed or distributed to any third party, no such third party

shall be entitled to place reliance upon any information, warranties or representations which

may be contained within this document and the recipient of this document shall indemnify SRK

against all and any claims, losses and costs which may be incurred by SRK relating to such

third parties.

© SRK Consulting (UK) Limited 2011



SRK Consulting (UK) Limited



SRK Legal Entity:



5th Floor Churchill House, 17 Churchill Way,

City and County of Cardiff, CF10 2HH

Wales, United Kingdom.



SRK Address:



September 2012



Date:

Project Number:

SRK Project Director and

Project Manager:



UK3823

Fiona Cessford



Corporate Consultant (Environment)

Marampa Iron Ore Limited



Client Legal Entity:



Victoria Place

31 Victoria Street

Hamilton

Bermuda (British Overseas Territory)

HM10



Client Address:



U3823_Marampa_ESIS_Final.docx



September 2012

Page i of i



SRK Consulting



Marampa Iron Ore Project ESIS – Table of Contents



Volume 1: Executive Summary

Volume 2: Main Environmental and Social Impact

Statement (this volume)

Table of Contents

1



INTRODUCTION ................................................................................................. 1

1.1 Project setting .......................................................................................................................... 1

1.2 Project proponent .................................................................................................................... 4

1.3 ESIA team ................................................................................................................................ 4

1.4 Project background .................................................................................................................. 6

1.5 Project motivation .................................................................................................................... 8

1.6 Structure of the report .............................................................................................................. 8



2



ENVIRONMENTAL AND SOCIAL REGULATORY FRAMEWORK ................. 11

2.1 Sierra Leone requirements .................................................................................................... 11

2.1.1 ESIA/ EIA requirements in the EPA Act 2008 ............................................................. 11

2.1.2 ESIA/ EIA requirements in terms of the Mines and Minerals Act 2009 ....................... 12

2.1.3 Other environmental and social permissions .............................................................. 13

2.2 International guidelines and standards considered ............................................................... 14

2.2.1 Equator Principles, IFC requirements and WBG EHS guidelines ............................... 14

2.2.2 Self-regulation in the mining sector ............................................................................. 14



3



ESIA OBJECTIVES AND PROCESS................................................................ 16

3.1 Objectives .............................................................................................................................. 16

3.2 Study area.............................................................................................................................. 17

3.3 ESIA Process ......................................................................................................................... 17

3.3.1 Phase 1: Scoping activities ......................................................................................... 20

3.3.2 Phase 2: Baseline investigations................................................................................. 21

3.3.3 Phase 3: Impact identification and definition ............................................................... 27

3.3.4 Phase 4: ESIA report review and decision-making ..................................................... 35

3.3.5 Stakeholder consultation ............................................................................................. 36

3.4 Assumptions and limitations .................................................................................................. 39



4



PROJECT DESCRIPTION ................................................................................ 40

4.1 Construction ........................................................................................................................... 41

4.1.1 Land acquisition and resettlement............................................................................... 41

4.1.2 Construction camp and laydown area ......................................................................... 42

4.1.3 Land clearance and infrastructure development ......................................................... 42

4.1.4 Construction management .......................................................................................... 44

4.2 Mine site operation ................................................................................................................ 44

4.2.1 Preliminary pit design .................................................................................................. 44



U3823_Marampa_ESIS_Final.docx



September 2012

Page i of ix



SRK Consulting



Marampa Iron Ore Project ESIS – Table of Contents



4.2.2 Preliminary production schedule ................................................................................. 45

4.2.3 Mining operations ........................................................................................................ 51

4.2.4 Mining equipment ........................................................................................................ 55

4.2.5 Explosives storage ...................................................................................................... 55

4.2.6 Waste rock dumps ....................................................................................................... 56

4.2.7 Topsoil ......................................................................................................................... 57

4.3 Processing ............................................................................................................................. 57

4.3.1 Stage 1 Beneficiation Plant ......................................................................................... 57

4.3.2 Stage 2 Beneficiation Plant expansion ........................................................................ 58

4.3.3 Reagents ..................................................................................................................... 61

4.4 Tailings storage facility .......................................................................................................... 64

4.4.1 Tailings and TSF decant water pipelines .................................................................... 64

4.4.2 TSF design .................................................................................................................. 64

4.4.3 TSF operation .............................................................................................................. 65

4.5 Power supply ......................................................................................................................... 66

4.6 Water supply .......................................................................................................................... 66

4.7 Concentrate transport ............................................................................................................ 69

4.7.1 Stage 1 development .................................................................................................. 69

4.7.2 Stage 2 development .................................................................................................. 69

4.8 Other site infrastructure and services .................................................................................... 69

4.8.1 Roads and freight ........................................................................................................ 69

4.8.2 Storm water management ........................................................................................... 70

4.8.3 Waste management .................................................................................................... 70

4.8.4 Communications .......................................................................................................... 71

4.8.5 Accommodation ........................................................................................................... 71

4.8.6 Medical services .......................................................................................................... 71

4.8.7 Fire fighting .................................................................................................................. 73

4.8.8 Mobile Equipment ........................................................................................................ 73

4.8.9 Fuel use and storage ................................................................................................... 73

4.8.10 Security ........................................................................................................................ 73

4.8.11 Ancillary buildings ........................................................................................................ 74

4.9 Project implementation .......................................................................................................... 74

4.9.1 Project milestones ....................................................................................................... 74

4.9.2 Operation management ............................................................................................... 74

4.9.3 Human resources management .................................................................................. 75

4.9.4 Procurement ................................................................................................................ 76

4.10 Pollution control ..................................................................................................................... 76

4.11 Project closure ....................................................................................................................... 78

4.12 Project Alternatives ................................................................................................................ 79

4.12.1 Power supply ............................................................................................................... 79

U3823_Marampa_ESIS_Final.docx



September 2012

Page ii of ix



SRK Consulting



Marampa Iron Ore Project ESIS – Table of Contents



4.12.2 Water supply................................................................................................................ 79

4.12.3 Concentrate transport .................................................................................................. 79

4.13 Future studies ........................................................................................................................ 80



5



BIOPHYSICAL BASELINE DESCRIPTION ...................................................... 81

5.1 Physiography and Landscape ............................................................................................... 81

5.2 Geology and Geochemistry ................................................................................................... 82

5.2.1 Geology ....................................................................................................................... 82

5.2.2 Geochemical characterisation ..................................................................................... 83

5.3 Natural Hazards ..................................................................................................................... 84

5.4 Climate ................................................................................................................................... 85

5.5 Water Resources ................................................................................................................... 86

5.5.1 Hydrology .................................................................................................................... 86

5.5.2 Hydrogeology .............................................................................................................. 89

5.5.3 Water quality................................................................................................................ 89

5.6 Soils ....................................................................................................................................... 90

5.6.1 Soil quality ................................................................................................................... 93

5.6.2 Sediment quality .......................................................................................................... 94

5.7 Air Quality .............................................................................................................................. 95

5.8 Noise ...................................................................................................................................... 97

5.9 Biodiversity............................................................................................................................. 98

5.9.1 Terrestrial habitats and faunal associations ................................................................ 99

5.9.2 Terrestrial species of conservation significance ........................................................ 102

5.9.3 Aquatic habitats and faunal associations .................................................................. 103

5.9.4 Aquatic species of conservation concern .................................................................. 106

5.9.5 Aquatic ecosystem health ......................................................................................... 106



6



SOCIO-ECONOMIC BASELINE DESCRIPTION ............................................ 108

6.1 Approach and methodology ................................................................................................. 108

6.2 Population ............................................................................................................................ 110

6.2.1 Population in the study area ...................................................................................... 110

6.2.2 Ethnicity ..................................................................................................................... 110

6.3 Economy .............................................................................................................................. 111

6.3.1 Description of livelihoods in the study area ............................................................... 111

6.3.2 Value addition ............................................................................................................ 118

6.4 Land tenure .......................................................................................................................... 119

6.5 Living standards ................................................................................................................... 121

6.5.1 Possessions and expenditure ................................................................................... 122

6.5.2 Food Security ............................................................................................................ 122

6.5.3 Habitation .................................................................................................................. 123

6.5.4 Energy sources.......................................................................................................... 123



U3823_Marampa_ESIS_Final.docx



September 2012

Page iii of ix



SRK Consulting



Marampa Iron Ore Project ESIS – Table of Contents



6.6 Social stratification ............................................................................................................... 123

6.7 Vulnerable groups ................................................................................................................ 123

6.8 Health................................................................................................................................... 123

6.9 Education ............................................................................................................................. 125

6.10 Infrastructure ........................................................................................................................ 125

6.11 Ongoing governmental and non-governmental programmes .............................................. 126

6.12 Contemporary social system and practices ......................................................................... 126

6.13 Archaeology and cultural heritage ....................................................................................... 126

6.14 Community perceptions: needs and apprehensions ........................................................... 127



7



BIOPHYSICAL IMPACT ASSESSMENT ........................................................ 129

7.1 Land transformation ............................................................................................................. 131

7.1.1 LT1: Change in land use as a result of mine and related infrastructure limiting use by

local communities ...................................................................................................... 131

7.1.2 LT2: Disruption of community access routes by mine infrastructure, potentially

resulting in social disruption ...................................................................................... 133

7.1.3 LT3: Mine infrastructure and activities potentially resulting in visual impacts for local

communities .............................................................................................................. 134

7.1.4 LT4: Loss of topsoil through erosion, decreasing land capability ............................. 136

7.1.5 LT5: Fugitive dust potentially resulting in changes in soil chemistry and agricultural

land capability ............................................................................................................ 138

7.2 Water resources .................................................................................................................. 140

7.2.1 WR1: Pit dewatering potentially resulting in reduced groundwater availability to

ecological systems and local communities ............................................................... 141

7.2.2 WR2: Surface water abstraction affecting downstream users .................................. 143

7.2.3 WR3: Project infrastructure causing altered surface water flow conditions, affecting

downstream users ..................................................................................................... 144

7.2.4 WR4: Surface water diversions potentially causing changes to flood risk to adjacent

agricultural areas and communities........................................................................... 149

7.2.5 WR5: Seepage from mining wastes potentially resulting in deteriorated groundwater

quality affecting communities and ecological systems .............................................. 151

7.2.6 WR6: Discharges or runoff to surface water potentially resulting in deteriorated water

quality affecting communities and ecological systems .............................................. 153

7.3 Ecology and biodiversity ...................................................................................................... 157

7.3.1 EB1: Site clearance and positioning of Project infrastructure potentially resulting in

habitat loss and fragmentation, and direct loss of fauna and flora ............................ 157

7.3.2 EB2: Soil disturbance facilitating the establishment and spread of invasive species,

potentially affecting indigenous ecosystems ............................................................. 161

7.3.3 EB3: Project activities resulting in sensory or other disturbance to wildlife .............. 163

7.3.4 EB4: Mine infrastructure and activities attracting nuisance species, potentially

resulting in impacts on indigenous ecosystems ........................................................ 165



8



SOCIO-ECONOMIC IMPACT ASSESSMENT ................................................ 167

8.1 Economic development ....................................................................................................... 167

8.1.1 ED1: Employment generation by the Project resulting in increased standard of living

for the local community ............................................................................................. 168



U3823_Marampa_ESIS_Final.docx



September 2012

Page iv of ix



SRK Consulting



Marampa Iron Ore Project ESIS – Table of Contents



8.1.2 ED2: Employee training leading to skills development in the local community ........ 170

8.1.3 ED3: Increase in government income (from taxes and royalty on mining) potentially

leading to social development in Project area ........................................................... 171

8.1.4 ED4: Opportunities for local suppliers and contractors leading to local economic

growth ........................................................................................................................ 172

8.2 Resettlement and loss of land, social and natural resources .............................................. 173

8.2.1 RL1: Impoverishment through loss of shelter, land and communal natural resources174

8.2.2 RL2: Changes to community access as a result of the Project potentially affecting

livelihoods, access to communal social services and infrastructure and community

cohesion .................................................................................................................... 176

8.2.3 RL3: Added pressure on limited host community resources potentially resulting in

food insecurity and malnutrition ................................................................................. 178

8.3 Social order .......................................................................................................................... 179

8.3.1 SO1: Influx of job seekers causing increased pressure on government services and

infrastructure, potentially resulting in reduced standard of living .............................. 179

8.3.2 SO2: Increase in social ills/problems ........................................................................ 180

8.3.3 SO3: Real or perceived unequal distribution of Project benefits potentially leading to

social tension ............................................................................................................. 182

8.4 Archaeology and cultural heritage ....................................................................................... 183

8.4.1 AC1: Possible disturbance to sacred bushes and cemeteries leading to loss of

community’s access to cultural resources ................................................................. 183

8.5 Decommissioning and closure ............................................................................................. 184

8.5.1 DC1: Closure of the mine leading to economic decline ............................................ 185



9



COMMUNITY HEALTH, SAFETY AND SECURITY IMPACT ASSESSMENT 187

9.1 Air quality ............................................................................................................................. 188

9.1.1 AQ1: Dust emissions causing nuisance and health impacts on local communities .. 189

9.2 Noise and vibrations ............................................................................................................ 196

9.2.1 NV1: Blasting causing air overpressure and vibrations, potentially resulting in

disturbance of local communities .............................................................................. 197

9.2.2 NV2: Operation of mining equipment and vehicles potentially resulting in increase in

background noise levels for local communities ......................................................... 200

9.3 Traffic safety ........................................................................................................................ 204

9.3.1 TS1: Increase in Project-related traffic on local and national roads causing increased

wear and tear and risk of road accidents .................................................................. 204

9.3.2 TS2: Use of mine site roads by local communities and their livestock causing

increased safety risks due to road accidents ............................................................ 207

9.4 Security and Social risks...................................................................................................... 208

9.4.1 SR1: Risk of human rights abuses due to conflict with the communities .................. 208

9.4.2 SR2: Increased exposure to communicable diseases due to an influx of workers,

potentially resulting in a deterioration in public health............................................... 210

9.5 Other hazards potentially resulting in injury......................................................................... 211

9.5.1 OH1: Blasting resulting in fly rock potentially harming people or their possessions . 211

9.5.2 OH2: Community exposure to toxic or hazardous substances ................................. 212



U3823_Marampa_ESIS_Final.docx



September 2012

Page v of ix



SRK Consulting



Marampa Iron Ore Project ESIS – Table of Contents



9.5.3 OH3: Fire or explosions due to storage of explosives and use of combustible

materials .................................................................................................................... 213

9.5.4 OH4: Failure of the TSF resulting in pollution or harm to individuals ........................ 213



10 CUMULATIVE IMPACTS ................................................................................ 214

10.1 Water resources .................................................................................................................. 216

10.2 Economic growth ................................................................................................................. 217

10.3 Social change associated with population increase due to in-migration ............................. 217



11 ENVIRONMENTAL AND SOCIAL MANAGEMENT SYSTEM ........................ 219

11.1 Planning elements ............................................................................................................... 221

11.1.1 Leadership and accountability ................................................................................... 221

11.1.2 Legal requirements and other obligations ................................................................. 221

11.1.3 Aspect identification and impact assessment throughout the Project life ................. 222

11.1.4 Objectives, targets and plans for management throughout the life of the Project .... 222

11.2 Implementation (Do) elements............................................................................................. 224

11.2.1 Roles and responsibility ............................................................................................ 224

11.2.2 Contractors, suppliers and vendors........................................................................... 224

11.2.3 Training ...................................................................................................................... 226

11.2.4 Communication.......................................................................................................... 227

11.2.5 Operational controls .................................................................................................. 227

11.2.6 Documentation and record keeping .......................................................................... 228

11.3 Monitoring and reporting (Check) elements ........................................................................ 228

11.3.1 Assessing, correcting and improving performance ................................................... 228

11.3.2 Non-conformances and incident reporting ................................................................ 230

11.3.3 EMP and ESMS Reporting ........................................................................................ 231

11.4 Act elements ........................................................................................................................ 231

11.4.1 Governance/ Management review ............................................................................ 231

11.4.2 Management of change ............................................................................................. 231

11.5 Stakeholder engagement..................................................................................................... 232

11.6 Emergency preparedness and response ............................................................................. 233



12 CONCLUSIONS AND OVERALL ASSESSMENT .......................................... 237

13 REFERENCES ................................................................................................ 243



List of Tables

Table 1-1: Project Proponent Details ...................................................................................................... 4

Table 1-2: ESIA Team Members ............................................................................................................ 5

Table 1-3: Structure of the ESIS ............................................................................................................. 8

Table 2-1: Sierra Leone environmental and sustainable development legislation ............................... 11

Table 2-2: Environmental and social permissions needed for the Project ............................................ 15

Table 3-1: MIOP ESIA process ............................................................................................................. 19

Table 3-2: Preliminary impacts identified for the Marampa Project ...................................................... 22

Table 3-3: Specialist Studies undertaken during the ESIA ................................................................... 26

Table 3-4: Characteristics used to describe an impact ........................................................................ 31

U3823_Marampa_ESIS_Final.docx



September 2012

Page vi of ix



SRK Consulting



Marampa Iron Ore Project ESIS – Table of Contents



Table 3-5: Method for rating the significance of impacts ...................................................................... 33

Table 3-6: Example of impact significance rating summary table......................................................... 35

Table 3-7: High-level summary of stakeholder issues raised and where addressed in the ESIS ........ 38

Table 4-1: Preliminary Ore/Waste Volumes per Pit .............................................................................. 44

Table 4-2: Indicative production schedule ............................................................................................ 49

Table 4-3: Mining equipment ................................................................................................................ 55

Table 4-4: Reagents and other materials likely to be used in the beneficiation plant ......................... 64

Table 4-5: TSF design criteria .............................................................................................................. 65

Table 4-6: Power station capacity and requirements ............................................................................ 66

Table 4-7: Water storage facilities ........................................................................................................ 67

Table 4-8: Management of non-mining wastes ..................................................................................... 72

Table 4-9: Mobile equipment list for site operation ............................................................................... 73

Table 4-10: Estimate of operational personnel requirements ............................................................... 76

Table 4-11: Expected emissions and effluents from mining operations ............................................... 77

Table 5-1: Climate data from MIOL meteorological station .................................................................. 85

Table 5-2: Calculated surface water flows ............................................................................................ 87

Table 5-3: Air quality baseline monitoring programme at mine site ...................................................... 95

Table 5-4: Baseline noise level measurements March 2011 (dBA) ...................................................... 98

Table 6-1: Population in the study area villages ................................................................................. 110

Table 6-2: Distribution of livelihood strategies (aggregated for all study villages) .............................. 111

Table 6-3: Livestock husbandry in the Project area ............................................................................ 114

Table 6-4: Traded wild products ......................................................................................................... 118

Table 6-5: Artisans and specialist skills in the study villages .............................................................. 120

Table 6-6: Income sources in the study area ...................................................................................... 122

Table 6-7: Annual household expenditure in the study area .............................................................. 122

Table 6-8: Most prevalent health problems in the Project area .......................................................... 124

Table 6-9: Consultation of medical services in the study area ........................................................... 124

Table 6-10: Educational levels in the study area ................................................................................ 125

Table 7-1: Summary of evaluated biophysical impacts ...................................................................... 129

Table 7-2: Current use of land directly disturbed by mine infrastructure ............................................ 132

Table 7-3: Predicted changes to 1 in 100 year peak flows and catchment areas for sub-catchments in

the Project area ......................................................................................................... 146

Table 7-4: Area of each habitat type directly impacted by the Project ............................................... 158

Table 8-1: Summary of evaluated social impacts ............................................................................... 167

Table 9-1: Summary of evaluated community health and safety impacts or risks.............................. 188

Table 9-2: Predicted 24-hour dust concentrations at local villages .................................................... 194

Table 10-1: Past, present and reasonably foreseeable activities in Project affected area potentially

resulting in cumulative impacts ................................................................................. 215

Table 11-1: Elements of the ESMS ..................................................................................................... 220

Table 11-2: Key Roles for Environmental and Social Management ................................................... 225

Table 11-3: Relationship between stakeholder engagement and the ESMS elements ..................... 233

Table 12-1: Preliminary summary of environmental, socio-economic and health and safety impact

ratings ........................................................................................................................ 240



List of Figures

Figure 1.1: Location of the Project site within Sierra Leone ................................................................... 2

Figure 1.2: Regional setting for the Project site, showing exploration license numbers ........................ 3

Figure 1.3: Interpretive geology of EL46/2011, relative to initial Project layout ..................................... 7

Figure 3.1: Study areas for MIOP ESIA ................................................................................................ 18

Figure 3.2: Overview of the stakeholder engagement process undertaken ......................................... 37

Figure 4.1: Overall site layout plan for the Project, with additional detail on the beneficiation plant and

road crossing ............................................................................................................... 43

Figure 4.2: Mafuri prospect interpretive geology................................................................................... 45

Figure 4.3: Rotret prospect interpretive geology ................................................................................... 46

Figure 4.4: Gafal prospect interpretive geology .................................................................................... 47

Figure 4.5: Matukia Prospect Interpretive Geology .............................................................................. 48

Figure 4.6: Layout for Stage 1 mining, showing preliminary surface water management design ........ 52

Figure 4.7: Layout for Stage 2 mining, showing preliminary surface water management design ........ 53



U3823_Marampa_ESIS_Final.docx



September 2012

Page vii of ix



SRK Consulting



Marampa Iron Ore Project ESIS – Table of Contents



Figure 4.8: Layout at end of mine, showing backfilled pits and preliminary surface water management

design .......................................................................................................................... 54

Figure 4.9: Schematic process flow diagram for Stage 1 .................................................................... 59

Figure 4.10: Schematic process flow diagram for Stage 2 (full development) ..................................... 60

Figure 4.11: Beneficiation plant layout for Stage 1 ............................................................................... 62

Figure 4.12: Beneficiation plant layout, showing Stage 2 expansion ................................................... 63

Figure 4.13: Site layout for end of mine showing locations of settlement ponds and water storage

reservoir ....................................................................................................................... 68

Figure 4.14: Proposed organisation chart for operations...................................................................... 75

Figure 5.1: Low lying swamp area previously used as rice paddy field ................................................ 81

Figure 5.2: River basin to the north west of the Project area ................................................................ 82

Figure 5.3: Topography of Sierra Leone (red symbol indicates Project location) ................................. 82

Figure 5.4: Automatic meteorological station at the MIOL site office ................................................... 86

Figure 5.5: Catchments in the Project area .......................................................................................... 88

Figure 5.6: Measurement of depth to water table using a dip meter .................................................... 89

Figure 5.7: Locations of groundwater and surface water monitoring points ......................................... 91

Figure 5.8: Soil sampling using hand auger.......................................................................................... 92

Figure 5.9: Soil and sediment sampling locations ................................................................................ 93

Figure 5.10: Air quality and noise monitoring locations ........................................................................ 96

Figure 5.11: Photographs of terrestrial habitats within the study area ............................................... 100

Figure 5.12: Distribution of terrestrial habitats across the study area ................................................ 101

Figure 5.13: Photographs of aquatic habitats within the study area ................................................... 104

Figure 5.14: Distribution of aquatic habitats across the study area and locations of baseline and

biomonitoring sampling sites ..................................................................................... 105

Figure 5.15: Impacts on streams due to road construction on neighbouring concession area .......... 107

Figure 6.1: Location of villages covered under household survey and rural livelihoods study ........... 109

Figure 6.2: Photographs of different agricultural methods .................................................................. 112

Figure 6.3: Photographs of different crops.......................................................................................... 113

Figure 6.4: Photograph of crops fenced against livestock .................................................................. 114

Figure 6.5: Photographs of different fishing related activities ............................................................. 115

Figure 6.6: Photograph of medicinal plants and plants used for construction .................................... 116

Figure 6.7: Photographs of different types of traps ............................................................................. 117

Figure 6.8: Photographs of sand mining ............................................................................................. 118

Figure 6.9: Photographs of value addition to crops ............................................................................ 119

Figure 6.10: Photographs of artisanal work ........................................................................................ 121

Figure 6.11: Traditional houses .......................................................................................................... 123

Figure 6.12: Examples of educational facilities ................................................................................... 125

Figure 6.13: Location of archaeological and cultural heritage sites in the study area ........................ 128

Figure 7.1: Catchment areas affected by surface water diversion and storage infrastructure, indicating

flow directions ............................................................................................................ 148

Figure 7.2: The invasive alien plant Chromlaena odorata (Triffid Weed) ........................................... 162

th

Figure 9.1: Maximum predicted 98 percentile PM10 concentrations over the Project area, without

management.............................................................................................................. 192

th

Figure 9.2: Maximum predicted 98 percentile PM10 concentrations over the Project area, with

management.............................................................................................................. 193

Figure 9.3: Noise contour map at day time for 100 Mtpa mining rate, relative to local villages ......... 201

Figure 9.4: Noise contour map at night time for 100 Mtpa mining rate, relative to local villages ....... 202

Figure 11.1: Types of obligations relevant to the ESMS ..................................................................... 221



List of Technical Appendices

A



SUMMARY OF APPLICABLE LEGISLATION AND INTERNATIONAL

GUIDELINES ....................................................................................................A-1



B



SLEPA APPLICATION FORM AND SUPPORTING CORRESPONDENCE ...B-1



C



STAKEHOLDER ENGAGEMENT PLAN .........................................................C-1



D



RESETTLEMENT FRAMEWORK ....................................................................D-1



U3823_Marampa_ESIS_Final.docx



September 2012

Page viii of ix



SRK Consulting



Marampa Iron Ore Project ESIS – Table of Contents



E



PRELIMINARY PROJECT DESIGN DRAWINGS ............................................ E-1



F



ENVIRONMENTAL MANAGEMENT PROGRAMME ....................................... F-1



G PRELIMINARY

ENVIRONMENTAL

AND

SOCIAL

MONITORING

PROGRAMMES .............................................................................................. G-1

H



MIOL POLICIES ...............................................................................................H-1



VOLUME 3: SUPPORTING DOCUMENTATION

1

2

3

4

5

6

7

8

9

10

11

12

13



SD 1: Terms of Reference for Specialist Studies

SD 2 A: Climate and Air Quality Baseline

SD 2 B: Impact Modelling Reports

SD 3 A: Noise Baseline

SD 3 B: Impact Modelling Reports

SD 4 A: Biodiversity Baseline

SD 4 B: Aquatic Bio-Monitoring Report

SD 5: Soils and Geomorphology Baseline Report

SD 6: Geochemistry ARDML Baseline Report

SD 7: Water Reasources Baseline and Impact Assessment Report

SD 8: Archaeology and Cultral Heritage Baseline Report

SD 9: Socio-Economic Baseline Report

SD 10: Natural Resource Use/Rural Livelihoods Baseline Report



U3823_Marampa_ESIS_Final.docx



September 2012

Page ix of ix



SRK Consulting (UK) Limited

5th Floor Churchill House

17 Churchill Way

City and County of Cardiff

CF10 2HH, Wales

United Kingdom

E-mail: enquiries@srk.co.uk

URL: www.srk.co.uk

Tel:

+ 44 (0) 2920 348 150

Fax: + 44 (0) 2920 348 199



MARAMPA IRON ORE PROJECT ENVIRONMENTAL AND SOCIAL

IMPACT STATEMENT - VOLUME 2

1



INTRODUCTION

SRK Consulting (UK) Ltd (“SRK”) has been commissioned by Marampa Iron Ore (S.L.)

Limited (“MIOL”) to undertake an Environmental and Social Impact Assessment (“ESIA” 1) for

the Marampa Iron Ore Project (the “Project” or “MIOP”) that meets the requirements of

Environment Protection Agency Act No. 11 of 2008. This environmental and social impact

assessment statement (“ESIS”) is the documented findings of the ESIA process.

The Project is located near the township of Lunsar, some 90 km northeast of the capital city of

Freetown, in the Port Loko district of Sierra Leone, West Africa. The Project comprises

Exploration Licences, EL46/2011 A and B, held by MIOL, which cover an area of 305.12 km2.

EL46/2011 A encloses (but excludes) Mining Lease ML02/09 (13.82 km2) held by London

Mining plc, as shown on Figure 1.2. ML02/09 contains the former Sierra Leone Development

Company Ltd (“DELCO”) open pit mining operation (see Section 1.4 for background on mining

in the area). The Project involves the open pit mining and beneficiation 680 Mt of iron ore from

four resource deposits in the MIOL exploration licence area.

MIOL are in an early stage of Project planning (engineering scoping) and acknowledge the

importance of addressing environmental and social issues early in the planning process. The

ESIA process has therefore been initiated at this early stage to maximise the opportunity for

interactions between the ESIA and Project design teams, and to provide sufficient time for the

collection of suitable environmental and social baseline information as input to the ESIA

process and ongoing Project design.



1.1



Project setting

The Project is located in Sierra Leone, West Africa (refer to Figure 1.1). The site is

approximately 90 km northeast of the capital Freetown near the town of Lunsar in the Port

Loko District on the coastal plain of Sierra Leone (see regional setting in Figure 1.2). The

region around the Project area is relatively flat and low-lying at a height of approximately 5090 m above sea level (“masl”). The exploration area is characterised by two main drainage

regimes; the Rokel River in the south flows from east to west and the north is drained to the

west by tributaries of the Port Loko Creek. The country has a tropical savannah climate with

distinct wet and dry seasons. The dry season lasts from December to mid-February, changing

to wetter and warmer conditions in mid-February to April, and the rainy season stretches from

May to December.



1



The abbreviation ESIA is one of several commonly used terms for impact assessment. Another frequently used abbreviation,

“EIA” (environmental impact assessment), has been adopted by the Sierra Leone legislation. The term ESIA is used herein to

emphasize the inclusion of social aspects in the impact assessment (environmental and social impact assessment). The ESIA

is equivalent to the EIA referred to in the Sierra Leone requirements summarized below. The definition of the word

“environment” given in the EPA Act implies that it includes social aspects.

Group Offices:

Registered Address: 21 Gold Tops, City and County of Newport, NP20 4PG,

Wales, United Kingdom.

SRK Consulting (UK) Limited Reg No 01575403 (England and Wales)



Africa

Asia

Australia

Europe

North America

South America



SRK Consulting



Marampa Iron Ore Project ESIS – Main Report



Figure 1.1: Location of the Project site within Sierra Leone



Sierra Leone is part of the westernmost part of the upper Guinean lowland forest, which is rich

in terms of biodiversity. The natural habitat type for the coastal plain of Sierra Leone is

savannah, however the biological environment around the study area is characterised by a

highly disturbed environment with significant anthropogenic influences such as slash and burn

and subsistence agriculture. These activities have resulted in a prevalence of secondary

vegetation growth and a lack of undisturbed habitats.

In the Project area, the traditional economic activities are agriculture (largely subsistencebased), charcoal making, animal husbandry, fishing, and trading. Mining is emerging as an

additional employment sector due to presence of MIOL, African Minerals Limited (“AML”) and

London Mining plc (“London Mining”), the latter of which recently commenced operations at

the end of 2011.

The largest town in the Port Loko District is Lunsar, in which MIOL’s local office is located.

The population of the town has significantly increased in recent years due to the influx of

people from surrounding rural areas, thought to be due to the arrival of mining companies in

the area. A number of villages surround Lunsar. The houses in the villages are largely built

out of mud with palm leaf or corrugated iron roofs. Most villages have a hand-pump well for

water supply, but do not have a formal drainage system.



U3823_Marampa_ESIS_Final.docx



September 2012

Page 2 of 244



SRK Consulting



Marampa Iron Ore Project ESIS – Main Report



Figure 1.2: Regional setting for the Project site, showing exploration license numbers

U3823_Marampa_ESIS_Final.docx



September 2012

Page 3 of 244



SRK Consulting



Marampa Iron Ore Project ESIS – Main Report



A culturally important feature of the local communities is the presence of traditional secret

societies. These are ancient cultural institutions in the Upper Guinea Coast of West Africa that

remain a key element in political relations in rural Sierra Leone (UNHCR, 2007). Society

rituals are often performed in dedicated areas of forest called “society bush” having restricted

access for non-society members.

The natural environment is also an important livelihood resource in terms of food, construction

materials, firewood and medicine.



1.2



Project proponent

The Project is owned by MIOL, a wholly owned subsidiary of Marampa Iron Ore Limited (a

Bermudan registered private company), which is a wholly owned subsidiary of Cape Lambert

Resources Limited (“Cape Lambert”). Cape Lambert is an Australian domiciled public

company with interests in a number of resource Projects and companies with mineral assets

located in Australia, Africa, Greece and South America. Cape Lambert’s stock is listed on the

Australian Stock Exchange with ticker “CFE”.

Proponent details are provided in Table 1-1:

Table 1-1: Project Proponent Details



1.3



Responsible person:



Jack Rowley



Position:



Project Director



Contact numbers:



Mobile : +61 422 043 125

Office : +61 8 9380 9555

Fax : +61 8 9380 9666

Email : JackR@capelam.com.au



Address:



32 Harrowgate Street

West Leederville WA 6007

PO Box 144 West Perth WA 6872



ESIA team

The Project’s ESIA team is largely made up of staff from a number of SRK’s global offices

(UK, South Africa and Turkey practices), as well as specialists from various other

consultancies. The key team members and their roles are outlined in Table 1-2. SRK is the

overall Project manager for the ESIA process and has: provided reporting expertise; given

insight on interpretation of the relevant guidelines and standards; and co-ordinated liaison

with the Project’s client and engineering teams. Where possible, in-country expertise has

been used for logistical support, ongoing water, climatic and air quality monitoring,

identification of vegetation and interviewing communities during the natural resource use

survey, and assistance with stakeholder consultations (in particular with regulatory authorities

and local communities).



U3823_Marampa_ESIS_Final.docx



September 2012

Page 4 of 244



SRK Consulting



Marampa Iron Ore Project ESIS – Main Report



Table 1-2: ESIA Team Members

Company



Name



Role in ESIA Process



Qualifications/Experience



Fiona Cessford



Project manager



MSc, Pr.Sci.Nat., Corporate Consultant

(Environment)



Nicola Rump and

Steve King



Project co-ordinators



MSc , Consultant (Environmental)

MSc, Senior Consultant (Environmental)



Lalit Kumar



Socio-economic study and

stakeholder consultation.



BA (Sociology), MA (Development

Planning and Administration)



Hilde van

Vlaederen



Socio-economic study

reviewer



PhD (social psychology), Principal

Consultant (Social)



Bora Arpacioglu



Noise baseline

characterisation



MSc, ME, Principal Environmental

Engineer



Matt Dey



Geochemistry (ARDML)

characterisation



Principal Consultant (Geochemical

Engineering)



Vis Reddy



Air quality baseline

characterisation and

predictive modelling



MSc (Environmental Geochemistry),

Pr.Sci.Nat., Principle Consultant



Ruth Warrender



Soils and geomorphology

characterisation



PhD; Consultant (Geochemistry)



Tony Rex



Water resources study

and predictive modelling

team leader



PhD, C.Geol FGS, Corporate Consultant

(Hydrogeology)



Jeff Hamilton



Engineering liaison and

reviewer



General Manager



Steve Kesler



Reviewer



CEO



Jack Rowley



ESIA client manager and

reviewer



Project Director



Local MIOL staff

members



Support water resources

study team through

ongoing water monitoring



Trained and supervised by T. Rex of SRK



Local MIOL staff

members



Management of on-site

weather station



Trained and supervised by T. Rex of SRK



Aminata Kamara



Support social team with

stakeholder engagement

and social survey data

collection;

Manage field survey

teams



Bachelor of Social sciences degree and

over 10 years’ experience in mining and

infrastructure Projects in Sierra Leone



Mr A.M.B. Feika



Identification of vegetation

and assistance with

surveys for Natural

Resource Use study.



Chief Technician - Department of Biological

Sciences, Njala University; Sierra Leone

national museum curator.



Nexus Heritage



Gerry Wait



Archaeology and cultural

heritage baseline study



FSA, DPhil, MIfA



Ecorex

Consulting

Ecologists



Warren

McCleland



Ecological baseline study



Terrestrial ecologist with 14 years’

experience.



Tepid

Consultants



Robert Palmer



Ecological baseline study

(Aquatic components)



PhD (aquatic ecology) and 20 years’

experience.



Jenny Wong;

Bryan Dickinson



Natural Resource Use

study team



PhD, study team leader; BSc, MPhil;



SRK



MIOL



Sierra Leone

consultants



Wild Resources

Limited



U3823_Marampa_ESIS_Final.docx



September 2012

Page 5 of 244



SRK Consulting



1.4



Marampa Iron Ore Project ESIS – Main Report



Project background

The area around Lunsar was the focus of significant mining operations run by DELCO

between 1933 and 1975. This mining operation, which is located within ML02/09, mined both

the lateritic cap from Masaboin and Gafal Hills, and the underlying specular hematite schists.

The specular hematite was concentrated by crushing, coarse grinding and gravity separation,

with production reaching approximately 2.5 million tonnes per annum (“Mtpa”) of concentrate

in the late 1960s (Cape Lambert, 2009). DELCO constructed a railway and port loading

facility at Pepel Port for transport of the product to worldwide markets.

During the DELCO period of operation, a large community was established in connection with

the mine, which included hospitals, schools, community hall and sports facilities for

employees and the local community. The health centre was a recognised training centre for

student nurses and an apprentice scheme for boys was also established. The Delco mining

operation closed in 1975, following a drop in iron ore prices, resulting in significant job losses.

Smaller-scale operations began again in 1981, which involved dredging of the tailings by

Austrian company, Austromineral GMBH. This operation was abandoned in 1985 due to

increasing production costs.

Recent exploration by MIOL identified six priority areas prospective for specular hematite

schist mineralisation (Figure 1.3):





Gafal Prospect (including Gafal South and West) - an area comprising gravity high and

scattered magnetic high anomalies located immediately to the west of the old Gafal Hill

mining area and abutting ML02/09;









Matukia Prospect - an area 1.5 km long covering a gravity high located immediately

along strike to the north of the old Masaboin Hill mining area abutting ML02/09;

Makambo Prospect - located approximately 8km north of the town of Lunsar;







Mafuri Prospect - a gravity high located approximately 3 km west of Gafal;







Rotret Prospect - a gravity high located approximately 1.5 km south of Gafal;







Toma Prospect - approximately 7 km south of Lunsar and south of the Rokel River. The

presence of hematite schist was confirmed in old prospecting pits during initial field

reconnaissance in early 2009.



Of the six priority areas, MIOL is currently focussing on the development of the Gafal, Rotret,

Mafuri and Matukia Prospects for the current ESIA and mining licence application.

An environmental and social reconnaissance survey was carried out by SRK in June 2009.

The objectives of the survey were to assess the current environmental and social conditions

of the Project area and to identify specific aspects that may require particular consideration

during the development of the Project. This survey was considered to be a pre-ESIA activity,

but it collected useful information for the scoping process (the first stage of the ESIA process).

The survey concluded there was little existing environmental and social data available for the

area likely to be affected by the Project and site-specific information would be required as the

Project progresses for both engineering and environmental purposes.



U3823_Marampa_ESIS_Final.docx



September 2012

Page 6 of 244



SRK Consulting



Marampa Iron Ore Project ESIS – Main Report



Figure 1.3: Interpretive geology of EL46/2011, relative to initial Project layout



2



2



Source: Cape Lambert, 2011



U3823_Marampa_ESIS_Final.docx



September 2012

Page 7 of 244



SRK Consulting



Marampa Iron Ore Project ESIS – Main Report



Due to the presence of historic mining activities close to the geological target areas, a longterm baseline monitoring programme commenced so that the pre-disturbance water, sediment

and soil quality status in the area potentially affected by the Project could be fully

characterised, as these may have been negatively affected by the previous mining activities.

Social issues such as land ownership, compensation and in-migration were also highlighted

as issues requiring particular consideration as the Project progressed.

Following the outcome of the survey, SRK commenced the Environmental Scoping Study

(“ESS”) in June 2010, which progressed to a full ESIA process in January 2011.



1.5



Project motivation

A preliminary mining scoping study conducted by Bateman Engineering Pty Ltd (“Bateman”)

concluded that mining at a capacity of up to 15Mtpa is technically feasible, and financial

estimates to date are positive. The Project Mineral Resource is estimated at 680 million

tonnes with an in-situ grade of 28.2% Fe (15% Fe cut-off grade) and, with processing, could

generate a high quality saleable iron concentrate (~65% Fe), with low levels of deleterious

elements.

Access to existing rail and port infrastructure, which was recently upgraded and returned to

operation by AML, has the advantage of lower capital investment start-up costs and Project

lead time, as well as significant environmental advantages, as opposed to construction of a

new port and rail. Open pit mining is the preferred mineral extraction method, further reducing

capital development costs.

As the area currently experiences high unemployment rates and has little or no infrastructural

development, through appropriate management, there is potential for local communities to

benefit from the Project through direct and indirect employment and development

opportunities. Much of the Project footprint area has been disturbed through both previous

mining and subsistence agriculture, and therefore is not ecologically pristine, reducing its

conservation value and the likely environmental impact.



1.6



Structure of the report

The ESIS is presented in three volumes; the structure and content of the three volumes is

described in Table 1-3. Information contained within this main report (Volume 2) aims to be

concise with supporting technical information presented as Supporting Documents (“SD”) in

Volume 3. A glossary of terms is presented at the end of the report and gives an explanation

of the main terms used throughout the report.

Table 1-3: Structure of the ESIS

Volume



Short Description



Volume 1



Non-Technical Summary



Non-Technical Summary



A non-technical summary of the ESIA process and main conclusions

Information aims to be concise and easily understood by all interested

parties.



Volume 2



Environmental and Social Impact Statement



Chapter 1: Introduction



Gives general information about the Project and its proponent.



Chapter 2: Environmental

and Social Regulatory

Framework



Outlines the legislative and regulatory requirements of Sierra Leone, as

relevant to the Project, along with reference to international standards

also considered during the study.



U3823_Marampa_ESIS_Final.docx



September 2012

Page 8 of 244



SRK Consulting



Marampa Iron Ore Project ESIS – Main Report



Volume



Short Description



Chapter 3: ESIA Objectives

and Process



Provides an overview of the objectives of the ESIA and the process

undertaken including the scope of work, baseline studies, impact

assessment process, and public consultation and disclosure

requirements. It includes the assumptions and limitations that have been

recognised in the preparation of this ESIA.



Chapter 4: Project

Description



Describes the proposed Project, including the mine development,

processing, tailings management, power generation, water supply,

transport, waste management and other associated infrastructure.



Chapter 5: Bio-physical

Baseline Description



Describes the existing condition of the physical and biological

components of the environment in relation to international and Sierra

Leone environmental standards.



Chapter 6: Socio-economic

Baseline Description



Describes the current social and economic conditions in the regional and

local area, with reference to conditions in Sierra Leone as a whole.



Chapter 7: Bio-physical

Impact Assessment



Identifies and evaluates bio-physical impacts likely to arise as a result of

the Project in relation to sensitive natural and human receptors, and

determines the overall significance of each impact. It includes

identification of appropriate management measures.



Chapter 8: Socio-economic

Impact Assessment



Identifies and evaluates the socio-economic impacts including

identification of appropriate management measures.



Chapter 9: Community

Health and Safety Risks



Summarises the potential health and safety risks to local communities as

a result of the Project, and identifies appropriate management measures.



Chapter 10: Cumulative

Impacts



Discusses potential cumulative impacts resulting from other

developments in the area as well as future phases of the Project.



Chapter 11: Environmental

and Social Management

System



Provides a framework for the environmental and social management

system that will need to be implemented in response to the impacts

identified in Sections 7 and 8. It provides an environmental and social

management plan, and includes a monitoring programme and the

Stakeholder Engagement Plan (SEP) for the Project.



Chapter 12: Conclusions



Summarises the key findings and outcomes of the ESIA process.



Chapter 13: References



Contains references to documentation and other sources of information

that were used in this ESIS.



Appendices



Includes appendices for the main body of the report



Appendix A



Summary of applicable legislation and international guidelines



Appendix B



SLEPA application form and supporting correspondence



Appendix C



Stakeholder Engagement Plan and supporting information



Appendix D



Resettlement Framework



Appendix E



Preliminary Project design drawings



Appendix F



Environmental Management Plan



Appendix G



Preliminary Monitoring Programmes



Appendix H



MIOL policies



Volume 3



Supporting Documents



SD 1: Terms of Reference

for Specialist Studies



Defines both general and study-specific Terms of Reference (ToR)

provided to the specialists and on which their respective studies were

based.



SD 2: a) Climate and Air

Quality Baseline and b)

Impact modelling reports



Characterises the current air quality on site (baseline) and predicts (via

modelling) potential impacts on air quality resulting from the Project.



SD 3: a) Noise Baseline

and b) Impact modelling

reports



Characterises the current noise levels on site (baseline) and predicts (via

modelling) potential noise impacts on surrounding communities resulting

from the Project.



SD 4: a) Biodiversity

Baseline and b) Aquatic

Bio-monitoring Report



Characterises the present ecological state (baseline) of the Project area

and indicates existing impacts, sensitive habitats and species of special

concern.



SD 5: Soils and

Geomorphology Baseline

report



Characterises and comments on the soil quality for the study area

relative to relevant quality guidelines and average crustal abundance.



U3823_Marampa_ESIS_Final.docx



September 2012

Page 9 of 244



SRK Consulting



Marampa Iron Ore Project ESIS – Main Report



Volume



Short Description



SD 6: Geochemistry

ARDML Baseline report



Characterises the expected tailings, waste rock and ore product with

regard to predicted acid generation and mineral leaching properties



SD 7: a) Water Resources

Baseline and b) Impact

Assessment report



Characterises the current water quality and flow dynamics (both surface

and ground water), and makes predictions (via modelling) regarding

potential impacts on water resources



SD 8: Archaeology and

Cultural Heritage Baseline

report



Identifies and maps sites of cultural heritage importance within the study

area and makes recommendations for further work required (Phase 2

assessment) should the Project be authorised.



SD 9: Socio-economic

baseline report.



Summarises the current social and economic status of the area in the

local and regional context, and provides background on Sierra Leone as

a country.



SD 10: Natural Resource

Use / Rural Livelihoods

baseline report.



Identifies, characterises and (where possible) maps the plant and animal

species used by local communities and describes agricultural and

harvesting practices, including information on seasonality.



U3823_Marampa_ESIS_Final.docx



September 2012

Page 10 of 244



SRK Consulting



2



Marampa Iron Ore Project ESIS – Main Report



ENVIRONMENTAL AND SOCIAL REGULATORY FRAMEWORK

This chapter summarises the environmental and social regulatory framework for the Project,

with an emphasis on requirements relating to the impact assessment process. Section 2.1

presents a brief summary of the legal/regulatory requirements of Sierra Leone and Section

2.2 describes international guidelines and standards that were referred to in the preparation of

this report. Further detail on the applicable legislation and international guidelines

summarised below and considered when preparing this ESIS is provided in Appendix A.



2.1



Sierra Leone requirements

Key Sierra Leone legislation pertinent to the environment and to sustainable development

considered in the planning of the Project is listed in Table 2-1. The legislation most relevant

to the ESIA process is:





the Environment Protection Agency Act No. 11 of 2008 (EPA Act 2008); and







the Mines and Minerals Act 2009.



A brief outline of the relevant requirements of these two Acts is presented in Sections 2.1.1

and Section 2.1.2, respectively, with more detail given in Appendix A. Environmental and

social permissions needed by the Project are identified in Section 2.1.3.

Table 2-1: Sierra Leone environmental and sustainable development legislation

Primary subject



Policy



Legislation



Environment and

sustainable

development



National Environmental

Policy (1994)







The Environment Protection Agency Act, 2008

(No. 11 of 2008)



Mineral resources

and mining



Core Mineral Policy of the

Government of Sierra

Leone (2008)







National Reconstruction and Development Act,

1999 (No. 5 of 1999)

Mines and Minerals Act, 2009



Water



National Water and

Sanitation Policy (August

2008)









The Water (Control and Supply) Act, 1963

Sierra Leone Water Company Act, 2001 (No. 6

of 2001)



Biodiversity and

biological

resources



National Biodiversity

Strategy and Action Plan

(developed in accordance

with the requirements of

the 1992 Convention on

Biodiversity)







Wildlife Conservation Act, 1972 (No. 27 of 1972)







Forestry Regulations, 1989 (P.N. No. 17 of

1990)

Forestry Act, 1988

Devolution of Estates Act, 2007 (No. 21 of

2007)

Land Commission Act (not promulgated yet)

Commercial Lands Act (not promulgated yet)

Protection from Radiation Act, 2001 (No. 14 of

2001)

The Factories Act, 1974 (1974)



Forestry



Land



National Lands Policy

(2005)



Radiation



2.1.1



















Occupational

environment







Local government







Local Government Act, 2004 (2004): An Act

which provides for decentralisation and

devolution of functions, powers and services to

local councils.



ESIA/ EIA requirements in the EPA Act 2008

The EPA Act 2008 forms the legal basis for environmental management and protection in

Sierra Leone. It provides for the establishment of an Environment Protection Agency (“EPA”



U3823_Marampa_ESIS_Final.docx



September 2012

Page 11 of 244



SRK Consulting



Marampa Iron Ore Project ESIS – Main Report



or “SLEPA”), which 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 governing body of the EPA is a Board of

Directors, which comprises a chairman and senior representatives of several ministries with

an interest in environmental matters and people knowledgeable in commence, finance and

law.

The EPA Act requires EIA licences to be obtained for Projects with the potential to have

significant impacts. The Act charts the procedure to obtain an EIA licence, with emphasis on

the responsibilities of the EPA and the EPA Board, as outlined below.





An application must be made to the EPA for a licence, accompanied by a description of

the proposed Project (refer to Appendix B for Application and Screening Forms

th

submitted to SLEPA, dated 17 August 2010) .







The EPA will decide (within 14 days) whether an EIA is required.







If required, the applicant should then prepare an EIA (refer to Appendix B for

th

correspondence from SLEPA dated 20 August 2010, in which it is confirmed that an EIA

is required).







On receipt of the EIA, the EPA will circulate it to professional bodies or associations,

Government Ministries and non-governmental organisations (“NGOs”) for review.







The EPA will also open the EIA for public inspection and comment. It 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 EIA, together with the EIA, to the Board for

consideration.







If the Board approves the EIA, it will instruct the Executive Director of the EPA to issue

an EIA licence.







The EPA will issue a licence to undertake the activity/ Project. An EIA licence will have a

period of validity and contain conditions for the protection of the environment.



The EIA licence procedure presented in the EPA Act 2008 appears to be the same as that

presented in the repealed Environment Protection Act 2000, except that the agencies

responsible for implementation of the EIA provisions have changed. Guidelines on EIA

procedures were published by the MLCPE in July 1999. The same guidelines were re-issued

by the MLCPE in July 2002.

The guidelines were originally intended to facilitate

implementation of the EIA provisions in the old Environment Protection Act 2000 and are

currently considered by the MLCPE to be valid for the EIA provisions in the new EPA Act,

2008. A summary of the EIA procedure to be followed in terms of the MLCPE guidelines is

presented in Appendix A.



2.1.2



ESIA/ EIA requirements in terms of the Mines and Minerals Act 2009

The Ministry of Mineral Resources (“MMR”) controls mining and mining-related matters by

means of the Mines and Minerals Act 2009. This Act replaces the Mines and Minerals Act

1994 and puts more emphasis on protection of the environment, community development and

health and safety.

The Act requires an application for a large-scale mining licence be accompanied by:





an EIA licence issued by the EPA and the corresponding EIA and environmental

management programme (“EMP”);



U3823_Marampa_ESIS_Final.docx



September 2012

Page 12 of 244



SRK Consulting



Marampa Iron Ore Project ESIS – Main Report







a list of interested and affected parties, including land owners and occupiers of the area,

and details of public consultation; and







proposals for the progressive reclamation and rehabilitation of land disturbed by mining

(Article 106).



The EMP will become legally binding and will be attached to the mining licence. Compliance

with the EMP will be included in the terms and conditions of the licence (Article 110).

Additional conditions relating to rehabilitation could also be included in the conditions of the

licence (Article 136).

Specifications for the EIA, EMP and public consultation are given in a part of the Act

dedicated to Environmental Protection (Part XV, Sections 131 and 137). Reports on progress

in the implementation of the EMP must be submitted to the MMR annually (Article 134).

Financial assurance is required to provide for obligations originating from the EIA and EMP

(Article 136).

There are several other provisions in the Act that were considered during the ESIA process.

These are summarised below.



2.1.3







The Act creates an obligation on large-scale mining licence holders to promote

community development and it establishes the framework through which companies and

communities enter into formal agreements (Part XVI, Articles 138 to 141). Licence

holders are obliged to comply with community development agreements (Article 115).







The Act promotes preferential employment of citizens of Sierra Leone, as well as

preferential procurement of goods and services from Sierra Leone. Relevant sections of

the Act include Articles 106, 163 and 164. An application for a mining lease must be

accompanied by proposals to achieve this. Commitments made in these proposals will

become legally binding by means the terms and conditions of the mining licence (Article

110).







Land tenure and compensation for disturbance of surface rights are dealt with in Articles

32 to 38 of the Act. Rural land in Sierra Leone is held by landowning families (extended

families or lineages) with a chieftaincy structure playing a significant administrative and

custodian role. At present, the sale of land is virtually impossible and leasing of land is

challenging because property boundaries have not been surveyed, written deeds do not

exist and both chiefs and recognised representatives of land owning families have to be

involved in decisions on leasing of land (Appendix A). The Act states a holder of a

mineral right must obtain written consents from landowners/ occupiers and/or regulatory

authorities to use land currently used for other purposes. Compensation must be paid in

the event of damage to property and cultivated land.



3



Other environmental and social permissions

A preliminary identification of the environmental and social permissions needed for the Project

was undertaken and these are listed in Table 2-2. Additional permissions may be identified

during the ongoing Project development process as a result of ongoing consultation with

regulatory authorities and as a result of any legal reviews undertaken by MIOL.



3



The term “land tenure” is used here to refer to rights to occupancy and use of a specified area of land.



U3823_Marampa_ESIS_Final.docx



September 2012

Page 13 of 244



SRK Consulting



2.2



Marampa Iron Ore Project ESIS – Main Report



International guidelines and standards considered

Although not legally binding on the Project, the ESIA team took consideration of a number of

international guidelines and standards whilst undertaking the ESIA. These are described

below, and further detail is provided in Appendix A.



2.2.1



Equator Principles, IFC requirements and WBG EHS guidelines

Development financiers can play a major role in the development and enforcement of

sustainable development standards through the conditioning of their loans. A significant

number of these institutions have now signed up to the Equator Principles, which provide a

framework for the assessment and management of environmental and social risks in a Project

by those seeking Project finance. The Principles require observance of the International

Finance Corporation Performance Standards on Social and Environmental Sustainability

(“IFC PS”) and the Environmental, Health and Safety (“EHS”) Guidelines when developing

4

Projects in non-high income OECD countries.

5



The individual IFC PS 2007 are titled:

1: Social and Environmental Assessment and Management System;

2: Labour and Working Conditions;

3: Pollution Prevention and Abatement;

4: Community Health, Safety and Security;

5: Land Acquisition and Involuntary Resettlement;

6: Biodiversity Conservation and Sustainable Natural Resource Management;

7: Indigenous Peoples; and

8: Cultural Heritage.

The EHS Guidelines are technical reference documents with general and industry-specific

examples of Good International Industry Practice (“GIIP”), as defined in IFC's Performance

Standard 3 on Pollution Prevention and Abatement.



2.2.2



Self-regulation in the mining sector

A number of voluntary business charters, codes of conduct/ethics/toolkits and good-practice

guidelines have been generated specifically for the mining industry. Those of particular

relevance to environmental management and sustainable development are:





International Council on Mining and Metals Sustainable Development Framework - which

comprises a set of ten principles, public reporting; and independent assurance;







E3 Plus - a Framework for Responsible Exploration;







the Voluntary Principles on Security and Human Rights;







the Extractive Industry Transparency Initiative; and







the Mining and Metals Sector Sustainable Development Good Practice website.



4



Organization for Economic Cooperation and Development

The IFC PS have recently been reviewed and new standards took effect as of 1 January 2012, however as these were not in

force at the time most of the ESIA work was undertaken, the old PS were the main reference document for the ESIA process.



5



U3823_Marampa_ESIS_Final.docx



September 2012

Page 14 of 244



SRK Consulting



Marampa Iron Ore Project ESIS – Main Report



Table 2-2: Environmental and social permissions needed for the Project

Permission



Relevant legislation (and

corresponding guidelines)



EIA licence







Mineral right: Large-scale mining licence



Environment Protection Agency

Act, 2008

• Guidelines on EIA procedures

published by MLCPE in July

1999

Mines and Minerals Act 2009



Written consent to use land



Mines and Minerals Act 2009



Lease agreements where the holder of a

mineral right requires exclusive use of land.



Mines and Minerals Act 2009



Written permission to disturb classified/

protected forest (Licence for national forest,

permission for community forest)

Licence for clearing of vegetation to develop

mine infrastructure

Licence for clearing vegetation on the banks

of a watercourse (within 1 in 100 year flood

line/ about 30 m of a watercourse)

Clearance authority for clearing vegetation

from land designated as sacred bush.

Water use licences

Discharge permits



Forestry Act 1988

Forestry Regulations 1989



Responsible regulatory

authority/ parties to the

agreement

EPA









MMR



Consent from the owners

or occupants of the land.

Lease agreement

between the holder of

the mineral right and the

owners or occupiers of

the land

The Chief Conservator



Forestry Regulations 1989



Main submissions to be made

Screening form - submitted at the screening stage (refer

to Appendix B).

An ESIS (this document) to obtain an EIA licence.



Mining lease application accompanied by:

• an EIA licence and corresponding EIA and EMP;

• a list of interested and affected parties, including land

owners and occupiers of the area, and details of public

consultation; and

• proposals for rehabilitation of land disturbed by mining;

• proposals and a programme for preferential

employment and training of citizens of Siena Leone;

• proposals with respect to the procurement of goods and

services obtainable within Sierra Leone.

Not specified.

Not specified.



Not specified.



Forestry Regulations1989



An inspector of the

Forestry Division

Division inspector



Not specified.

Not specified.



Forestry Regulations, 1989



The Chief Conservator



Not specified.



None (see water legislation in

Appendix A)



U3823_Marampa_ESIS_Final.docx



September 2012

Page 15 of 244



SRK Consulting



3



Marampa Iron Ore Project ESIS – Main Report



ESIA OBJECTIVES AND PROCESS

This chapter describes the objectives of the ESIA (Section 3.1), the study area considered

during the ESIA process (Section 3.2), the activities carried out (Section 3.3) and the

assumptions and limitations of the study (Section 3.4).



3.1



Objectives

The overall objectives of the ESIA process are to:





identify issues and concerns regarding the proposed Project that need to be addressed;







identify national, international and corporate management requirements which the

Project must satisfy;







gather and evaluate baseline information to characterise the affected environment and

communities;







undertake consultation with stakeholders and promote full disclosure of information and

transparency in regard to the Project;







identify, define and evaluate environmental and social impacts so that the potentially

significant impacts can be adequately addressed during Project design;







develop a framework management system that sets out key management and monitoring

objectives for the life of the mine that can be further developed and implemented by

MIOL and any contractors involved;







assess and provide feedback on selected Project alternatives as part of the pre-feasibility

and feasibility phases; and







promote environmentally and socially sustainable development.



This ESIA has been planned and undertaken with due consideration of the legal, regulatory

and policy requirements outlined in Chapter 2. The Third Schedule (Section 26) of the Sierra

Leone EPA Act (2008) provides the specification that an EIA should include a description of

the following aspects. References to the sections in this report where these requirements are

met include:

a)

b)

c)

d)

e)

f)

g)

h)

i)

j)



the location of the Project and its surroundings (Section 1.1);

the principle, concept and purpose of the Project (Section 1);

the direct or indirect effects that the Project is likely to have on the environment

(Chapter 7);

the social, economic and cultural effect that the Project is likely to have on people and

society (Chapter 8);

the communities, interested parties and Government ministries consulted (Section

3.3.5);

any actions or measures which may avoid, prevent, change, mitigate or remedy the

likely effect on people and society (Chapter 11);

any alternatives to the proposed Project (Section 4.11);

natural resources in the locality to be used in the Project (Sections 4.6 and 7.2);

the plans for decommissioning of the Project (Section 4.11);

such other information as may be necessary for a proper review of the potential

environmental impact of the Project (Chapter 3 (description of methodology); report

Appendices and Volume 3 Support Documents).



U3823_Marampa_ESIS_Final.docx



September 2012

Page 16 of 244



SRK Consulting



Marampa Iron Ore Project ESIS – Main Report



In line with these objectives, the ESIA process supports the priorities of:



3.2







the Project proponent – including the Project design team, the future operations

management team and shareholders, who wish to develop and operate the Project in

accordance with Sierra Leone law and (where possible) international standards;







the responsible government authorities who will decide whether the Project can be

approved and what conditions of approval should be applied; and







other stakeholders, particularly local communities, who wish to understand the

development proposal and the impacts on their communities and environment.



Study area

The initial ESIA study area consisted of three independent zones representing possible areas

of disturbance, and two corridors linking these areas, as outlined below.





Area 1 (29.3 km ) covers the proposed locations of the processing plant, power

generators and auxiliary infrastructure, staff village, and tailings storage facility, with the

AML rail corridor crossing through the area.







Areas 2 (18.8 km ) and 3 (29.6 km ) cover the geological target zones of Matukia and

Gafal (and the nearby Rotret and Mafuri resource areas), respectively. The waste rock

dumps will be located close to the mining areas within Areas 2 and 3.







Two corridors of 100 m width (approximately 4.6 km ) have been identified for

transportation of the ore (via haul roads) from the mining areas in Areas 2 and 3 to the

processing infrastructure in Area 1.



2



2



2



2



The study areas used for the purposes of the ESIA are shown on Figure 3.1. The figure

indicates that the initial study area was expanded towards the end of the study to incorporate

changes in the Project design.

The scope of the ESIA is restricted to the mining and processing operations, and specifically

excludes third party infrastructure for transportation of the concentrate from the site via rail to

the port, and facilities at the port. The upgrade and operation of these rail and port facilities

has been undertaken by a third party and are not reliant on the feasibility of this Project, and

therefore are not considered to be within the Project’s area of influence.



3.3



ESIA Process

The ESIA comprises the integrated assessment of physical, biological and social

environments potentially affected by the Project. The ESIA process undertaken for the

Project consists of the following four phases: scoping; baseline characterization; impact

assessment and reporting; and review and decision-making. The specific objectives and

activities of these phases are outlined in Table 3-1 and described in the following sections.

Stakeholder consultation is a critical component of the ESIA process and is highlighted in the

table, with further information provided in Section 3.3.5.



U3823_Marampa_ESIS_Final.docx



September 2012

Page 17 of 244



SRK Consulting



Marampa Iron Ore Project ESIS – Main Report



Figure 3.1: Study areas for MIOP ESIA



U3823_Marampa_ESIS_Final.docx



September 2012

Page 18 of 244



SRK Consulting (UK) Ltd



Marampa Iron Ore Project ESIS – Main Report



Table 3-1: MIOP ESIA process

Phases



Main purpose



Main activities



Documents produced



Phase 1: Scoping







Preliminary planning of the ESIA approach and

incorporation of the ESIA plans into the overall

programme.

Initial round of issue identification to define

baseline and specialist investigations required

to support the ESIA process.

Desktop social scan to enable the engagement

process to be planned, followed by the first

round of consultation to share information and

gather issues of concern that might influence

the terms of reference for the ESIA (discussed

further in Section 3.3.5).

Collect background information on the

environmental and social setting of the Project







The ESIA team used a preliminary Project

description from the Project planning team to

determine what specialist studies were likely to

be required.

Scoping-level stakeholder consultation indicated

what issues were of concern. This was used to

refine the terms of reference for specialist

studies.











Baseline specialist investigations







Reports by the specialists



Investigate specific issues raised (by

stakeholders, specialists and the ESIA team).

Define the potential impacts of the Project and

identify measures for the management of the

impacts.

Determine the significance of the potential

impacts with and without management.

Evaluate the overall acceptability of the Project

(from environmental and social perspectives).







Review of available Project information and

information from the scoping exercise and the

baseline investigations.

Discussions with Project engineers to identify

opportunities to eliminate or mitigate impacts

through modification of the Project.

Further specialist investigations of specific

issues.

Impact assessment exercise.

Report compilation.

Consultation with the Project team to develop a

plan that covers:

policies, procedures, practices and action plans

where necessary;

monitoring and evaluation procedures;

resource needs (human and financial);

a management system framework for

implementation of the programme.









Reports by specialists

ESIS







Framework implementation and

management plan.









Phase 2: Baseline

investigations







Phase 3:

Impact assessment

and report compilation













Phase 4: Development

of a detailed

implementation and

management plan











Develop an environmental and social

management system framework for the Project

to ensure that:

the management commitments in the ESIA

report and the conditions of approval are fully

implemented;

there is ongoing improvement in social and

environment performance throughout the life of

the Project.



























U3823_Marampa_ESIS_Final.docx











A stakeholder engagement plan

and stakeholder database

An ESIA scoping report (including

the terms of reference for the

ESIA)

A background information

document for stakeholders

Records of engagement of

stakeholders



September 2012

Page 19 of 244



SRK Consulting



3.3.1



Marampa Iron Ore Project ESIS – Main Report



Phase 1: Scoping activities

“Scoping” is a term conventionally applied by ESIA practitioners to indicate the beginning or

inception phase of an ESIA process. The United Nations Environment Programme (“UNEP”)

environmental assessment training programme (June 2002 and April 2007) explains that the

main purpose of scoping is to identify:





the important issues to be considered in the ESIA;







the appropriate time and space boundaries of the assessment;







the information necessary for decision-making; and







the potential impacts (significant effects) to be studied in detail.



Desktop review and environmental and social scan

An environmental and social scan of the study area was carried out in June 2010. The aim of

the scan was to update the information collected during the reconnaissance survey (Section

1.4.1) and visit the new geological target areas. The scan involved the following activities:





a review of any new information (prepared since June 2009) and maps of the study area;







discussions with staff at the site relating to exploration activities, status of Project

development and community relations; and







general observations of the surrounding biophysical and social environment.



Stakeholder engagement

Following a period of stakeholder identification and analysis, a stakeholder engagement plan

(“SEP”) was developed to guide the stakeholder consultation process. As part of the scoping

consultations, a background information document (“BID”) was prepared and distributed

among stakeholders to help explain the Project and the ESIA process. Preliminary

consultation meetings were held with key Government ministries during July 2010.

Scoping consultations with local communities and other key Project stakeholders were

undertaken in March 2011. Following these meetings, the Terms of Reference (“ToR”) for the

ESIA and specialist studies were reviewed to incorporate stakeholder issues where required.

Preliminary hydrological assessment

A hydrologist visited the site during June 2010 to undertake a preliminary hydrological and

hydrogeological assessment of the study area and to install an on-site meteorological station

(for collection of on-site meteorological data for use during the ESIA). The activities carried

out during this site visit were:





collection and summary of background data and maps from previous studies;







site walk-over with GPS and compilation of surface and groundwater feature inventory;







identification of surface water monitoring sites and measurement of river flow and basic

water chemistry on the Baki, Batabana and Kagbu Rivers at the time of the visit; and







inventory and water-table monitoring of existing boreholes where possible.



Issue identification

During scoping and continuing through the ESIA process, issues on which attention needed to

be focused were identified from the following:





iterative and systematic review of the Project description as it was developed by the

Project team to identify Project aspects that could be possible sources of impacts



U3823_Marampa_ESIS_Final.docx



September 2012

Page 20 of 244



SRK Consulting



Marampa Iron Ore Project ESIS – Main Report



(“aspects” is a term for the “mechanisms” by which Project activities cause environmental

and social impacts);





consideration of the areas of influence;







careful consideration of comments made and concerns raised by stakeholders; and







review of the findings of baseline investigations and specialist investigations.



The main aspects that have been identified are listed in Table 3-2. Identified impacts

associated with these aspects were grouped under issue headings to keep the analysis of

impacts as simple, streamlined and coherent as possible. The issue headings were chosen

considering similarities and links between impacts and management measures required to

address the impacts. The chosen issue headings are given in Table 3-2.

The identified impacts and issues influenced the approach to presentation of information in

this ESIS. The information on the Project description (Chapter 4) and environmental and

social baseline description (Chapters 5 and 6) has been presented in a manner providing a

foundation for the detailed discussion of impacts (Chapters 7, 8 and 9).

Identification and analysis of Infrastructure site alternatives

As part of the ESIA process the ESIA team undertook an analysis of the proposed Project

alternatives for major infrastructure such as the tailings facility and waste rock dump locations.

Project infrastructure site alternatives that are of importance from environmental and/or social

perspectives are discussed in Section 4.11. Decisions taken on site alternatives, and the

factors influencing these decisions, are outlined in the analysis.



3.3.2



Phase 2: Baseline investigations

Baseline studies were performed to provide information on the environmental and social

setting of the Project, characterize the pre-disturbance environment and provide a baseline

against which impacts can be assessed and monitored. A description of the baseline,

including the results of these studies, is provided in Chapters 5 and 6. Baseline study scopes

of work and more detailed information on the baseline studies is contained in Volume 3

(Support Documents).

A list of the specialist studies undertaken for the ESIA is presented in Table 3-3. The baseline

studies were managed by SRK (UK) and undertaken by groups of local and international

specialists in each respective field. The studies were undertaken in accordance with ToR, a

copy of which is included as Support Document 1 of Volume 3, and was provided to SLEPA

prior to commencement. Detailed ToR for each specialist study is provided in the baseline

study reports, which are provided in Volume 3 (Support Documents 2 to 10) of the ESIS.



U3823_Marampa_ESIS_Final.docx



September 2012

Page 21 of 244



SRK Consulting (UK) Ltd



Marampa Iron Ore



Project ESIS – Main Report



Table 3-2: Preliminary impacts identified for the Marampa Project

Aspect group



Aspect



Mechanism



Land transformation



Surface

disturbance at

the mine site;

Topographic

change at the

mine site

(open pit

workings,

waste rock

dumps, and

tailings storage

facilities)



Site clearance within footprint of mine and

associated infrastructure

Construction of open pits, waste rock

dumps and TSF.



Water take



Abstraction for mine supply

Dewatering of workings

Interruption of or changes to surface water

channels to accommodate construction of

mine infrastructure

Seepage from mine and mineral-processing

waste disposal / dirty water holding

facilities;

Uncontrolled discharges (such as during

storm events, spills, leaks etc.);

Wastewater discharges;

Runoff from exposed surfaces (sediment

mobilisation, nitrates from blasting);

Seepage from potential pit lakes formed at

closure

Contamination of water resources;

Abstraction from and changes to flow of

streams



Water

resources



Water

diversion

Discharges

from point and

diffuse sources



Biodiversity

and ecology



Alterations to

natural water

courses

Loss of

indigenous

vegetation



Potential impacts















Alteration of surface water drainage at the

sites of infrastructure



Clearing for mine infrastructure



















Disturbance of sites of archaeological, historic or cultural importance

Loss of land available to local communities

Disruption of tracks and roads by infrastructure (such as fences, water supply pipeline,

haul roads etc.)

Mine infrastructure and activities resulting in visual intrusion and loss of ‘sense of place’

on local communities

Changes to land capability

Habitat loss or fragmentation and direct loss of plants and animals leading to alteration of

ecosystem services

Indirect habitat alteration through colonisation by invasive species

Changes in availability of water to downstream water users and ecosystems

Changes in spatial and temporal patterns of flow, influencing erosion, sedimentation, and

flooding, affecting downstream water users and ecosystems

Interference or reduced availability of water to other users and ecological receptors

Alteration of watercourse flow regimes, resulting in changes to flood patterns, fluvial

processes, erosion, aquatic habitat, ecosystems and ecosystem services

Increase in stream turbidity and siltation, affecting aquatic fauna and flora







Deterioration of groundwater and surface water quality potentially impacting on

communities and ecological systems, for example from increased turbidity from sediment

laden runoff, heavy metal leachate from mine facilities and nutrients from blasting or

sewage treatment etc.

Adverse health effects on the health of humans or animals drinking the water











Loss of natural habitat for aquatic / wetland species

Threat to species of special concern due to loss of habitat

Effects on community usage of rivers (for harvesting of natural resources)











Increase in spread of alien invasive species

Loss of habitat and food sources for indigenous species

Loss of important resource for local communities



U3823_Marampa_ESIS_Final.docx



September 2012

Page 22 of 244



SRK Consulting (UK) Ltd



Marampa Iron Ore



Aspect group



Aspect



Mechanism



Soil quality



Land

Clearance







Erosion of topsoil by wind or surface

water runoff













Construction of

mine buildings

and related

facilities









Loss of agricultural land

Soil compaction









Run-off from

mine facilities







Contaminated stormwater runoff from

exposed surfaces



Point

emissions











Vehicle emissions;

Stack emissions;

Stationary sources (such as

generators, crusher);

Incinerators



Air quality







Potential impacts

















Noise and

vibration



Waste

production

(wastes other

than mine

waste)



Diffuse

emissions







Equipment/

vehicle

operation

Blasting

Domestic,

construction

and

operational

wastes



















Fugitive dust emissions from dry

surfaces (such as TSF, waste rock

dumps, stockpiles and other exposed

areas)

Noise emissions;

Vibrations from blasting and equipment

/vehicles

Litter;

Sewage;

Non-process related industrial wastes;

Hazardous wastes (such as waste oils,

chemicals, spent packaging)



Project ESIS – Main Report











Reduction in protective vegetation cover

Increased potential for soil erosion and sediment mobilisation

Sediment deposition on down-gradient land and in downstream water courses

Increased potential for leaching of soils, increasing iron or zinc concentrations in surface

water runoff

Loss of currently productive and potentially viable land

Decline in crop production, with subsequent pressure on food supplies to local

communities

Reduced soil productivity potential

Degradation of soils within exposed areas and in vicinity of roads and other developed

areas

Potential decline in soil chemical quality and productivity potential

Increase in background concentrations of fine particulate matter (dust) leading to

nuisance and health effects for nearby communities

Increase in background concentrations of gaseous pollutants (such as sulfur dioxide,

nitrogen dioxide and carbon dioxide etc.) potentially causing health risks to nearby

communities

Increase in national (Sierra Leone) contribution of greenhouse gases to global

greenhouse gas concentrations.

Increase in concentrations of course particulate matter leading to nuisance and health

effects for nearby communities







Increased disturbance to nearby sensitive receptors (such as local communities, schools

etc.)

Sensory disturbance resulting in animal displacement













Waste disposal sites resulting in creation of an attractive nuisance to scavenger animals

Contamination of soil and/or water

Degradation of land and health risks associated with the above impacts

Visual and ecological impacts due to uncontrolled dumping of waste



U3823_Marampa_ESIS_Final.docx



September 2012

Page 23 of 244



SRK Consulting (UK) Ltd



Marampa Iron Ore



Aspect group



Aspect



Mechanism



Economic

development



Job creation

Procurement

of services and

supplies







Payment of tax

and levies















Resettlement

and land

acquisition



Community

investment

Land

acquisition

within the

Project site













Direct employment during construction

and operation;

Indirect employment by service

providers and suppliers



Potential impacts













Tax on profits;

Duties on imports;

Payroll tax;

Value added tax

Investment in social development

initiatives

Physical displacement (relocation of



dwellings / villages)



Economic displacement (loss of access

to land used for agriculture, artisanal



mining, natural resources etc.)













Social

organisation



In-migration of

job-seekers to

local villagers









Influx of job seekers to local villages



placing additional pressure on already



limited resources and resulting in social •

ills









Archaeology

and cultural

heritage



Loss of cultural

heritage items

/ areas







Clearing of land for mine infrastructure,

causing loss or disturbance of items /

areas of cultural / heritage importance.



Project ESIS – Main Report













Direct or indirect employment of locals contributing to alleviation of widespread

unemployment and poverty

Skills acquisition through job training

Improved infrastructure and services

Potential for sustainable economic developments

Improved standard of living for local communities through social development initiatives



Involuntary impoverishment – loss of assets, income and livelihood

Loss of access to common property resources (such as wells, boreholes, schools, health

clinics etc.

Loss of access to cultural resources such as sacred bush

Human rights abuses (related to resistance of displacement)

Psychological impacts on individuals manifesting as apathy, helplessness and a sense of

inadequacy

Breakdown of social networks and community cohesion (community disarticulation)

Reduced food security leading to malnutrition and poor health

Civil unrest and instability, particularly between host communities and resettled

population

Exacerbation of inequality

Increased pressure on government services

Development of informal settlements

Increases in social ills (petty crime, alcohol abuse, prostitution, vandalism)

Health deterioration resulting from an increased risk of exposure to disease

Increased pressure on natural resources (such as clearance of land for subsistence

agriculture)

Increased pressure on natural resources such as wood (for fuel) and fauna (increased

bush meat consumption)

Increased cost of living for those not benefiting from the Project

Lack of understanding or appropriate mitigatory / compensatory action by developers,

causing dissatisfaction amongst local communities

Loss of items / areas of heritage importance from communities and society as a whole

Social impacts relating to loss of cultural identity



U3823_Marampa_ESIS_Final.docx



September 2012

Page 24 of 244



SRK Consulting (UK) Ltd



Marampa Iron Ore



Aspect group



Aspect



Mechanism



Closure



Retrenchment

/

Cease of

operations











Loss of employment/business;

Outward migration;

Cessation of taxes, fees and royalties

to government



Potential impacts













ARDML /

contamination

of water or soil









Consumption of contaminated fish,

fauna or forest products

Consumption or use of water from pits

for irrigation or livestock watering



Project ESIS – Main Report







Unemployment and loss of income

Closure of support and service businesses

Outward migration of skilled workers, leaving the elderly and the unskilled behind leading

to the eradication of the consumer base

Psychological impacts on individuals manifesting as apathy, helplessness and a sense of

inadequacy

Erosion of Governments’ revenue base leading to a reduction in the allocation of funds to

the area and subsequently deterioration in quality of life

Health impacts on humans and animals relating to bioaccumulation of heavy metals etc.

in soil and water resources near the mine



U3823_Marampa_ESIS_Final.docx



September 2012

Page 25 of 244



SRK Consulting (UK) Ltd



Marampa Iron Ore Project ESIS – Main Report



Table 3-3: Specialist Studies undertaken during the ESIA

Supporting documentation

reference



Name of study



Source



Climate and Air quality



SRK (South Africa)



ESIA Volume 3, SD 2



Noise



SRK (Turkey) and Eddie Jewel

Acoustics (impact modelling)



ESIA Volume 3, SD 3



Ecology and Biodiversity



Ecorex Consulting Ecologists

and Nepid Consulting



ESIA Volume 3, SD 4



Soils and Geomorphology



SRK (UK)



ESIA Volume 3, SD 5



Geochemistry - Acid Rock Drainage

and Metal Leaching



SRK (UK)



ESIA Volume 3, SD 6



Water Resources



SRK (UK), with in-country

assistance



ESIA Volume 3, SD 7



Archaeology and Cultural Heritage



Nexus Heritage



ESIA Volume 3, SD 8



Socio-economic



SRK (UK), with in-country

assistance



ESIA Volume 3, SD 9



Natural Resource Use



Wild Resources Limited , with

in-country assistance



ESIA Volume 3, SD 10



The general objectives of these bio-physical and social baseline reports are to:





provide an overview of existing available literature relevant to the biophysical and social

characteristics of the area (international, national, regional and local context);







justify the methodology used to undertake the study (sampling, analysis and assessment

tools), highlighting any limitations or assumptions;







provide a description of the existing bio-physical and/or social setting (baseline

conditions);







provide a statement on the conservation importance of each component of the

environment;







identify sensitive natural and human receptors susceptible to impacts arising from

possible Project activities;







bench mark the baseline conditions of the Project-affected area against recognised incountry and international guidelines and standards; and







provide recommendations on further studies that may be required and recommendations

for management and monitoring of the potentially affected environment should impacts

occur.



The scope of baseline study requirements were finalised following consultation with SLEPA,

and have taken into account the issues or concerns raised by stakeholders and the public

during scoping consultations (Section 3.3.5). The baseline study reports will be submitted to

SLEPA as part of the ESIS and can be made available by MIOL to other stakeholders upon

written request.

Where available, Sierra Leone standards and guidelines have been used, supplemented with

the most appropriate international guidelines. However, in most cases appropriate local

guidelines were not available and the specialists used their professional judgement in

selecting the most appropriate international guidelines for their respective studies. In doing so,

consideration was given to similarities in environmental conditions between Sierra Leone and

the country-specific standard to be adopted (unless the standard is not country-specific, such

as standards developed by the World Health Organisation or IFC).

U3823_Marampa_ESIS_Final.docx



September 2012

Page 26 of 244



SRK Consulting (UK) Ltd



Marampa Iron Ore Project ESIS – Main Report



Each of the baseline study reports (included in Volume 3 and summarised in Chapters 5 and

6) specified which standards or guidelines were used for that particular study. It is noted that

these guidelines are not legally binding but merely intended for reference purposes. Using the

baseline conditions measured on site, site-specific criteria for acceptable limits may be

devised for the Project if required at a later stage.



3.3.3



Phase 3: Impact identification and definition

Starting in the scoping phase and refined throughout the ESIA process, specific aspects of

the Project are identified that may give rise to impacts, positive or negative. Impact definition

is iterative throughout the ESIA process and generally entails developing a description of the

aspect, pathway and receptor that comprise the impact, as outlined below (social impact may

require a different approach – discussed further below):





aspect is the mechanism by which Project activities may cause impacts (for example,

gaseous emissions to the atmosphere or effluent discharges to a water body);







receptor is a person, natural ecosystem, structure or infrastructure system that

experiences the impact; and







pathway is the mechanism by which the aspect affects the receptor (such as inhalation of

air or drinking of water).



Impacts are defined where there is a plausible pathway between the Project aspects and

receptors. The aspects, pathways and receptors are identified based on:





previous environmental or social studies;







review of the evolving Project description to identify aspects;







consideration of the area of influence to determine pathways and receptors;







experience of the ESIA and Project specialists;







consideration of issues raised by stakeholders; and







findings of baseline investigations as they become available.



Impact assessment

Impact assessment is an iterative process starting with issue identification and impact

definition during the scoping phase, as outlined in Section 1.1.1. As the ESIA progresses, the

emphasis shifts to impact evaluation, which consists of the systematic evaluation of each of

the identified impacts using criteria enabling the significance of the impacts to be determined

and the impacts to be ranked accordingly. As part of this process, management measures

are defined to reduce the significance of negative impacts or enhance positive ones. After

consideration of the management measures, the significance of the resulting (residual)

impacts is re-evaluated using the same criteria. The identified management measures form

the basis for subsequent development of the Project’s environmental and social management

programme.

In some cases impact evaluation involves the use of predictive modelling to determine impact

significance. The results of these studies are presented in the impact assessment chapters,

and more detailed information is contained in the support documents as outlined in Table 3-3.

The predictive modelling exercises undertaken include:





air quality;







water resources (both chemical and physical changes); and







noise.



U3823_Marampa_ESIS_Final.docx



September 2012

Page 27 of 244



SRK Consulting (UK) Ltd



Marampa Iron Ore Project ESIS – Main Report



Cumulative impacts consider other proposed or anticipated future activities in the vicinity of

Lunsar that may have additive or synergistic effects on the impacts of the Project. These

include the construction and operation of a mine within ML02/09 (London Mining concession

area) and the AML railway line to Pepel Port, which runs through the Project area. Both of

these developments began operation in late 2011. Cumulative impacts were considered in the

ESIA process and are discussed in Section 10.

Impact grouping

Different types of impacts are often interrelated and therefore an integrated holistic approach

has been taken to impact assessment. For example: different aspects can impact on the

same receptor; different impacts can have cumulative impacts on receptors; one impact could

result in a sequence of different impacts (a chain of different impact events); and one primary

impact could have a diversity of secondary impacts. This interrelationship between impacts

can make description and evaluation of impacts complicated and repetitive. For this reason

and to facilitate impact evaluation, impacts have been grouped where possible. Generally

grouping takes account of similarities in the sources of the impacts, the aspects, the pathways

of exposure, the receptors and/or the management measures required to address the

impacts.

There are no strict rules about how impacts should be grouped and people may group

impacts differently. What is important is that grouping facilitates a reader-friendly and

structured discussion of impacts. The groupings of impacts are not discrete; there are

overlaps between groups of impacts that require cross-referencing.

Social impacts may be grouped and evaluated slightly differently, taking cognisance of the

points listed below:





social issues are often clustered and interdependent rather than clearly separable;







communities are dynamic and in a continual process of change, with the Project one

factor contributing to this change - it is often difficult to identify if an issue is attributable to

a Project aspect, to factors beyond the Project’s control or a combination of both;







social issues are not always objectively measurable and often need to be inferred rather

than measured - a combination of insight into social processes in general and knowledge

of the communities under study are important to draw valid inferences;







social issues are often unavoidable and difficult to manage, and as such management

strategies aim to manage change rather than avoid an issue; and







successful management of a potentially negative issue may result in a positive outcome.



A section on Community Health and Safety Impacts has been included (Chapter 9) to discuss

specific health and safety issues associated with the Project on surrounding communities.

These issues include noise, air quality, and the various safety risks (including traffic); specific

management measures are provided.

Impact description

There is a trend away from highly prescriptive approaches to impact evaluation. Most ESIA

practitioners recognise that impact evaluation is not a purely objective and quantitative

exercise. It has a subjective element; often based on qualitative judgement and values as

well as scientific criteria. Consequently, in the impact assessment chapter’s emphasis is

placed on describing how impacts have been interpreted so others can understand the

rationale of the assessment.

U3823_Marampa_ESIS_Final.docx



September 2012

Page 28 of 244



SRK Consulting (UK) Ltd



Marampa Iron Ore Project ESIS – Main Report



Each impact description:





starts with a definition of the impact using an impact statement outlining the aspectpathway-receptor;







describes the sensitivity, importance or value of the receiving environment or receptors;







explains the extent of change associated with the impact;







rates the significance of the impact;







explains the effectiveness of proposed management measures; and







characterises the level of uncertainty in the impact assessment.



The significance of an impact is determined based on the product of the consequence of the

impact and the probability of its occurrence. The consequence of an impact, in turn, is a

function primarily of three impact characteristics:





magnitude;







spatial scale; and







timeframe.



Magnitude is determined from quantitative or qualitative evaluation of a number of criteria

discussed further below. Where relevant, this includes consideration of the sensitivity of the

receptor, the importance or value of the receptor and the extent of change experienced by the

receptor.

The sensitivity of existing or reasonably foreseeable future receptors reflects their ability to

tolerate disturbance or change. More vulnerable receptors may be less adaptable than the

majority of receptors. For example, if a minor disturbance has the potential to result in the

permanent loss of the biodiversity of a habitat, the affected environment would be categorised

as having a low tolerance to disturbance and is consequently a highly sensitive habitat. In

another example, a population with high levels of unemployment is likely to be more sensitive

to job creation than an area with low unemployment, meaning that new jobs will have a

greater positive magnitude in an area where people need jobs.

The importance or value of the receptor can be described using the following indicators:





status of legal protection;







inclusion in local government policy;







level of public concern;







number of receptors affected;







intrinsic or perceived value placed on the receiving environment by stakeholders; and







economic value to stakeholders.



Where legally designated protection is not specified, importance or value is likely to be a

subjective evaluation based on available information, the opinion of the experts on the ESIA

team and consideration of the views of affected stakeholders.

The extent of change may be measured qualitatively or quantitatively. One way of

measuring change is by comparing to relevant thresholds. Examples of possible thresholds

are listed below with the main sources of legal and functional thresholds applied in the ESIA

being the host country standards and the World Bank Group EHS Guidelines:





legal thresholds - established by law or regulation and often numeric in nature;







functional thresholds – where if exceeded, the impacts will disrupt the functioning of an

ecosystem sufficiently to destroy resources important to the nation or biosphere



U3823_Marampa_ESIS_Final.docx



September 2012

Page 29 of 244



SRK Consulting (UK) Ltd



Marampa Iron Ore Project ESIS – Main Report



irreversibly and/or irretrievably;





normative thresholds - established by social norms, usually at the local or regional level

and often tied to social or economic concerns;







preference thresholds - preferences for individuals, groups or organizations only, as

distinct from society at large; and







reputational thresholds – the level of risk a company is willing to take when approaching

or exceeding the above thresholds.



Spatial scale is another impact characteristic affecting impact consequence. The spatial

scale of impacts can range from localized (confined to the proposed Project site) to extensive

(national or international extent). They also may vary depending on the component being

considered. Different scales have been used for the bio-physical impacts and the socioeconomic impacts.

The impact timeframe is the third principal impact characteristic defining impact consequence

and relates to either its duration or its frequency (when the impact is intermittent). Impact

duration can range from relatively short (less than four years) to long (beyond the life of the

Project). Frequency ranges from high (more than 10 times a year) to low (less than once a

year). These timeframes will need to be established for each Project based on its specific

characteristics and those of the surrounding environment.

Additional characteristics, including reversibility, sustainability and timing (onset) of the

impact, can also play a role in consequence determination of some types of impact. As

appropriate, these additional characteristics are considered and described alongside the three

primary characteristics of magnitude, spatial scale and duration.

Once the impact consequence is described on the basis of the above impact characteristics,

the probability of impact occurrence is factored in to derive the overall impact significance.

The probability relates to the likelihood of the impact occurring, not the probability that the

source of the impact occurs. For example, a continuous Project aspect (such as generation

of dust) may result in an unlikely probability of impact if there are no receptors within the area

influenced by that activity.

The resulting significance rating may be further qualified by explaining the effectiveness of

proposed management measures designed to mitigate or enhance the impact, and by

characterizing the level of confidence or uncertainty in the assessment. The characteristics

used for the written impact descriptions are outlined in Table 3-4. The next section outlines

the specific process used in this ESIA for impact significance rating.



U3823_Marampa_ESIS_Final.docx



September 2012

Page 30 of 244



SRK Consulting (UK) Ltd



Marampa Iron Ore Project ESIS – Main Report



Table 3-4: Characteristics used to describe an impact

Characteristics



Sub-components



Nature

Phase of Project



Sensitivity of receptor



Magnitude



Spatial scale



Timeframe



Terms used to describe the impact













Type

















Importance or value of receptor



Positive (a benefit), negative (a cost) or neutral

Biophysical, social, cultural, health or economic

Direct, indirect or cumulative

Construction, operation, decommissioning or post

closure

High, medium or low capacity to accommodate change

High, medium or low conservation importance

Vulnerable or threatened

Rare, common, unique, endemic

High, medium or low concern to some or all stakeholders

High, medium or low value to some or all stakeholders

(for example, for cultural beliefs)

Locally, nationally or internationally important

Protected by legislation or policy

Gravity or seriousness of the change to the environment

Intensity, influence, power or strength of the change

Never, occasionally or always exceeds relevant

thresholds



Severity or degree of change to the

receptor















Area affected by impact boundaries at local and regional

extents will be different for

biophysical and social impacts.











Area or volume covered

Distribution

Local, regional, transboundary or global













Short term or long term

Intermittent (what frequency) or continuous

Temporary or permanent

Immediate effect (impact experienced immediately after

causative Project aspect) or delayed effect (effect of the

impact is delayed for a period following the causative

Project aspect)

Definite (impact will occur with high likelihood of

probability)

Possible (impact may occur but could be influenced by

either natural or Project related factors)

Unlikely (impact unlikely unless specific natural or

Project related circumstances occur)

Potential for recovery of the endpoint from the impact

Reversible or irreversible

Sustainable beyond the Project’s life

Indication of what could occur in the absence of

management measures

Effectiveness of proposed measures

Scientific uncertainty – limited understanding of

ecosystem (or community) and processes governing

change

Data uncertainty – restrictions introduced by incomplete

or incomparable information, or by insufficient

measurement techniques

Policy uncertainty – unclear or disputed objectives,

standards or guidelines

Personal opinion – some impact may be perceived

different by different people



Length of time over which an

environmental impact occurs or

frequency of impact when

intermittent





Probability - likelihood or chance an impact will occur









Reversibility / sustainability

Effectiveness of management measures (will

management measures reduce impact to an

acceptable level)



















Confidence in impact evaluation (degree of

certainty in the significance ascribed to the impact)









Impact significance rating

The impact significance rating process serves two purposes: firstly, it helps to highlight the

critical impacts requiring consideration in decision making processes (such as engineering

planning decisions, government approval of the Project, the feasibility decision and Project

finance approvals); secondly, it serves to show the primary impact characteristics, as defined

above, used to evaluate impact significance. The impact rating system used in the ESIA was

selected because it:

U3823_Marampa_ESIS_Final.docx



September 2012

Page 31 of 244



SRK Consulting (UK) Ltd



Marampa Iron Ore Project ESIS – Main Report







is simple and does not detract from the written description of potential impacts;







is easy for stakeholders to understand; and







is useful in helping to distinguish impacts needing to be brought to the attention of

decision makers.



Impact assessment matrices can become complex if too many categories are used or if

specific criteria are developed for each environmental component or Project activity. The

rating system used here is a simple 3x3 matrix and is standardised across all environmental

components and activities. It relies on the clear description of the impact given in the text to

show the reader how the final significance rating has been arrived at. It is recognised that this

simple approach may limit the evaluation of some impacts associated with a specific

environmental component or activity. Therefore under certain circumstances the ESIA

practitioner may choose to modify the criteria used in the matrix table for that specific

evaluation; any such modifications are clearly explained in the text.

The impact significance rating system is presented in Table 3-5 and involves three parts as

outlined below.





Part A: Define impact consequence using the three primary impact characteristics of

magnitude, spatial scale and duration. When assessing the magnitude, it is not

necessary that all definitions given by the table agree with the assessment chosen. The

justification for the assessment should be clearly explained in the impact discussion. In

the case of negative impacts, the most conservative definition should generally be used

– in other words, if any of the definitions fall under the major category then the overall

magnitude is major. For positive impacts, a balance should be sought with the rating

reflecting the most likely definition that applies.







Part B: Use the matrix to determine a rating for impact consequence based on the

definitions identified in Part A; and







Part C: Use the matrix to determine the impact significance rating, which is a function of

the impact consequence rating (from Part B) and the probability of occurrence.



U3823_Marampa_ESIS_Final.docx



September 2012

Page 32 of 244



SRK Consulting (UK) Ltd



Marampa Iron Ore Project ESIS – Main Report



Table 3-5: Method for rating the significance of impacts

PART A: DEFINING CONSEQUENCE IN TERMS OF MAGNITUDE, DURATION AND SPATIAL SCALE

Use these definitions to define the consequence in Part B

Definition



Criteria

Negative







Major

















MAGNITUDE



Moderate

















Minor









Large number of receptors affected

Receptors highly sensitive and/or are

of conservation importance

Substantial deterioration, nuisance or

harm to receptors expected

Relevant thresholds often exceeded

Significant public concern expressed

during stakeholder consultation

Receiving environment has an

inherent value to stakeholders

Some receptors affected

Receptors slightly sensitive and/or of

moderate conservation importance

Measurable deterioration, nuisance

or harm to receptors

Relevant thresholds occasionally

exceeded

Limited public concern expressed

during stakeholder consultation

Limited value attached to the

environment

No or limited receptors within the

zone of impact

Receptors not sensitive to change

Minor deterioration, nuisance or harm

to receptors

Change not measurable or relevant

thresholds never exceeded

Stakeholders have not expressed

concerns regarding the receiving

environment

Duration of continuous aspects



TIMEFRAME

(determine

specific to

each Project)



































Large number of receptors

affected

Receptors highly amenable to

positive change

Receptors likely to experience a

big improvement in their

situation

Relevant positive thresholds

often exceeded



Some receptors affected

Receptors likely to experience

some improvement in their

situation

Relevant positive thresholds

occasionally exceeded



No or limited receptors affected

Receptors not sensitive to

change

Minor or no improvement in

current situation

Change not measurable

Relevant positive thresholds

never exceeded

No stakeholder comment

expected

Frequency of intermittent aspects



Short term/

low frequency



Less than 4 years from onset of impact



Occurs less than once a year



Medium term/

frequency



More than 4 years from onset of impact up to

end of life of Project (approximately 15 years)



Occurs less than 10 times a year but

more than once a year



Long term/

high frequency



Impact is experienced during and beyond the

life of the Project (greater than 15 years)



Occurs more than 10 times a year



Biophysical

SPATIAL

SCALE

(determine

specific to

each Project)



Positive



Socio-economic



Small



Within 200 m of the Project footprint area



Within the chiefdom in which the activity

occurs



Intermediate



Within the district in which the facilities are

located



Within the province in which the activity

occurs



Extensive



Beyond the district in which the facilities are

located



Beyond the province in which the activity

occurs (national / international)



U3823_Marampa_ESIS_Final.docx



September 2012

Page 33 of 244



SRK Consulting (UK) Ltd



Marampa Iron Ore Project ESIS – Main Report



PART B: DETERMINING CONSEQUENCE RATING

Rate consequence based on definition of magnitude, spatial extent and duration

SPATIAL SCALE

MAGNITUDE



TIMEFRAME



Minor



Moderate



Major



Small



Intermediate



Extensive



Short term / low frequency



Low



Low



Medium



Medium term / frequency



Low



Low



Medium



Long term / high frequency



Medium



Medium



Medium



Short term / low frequency



Low



Medium



Medium



Medium term / frequency



Medium



Medium



High



Long term / high frequency



Medium



High



High



Short term / low frequency



Medium



Medium



High



Medium term / frequency



Medium



Medium



High



Long term / high frequency



High



High



High



PART C: DETERMINING SIGNIFICANCE RATING

Rate significance based on consequence and probability

CONSEQUENCE



PROBABILITY

(of exposure to

impacts)



Low



Medium



High



Definite



Low



Medium



High



Possible



Low



Medium



High



Unlikely



Low



Low



Medium



+ denotes a positive impact.



Using the matrix, the significance of each described impact is initially rated. This initial rating

assumes the management measures inherent in the Project design and described in the

Project description (Chapter 4) are in place. For example, if a fuel store has been designed

with secondary containment, the initial impact rating takes this into account.

For most impacts an impact summary table is given to present the rating results, as shown in

the example below. The heading row of the table gives the impact definition (see above).

The following rows present the impact characteristics and significance ratings. The final row

presents any additional management measures identified by the impact assessor as required

to appropriately control/enhance the impacts. These would be over and above the inherent

management measures incorporated into the Project design. Included in the summary table

is a confidence assessment, which provides the reader with an indication of the assurance

level placed on the rating process and addresses the concept of uncertainty. A statement is

also given on whether the impact is reversible or sustainable.

The management measures given in the table will take the form of either: mitigation measures

(those measures needed to reduce the significance of negative impacts to an acceptable

level); or enhancement measures (those measures needed to optimise the effects of positive

impacts). Where such measures are stipulated, the final table row provides the rating for the

‘residual impact’ (negative impacts) or ‘enhanced impact’ (positive impacts), which assumes

these measures are successfully implemented and reflects the actual impact expected from

the Project. Where no residual impact is given the actual impact of the Project is the initial

impact.



U3823_Marampa_ESIS_Final.docx



September 2012

Page 34 of 244



SRK Consulting (UK) Ltd



Marampa Iron Ore Project ESIS – Main Report



Table 3-6: Example of impact significance rating summary table

Impact X: Example impact statement (aspect, pathway and receptor)

Impact characteristics



Residual or optimised impact (taking

cognisance of management measures)



Initial impact



Type (+ / - /neutral)

Sensitivity

Magnitude

description



Receptor importance

or value

Extent of change /

threshold compliance

Magnitude rating

Duration



Timeframe

description



Frequency

Timeframe rating



Scale

CONSEQUENCE RATING

PROBABILITY RATING

SIGNIFICANCE RATING

Reversibility/sustainablity

Confidence



Management measures





Measure 1







Measure 2 etc.



The strategy for selecting practical mitigation measures is as follows:





avoid the impact wherever possible by removing the cause(s) – always preferred;







reduce the impact as far as possible by limiting the cause(s) – preferred where impacts

cannot be avoided;







ameliorate the impact by protecting the receptor from the cause(s) of the impact – only

where the causes of the impact cannot be reduced; and







providing compensatory measures to offset the impact – this is used only when none of

the above are appropriate and is often used when impacts to biodiversity resources

cannot be mitigated.



All relevant management measures (inherent design measures, mitigation measures,

enhancement measures and good practice measures) are eventually consolidated into the

environmental and social management programme, which forms a fundamental part of the

environmental and social management system described in Chapter 11 and which may

become legally binding.



3.3.4



Phase 4: ESIA report review and decision-making

The purpose of this ESIA report is to present the information from the ESIA process that is

available and relevant in an integrated and holistic manner. It aims to provide the big picture

in as non-technical a manner as far as possible. Technical detail is provided in the various

supporting documentation such as the specialists baseline and impact assessment studies,

which are provided as the supporting documentation in Volume 3 of the ESIA report.

The ESIA will be submitted to the relevant regulatory authorities for review and consideration.

The review will inform the government’s decision and enable it to set the conditions of



U3823_Marampa_ESIS_Final.docx



September 2012

Page 35 of 244



SRK Consulting (UK) Ltd



Marampa Iron Ore Project ESIS – Main Report



approval. The ESIA report will also be made available for public review and there will be

feedback consultations with stakeholders.

The feedback consultations will inform

stakeholders about progress with Project planning, expected impacts and proposed mitigation

measures. The consultations will acknowledge issues raised by stakeholders and tell them

how these are to be addressed, and they will provide stakeholders with an opportunity to

comment on the Project and proposed mitigation measures.

Stakeholders that have shown an interest in the ESIA will be involved in the feedback

consultations. Records of the feedback consultations will be provided to regulatory authorities

for consideration in the Project approval decision. The feedback consultations will not be

replaced by any government public hearing that are prescribed because they are important to

the long-term constructive relationship between the Project and stakeholders, but it is possible

that the government may be amenable to replacing/ integrating public hearings with the

feedback consultations.



3.3.5



Stakeholder consultation

The purpose of stakeholder consultation during the ESIA process is to enable the views,

interests and concerns of Project stakeholders, including vulnerable or disadvantaged groups,

to be taken into account. The objectives and activities of the stakeholder consultation, and

how these link to the ESIA process, are shown schematically in Figure 3.2.

Approach

During the Scoping phase, and following a process of stakeholder identification and analysis,

an initial SEP was developed to guide the initial and ongoing stakeholder consultation

process. As part of the scoping consultations, a BID was prepared and distributed among

stakeholders to help explain the proposed Project and the ESIA process.

Details on the ESIA stakeholder consultation are presented in the SEP. The SEP is a live

document, which has been updated throughout the ESIA process and will continue to evolve

as the Project proceeds through the construction, operation and decommissioning phases.

The purpose of the SEP to date was to guide and record public consultation and disclosure

activities during the ESIA process. The SEP to guide the stakeholder engagement process

through the construction phase and the rest of the life of the Project has been presented as

part of the ESMS.

Summary of ESIA stakeholder consultation

Initial stakeholder consultations focused on formally initiating the ESIA process with SLEPA

and identifying specific regulatory requirements of relevant Government ministries. The

meetings were held on a one to one basis in the relevant Government ministry office. A BID

outlining the status of the Project was provided to ministry representatives, who were given

the opportunity to raise issues associated with the Project and were encouraged to contact

MIOL if queries arose. Minutes of these meetings are included as Appendix 2 to the SEP

(Appendix C).

Following these meetings, a screening form was completed and submitted to SLEPA in line

with the national Environmental Impact Assessment (EIA) process (Section 2.1). SLEPA

categorised the Project as Category A, thus requiring an Environmental and Social Impact

Assessment (ESIA) for the Project (refer to Appendix B for correspondence from SLEPA

dated 20th August 2010).



U3823_Marampa_ESIS_Final.docx



September 2012

Page 36 of 244



SRK Consulting (UK) Ltd



Marampa Iron Ore Project ESIS – Main Report



Figure 3.2: Overview of the stakeholder engagement process undertaken



U3823_Marampa_ESIS_Final.docx



September 2012

Page 37 of 244



SRK Consulting (UK) Ltd



Marampa Iron Ore Project ESIS – Main Report



An interim consultation meeting to discuss the ToR for the baseline studies and other issues

was held SLEPA in February 2011. Stakeholder consultation meetings for the scoping phase

of the ESIA were held with local communities, NGO’s and authorities in March 2011, and any

additional issues raised that had not already been included in the ToR for the baseline studies

were included at that stage.

A list of the stakeholders who were engaged during the ESIA process is appended to the

SEP. The stakeholders include:





local communities;







national, provincial and local government and authorities;







community based organisations (“CBOs”) and NGOs; and







others, such as private sector, academia and the media.



Issues raised by stakeholders during the ESIA process have been recorded in a database,

along with a response indicating how these issues have been addressed through the ESIA

process, and are summarised in Table 3-7. A summary of the issues and responses to each

issue is included as an Issues Report in Appendix C. The Issues Report details the issues

raised; identifies people who raised them and their affiliations; and shows how the issues

have been addressed in the ESIA by means of comments and/or cross referencing to relevant

sections of the ESIA report.

A final round of stakeholder consultations for the ESIA process will be held on submission of

the draft ESIA report to SLEPA, following which any additional issues raised will be addressed

in the final ESIA report submitted to SLEPA for approval.

A full record of the stakeholder consultation process to date is presented in the SEP. The

current version of the SEP is presented in Appendix C and this will be updated following

feedback consultation with stakeholders.

Table 3-7: High-level summary of stakeholder issues raised and where addressed in the ESIS

Subcategory



Issue raised



Addressed in ESIA report



Community health and

safety



Dust and noise impacts on local communities



Section 9.1 and 9.2



Safe use of explosives



Section 9.5.1



Traffic safety



Section 9.3



Loss of agricultural land and insufficient

rehabilitation



Section 7.1



Visual impacts



Section 7.1



Ecological



Use of appropriate vegetation for

rehabilitation



Section 7.3



Water resources



Added pressure on limited water resources



Section 7.2



Economic

development



Requirement for tangible community

development



Section 8.1



Employment for local communities (and

attracting workers from farms and schools)



Section 8.1



Social organisation



Conflict within and between communities



Section 8.3



Resettlement and land

acquisition



Compensation for land



Section 8.2



Correct implementation of resettlement



Section 8.2



Management

measures



Implementation and monitoring of

management measures



Chapter 11



Land transformation



U3823_Marampa_ESIS_Final.docx



September 2012

Page 38 of 244



SRK Consulting (UK) Ltd



3.4



Marampa Iron Ore Project ESIS – Main Report



Assumptions and limitations

The ESS was initiated early in the Project planning process and as such limited Project

information was available at that stage. In the absence of a provisional Project layout, a

general study area was defined indicating zones within which disturbance was considered

likely. By the time most of the baseline studies were complete, the Project description had

been refined and new study areas were delineated (Figure 3.1), which were slightly larger

than the original study areas. As additional Project information became available, the focus

areas for subsequent field trips supporting the ESIA process were amended accordingly and

in consultation with the Project team. The initial baseline field work areas were however

defined based on the original (slightly reduced) study area compared to the revised Project

study areas, which show expansion mainly in Areas 1 and 2. This does not represent a fatal

flaw for the baseline as the areas involved are similar. However this has meant that baseline

information used in the impact assessment has been extrapolated over a wider and

marginally different area.

Stakeholder consultations with local communities and the general public were delayed until

March 2011, which represented a limitation for the scoping process, as not all stakeholder

issues were available prior to initiating the baseline studies. However, this did not preclude

stakeholder issues from being considered in these studies as soon as they were available.

SRK can confirm no critical new issues were identified and the minor issues were

appropriately addressed by the ongoing baseline studies before completion. Therefore the

delay in consultations is not considered to be critical to the ESIA nor the stakeholder

engagement process as a whole, nor to have resulted in issues not being suitably addressed.

The scope of the ESIA is restricted to the potential mining and processing operations around

Lunsar and specifically excludes construction of the rail transportation of the concentrate from

the site to the port, and facilities at the port. As a third party is responsible for these facilities,

the rail line and ports are not considered to be within the Project’s area of influence. It does

however include product transport pipelines, running from the ore processing area on site to

Tagrin Port, along an existing rail corridor that is also operated by a third party.

The Project is currently at a pre-feasibility study and thus some details of the design may

change as the Project moves into the feasibility and detailed design phase. At this stage no

significant changes are expected, however should changes to the Project description occur

that materially affect the outcome of this impact assessment report, an addendum would be

prepared.



U3823_Marampa_ESIS_Final.docx



September 2012

Page 39 of 244



SRK Consulting (UK) Ltd



4



Marampa Iron Ore Project ESIS – Main Report



PROJECT DESCRIPTION

This Chapter provides a preliminary description of the major Project components based on

2

the Project design. The exploration licence area (EL46/2011) covers 305.12 km in total. The

development area of the Project’s footprint (and hence the study area for this ESIA) is 52.3

2

km . Further detail of the preliminary design is provided in Appendix E.

The ultimate Project involves the construction of facilities and infrastructure to produce up to

6

15 Mtpa of iron concentrate. This will be done in two stages. Stage 1 will involve the

construction of facilities to produce 2.5 Mtpa of iron concentrate through the mining of oxide

ore only. Stage 2 (an extension to Stage 1) involves expanding these facilities, and the

construction of additional facilities, to enable the production of a total of up to 15 Mtpa of iron

concentrate through the mining of oxide and/or fresh ore.

While the development plan of Stage 2 of the Project is reasonably known at this time, it will

be the subject of a detailed feasibility study moving forward. Where possible this ESIA will

describe (and assess impacts relating to) the full proposed development, i.e. production of up

to 15 Mtpa of concentrate (Stage 2), clearly stating where detail relates specifically to Stage 1.

Changes and additional components (such as for product export) to the Stage 2 development

proposal resulting from the outcomes of the detailed feasibility study (and therefore not

described or assessed in this ESIA) will however be covered by a future amendment to the

ESIA. Potential future expansion plans are discussed further in Section 4.13.

The existing railway between Marampa and the Pepel Port facilities has been refurbished and

placed back in to operation by AML to service their Tonkolili Mine. An access agreement is in

place with AML, allowing MIOL to export 1.8 Mtpa (potentially increasing to 3.4 Mtpa) of

concentrate through the rail and Pepel port facilities for its Stage 1 development. An

environmental authorisation has been obtained for these as part of AML’s Project, and they

are therefore not included in this ESIA. Product export will involve pumping concentrate via

pipelines to the port of Tagrin and will be covered in the amendment to this ESIA.

The main Project components included in this ESIA are listed below:





Four open pits (Matukia, Gafal, Rotret and Mafuri) and four associated waste rock dumps

(“WRD”)







Run of mine (“ROM”) and low grade stockpiles







Beneficiation plant, comprising:

-



crushing;

stockpiling;

ore reclamation;

scrubbing / grinding;

rougher / scavenger magnetic separation;

rougher / scavenger concentrate regrind;

cleaner and recleaner magnetic separation;

concentrate thickening and filtration;

tailings thickening;

reagent storage and use; and



6



It should be noted that references to concentrate production rates refer to dry metric tonnes. The moisture content of the

product may range between 8-10%, which will increase the actual tonnage of concentrate produced, transported and exported

accordingly (wet metric tonnes).

U3823_Marampa_ESIS_Final.docx



September 2012

Page 40 of 244



SRK Consulting (UK) Ltd



-



Marampa Iron Ore Project ESIS – Main Report



supporting utilities.







Tailings storage facility (“TSF”)







Power generation and distribution facilities







Water supply facilities







Stormwater management facilities







Waste water management systems







Communications systems







Accommodation







Medical and emergency services







Utilities (potable water supply, fire water system, air compressor systems)







Mobile equipment (vehicles etc.)







Buildings for storage, offices, workshop, laboratory, etc.







A rail spur and head, connecting to the existing Pepel railway line







Use of existing road routes for transport of supplies to the mine (including the existing

Makeni Highway, connecting Freetown to Lunsar) and some new on-site roads to

connect Project infrastructure



The design, construction, operation and closure of the Project components are described in

the following sub-sections. For some components, such as power and water supply,

alternative options and their social or environmental implications were evaluated. These are

described together with the decision-making rationale. Where relevant, inherent design

measures to protect the bio-physical or social environmental have been highlighted; these

measures are assumed to be in place when evaluating the initial Project impacts in Chapters

7, 8 and 9.



4.1



Construction

The facilities at the mine site for Stage 1 will be constructed over an 18 month period. Once

Stage 1 is in operation construction of Stage 2 will commence, and will continue for a further

18 to 24 months. The total construction period for the Project will therefore be approximately 3

to 3½ years. This section outlines the activities occurring during or just prior to construction,

which may impact upon the bio-physical or social environment.



4.1.1



Land acquisition and resettlement

The resettlement and compensation process will be undertaken in adherence with the

legislative requirements in Sierra Leone and the international guidelines. The objective will be

to ensure that the standard of living and livelihoods of Project affected people (“PAPs”) are

either improved, or at least restored to pre-resettlement levels.

The approach to the resettlement process will involve establishment of a Resettlement

Working Group (“RWG”) to facilitate the consultation process and negotiations and

establishment of a Grievance Committee. The planning phase of the resettlement process

will include a census and assets survey to provide the baseline profile of each affected

household, and a valuation survey to establish the market value and cost of production for the

main local crops and buildings. Following this, an entitlement framework for the PAPs will be

prepared and signed off by the RWG and relevant government agencies. Once agreed with

the PAPs, a moratorium will be declared that restricts the construction of new

buildings/structures in the Project displacement areas. The implementation phase of



U3823_Marampa_ESIS_Final.docx



September 2012

Page 41 of 244



SRK Consulting (UK) Ltd



Marampa Iron Ore Project ESIS – Main Report



resettlement will include the following activities:



4.1.2







Construction of resettlement sites in preparation for physical relocation of PAPs;







Initiation of income restoration and sustainable development initiatives to restore or

improve the standard of living of PAPs; and







Concurrent monitoring and evaluation to determine the standard of living of PAPs relative

to pre-resettlement levels.



Construction camp and laydown area

During the construction phase, contractors will provide temporary facilities to house

construction personnel. It is expected that this will be separate from MIOL’s accommodation

camp. The location of this camp has not yet been determined. The decision regarding a

location will be driven by Project requirements (proximity to construction sites) but will take

cognisance of the local communities in the area. The camp will be powered from diesel

generators, water will come from the mine site’s potable water system (though a temporary

treatment system may be required until such time as the full system is in place) and waste

disposal will be via suitable package sewage treatment works with a discharge of treated

effluent to a soakaway or evaporation basin.

A fenced and secured construction laydown area will be built in proximity to the camp or

construction site to store construction materials. This will mainly comprise a compacted earth

base, however if hazardous material (for example fuels, oils, lubricants, paints etc.) storage is

required this will be within suitable constructed containment facilities (with impermeable bases

and roofs as required).



4.1.3



Land clearance and infrastructure development

Initial construction activities include land clearance, site grading for temporary material

laydown areas, permanent structure foundations, roadway development and storm water

management ponds. This will be followed by construction of the infrastructure. In addition to

infrastructure footprint areas and mine pre-stripping, land will be cleared to provide access to

borrow pits. At this stage the location of the borrow pits is not known but wherever possible

these will be located within the footprints of areas to be disturbed.

Construction equipment will include rock crushers, concrete mixer trucks, concrete pumper

trucks, mobile cranes, container handler, forklifts, excavators, loaders, dozers, graders, water

trucks, and pick-up trucks.

Most construction activities take place within the Project component footprints but some

existing (non-Project) linear infrastructure will be affected during construction as listed below.

In these cases, MIOL will interact with the operator of the relevant infrastructure to minimise

disturbance during the construction period.





The haul roads between the pits and the beneficiation plant cross the national road to

Freetown. At these locations the haul road will be constructed in a culvert under the

national road.







The pipeline from the beneficiation plant to the TSF crosses the existing rail way line.

This will also be constructed in a culvert under the railway line.







The new MIOL rail spur will need to link into the existing rail line to Pepel port.



U3823_Marampa_ESIS_Final.docx



September 2012

Page 42 of 244



SRK Consulting (UK) Ltd



Figure 4.1: Overall site layout plan for the Project, with additional detail on the beneficiation plant and road crossing



U3823_Marampa_ESIS_Final.docx

Page 43 of 244



SRK Consulting (UK) Ltd



4.1.4



Marampa Iron Ore



Project ESIS – Main Report



Construction management

The construction activities will be managed by an Engineering, Procurement and Construction

Management (“EPCM”) contractor. The EPCM contractor will be managed by a small team of

owner’s construction personnel. The EPCM contractor will select and recommend main

contracting companies for the various stages of the work including earthworks, concrete

works, structural works, mechanical and piping works, electrical works and building works.

Due to the specialised nature and extent of the construction works, it is expected that the

main contracting companies will be sourced from outside of Sierra Leone. It will be a

requirement of the contracts, however, that the main contractors employ, or sub-contract to,

Sierra Leoneans where possible.

It is expected that the construction labour force will peak at around 600 – 700 personnel, of

which 30 – 70% could be locally sourced unskilled labour, depending on the type of

construction work being conducted at the time (e.g. concrete works, earthworks, mechanical

and electrical installations). Due to the specialist nature of the construction works, it is

expected that the majority of the skilled workforce will come from outside of Sierra Leone. The

Company will implement a policy, however, where-in the use of Sierra Leonean labour is

maximised where-ever possible, with training provided to maximise opportunities for such

staff to transfer to operational roles.



4.2



Mine site operation



4.2.1



Preliminary pit design

Four open pits have been designed to access ore bodies; Rotret Pit, Matukia Pit, Mafuri Pit

and Gafal Pit. The main ore type at each location is a specular hematite schist, with minor

amounts of magnetite and goethite. The Stage 1 development is based on the mining of

shallow oxide ore, to produce nominally 2.5 Mtpa of concentrate. The Stage 2 development

will continue with mining of any remaining oxide ore and mine fresh ore to produce up to 15

Mtpa of concentrate.

Provisional pit dimensions and ore and waste recovery volumes are presented in Table 4-1.

The total mine life is approximately fourteen years.

Table 4-1: Preliminary Ore/Waste Volumes per Pit

Deposit



Ultimate Pit

Length (m)



Ultimate Pit

Width (m)



Pit Area

(ha)**



Ore (kt)



Waste (kt)



Total (kt)



Gafal



2,200



800



150



151,541



181,721



333,263



Mafuri



2,700



800



200



177,933



199,904



377,838



Matukia



1,600



800



125



128,392



185,201



313,592



Rotret



1,500



500



Total

** Approximate area of disturbance in hectares



75



55,246



45,366



100,612



550



513,112



612,192



1,125,305



Average pit slopes will be 30 degrees, and slope heights vary between 20 and 55 m. The

oxide ore will be mined from within 40-50m of the natural ground level with the ultimate pit

shells expected to extend to depths varying from 150- 280 metres below ground level

(“mbgl”), and crest elevations of 70 to 90 mRL (reduced level in meters with respect to mean

sea level).. The average mine life for each pit is approximately ten to thirteen years, with the

exception of Rotret, which has an expected mine life of six to seven years.

U3823_Marampa_ESIS_Final.docx



September 2012

Page 44 of 244



SRK Consulting (UK) Ltd



Marampa Iron Ore



Project ESIS – Main Report



The pits will be bunded to prevent surface water inflow. Runoff from the area surrounding the

pits will be diverted to stormwater settlement ponds (located close to each pit).



4.2.2



Preliminary production schedule

The provisional mining schedule is presented in Table 4-2. Mineral extraction is due to

commence within 18 months with mining rates varying from 8-12 Mtpa. Total movements will

increase from 12 to 66 Mtpa during Stage 1 and up to 110 Mtpa during Stage 2 (due to

commence 18 months after the start of Stage 1), as production increases and deeper pit

stages are developed. The four pits will be mined in sequence to prioritise recovery of oxide

ore for staged processing and open up areas of ore for the expanded Stage 2 circuit. Cross

sections showing the interpretive geology for each pit (showing the oxide and fresh ore

proportions) are provided in Figure 4.2 to Figure 4.5.



Figure 4.2: Mafuri prospect interpretive geology



U3823_Marampa_ESIS_Final.docx



September 2012

Page 45 of 244



SRK Consulting (UK) Ltd



Marampa Iron Ore



Project ESIS – Main Report



Figure 4.3: Rotret prospect interpretive geology



U3823_Marampa_ESIS_Final.docx



September 2012

Page 46 of 244



SRK Consulting (UK) Ltd



Marampa Iron Ore



Project ESIS – Main Report



Figure 4.4: Gafal prospect interpretive geology



U3823_Marampa_ESIS_Final.docx



September 2012

Page 47 of 244



SRK Consulting (UK) Ltd



Marampa Iron Ore



Project ESIS – Main Report



Figure 4.5: Matukia Prospect Interpretive Geology



U3823_Marampa_ESIS_Final.docx



September 2012

Page 48 of 244



SRK Consulting (UK) Ltd



Marampa Iron Ore



Project ESIS – Main Report



Table 4-2: Indicative production schedule



U3823_Marampa_ESIS_Final.docx



September 2012

Page 49 of 244



SRK Consulting (UK) Ltd



Marampa Iron Ore Project ESIS – Main Report



The development sequences for the deposits, over the full Project development, can be

summarised as follows:

















Rotret pit development in four pit phases:

o



Oxide pit development in two phases, southern part first;



o



Deeper pit development in two pit phases, southern part first.



Mafuri pit development in six pit phases:

o



Oxide pit development in two pit phases, first the wider area at west and then

along strike to east;



o



Deeper pit development in four pit phases, first the wider area at the west, then

the two pit phases along strike to east and final southern wall cutback along

strike.



Gafal pit development in six pit phases:

o



Oxide pit development in three pit phases from west to east (Gafal South last);



o



Deeper pit development in three pit phases from west to east (Gafal South last).



Matukia pit development in three pit phases:

o



Oxide pit development as a single phase;



o



Deeper pit development in two pit phases along strike, first stage located

centrally and second phase cutting final walls along strike.



Once the Rotret Pit and the third phase of the Mafuri Pit are complete, they will be backfilled

with waste rock from further expansion of the Gafal Pit and an extension of the Mafuri Pit to

3

the south-east. The Matukia Pit will be used to store 120 Mm of tailings towards the end of

the mine life.

Surface water management

Major drainage diversion works are required prior to and during the development of the Mafuri

oxide pit and Mafuri expansion towards Gafal open pit, as the eventual pit is likely to totally

cut across the Gafal stream. The proposed sequence of mining and backfilling of pits (filling

approximately 50% of the pit areas with waste and tailings material, reducing the area

required for the WRD) listed below will determine the timing for the various components of the

drainage diversion works required.





Development of the western part of the Mafuri pit first, making it available for waste

backfilling (from the development of eastern pit areas) after year 5;







Completion of Matukia pit by year 9, making it available for tailings storage for the rest of

mine life;







Completion of Rotret pit by year 10, making it available for waste backfilling from the later

pit phases in the Gafal West and Mafuri East areas; and







Completion of the Mafuri eastern and Gafal western pit boundaries (adjoining) last to

delay the Mafuri East stream diversion towards the end of mine life.



There are no major drainage routes crossing through the Gafal and Rotret open pits as they

are located mostly at higher ground. Significant flows are not expected through the two

streams crossing the Matukia pit as the catchment areas feeding these streams are small.

Major drainage works are however required for the development of Mafuri pit in phases,

preliminary plans for which are summarised below and depicted in Figure 4.6 to Figure 4.8.

U3823_Marampa_ESIS_Final.docx



September 2012

Page 50 of 244



SRK Consulting (UK) Ltd



Marampa Iron Ore Project ESIS – Main Report



Further detail on the water management plan for the mine will be developed during feasibility

studies.





A drainage channel (5 m width) will be required to divert the Mafuri West stream before

the start of mining Mafuri oxide pits (year 2). With the exception of a 200 m section

cutting through a hill, the drainage channel to the west of the pit boundary will be

generally shallow. Some sections of the channel will require bunding to divert the water

from the pit. The material excavated for construction of the channel (50 000 bcm) will be

used to construct this bund.







Excavation of a major drainage channel (maximum depth 10-12 m and length 600 m) at

the north of the Mafuri pit to divert the water from the Mafuri East stream before the

development of last phases of Mafuri and Gafal pits (~ year 8).







As the channel excavation at the north of Mafuri is completed, mining and waste

backfilling of the Mafuri pit in the central area will be finalised to allow diverted water to

cross the Mafuri pit. Suitable materials and construction methods will be used to seal the

channel over the waste backfill.







After the construction of the channels listed above (~year 8), the water flow in the main

Mafuri West stream will be diverted by means of a bund. This will cause damming to

approximately 3-4m depth in the lower catchment as the water level rises and flows

through the newly excavated channel further north.



The expected layout at the end of Stage 2 mining is shown in Figure 4.8.



4.2.3



Mining operations

Conventional open pit mining methods including drilling, blasting, loading and hauling will be

used. Ore will be transported from the pits via haul truck and taken directly to the

beneficiation plant area, located approximately 6 km from the pits. Mining will be conducted

on a 24 hour basis, with three crews working two 12 hour shifts.

The waste to ore strip ratio is expected to be 1.2 over the life of mine and approximately 0.4

when mining the oxide material (Stage 1). Where possible, waste material mined will be used

for the construction of access and haul roads, as well as for construction of the embankment

for the tailings storage facility.

Haul roads will generally be constructed to a width of 18 m. Underpasses will be required at

the Makeni Highway in two locations, one to the west of Lunsar and the other to the east of

Lunsar (see locations on Figure 4.1). The haul roads will be designed to achieve a haulage

level a few meters above the maximum standing water level.

Blasting activity during the mining of oxide material will be minimal, with the rate of activity

increasing as the mining of fresh ore (Stage 2) commences and would generally occur during

the day time only. Blasting is likely to utilise ammonium nitrate-fuel oil (ANFO) as a bulk

explosive and non-electric surface and down hole delays. Each hole will be stemmed prior to

blasting.



U3823_Marampa_ESIS_Final.docx



September 2012

Page 51 of 244



SRK Consulting (UK) Ltd



Marampa Iron Ore Project ESIS – Main Report



Figure 4.6: Layout for Stage 1 mining, showing preliminary surface water management design

U3823_Marampa_ESIS_Final.docx



September 2012

Page 52 of 244



SRK Consulting (UK) Ltd



Marampa Iron Ore Project ESIS – Main Report



Figure 4.7: Layout for Stage 2 mining, showing preliminary surface water management design



U3823_Marampa_ESIS_Final.docx



September 2012

Page 53 of 244



SRK Consulting (UK) Ltd



Marampa Iron Ore Project ESIS – Main Report



Figure 4.8: Layout at end of mine, showing backfilled pits and preliminary surface water management design

U3823_Marampa_ESIS_Final.docx



September 2012

Page 54 of 244



SRK Consulting (UK) Ltd



Marampa Iron Ore Project ESIS – Main Report



Preliminary hydrological and hydrogeological studies indicate major dewatering operations will

be necessary to manage the combination of rainfall runoff and groundwater inflow.

Dewatering requirements, based on seasonal conditions, will range from less than

3

3

10,000m /d to greater than 40,000m /d at maximum pit development. Dewatering is likely to

be achieved through a combination of groundwater abstraction ahead of mining, and in-pit

sump dewatering. The excess water will pumped to settlement ponds before release to the

natural water courses that drain to the Rokel River with a proportion directed to the TSF

during the dry season.



4.2.4



Mining equipment

The preliminary estimates of the mining equipment required for the production schedule is

provided in Table 4-3. The numbers may vary slightly over the mine life depending on the ore

and waste haul distances. The truck requirements per excavator are relatively high due to the

6 km ore haulage to the plant site and generally low waste to ore ratios. Based on 300 mining

days per year (assuming about 60 days lost due to high rainfall), it is estimated that up to

about 85 kt ore would need to be transported per day from the pit to the beneficiation plant

(requiring approximately 350 movements in a 240 tonne truck), and 120 kt rock waste per day

(requiring approximately 500 truck movements between the pits and the waste rock dumps).



Table 4-3: Mining equipment

Mine development Stage



Stage 1



Stage 2



Liebherr R984C Excavator



2



2



Caterpillar 777D/F D/Truck



12



16



Liebherr R995 Excavator



6



Caterpillar 793 D D/Truck



48



Cat D10T Dozer



2



8



Cat 16M Grader



1



6



Cat 773D WT Water truck



2



6



Caterpillar 992 FEL



1



2



Tamrock Drill



1



2



Reedrill SKSS Drill



2



8



The workshop for servicing the mining equipment will be located to the north of Mafuri Pit

(location shown on Figure 4.1) and include 5 maintenance bays and a washdown bay. If the

wash down only involves the removal of external dirt and dust, a sedimentation process will

be used to reduce the total suspended solids content before discharging the waste water. If

machinery, engines, engine parts and other equipment are being cleaned, then the washdown

bay will drain through an appropriate filtration system consisting of a holding tank and

oil/water separator.

Hazardous materials (reactive, flammable, corrosive and toxic) will be stored in clearly

labelled containers (in a designated storage area) and vehicles. Storage and handling of

hazardous materials will be in accordance with local regulations, and appropriate to their

hazard characteristics. Fire prevention and secondary containment will be provided for the

workshop and storage facilities.



4.2.5



Explosives storage

The daily bulk explosive requirement for the mining operations will be minimal during the



U3823_Marampa_ESIS_Final.docx

Page 55 of 298



SRK Consulting (UK) Ltd



Marampa Iron Ore Project ESIS – Main Report



Stage 1 mining operation. For Stage 2 it will vary between 25-40 tonnes per day, depending

on the depth of the pits and strength of the rocks mined. Approximately two weeks supply of

bulk explosives will be stockpiled at the site in a purpose built shed, the location of which is

indicated close to the Gafal waste dump on Figure 4.1. The shed will be designed, structured,

ventilated and secured based on Australian standards (AS 2187) or other acceptable

international standards. It is expected that approximately 1-2 bulk explosives trucks will arrive

to site daily for 4-5 days of the week, with detonating explosives and other accessories

transported every 1-2 weeks,

A steel container transportable explosives magazine, built to industry standards, will be

located away from other installations and critical infrastructure. The magazine will be secured

for access to authorised personnel only, ventilated sufficiently, provided with adequate lighting

and electrical wiring in compliance with regulations.

The detonators and explosives for the site will be transported separately in containers and

vehicles built to appropriate standards. Licensed professionals and equipment and a

sufficient level of security personnel and equipment will be employed during the transport of

the explosives. The explosives at the site will be handled by the licensed shot firers and

appropriate equipment will be used in transportation and installation before the blasts.

The explosive storage areas will be located and drained adequately to prevent any flooding.

The explosives magazine will be effectively earthed against lightning. The explosive

structures will be marked clearly in the site plans, and the facilities and equipment will be

clearly signed for identification.



4.2.6



Waste rock dumps

Excavated waste rock over the life of the mine is estimated to total approximately 612 Mt

(Table 4-1), and will initially be transported via haul trucks to four WRDs, one adjacent to each

pit. The exact configuration of the WRDs will depend on the final pit outlines, though the

dumps are currently anticipated to have an average height of between 15 and 20 m above

natural topography during Stage 1, increasing to 50 m in height by the end of mine life. In

addition to the external waste dumps, a total of approximately 200 ha of earlier mined out pits

will be backfilled progressively with the waste mined from later pit stages.

The approximate areas of disturbance for each of the final waste dumps are as follows:





100 ha



Gafal waste dump







100 ha



Mafuri waste dump







350 ha



Matukia waste dump







250 ha



Rotret and Gafal waste dump







800 ha



Total area required for external waste dumps



During Stage 1, a relatively large amount of laterite low grade ore will need to be stockpiled.

This stockpiled laterite material will be reclaimed during the Stage 2 operation and blended to

make up 10% of the process plant feed. It is proposed that the ROM and long-term stockpile

area will be used for this purpose. The preliminary estimate of area requirement for the ROM

pad and long term ore stockpiles is approximately 100 ha.

The waste dumps will be constructed in 20 m lifts as the final face slopes are formed

progressively as each lift reach the area limits. The waste dump face slopes will be less than

20 degrees with 10 m wide berms located between 10-20 m vertical intervals to prevent

erosion from high rainfalls. The overall slope of the waste dumps will be 16-18 degrees.

U3823_Marampa_ESIS_Final.docx

Page 56 of 298



SRK Consulting (UK) Ltd



Marampa Iron Ore Project ESIS – Main Report



Any waste that might be an environmental concern and any oxide waste that might be a

stability concern will be dumped internally within the dumps and covered with neutral waste to

protect against weathering. Geochemical investigations have been completed on expected

waste rock samples from the four pits, as well as the expected ore, concentrate and tailings

materials and reveal low potential for acid generation. Leaching of metals from the waste rock

is also unlikely (although further geochemical assessment will be conducted to confirm this).

Drainage channels will be constructed around the waste dump areas and through the waste

dump slopes, as necessary, to direct the surface water flow to the settlement ponds. The

settled water in the ponds will be released to environment with regular water quality tests

performed to monitor the quality of the discharge. If the water in the pond exceeds the agreed

water quality standards, it will be contained until it complies or redirected to the TSF.



4.2.7



Topsoil

Topsoil recovered from the pit and waste dump areas will be stored separately and used for

the rehabilitation of the waste dump surfaces and other structures.



4.3



Processing

The beneficiation plant will consist of facilities and areas for crushing, stockpiling, ore

reclamation, grinding, wet high intensity magnetic separation (including roughing and

scavenging, regrinding, cleaning and recleaning), concentrate thickening and filtration, tailings

thickening and utilities, and reagent storage. The general arrangement of the beneficiation

plant (showing the components for Stage 1 and the additional components for the Stage 2

7

expansion) is shown on Figure 4.10 . The TSF and rail loading spur will be located close to

the beneficiation plant (Figure 4.1).



4.3.1



Stage 1 Beneficiation Plant

During Stage 1, processing will treat oxide ore only to nominally produce 2.5 Mtpa of iron ore

concentrate, although the actual production output will be matched to the tonnage of sales in

place at the time. The process flowsheet for Stage 1 is shown schematically in Figure 4.9.

Parts of the Stage 1 process plant will be constructed at a larger capacity, to facilitate the

Stage 2 expansion. The Stage 1 process plant will include the following key components,

shown on Figure 4.10:





5 Mtpa primary crushing module;







2.5 Mtpa wet scrubbing module;







2.5 Mtpa Wet High-Intensity Magnetic Separation (WHIMS) plant;







5 Mtpa concentrate thickener;







5 Mtpa tailings thickener;







2.5 Mtpa concentrate pressure filtration facility;







1,000,000 tonne linear product stockpile including stacking equipment; and







A rail spur to connect to the Project to the existing Tonkolili to Pepel railway line.



Oxide ore will be hauled from the pits to the beneficiation plant and deposited by haul truck

either directly into the primary crusher, or stockpiled on the ROM ore pad before being loaded

by front end loader into the primary crusher. The primary crushing plant will consist of sizers



7



Note the pipeline to Tagrin port shown on this layout plan is not included in the scope of this ESIA



U3823_Marampa_ESIS_Final.docx

Page 57 of 298



SRK Consulting (UK) Ltd



Marampa Iron Ore Project ESIS – Main Report



(toothed rolls crushers) to reduce the ore to rocks of less than 250 mm. The ore will then be

fed by conveyor to a rotary wet scrubber where it is further reduced in size to 850 µm.

Scrubbed material will be pumped directly to the rougher magnets within the WHIMS circuit.

Scrubber oversize material will be directed to a temporary stockpile and will be processed

through the comminution circuit for the fresh ore, when it is installed in the Stage 2

beneficiation plant.

The scrubbed ore will be processed initially via three sequential stages of WHIMS including

initially, two stages of roughers and a scavenger stage. The scavenger WHIMS units will be

operated at higher field strength to maximize overall iron recovery. The non-magnetic fraction

from the scavenger stage will be the final beneficiation plant tailings stream, which will be

thickened prior to disposal to the TSF. The scavenger concentrate will be reground to a top

size of 180 µm before recycling to the first stage rougher WHIMS unit to optimize iron

recovery from the beneficiation plant.

The concentrates from both the rougher stages will be screened at 250µm, with the -250µm

fraction reporting directly to the cleaner WHIMS units. The +250µm fraction will undergo

regrinding in closed circuit with a 250µm screen before proceeding to the cleaner WHIMS

magnets. The cleaner tails will be directed back to the rougher WHIMS, whilst the cleaner

concentrate passes to the recleaner stage. The final concentrate product from the recleaner

stage will have an iron grade of approximately 65% iron with low levels of deleterious

elements. The recleaner tailings are returned to the cleaner magnetic separators.

All of the WHIMS magnetic separators require significant amounts of wash water to remove

the magnetic fraction from the WHIMS magnet matrix. The concentrate fractions will be

dewatered using hydrocyclones, and the cyclone overflow streams will be recycled within the

plant as wash water.

The final concentrate is flocculated and thickened to approximately 65% solids via a

conventional thickener and then pumped to three agitated slurry holding tanks of

3

approximately 4,580m each with surge capacity to store concentrate for approximately 20

hours of plant operation. The clear thickener overflow will be returned as wash water for the

cleaner and recleaner magnetic stages. From the holding tanks, thickened product will feed a

pressure filtration plant for dewatering. The filter cake (with a moisture content of

approximately 8%) will be stacked onto 1,000,000 tonne linear stockpiles adjacent to the rail

siding. Front end loaders will recover the product from these stockpiles for loading into the

rail cars, for transport to Pepel port.

Supernatant water from the TSF will be recovered and recycled within the beneficiation plant.



4.3.2



Stage 2 Beneficiation Plant expansion

During Stage 2, processing will continue to treat oxide and/or fresh ore to nominally produce

up to 15 Mtpa of concentrate. The process flowsheet for the full Project (Stage 2) is shown

schematically in Figure 4.9. The Stage 2 expansion will generally replicate the Stage 1

process plant modules, but will also add a secondary and tertiary crushing and screening

plant to process the harder fresh ore material (Figure 4.10).



U3823_Marampa_ESIS_Final.docx

Page 58 of 298



SRK Consulting (UK) Ltd



Marampa Iron Ore Project ESIS – Main Report



Figure 4.9: Schematic process flow diagram for Stage 1

U3823_Marampa_ESIS_Final.docx



September 2012

Page 59 of 298



SRK Consulting (UK) Ltd



Marampa Iron Ore Project ESIS – Main Report



Figure 4.10: Schematic process flow diagram for Stage 2 (full development)

U3823_Marampa_ESIS_Final.docx



September 2012

Page 60 of 298



SRK Consulting (UK) Ltd



Marampa Iron Ore Project ESIS – Main Report



The expansion will add the following key components at the beneficiation plant:





2 x 5 Mtpa primary crushing modules;







1 x 2.5 Mtpa wet scrubbing module;







3 x 5Mtpa secondary / tertiary crushing and screening modules;







3 x fine ore stockpile stacking equipment and six fine ore stockpiles, including 6 x 2.5

Mtpa tunnel reclaim systems;







6 x 2.5Mtpa primary ball milling modules;







5 x 2.5 Mtpa WHIMS plant;







2 x 5 Mtpa concentrate thickener;







2 x 5 Mtpa tailings thickener;







2.5 Mtpa concentrate pressure filtration facility; and







4 x concentrate slurry storage tanks.



Oxide ore will continue to be processed as described in Section 4.3.1, but at an increased

capacity of concentrate production. Fresh ore will be blended with a minor component of

laterite ore and fed from the primary crusher directly to the secondary / tertiary crushing and

screening plant. The crushed -10mm product from this plant will then be discharged to fine

ore stockpiles for temporary storage. Tunnel reclaimers will recover the fine ore from the

stockpiles and convey it to the primary ball milling circuits. The primary ball mills will operate

in closed circuit with vibrating screens, creating a milled product finer than 850µm. This will

then proceed to the rougher magnets in the WHIMS circuit. From here the two ore types are

processed in the same way, following the description in the section above.

During Stage 2, 1.8 Mtpa (or up to 3.4 Mtpa) of concentrate will continue to be railed to and

stored at Pepel, for subsequent export, while the remaining concentrate will be exported via

the port of Tagrin.

The entire plant will be controlled using modern instrumentation including magnetic

flowmeters, level sensors, density control systems (non-radio-active), automated valves,

variable speed motors, etc. These units will be integral components to a computer operated,

intelligent process logic control system, which will be managed by trained beneficiation plant

operators from central Control Rooms situated within the plant.



4.3.3



Reagents

As the processing circuit is largely based on physical separation techniques, few chemical

reagents are required. The only reagent required is flocculant, which is used to thicken the

concentrate and the tailings to accelerate the settling of fine solids out of the slurry. Other

materials used in the process are described in Table 4-4. The reagents storage area at the

beneficiation plant is shown on Figure 4.11 as item 13 and on Figure 4.12 as item 20.



U3823_Marampa_ESIS_Final.docx



September 2012

Page 61 of 298



SRK Consulting (UK) Ltd



Marampa Iron Ore Project ESIS – Main Report



Figure 4.11: Beneficiation plant layout for Stage 1



U3823_Marampa_ESIS_Final.docx



September 2012

Page 62 of 298



SRK Consulting (UK) Ltd



Marampa Iron Ore Project ESIS – Main Report



Figure 4.12: Beneficiation plant layout, showing Stage 2 expansion

U3823_Marampa_ESIS_Final.docx



September 2012

Page 63 of 298



SRK Consulting (UK) Ltd



Marampa Iron Ore Project ESIS –– Main Report



Table 4-4: Reagents and other materials likely to be used in the beneficiation plant

Name



Use



Hazard

*

rating



Quantity

used (t/a)



Containers



Flocculant Anionic type



Concentrate thickener– to

accelerate solids settling



Non

hazardous



20 grams

per tonne

of solids



1 Tonne Bulk

Bags



Flocculant Anionic type



Tailings thickener – to

accelerate solids settling

process



Non

hazardous



20 grams

per tonne

of solids



1 Tonne Bulk

Bags



Equipment oil, coolants

and hydraulic fluids



Mobile equipment and

vehicles



Hazardous



TBD



200 L drums



* Classification is based on the United Nations (UN) Recommendations on the Transport of Dangerous

Goods - Model Regulations (UN, 2009)



4.4



Tailings storage facility

A TSF will be constructed in two phases, as shown in Figure 4.1, and will store tailings for the

first 12 years of the operation. Following this period, tailings will be stored within the mined

out Matukia Pit.



4.4.1



Tailings and TSF decant water pipelines

Tailings material and TSF decant water will be transported to and from the TSF respectively

via HDPE pipelines (1 km pipeline in each direction). The pipelines will be above ground, but

buried under a protective soil mound, and if stream crossings are required these will be

handled via bridges. No pump stations will be required along the pipelines



4.4.2



TSF design

A conventional multiple cell valley-type TSF will be constructed across three adjacent valleys

north of the processing facilities (figures showing the proposed layout of the TSF and

embankment wall construction can be found in Appendix E. The final configuration of the

facility will cover 750 ha and will have the capacity to store approximately 200 Mt of tailings.

The facility will be constructed in stages, using perimeter embankments around the four sides

of the facility along ridgelines. The starter embankments of the TSF will be constructed to a

maximum height of 23 m, and will be raised by upstream construction techniques in stages (3

x 5m lifts) to a maximum embankment height of 38 m, with a nominal freeboard of 5 m. The

facility will be unlined due to low permeability of in-situ bedrock.

Construction materials for the starter embankment will include clayey gravel sourced from

borrow areas within the final TSF footprint. Borrow material from within and outside the

footprint will also be used for upstream construction and mine waste may also be used during

the later years of the facility life.

A decant system and under drainage will be constructed to recover supernatant water from

consolidation of the tailings material. At start-up, the decant system will consist of temporary

pumps (land based or floating pontoon mounted). After Year 3 a fixed pump decant within

each TSF cell will be utilised for supernatant water recovery. The decant towers will comprise

slotted pipes stacked vertically and surrounded by clean filter rock. The decant towers will be

raised along with the perimeter embankments. Access to the decant facilities for light

vehicles and maintenance equipment will be via a decant access way constructed from

gravelly borrow materials or mine waste. Return water will be pumped back to the plant for

re-use in the process.



U3823_Marampa_ESIS_Final.docx



September 2012

Page 64 of 298



SRK Consulting (UK) Ltd



Marampa Iron Ore Project ESIS –– Main Report



An under drainage system will also be constructed to assist in the recovery of water, reduce

the potential for seepage losses and to prevent embankment failure. The under drainage

system will comprise a collection trench positioned upstream of the main embankments that

will drain to pump sumps. Pumps deployed down an inclined borehole will allow recovery of

water. The under drainage lines will typically comprise a shallow geotextile lined trench

backfilled with coarse aggregate. At the top of the trench geotextile will be wrapped and

stabilized with select rock. Water collected in the under drainage system will be pumped to

the decant area and hence back to the plant for re-use in the process.

The TSF will be designed such that upslope catchment areas will be small to limit watershed

(clean) run-off into the tailings area. Runoff will be by incident precipitation only. The facility

will be designed to contain a 1 in 1000 average recurrence interval three-day precipitation

event, whilst maintaining a freeboard of at least 0.3 m. As it is situated on an elevated area

relative to its surroundings, stormwater flow will naturally be directed away from the TSF.

Management of stormwater on the TSF will therefore not be required.

Table 4-5: TSF design criteria

Design component



Criteria



Throughput



22.8 Mtpa (max)



Solids content



60% (by weight)



Density

Seismic



Hydrology



4.4.3



Dry density 1.5 t/m³

²



Operating basis earthquake loading



0.06g (0.6 m/s )



Post-closure maximum credible

earthquake loading



0.1g (0.1 m/s²)



Embankment levels



Will contain design storm event while

maintaining 0.3 m freeboard



Design storm



1 in 1000 year return 3-day

precipitation event



TSF operation

Tailings will be deposited using sub-aerial deposition techniques from multiple spigot locations

located on the main and saddle embankments. At start-up, tailings deposition will be from the

main (northern) embankment, which will lead to the formation of a beach up the valleys,

moving in a south westerly direction. Temporary pumps for supernatant water recovery will

move up the valleys as the tailings and water levels rise.

The location of tailings spigots will be changed as required to ensure tailings beaches slope

towards the decant area and to direct the supernatant water pond away from the containment

embankments and maintain it around the decant facilities. The pond will be minimized as far

as practicable (while maintaining enough water to keep the tailings material moist and thereby

prevent tailings dust generation) to reduce evaporation and maximise water return.

Once the TSF is fully operational, water volumes surplus to plant and site requirements will be

removed from the TSF and discharged downstream via silt traps / constructed wetlands.

Discharge of water will be required to maintain constructability of the proposed upstream

embankment raising construction method and also embankment stability. Embankments,

tailings delivery and deposition, and water recovery systems will be inspected frequently by

an operator or shift supervisor (at least once per production shift) to limit operational

problems. Groundwater quality and quantities will be monitored frequently and the design

and operation of the TSF will be inspected by a qualified geotechnical engineer at least once

per year.



U3823_Marampa_ESIS_Final.docx



September 2012

Page 65 of 298



SRK Consulting (UK) Ltd



Marampa Iron Ore Project ESIS –– Main Report



As the TSF is situated on an elevated area relative to its surroundings, storm water flow will

naturally be directed away from the TSF. Management of storm water on the TSF will

therefore not be required. An emergency spillway will be installed as part of the TSF design to

manage discharge, should this occur.

Geochemical characterisation of the tailings material (ARDML potential) has indicated that it is

unlikely to generate acidity, but will also have limited buffering capacity. Net Acid Generation

(NAG) test leachate analysis of tailings samples also revealed little potential for leaching of

iron or trace metals from the metallurgical samples. For further detail refer to Marampa Iron

Ore Project ARDML Baseline Assessment Report (SRK Consulting, 2011), included in SD 6

of Volume 3.



4.5



Power supply

Power will be supplied to the Project using HFO generators, which will be introduced in stages

to match the staged development of the Project. A power station will be constructed close to

the beneficiation plant and rail spur line (Figure 4.1) and will be sized in accordance with the

details in Table 4-6.

Table 4-6: Power station capacity and requirements

Stage 1 (MW)



Stage 2 (MW)



Demand



Installed



Demand



Installed



22



45



115



145



The average HFO consumption would be approximately 4 t/h, based on an average specific

fuel consumption of 190 g/kWh. The HFO will be stored in steel tanks contained within a

3

bunded facility. The tanks will be sized to provide 1 month of total storage capacity (3,000 m

3

for Stage 1 and 15,000 m for Stage 2). HFO will be delivered to site by means or road

tankers owned and operated by a third party supplier.

Power will be generated at a medium voltage of 11 kV and will be distributed to the various

load centres at the same voltage. Each load centre will consist of a step down transformer(s)

and Motor Control Centres (MCC’s). The Low Voltage power supply will be reticulated at

550 V.

As the majority of the power usage will be within the beneficiation plant, the power plant will

be located as close as possible to minimise the length of transmission lines, and hence

maintenance, energy losses and probability of outages.



4.6



Water supply

To reduce the demand on local water sources, the majority of the water used in the process

will be sourced from rainfall captured in the TSF. A preliminary water balance established for

3

the Project, indicates that approximately 8,000m of make-up water per day would only be

required during the dry season. The maximum demand is estimated at approximately 1250

3

m /hr.

During the dry season the plant make-up water will be pumped from a newly constructed

pumping station on the Rokel River, positioned to the south of the plant (exact location yet to

be identified). Once the Project is operational, containment, controls and mine dewater input



U3823_Marampa_ESIS_Final.docx



September 2012

Page 66 of 298



SRK Consulting (UK) Ltd



Marampa Iron Ore Project ESIS –– Main Report



will provide routine closed cycle use, with top-up from the river supply if and when required.

The pump station at the Rokel River will contain electric pumps that will pump water via a

buried HDPE pipeline to the plant site. The water at the plant site will be stored in 2 steel

3

tanks, each 5,000 m capacity, from where it will be distributed.

Raw water will be clarified and filtered for use as potable water. Potable water will be

distributed to the plant and to a header tank in the accommodation village.

Details of the proposed water storage facilities for the mine site are provided in Table 4-7. As

indicated in Figure 4.13, four settlement ponds (one downstream of each open pit and WRD)

are included to manage stormwater runoff. Additional ponds may be required at the

beneficiation plant, long-term stockpile area and TSF, but the size and location of these ponds

is yet to be confirmed.

Table 4-7: Water storage facilities

Facility



Location



Storage

capacity



Raw

water tank



Beneficiation

plant



2 x 20,000m



3



Structure



Water source(s)



Destination (and

final use of water)



Steel

tanks











Pumped from

Rokel River











Process

water tank



Beneficiation

plant



2 x 20,000m



3



Steel

tanks



















Raw water Tank

Thickener tank

overflow

Reclaim water

from tailings

dewatering plant

Storm run-off

from collection

pond/s

Effluent from the

sewage treatment

plant

Reclaim from

TSF

Storm water

runoff (and pit

dewatering water

in the case of the

pit, if required)











Beneficiation

plant

Potable water

treatment

system

Fire water

system

Mine site fresh

water tank

Plant (process

water)



Transferred to

the process

water tank

Evaporation

Possible

discharge if

quality suitable



Storm

water

settlement

ponds



Mine pits

and WRD;

Beneficiation

plant,

stockpile

area and

TSF



50m x 200m;

Designed to

store 1:10 year, 24-h

storm event

during

operation



Excavated

pond



Mine

camp

potable

water tank



Mine camp



TBD



Steel tank







Potable water

treatment plant







Accommodation

camp



Mine site

raw water

tank/s



Mine area



TBD



Steel

tanks







Raw water tank







Dust

suppression



U3823_Marampa_ESIS_Final.docx









September 2012

Page 67 of 298



SRK Consulting (UK) Ltd



Marampa Iron Ore Project ESIS – Main Report



Figure 4.13: Site layout for end of mine showing locations of settlement ponds and water storage reservoir

U3823_Marampa_ESIS_Final.docx



September 2012

Page 68 of 298



SRK Consulting (UK) Ltd



4.7



Concentrate transport



4.7.1



Stage 1 development



Marampa Iron Ore Project ESIS – Main Report



During Stage 1, iron concentrate will be transported from the mine site to the Pepel port by

way of an existing railway between Marampa and the port of Pepel. The railway and the port

itself have been refurbished and placed back in to operation. Both facilities are owned and

operated by African Railways and Port Services Ltd (ARPS), a subsidiary of AML. MIOL has

an access agreement with AML for access to the rail and port facilities at Pepel.

Spur line

A 3.0 km spur line (shown in Figure 4.1 with additional detail in Figure 4.11) will be built to

connect the Project with the existing railway at chainage 71 km (from Pepel Port). The line

will be a single turnout from the main line. Incoming (empty) trains would pass directly

through the junction along the spur line and on into the load out siding. A departure loop

parallel to the spur line will be required to hold trains awaiting access to the mainline. A

‘Points man’ station will be required at the north end of the loop to control switching into and

out of the main line as well as the switch from the departure loop.

Load out area

Returning empty trains will enter the load out siding head on. The locomotives will be

decoupled from the wagons and will continue on a loop to re-join the wagons on the western

end. The newly loaded train will leave the load-out area head on and will run to the departure

loop prior to being released onto the main line. Switches in the siding area will be operated

by manual levers.

The load out area, shown in Figure 4.11, will include an 850 m-long track and a loading apron

of 10m width from which front end loaders will load the wagons. The loading apron will be

constructed on a suitably compacted sub base. Two 500,000 T linear product stockpiles will

located to the rear of the apron parallel to the track. The loaders will take material from the

part of the stockpile nearest the wagon being loaded.

Rolling stock

The rolling stock for ore transport will be supplied by AML, as part of the rail and infrastructure

agreement with MIOL.



4.7.2



Stage 2 development

During Stage 2, it is anticipated that product export as described for Stage 1 will continue, but

that the additional 13.2 Mtpa iron ore concentrate will be pumped to Tagrin Port via pipelines.

Details of the pumping system, dewatering and other activities associated with product export

will be described in the future amendment of this ESIA document.



4.8



Other site infrastructure and services



4.8.1



Roads and freight

Site roads

Roads will be constructed to connect the various components of the operation. Two large

haul roads will be required to transport ore from the Matukia Pit and the Rotret, Mafuri and



U3823_Marampa_ESIS_Final.docx



September 2012

Page 69 of 298



SRK Consulting (UK) Ltd



Marampa Iron Ore Project ESIS – Main Report



Gafal pits to the processing area. Each one of these haul roads will be approximately 6 km

long and the routes are shown on Figure 4.13. Smaller roads will also be required at the

beneficiation plant for light vehicles.

Two new road crossings will be required where the haul roads from the Gafal Pit and Matukia

Pit will cross the Makeni Highway. In these areas the Makeni highway will pass over multiplate arch culverts, through which the haul trucks will pass (see Figure 4.1 for the locations

and design detail of these road crossings).

The roads will be constructed from Laterite, which is naturally occurring in the upper soil

profile of the site. Preliminary investigations have confirmed the suitability of the in-situ

material for road construction. Water trucks will be used to minimise dust on the haul roads

during the dry season.

Freetown-Lunsar road

Inbound freight will travel from Freetown port to Lunsar via an existing sealed road (the

Makeni Highway). Specialized equipment will be supplied by the freight forwarder and

clearing agent to transport any oversized equipment to the site.



4.8.2



Storm water management

The high rainfall during the wet season will require effective drainage networks for process

and accommodation facilities. A water management plan will be developed to provide a

strategy for segregating two categories of water, defined either as impacted or non-impacted

(clean) water. Impacted water refers to run-off that potentially has low pH (acidic) or contains

elevated levels of naturally occurring metals or high sediment loads. Storm water settlement

ponds will form part of the drainage network to collect this impacted water. They will be sized

in accordance with EHS guidelines.

During normal operations, the sediment ponds will be cleaned out during the dry season, with

the collected sediment placed on the waste dumps for long term storage.



4.8.3



Waste management

A waste management plan will be implemented that:





Minimises waste generation by efficient use of resources;







Reduces the volume of

recycling;







Contains and isolates waste from groundwater and surface water, and enables storage,

treatment or collection of waste that does not result in long term impacts on the

surrounding environment; and







Minimises the environmental impacts of waste hydrocarbons and chemicals through

appropriate storage, handling and disposal.



unavoidable waste through product selection, re-use and



The types of wastes generated by the Project will include:





General Waste:

-







Domestic waste (e.g. plastic, paper, workshop wastes and domestic solid and food

wastes);

Construction and industrial waste (wood, scrap metal, tyres, rubber, lights, batteries);

Sewage.



Hazardous Waste:



U3823_Marampa_ESIS_Final.docx



September 2012

Page 70 of 298



SRK Consulting (UK) Ltd



-



Marampa Iron Ore Project ESIS – Main Report



Hydrocarbons (engine oils, lubricants etc.);

Medical waste;

Plant maintenance related chemicals (although only in small amounts).



Domestic and industrial waste will be disposed of in a dedicated landfill site built for the

purpose. Containerised sewage treatment plants will be used to handle sanitary waste water,

which will be installed at the beneficiation plant/office area, as well as the accommodation

camp. During construction, the village plant units will serve the construction camp. The

sewage treatment plants will be sized to accommodate the number of people working at the

Project.

Hazardous materials and waste will be stored in accordance with international standards.

Procedures will be prepared for the correct handling and storage of hazardous materials,

including the disposal of hazardous waste. Hazardous waste will be removed from site by a

licensed contractor for disposal in an approved facility, in accordance with the requirements of

controlled waste regulations.



4.8.4



Communications

Initial site communications during the early phases of construction will be via satellite. During

construction a mobile phone tower will be installed in a suitable position to enable coverage

across the operational mining area including the accommodation village, mining area and

beneficiation plant.

Telephone and data network cables will service the site and

accommodation village and will be buried.



4.8.5



Accommodation

For Stage 1, a 115-man staff village / accommodation camp will be constructed to

accommodate operational expatriate and senior national staff. The camp will be expanded to

accommodate a total of approximately 210 personnel for Stage 2 of the development. The

staff village is shown on Figure 4.1 and will consist of:





General Manager’s quarters;







Senior Manager quarters;







Manager quarters;







Messing and laundry facilities; and







Recreational facilities.



Operator level and junior supervisors will be sourced and/or housed within the existing

facilities in Lunsar. Buses will be utilised to transport personnel to the site. During the

construction phase, contractors will make provision for temporary facilities to house their

personnel.



4.8.6



Medical services

A clinic will be constructed near the beneficiation plant, to be manned by an expatriate

paramedical team, assisted by local medical professionals. The clinic will be fitted out to

provide standard general practice patient care and to provide stabilisation of patients who

may be injured in an accident. Injured patients, once stabilised, will be taken by ambulance to

either the Lunsar hospital or medivac’ed to Freetown to the better equipped hospitals.



U3823_Marampa_ESIS_Final.docx



September 2012

Page 71 of 298



SRK Consulting



Marampa Iron Ore Project ESIS – Main Report



Table 4-8: Management of non-mining wastes

Wastes



Temporary storage



Potential waste recycling



Waste treatment



Disposal



Domestic waste



Non-hazardous waste transfer station



Paper, wood products, plastics and

metals recycling



Landfill



Organic waste



Non-hazardous waste transfer station



Composting



Landfill



Tyres



Non-hazardous waste transfer station



Recycling



Scrap – such as scrap metal, wood

waste, worn conveyor belt, used wear

liners



Non-hazardous waste transfer station

(specifically demarcated containers)



Recycling



Landfill



Inert construction material and

demolition debris



Non-hazardous waste transfer station

(stockpiles)



Donate to local community



Landfill



Storage drums



Non-hazardous waste transfer station



Returned to suppliers or recycling



Sewage sludge



Wastewater treatment systems



None



Flue gas desulfurisation waste; spent

filter fabric and associated solids from

HFO plant



HFO plant



None



HFO sludge



Hazardous waste storage depot



None



Spent oil and lubricants



Hazardous waste storage depot



Recycling



Soils contaminated with hydrocarbons



Hazardous waste storage depot



Use in rehabilitation (once treated)



Clinic waste/ medical waste



In clinic in containers



None



By approved contractor



Hazardous waste from the plant area

and laboratory (including empty

storage containers)



Hazardous waste storage depot



None



By approved contractor



Non-hazardous waste



Landfill



Hazardous waste



U3823_Marampa_ESIS_Final.docx



By approved contractor

Bioremediation and then use for

rehabilitation



September 2012

Page 72 of 298



SRK Consulting



4.8.7



Marampa Iron Ore Project ESIS – Main Report



Fire fighting

Buildings and locations of flammable materials will be fitted with fire extinguishers. A fire

water system will be installed consisting of fire hydrants, hose reels, a sectional pressed steel

tank, electric fire pumps (one operating, one on standby), an electric jockey pump and a

diesel engine driven emergency pump with auto start and control system. The pumps will start

automatically in the event of a pressure drop in the pipeline, indicating a hose reel or hydrant

valve has been opened. Fire water will be distributed in a ring main to the plant and to the

accommodation village.



4.8.8



Mobile Equipment

The following table summarises a preliminary estimate of the number and types of mobile

equipment (additional to the mining equipment listed in Table 4-3) allowed for as a permanent

fleet:

Table 4-9: Mobile equipment list for site operation

Number provided

Vehicle

LDV/Utility vehicles



4.8.9



Stage 2

(additional)



Stage 1

38



14



Fire truck



1



Ambulance



1



Mobile crane – 50 t



1



Mobile crane – 20 t



1



1



Skid steel loader



2



2



Front end loader



4



Flat bed truck – 5 t



4



Tractor trailer



2



Forklift – 5 t



3



Buses – 54 seater



4



Waste skip trailer



1



Rail load out Front end loaders



3



2



Fuel use and storage

Fuel will be stored on site during the construction and operation of the Project. Fuel will be

stored in steel tanks at the beneficiation plant (see location on Figure 4.11 (item 16) and

Figure 4.12 (item 23)) and contained in bunded enclosures, designed to international

standards, to prevent any contamination of the environment. Two types of fuel will be

consumed at the site:





HFO - for the power generating facility (Section 4.5); and







Diesel fuel - for use in the mining fleet (Section 4.2.4) and mobile fleet (Section 4.8.7).



The storage facilities for HFO and diesel will be designed to provide a minimum of one month

3

3

operating capacity (3,000 m of each fuel type for Stage 1 and 15,000 m for Stage 2). It is

assumed that consumption (and therefore storage capacity) of HFO will approximately equal

that of diesel. Fuel will be supplied by road tankers from Freetown using third party suppliers.



4.8.10 Security





MIOL will provide its own security for the site. The accommodation camp, process plant,



U3823_Marampa_ESIS_Final.docx



September 2012

Page 73 of 298



SRK Consulting



Marampa Iron Ore Project ESIS – Main Report



office and workshop areas will be fenced (all other areas will be unfenced).



4.8.11 Ancillary buildings

The following buildings have been allowed for in the design:



4.9







Compressor house;







Offices / administration building;







Laboratory (with the capacity to process 100 samples per day, and including areas for

sample preparation, equipment and two offices);







Workshops and maintenance facilities;







Process equipment store;







Reagents / oil stores;







Refreshment and rest room facilities at the plant (for approximately 30 operators,

maintenance and warehouse staff);







Dining / recreation area;







Change house and laundry;







Clinic and fire station;







Communications centre / radio or satellite links; and







Security entrances – plant and accommodation camp.



Project implementation

This section outlines how the Project will be successfully implemented if approval to proceed

is received from the MIOL board and relevant regulatory authorities.



4.9.1



Project milestones

Subject to raising sufficient funds to finance the construction of the Stage 1 development, it is

expected that the Stage 1 operations will commence within 2 to 3 years of the Mining Licence

being granted.

While the Stage 1 development is in progress, the Company will conduct a feasibility study on

the Stage 2 expansion, with the target, subject to raising of sufficient funds to finance the

Stage 2 expansion, to commence construction of Stage 2 immediately after Stage 1 becomes

operational.



4.9.2



Operation management

The proposed organisation chart for the Project during operation is given below, though this

will be reviewed on an ongoing basis as the Project develops.



U3823_Marampa_ESIS_Final.docx



September 2012

Page 74 of 298



SRK Consulting



Marampa Iron Ore Project ESIS – Main Report



Figure 4.14: Proposed organisation chart for operations



4.9.3



Human resources management

It is likely key management positions will be sourced from Australia, with the remainder of the

expatriate personnel sourced from Europe and South Africa. As there is a well-developed

mining industry in several other African countries, a selection of personnel could be sourced

from these countries as well. Although there is a skilled labour force in Sierra Leone, it is likely

that competition between mining operators for this labour will be tight, and that considerable

training will be required for local nationals.

For the purposes of design, it has been assumed that expatriates will work a 6 weeks on/ 3

weeks off cycle, and that most national personnel will relocate to Lunsar. It is likely, however,

that some senior national staff will be housed in the accommodation village and commute to

work.

The estimated numbers and categories of personnel required for the permanent workforce

during Stage 1 and Stage 2 operations are shown in Table 4-10 below. Mining at the Project

will be undertaken by an experienced mining contractor. A contractor will also be used at the

accommodation camp (to provide messing and cleaning services) and for the power station

operation. All other personnel will be employed directly by MIOL.



U3823_Marampa_ESIS_Final.docx



September 2012

Page 75 of 298



SRK Consulting



Marampa Iron Ore Project ESIS – Main Report



Table 4-10: Estimate of operational personnel requirements

Area



Position



Manager



Operations Manager and Secretarial Support



Stage 1



3



3



Mine



Mine Manager and Staff



3



3



Mine Technical Services



30



44



7



10



175



500



Process Manager and Staff



3



3



Metallurgy and Laboratory



21



52



Concentrator



52



189



0



43



Mine Operations

Mining and Blast Contractors

Process Operations



Pipeline

Concentrate Storage & Load out

Maintenance



Commercial



OHS&E



21



51



Power Station



8



18



Maintenance Manager and Staff



3



3



Mechanical



26



72



Electrical



19



51



3



3



Administration, Accounting & Marketing



24



33



Supply / Warehouse



14



20



Accommodation Village Contractor



20



45



3



3



Commercial Manager & Staff



OHS&E Manager and Staff

Health and Safety



Security



10



14



Environment



4



4



Security Manager & Staff



2



2



91



91



Community Manager



1



1



Community Liaison



3



3



546



1261



Security

Community

Total



4.9.4



Stage 2



Procurement

It is unlikely to be possible to source the necessary goods for construction and operation of

the mine from within Sierra Leone, with the exception of minor consumables such as fuel,

food, stationary etc. Where possible however, additional goods will be sourced locally.



4.10 Pollution control

The expected emissions and effluents from the main operations are described in Table 4-11

along with the planned pollution control measures included in the Project design.



U3823_Marampa_ESIS_Final.docx



September 2012

Page 76 of 298



SRK Consulting



Marampa Iron Ore Project ESIS – Main Report



Table 4-11: Expected emissions and effluents from mining operations

Activity



Sources



Outputs



Planned control

Mining



Pit

excavation



Waste rock

dumps



Ore

transport



Drilling and

blasting



Noise, blasting

fumes and

vibrations







Standard blasting controls



Shovels and

front end loader



Dust







Groundwater

inflow and rainfall

into pit







Use of water sprays or other suitable binding

agents

Pump to tailings storage facility or sediment traps

prior to release to water courses



Haulage vehicle

emissions









Vehicle exhausts

Regular maintenance



Noise







Hearing protection for operators



Dust







Use of water trucks



Storm water runoff







Sedimentation ponds



Seepage







Ground preparation to minimise seepage



Dust













Water sprays or suitable binding agents

Control vehicle speeds

Oil-water separators at vehicle maintenance area /

workshop

Settlement ponds for sediment









Vehicle exhausts

Regular maintenance



Dumping of

waste rock



Haul trucks



Oil and waste

water from truck

shop

Haulage vehicle

emissions



Processing

Crushing,

screening

and

stockpiling



Primary

Grinding



ROM Ore

Stockpile



Dust from mobile

equipment

movements









Crushing and

Screening

Modules



Dust







Noise









Water trucks

Slope and contour the ROM pad such that run-off

water contained on the pad or drained to suitable

settlement pond

Dust generation at all transfer points and on all

conveyors within these circuits managed using

vacuum dust collection systems

Covered conveyors

Hearing protection for operators



Fine Ore

Stockpiles



Dust









Telescopic chutes to minimise ore drop heights

Fine misting sprays to minimise dust generation



Primary Grinding

Circuit



Slurry spillage















Build on an impermeable concrete pad with

adequate bunding around the perimeter to contain

spillage

Hose slurry spillage into concrete sumps built into

the concrete pad

Fit sumps with sump pumps to transfer the

material back into the grinding circuit

Hearing protection for operators

Consideration of noise bunding, if required

As for Primary Grinding Circuit.







Noise

WHIMS



Reagent

Storage



Rougher,

Scavenger,

Cleaner and

Recleaner

Circuits



Slurry spillage and

Noise



Regrind Milling

Circuits



Slurry spillages

and Noise







As for Primary Grinding Circuit.



Reagent Storage

Warehouse



Dry Flocculant

Spillage









Concrete floor

Regular sweeping of any dry flocculant spillage



U3823_Marampa_ESIS_Final.docx



September 2012

Page 77 of 298



SRK Consulting



Marampa Iron Ore Project ESIS – Main Report



Activity



Sources



Reagent

Mixing and

Dosing



Flocculant

Mixing and

Storage



Outputs



Planned control





Spills of flocculant









Tailings

Dewatering



Tailings

Thickener



Tailings Slurry Spill







Impermeable concrete pad with adequate bunding

around the perimeter to contain spillage

Hose any spillage into concrete sumps built into

the concrete pad

Fit sumps with sump pumps which transfer the

material back into the mixing or holding tank

As for reagent mixing and dosing



Power supply

Power

generation



HFO

transportation



HFO plant



Haulage vehicle

emissions







Require third party suppliers to use regularly

maintained vehicles with suitably trained drivers



Noise







Exhaust stacks



Spills of HFO







Emissions







Require third party suppliers to provide emergency

training to drivers and to have spill kits with each

truck

Standard exhaust systems



Noise









Enclosed in a building

Hearing protection for operators



TSF

Overflow from

TSF pond



Discharge of

tailings

supernatant







None, as supernatant expected to be of suitable

quality to meet discharge standards



TSF dry beach

and side walls



Dust







Tailings and

decant water

transport



Tailings and

decant water

pipelines



Spillage of tailings

or decant return

water



Revegetate side slopes as soon as practicable

after construction

Water sprays if necessary for slopes and dry

beach

Regular inspections of pipelines

Leak detection system



Concentrate

Dewatering



Concentrate

Thickener



Concentrate Spill







As for reagent mixing and dosing



Concentrate

Filtration



Filtration Building



Concentrate Spill







As for reagent mixing and dosing



Tailing

disposal











Concentrate transport



4.11 Project closure

The objective once mining operations are completed will be to ensure, as far as practicable,

rehabilitation achieves a stable and functioning landform, which is consistent with the

surrounding landscape and other environmental values.

The general strategy for the completion of mine development, assuming expansion is

possible, is that once mining of fresh ore is completed, the pits may be partially backfilled,

allowing for up to 50% of the pit areas to be backfilled with waste and tailings. Once the Rotret

Pit and Mafuri Pit are complete, they would be backfilled with waste rock from further

expansion of the Gafal Pit and an extension of the Mafuri Pit to the south-east. This will

minimise the need for waste rock disposal on surface, reduce the area of land to be disturbed

and assist with closure at the end of life of mine. The Matukia Pit may be used to store about

3

120 Mm of tailings towards the end of the mine life, also reducing surface disturbance and

facilitating closure implementation. The final site configuration at the end of mining is shown

on Figure 4.8.

Remnants of the mining activities post closure will include:





Open pit voids and pit lakes - as the Project involves bulk scale iron ore open pit mining



U3823_Marampa_ESIS_Final.docx



September 2012

Page 78 of 298



SRK Consulting



Marampa Iron Ore Project ESIS – Main Report



to below the natural water table, the open pits that remain post closure will fill with water

and form a lake.





Waste rock dumps - the WRD constructed during the mining operation will remain post

closure. Upon rehabilitation, the waste dumps will not be visually dissimilar to the

surrounding environment. Progressive rehabilitation as proposed above may reduce the

overall height of the dumps.







Tailings storage facility - the TSF will remain a permanent feature of the landscape and

the contained tailings will drain to an increasingly stable mass. A preliminary water

balance analysis of the facility indicates the facility could contain a large water pond

area, which would vary between the wet and dry seasons. As part of water management

at closure a lined spillway will be constructed to remove excess water from the TSF. Only

the top surface that will be permanently above the maximum water level will require

rehabilitation.







Removal of infrastructure - the main infrastructure built for the Project (such as the

beneficiation plant, workshops, pipelines, power station etc.) will be removed post

closure, with the infrastructure re-used, recycled or disposed of as appropriate.



For general infrastructure, such as general buildings, roads etc., MIOL will first consult with

the local authorities to determine what may be left intact for the benefit of the community.



4.12 Project Alternatives

Alternatives considered for the various Project components are discussed in the relevant

subsections above, as follows:



4.12.1 Power supply

The power alternatives considered for the Project include:





the Bumbuna Hydroelectricity generation plant; and







heavy fuel oil (HFO) power plant.



The Bumbuna hydroelectricity plant has an installed capacity of 50 MW but a stable capacity

of only 18 MW during the dry season, which is insufficient for MIOL’s requirements. There is

also currently no transmission link between the Bumbuna plant and the Project site, and for

these reasons this source was eliminated as a possibility and HFO was chosen as the

preferred option, as outlined in Section 4.5.



4.12.2 Water supply

Alternatives considered for water supply include the small lake within the London Mining lease

area. However, this supply would be inadequate for the purpose and possibly disrupt other

water users including villages in the area.



4.12.3 Concentrate transport

Road, rail and pipeline options were considered for the transport of the concentrate to the

port. Road transport is expensive, high risk from a community health and safety perspective

and challenging due to constraints with the existing national road network. It was therefore

determined that rail would be used to transport the concentrate to Pepel port as outlined in

Section 4.7.



U3823_Marampa_ESIS_Final.docx



September 2012

Page 79 of 298



SRK Consulting



Marampa Iron Ore Project ESIS – Main Report



4.13 Future studies

The current Project description is based on the processing of ore in the Gafal, Rotret, Mafuri

and Matukia resource areas to a produce up to 15 Mtpa of iron concentrate. This will be done

in two stages. Where Stage 2 (or other additional development of the mine) requires the

construction of new facilities not included in the description above and therefore not covered

by this ESIA, additional studies and an amendment to this ESIA will be required. Subject to

adequate financing being arranged, Stage 2 construction would commence immediately after

Stage 1 became operational.

Product transportation and export for Stage 2 is not included in this ESIA. However, it is

envisaged that concentrate will be pumped to the Tagrin port, which is planned for

development by AML. At Tagrin port, the concentrate will be dewatered and stockpiled, before

being recovered and loaded on to Cape Size vessels. Additional infrastructure requirements

to accommodate this will be confirmed during detailed feasibility studies, and assessed during

the above-mentioned amendment to this ESIA.

Other prospects have also been identified within EL46/2011 during the course of exploration

activities, which could (subject to feasibility studies and environmental approval) potentially be

exploited in the future. Infrastructure for the Project has therefore been sited to avoid

sterilisation of these resources and facilitate additional mine development if this proves

feasible.



U3823_Marampa_ESIS_Final.docx



September 2012

Page 80 of 298



SRK Consulting



5



Marampa Iron Ore Project ESIS – Main Report



BIOPHYSICAL BASELINE DESCRIPTION

Baseline studies were undertaken for environmental aspects that may be affected by Project

activities. The environmental baseline studies provide a database of physical, chemical and

biological parameters which are used to predict and monitor the effects of the Project on the

environment. The sections below provide a brief summary of the areas studied and methods

used to characterize the environmental aspects of the areas potentially affected by Project

infrastructure and activities. Detailed methods and findings are included in the full reports,

which are presented as supporting documents to the ESIA, in Volume 3.

It is recognised that the site has experienced disturbance due to mining and agricultural

practices in the past and therefore cannot be considered to be in a ‘natural state’. It should

also be noted that due to changes in the Project layout during the course of the ESIA, much of

the baseline studies were completed based on the study areas defined under a previous

layout, resulting in slight inconsistencies in this regard. This is however considered not to be

of consequence to the ESIA due to the relatively minor changes involved, and the fact that the

impact assessment has been conducted based on the Project description and layout

presented in Chapter 4.



5.1



Physiography and Landscape

Sierra Leone comprises three physiographic regions: a narrow band of coastal lowlands, the

interior wooded plains, and the upland plateau which includes scattered mountains and hills to

the north-east (Okoni-Williams et al., 2001). The Project is situated in the interior plains, as

marked by a red symbol in Figure 5.3.

The region around the Project area is relatively flat and low-lying at a height of approximately

40 to 90 masl and is characterised by gently undulating topography. The topographical

variation creates two main drainage regimes within the Area; the majority of the concession

area drains southwards into the Rokel River and the north of the Project Area drains

westward into the Port Loko Creek. The lowland river valleys are characterised by relatively

flat profiles with broad floodplains, which are generally waterlogged during the wet season

and often used for rice cultivation, as shown in Figure 5.1 and Figure 5.2 . Villages are

generally located on higher ground.



Figure 5.1: Low lying swamp area previously used as rice paddy field



U3823_Marampa_ESIS_Final.docx



September 2012

Page 81 of 298



SRK Consulting



Marampa Iron Ore Project ESIS – Main Report



Figure 5.2: River basin to the north west of the Project area



Figure 5.3: Topography of Sierra Leone (red symbol indicates Project location)



5.2



Geology and Geochemistry



5.2.1



Geology

The Project Area covers an area of Archean basement gneiss and granite structurally overlain

by rocks of the Marampa Group. The Marampa Group consists of an upper Rokotolon

Formation and a lower Matoto Formation. Iron ore mineralization at the Project is hosted in

specular hematite quartz mica schists (hematite schist) of the Rokotolon Formation, which is

interlayered with quartz-mica-albite schists.

The Marampa Group has been subject to multiple folding events which have imparted a

strong foliation in the rock units and resulted in a basin and dome pattern of synforms and



U3823_Marampa_ESIS_Final.docx



September 2012

Page 82 of 298



SRK Consulting



Marampa Iron Ore Project ESIS – Main Report



antiforms with iron mineralisation preserved in the synformal areas. Later uplift of the

basement has resulted in the current distribution of the hematite schists, with a concentration

in the south eastern area and along the eastern margin of the large basement dome.

Intense tropical weathering has produced a laterite cover over much of the Project area,

ranging from 2 – 6m in thickness. The laterite consists of a hard massive pisolitic cap

preserved on the many low elongate hills of the region. Laterite colluvium is common on the

flanks of the hills. Beneath the laterite an oxidised, saprolite zone extends to depths of 10 –

30m below surface.

The iron ore mineralisation occurs as units of hematite schist located within the metapelitic

schists of the Rokotolon Formation. Due to the complex folding and lack of outcrop it is

uncertain how many individual units of hematite schist occur and how they are related

stratigraphically. To date, seven major hematite schist prospects (excluding Gafal Hill and

Masaboin Hill) have been identified on the Marampa licence, with individual bodies of

mineralisation up to 100m thick and extending over strike lengths of several kilometres. The

locations of the seven hematite prospects are shown in Figure 1.3.



5.2.2



Geochemical characterisation

Mining activities result in disturbance and exposure of rock. This increases the surface area

and the likelihood of exposure of unoxidised surfaces to air and water, potentially generating

acidic conditions and mobilising metals. Although these weathering processes would occur

naturally over extensive geological timeframes, the disturbance by mining accelerates this

process. A geochemical characterisation study was undertaken by SRK (ARDML Baseline

Assessment for MIOL Project, SRK, 2012) to classify and quantify the potential acid rock

drainage and metal leaching potential (ARDML) contribution to the environment from the

deposit rocks. The geochemical characterisation study involved a review of previously

collected information, field investigations and an assessment of the ARDML potential of the

ore, waste rock, tailings and concentrate material using the following tests:





mineralogical characterisation using optical microscopy, Scanning Electron Microscopy

(SEM) and X-Ray diffraction;







whole rock assay using Multi-Acid digest and elemental analysis;







carbon and sulfur analysis, and neutralizing potential analysis for Acid Base Accounting

(ABA);







Neutralisation Potential (NP) to determine the sample’s ability to neutralise acidity;







Net Acid Generation (NAG) testing and NAG test leachate analysis; and







short-term leach tests.



Sampling was carried out to provide lithological and spatial representation of geological units

across the four pits proposed for this ESIA (Rotret, Matukia, Mafuri and Gafal). A total of 64

waste rock samples were selected from diamond drill cores from the four proposed pits, and

were prepared on site in the MIOL laboratory. Four of these samples were duplicates for

QA/QC analysis. QA/QC results were within reasonable limits expected for the test

procedures used and no further analytical reruns were recommended. The IFC Mining

Effluent Guidelines (IFC, 2007) and preliminary Sierra Leone Water Supply Guidelines

(domestic water quality standards) were used to evaluate the leachates produced.

In addition to the waste rock characterisation, a total of six samples of ore, tailings and

concentrate were selected for metallurgical testing.



U3823_Marampa_ESIS_Final.docx



September 2012

Page 83 of 298



SRK Consulting



Marampa Iron Ore Project ESIS – Main Report



Acid Rock Drainage Potential

Results from the static acid generation prediction testwork show that the samples tested are

predominantly classified as Non Acid Forming (NAF) with a low average sulfur content

(compared to average crustal abundance) below 0.1% sulfide sulfur. Only a small portion of

the dataset indicated uncertain characteristics with only one extreme sample showing

Potentially Acid Forming (PAF) characteristics. The Quartz Mica Schist (QMS) material was

found to generally have the highest sulfide content, up to 0.11%. However, in NAG tests,

QMS samples were found to produce a NAG pH greater than 7 and as such are still classified

as NAF. Only two samples were found to generate acidity in the NAG tests, both of which

were taken from the Rotret area and produced low NAG values of approximately 5 kg

CaCO3/tonne. Across the Project area, net acid generation from oxidation of waste rock is

considered to be unlikely.

Metals Leaching Potential

In the short-term leach tests, metal leaching from the waste rock samples was generally low.

Leachates showed a net alkalinity and relatively high pH levels comparable to Project area

groundwater. Release of zinc and manganese was observed for highly weathered clay and

saprolite samples, and iron and aluminium concentrations were elevated in higher pH

samples of unweathered material. Boron release was found to be spread across lithological

units and appeared to be solubility controlled.

Results from the NAG leachate analysis, which indicate long-term conditions, indicated

elevated chromium, manganese and boron release. Manganese release was associated with

the lower NAG pH samples suggesting pH controlled solubility. Boron release was found to be

slightly sporadic but correlated with higher concentrations from samples with a higher whole

rock boron concentration.

Overall, the potential exists for flushing and release of iron, aluminium, zinc, manganese and

boron from the waste rock dumps at concentrations which may require further management if

shown to be the case.

Metallurgical samples

Analysis of the ore, concentrate and tailings samples showed that all samples contained

negligible levels of sulfides and low levels of carbonate. The ore, concentrate and tailings are

therefore unlikely to generate acidity but will also have limited buffering capacity. ABA

predictions class all the metallurgical samples as NAF. With respect to metal leaching, there

is little potential for leaching of iron, manganese or trace metals from the metallurgical

samples although zinc and arsenic release was detected from the tailings material and iron

release was observed from the ore concentrate.



5.3



Natural Hazards

Sierra Leone is located on the African tectonic plate in one of the least seismically active

zones in Africa. Only five seismic events were reported in the region between 1947 and

1978, and none of these were recorded by the nearest seismological station in Senegal

(Nippon Koei, 2005).

The most common natural disasters occurring in Sierra Leone are flooding and disease

epidemics (mainly bacterial infectious diseases). From 1996 to 2009 flooding affected

221,000 people in Sierra Leone and 103 people were killed (EM-DAT, 2012). It is estimated



U3823_Marampa_ESIS_Final.docx



September 2012

Page 84 of 298



SRK Consulting



Marampa Iron Ore Project ESIS – Main Report



that a disease epidemic occurs every two years in Sierra Leone (Preventionweb, 2012).

Between 1985 and 2008, approximately 11,500 people were affected by disease epidemics

and approximately 1,000 people died as a result (EM-DAT, 2012).



5.4



Climate

Sierra Leone has a tropical savannah climate with distinct wet and dry seasons controlled by

the migration of the Inter-tropical Convergence Zone (“ITCZ”) between the northern and

southern hemispheres. The movement of this climatic feature creates a wet season from May

to October and a dry season from November to April. The dry Harmattan winds usually blow

from late November to mid-March transporting dust from the Sahara Desert. These winds

bring no precipitation apart from the occasional very light rain. Average wind speeds in Sierra

Leone are generally low. There is little seasonal variation in mean air temperatures, with

slightly hotter conditions in around midyear.

Historical climate data was available from the Freetown meteorological station; located 90 km

west of the Project site, and was used to evaluate long-term climate trends in the area.

0

Historical temperatures average 27 C and historic annual rainfall averages 1580.5 mm. The

nearest regional meteorological station to the Project area is located at Makeni; however this

station has only been recording data since 1990. Annual average temperature between 2002

and 2005 ranges from 25.0°C and 25.5°C and total annual rainfall ranges from 2524.3 mm in

2003 and 3370.8 mm in 2004 (Statistics Sierra Leone, 2008).

As part of the assessment of baseline environmental conditions at the site, an assessment of

ambient climatic conditions in the area was undertaken to enable evaluation of any potential

Project impacts influenced by to climate. The data was analysed by the air quality specialists

as a component of their study (included as SD 2 in Volume 3). Due to the lack of site-specific

data for the Project, a weather station was installed at the MIOL Office in Lunsar at a base

elevation of 64 m (see Figure 5.4). The parameters listed below were monitored continuously

and recorded every 10 minutes with data downloaded every month.





Wind speed and direction at 10 m above ground.







Temperature at 1.75 m above ground.







Solar radiation measurement at 2.5 m.







Relative humidity at 1.75 m.







Rainfall at 2.5 m.



Climate data collected from the on-site meteorological station is displayed in Table 5-1. The

station has been collecting data since June 2010, however due to malfunctioning of the

device between May and December 2011, only data for the 12 month period until May 2011 is

presented.

Table 5-1: Climate data from MIOL meteorological station

Month



Daily Temperature Average (°C)



Rainfall (mm)



Number of rainy

days



June 2010



27.5



8.8



3



July 2010



25.7



399



23



August 2010



25.4



376.6



29



September 2010



26.0



283.4



25



October 2010



26.3



384.2



27



November 2010



27.2



78.2



12



U3823_Marampa_ESIS_Final.docx



September 2012

Page 85 of 298



SRK Consulting



Marampa Iron Ore Project ESIS – Main Report



Month



Daily Temperature Average (°C)



Rainfall (mm)



Number of rainy

days



December 2010



27.5



32.4



4



January 2011



26.6



0



0



February 2011



28.7



0



0



March 2011



29.3



24



3



April 2011



29.3



17.4



8



May 2011



28.6



0.1



3



Total



-



1604.1



137



The average temperature recorded at the on-site weather station is 27.34°C, which remains

relatively constant year round due to the equatorial location. Rainfall data shows the distinct

contrast between the wet season and dry season with rainfall ranging from a minimum of

0 mm in January 2011 and February 2011 to 399 mm in July 2010 (when the highest daily

rainfall of 68 mm was also recorded).

The prevailing wind direction is consistent throughout the year, predominantly from the

southwest and west-southwest direction. Annual average wind speeds at the 10 m level in

Lunsar were 2.63 m/s; however the wind speeds and direction may be affected by tall trees

surrounding the weather station. Comparatively the Lunsar meteorological station is

representative of the historic temperature and rainfall data obtained from the Freetown

weather station.



Figure 5.4: Automatic meteorological station at the MIOL site office



5.5



Water Resources



5.5.1



Hydrology

Surface drainage within the Project area falls within two river catchments; the Rokel and Port

Loko Creek (also called Bankasoka River). The Bankasoka is to the North of the Project area



U3823_Marampa_ESIS_Final.docx



September 2012

Page 86 of 298



SRK Consulting



Marampa Iron Ore Project ESIS – Main Report



and drains predominantly east to west, before turning south west where it drains into the

Freetown Harbour (also known as the Sierra Leone River) at Tumbu Island. The Rokel is

Sierra Leone’s largest river originating in the Guinea Highlands, from where it flows south

west, passing in close proximity to the south of the site. The flow of the Rokel is regulated by

a hydroelectric dam (Bumbuna Dam) which is located approximately 100 km upstream of the

concession area. The Bumbuna Dam environmental impact assessment indicates flow

releases from the dam will be increased compared with the natural flows during the dry

season and below natural flow during the wet season, but the overall difference between

regulated and natural flows under normal dam operation will not be significant. However,

there are no flow-gauging stations on the Rokel downstream of Bumbuna with which to

accurately estimate regional flows.

Local drainage in the Project area is dendritic in form with shallow catchments and poorly

defined stream channels within flat-lying wide, marshy flood plains. The three rivers located

within the Project Area which all drain to the Rokel are the Kagbu, Baki and Batabana. The

catchments of these three drainages are shown on Figure 5.5.

Hydrological monitoring commenced at the mine site in June 2010. Surface water flow was

measured monthly using a Valeport electromagnetic flow meter at four locations. River level

stage gauging was also measured. Calculated flows from these sampling locations are

shown in Table 5-2.

The surface water flow monitoring sites MSW028 and MSW029 are located on the Kagbu

River with MSW030 located approximately 3.3 km further downstream from MSW028.

MSW031 and MSW034 are located on tributaries of the Kagbu River, both of which in a south

easterly direction before joining the Kagbu River

River depths were recorded approximately daily and the flow gauging monthly.

Table 5-2: Calculated surface water flows

Sample ID



River Name



Flow (m3/s)



MSW028



Kagbu



0.686



MSW029



0.708



MSW030



Kagbu

Small Tributary



MSW031



Kagbu



0.175



U3823_Marampa_ESIS_Final.docx



0.573



September 2012

Page 87 of 298



SRK Consulting



Marampa Iron Ore Project ESIS – Main Report



Figure 5.5: Catchments in the Project area



U3823_Marampa_ESIS_Final.docx



September 2012

Page 88 of 298



SRK Consulting



5.5.2



Marampa Iron Ore Project ESIS – Main Report



Hydrogeology

An assessment of the hydrogeological conditions at the Gafal and Matukia pits has been

undertaken by Coffey Geotechnics Limited. The hydrogeological setting of the Project area is

characterised by a shallow, weathered zone overlying fresh rock which supports an

unconfined aquifer. Groundwater is likely to be present in three distinct aquifer settings:

perched aquifers within the surface laterites, the base of the saprolite zone and the major

fracture systems within the fresh rock. The dominant aquifer is likely to be the base of the

saprolite to the top of fresh rock zone, supplemented by deeper fracture systems, many of

which may prove high yielding.

Groundwater conditions at Marampa are considered to be non-homogeneous and anisotropic,

with groundwater levels in individual bores (as well as groundwater yields) possibly controlled

by the hydraulic properties and recharge conditions of individual fracture systems with little

interconnection between such fractures in some areas.

SRK manually dipped 21 boreholes at Gafal, 6 at Matukia and two village wells to establish

the depth of the water table (see groundwater monitoring locations in Figure 5.7). In dry

season conditions (March, 2011), the water table was measured at a maximum depth of 16 m

below ground level and 7 to 8 m below ground level in the Matukia area (Figure 5.6).

Maximum depth in the water table occurs in areas of highest topography and the depth to the

water table decreases towards valley locations where it is likely to be coincident with surface

water (streams or swampy areas). Shallow groundwater in the Project area therefore

provides baseflow to the surface water network, probably on a perennial basis. Village water

supply wells and boreholes will most likely extract water from this resource.



Figure 5.6: Measurement of depth to water table using a dip meter



5.5.3



Water quality

One round of water quality sampling was undertaken by SRK during February 2011. Seven



U3823_Marampa_ESIS_Final.docx



September 2012

Page 89 of 298



SRK Consulting



Marampa Iron Ore Project ESIS – Main Report



surface water quality samples were collected from the villages of Marunku, Mabungu, Maso,

Matukia and Makump, and five groundwater samples were collected from village wells

(locations shown on Figure 5.7). As the groundwater samples were collected from actively

used community wells the wells were not purged prior to sampling. The samples were sent to

Severn Trent Services (STS) in the United Kingdom for analysis of basic parameters, total

and dissolved metals and petroleum hydrocarbons. The surface water sample results were

compared to the Australian and New Zealand Environmental Conservation Council

(“ANZECC”) Fresh and Marine Water Quality Guidelines (ANZECC, 2000) to indicate

ecosystem disturbance and the groundwater samples were compared to World Health

Organization (“WHO”) Guidelines for Drinking Water Quality (WHO, 2008) for public health

limits.

The surface water sample results showed moderate acidic to near-neutral pH ranging from

4.7 to 6.5 and generally low metal concentrations. Elevated levels of aluminium were

recorded, however, exceeding ANZECC guidelines (0.05 mg/l) in 5 out of 7 samples. The

average aluminium concentration across the sites was 0.29 mg/l and the maximum reached

0.79 mg/L. Nitrate concentrations were above the ANZECC guideline of 0.7 mg/l at one

sampling point (3.9 mg/l) and minor exceedances of ANZECC guidelines were recorded for

copper and zinc at three points. Total petroleum hydrocarbons were analysed in four of the

surface water samples. Two points were characterised by elevated TPH concentrations. This

was mainly found to be the C6-C40 fraction, which is associated with petrol and diesel

compounds and the C24-C40 fraction, which is associated with residual fuels (for example

fuel oil, lubricating oil, mineral oil and asphalt). In addition, elevated concentrations of the

C16-C24 (354 µg/l) and C10-C16 fractions (85 µg/l), associated with diesel range organics,

were found at one point.

Groundwater samples showed a moderately acidic to near-neutral pH ranging from 4.7 to 6.7.

The electric conductivity of 34 µs/cm to185 µs/cm for the samples indicates low salinity. The

groundwater samples were generally characterised by low metal concentrations with

parameters falling below the WHO drinking water quality guideline limits. Total petroleum

hydrocarbons were below the limit of detection in the samples.



5.6



Soils

The soils of Sierra Leone are recognised as being generally ferrallitic in nature. The soils of

the lowland regions in the coastal plains are characterised by seasonal water logging,

inadequate drainage and elevated iron and aluminium contents (NSADP, 2009). Soils are

generally red to yellow-brown in colour and acidic (pH 4-5) in nature due to frequent water

logging. Stobbs et al. (1963) recognise the soils in the lowland regions of Sierra Leone can be

classified into one of four groups:





Oxisols (also referred to as ferrallitic soils) – these highly weathered soils consist

primarily of hydrated oxides of iron and aluminium and are characterised by low organic

matter content. Their low residual primary mineral content results in a low cation

exchange capacity (CEC). The soils are typically red-brown in colour.







Groundwater laterites – characterised by poor drainage, high acidity and horizons with

elevated sesquioxide (iron and aluminium) concentrations. Generally characterised by

low organic matter content.







Acid gleysols (also referred to as hydromorphic soils) - these acidic soils (typically grey in

colour) are annually flooded and are characterised by seasonal anoxic conditions.



U3823_Marampa_ESIS_Final.docx



September 2012

Page 90 of 298



SRK Consulting



Marampa Iron Ore Project ESIS – Main Report



Hydormorphic processes are dominant and the leaching of soluble ferrous iron from the

soil profile results in its distinct grey coloration.





Alluviosols – these are generally young soils confined to levees and are characterised by

a good fertility as a result of the high nutrient content.



Figure 5.7: Locations of groundwater and surface water monitoring points

U3823_Marampa_ESIS_Final.docx



September 2012

Page 91 of 298



SRK Consulting



Marampa Iron Ore Project ESIS – Main Report



The soils in the vicinity of the Marampa region can be broadly classed as ferrallitic soils

(oxisols) and have low soil erosion potential, although this may be enhanced by high and

intense rainfall, land clearance and removal of vegetation cover.

A soil baseline study was undertaken by SRK (see SD 5 of Volume 3 for full study report) to

determine the physical and chemical characteristics of the soil and sediments specifically

located within the study area and assess the potential productivity of the soils based on soil

structure and nutrient status.

A total of 21 soil samples and 11 sediment samples (including duplicates for QA/QC) were

collected for chemical and physical characterisation in March 2011 (Figure 5.8 shows

sampling technique and Figure 5.9 the sampling locations). Soil samples were collected from

areas likely to be disturbed by the placement of Project-related infrastructure, around the

boundary of the London Mining concession, and agricultural areas.

Sediment samples were collected from locations downstream of potential operations or

proposed waste storage facilities. The soil and sediment samples (in the <0.05 mm fraction)

were analysed at Scientifics laboratory (Burton-on-Trent, UK) for chemical and physical

characteristics. Analysis of the >0.05 mm fraction was carried out by Soil Mechanics Ltd

(Bristol, UK).



Figure 5.8: Soil sampling using hand auger



U3823_Marampa_ESIS_Final.docx



September 2012

Page 92 of 298



SRK Consulting



Marampa Iron Ore Project ESIS – Main Report



Figure 5.9: Soil and sediment sampling locations



5.6.1



Soil quality

The soils were classified based on particle size using the United States Department of

Agriculture (“USDA”) soil classification system. The chemical results were compared to three

times crustal average abundance of elements (Mason, 1966) and the Canadian Council of

Ministers of the Environment, 2007 (“CCME”) soil quality guidelines for protection of

environmental and human health. The solution chemistry during the leach tests was



U3823_Marampa_ESIS_Final.docx



September 2012

Page 93 of 298



SRK Consulting



Marampa Iron Ore Project ESIS – Main Report



compared to IFC EHS guidelines for Mining (2007) to determine whether leaching of the soils

is likely to result in release of contaminants at concentrations above international effluent

discharge guidelines.

The majority of soil samples collected during the survey were classified as sandy loam (USDA

soil classification), due to the large proportion of sand (60%), with smaller proportions of silt

(33%) and clay (1.5%). There was limited variation in soil texture across the study area. The

moderate proportion (average: 46%) of fine particles (particle sizes < 0.1 mm) in the samples

indicated a potential for soil erosion however the moderate organic content indicates the

potential for erosion is low.

The soils were found to be moderately acidic in nature (pH 4.7 to 5.8), with a low cation

exchange capacity (10.5 to 19.7 meq/100g) and are dominated by iron and aluminium. These

are typical characteristics of soils in humid regions of the tropics, where the high chemical

weathering rates and high rainfall result in intense leaching of soil bases.

The organic matter content of the soils was found to vary from 1.19% to 5.09%, with cultivated

soils generally being characterised by a lower organic matter content (<2%). Levels of the

essential plant nutrients nitrogen and phosphorus were found to be generally within typical

levels for well drained soils, indicating the soils have good agricultural potential.

The majority of soil parameters were below CCME soil quality guidelines apart from boron,

selenium and chromium, but the cause of these exceedances is thought to be natural. The

moderately acidic pH of the soils is outside the CCME recommended range of 6 to 8 s.u. in all

samples collected.

Soil leachates were circum-neutral (pH 6.6 to 8.0). Most constituents were leached at very

low concentrations, with many parameters being at or near analytical detection limits in the

leachates. Iron and zinc were the only parameters to exceed IFC standards in the leachates.

For iron, exceedances were noted for 12 samples (from a total of 21) in the first stage of

leaching and for two samples in the second leaching stage. Exceedances for zinc were

observed for three samples in the first stage of leaching. All other parameters were

significantly below IFC standards. These low levels of leaching observed in the laboratory

tests are likely to be a function of the prevailing environmental conditions in the field; the high

levels of rainfall will have pre-flushed the soil column meaning that any readily-mobile

constituents will have leached out in-situ. However, iron and zinc showed the potential to be

leached from the soils.



5.6.2



Sediment quality

The sediment samples were generally characterised by higher gravel and lower silt content.

The particle size distribution is likely to relate to the predominant river flow regime in the

location the sample was taken; areas of fast flowing water characterised by gravelly sands

and areas of low flow characterised by higher silt content. Sample locations are shown in

Figure 5.9.

The sediments were found to be mildly acidic to circum-neutral (pH 5.3 to 6.5) and are

dominated by aluminium, manganese and iron, reflecting the geology of the local area. With

the exception of boron, all parameters were present at concentrations not exceeding the three

times average crustal concentration.

In addition all parameters were detected at

concentrations lower than CCME sediment quality guidelines, with the exception of chromium

which was found to be elevated in two samples (MSd005 and MSd006) collected from the

Rokel River.



U3823_Marampa_ESIS_Final.docx



September 2012

Page 94 of 298



SRK Consulting



5.7



Marampa Iron Ore Project ESIS – Main Report



Air Quality

An air quality baseline study was undertaken by specialists from SRK (SA) to measure the

baseline ambient conditions from which air quality impacts can be predicted (see SD 2 of

Volume 3 for the full study report). The monitored pollutants (sulphur dioxide, nitrogen

dioxide, particulate matter and dust fallout) were chosen based on the expected emissions

from the planned operations and the level of risk to human health posed by these pollutants.

Air quality sampling was carried out at numerous locations around the mine site (Figure 5.10

shows locations of particulate matter, dust fallout and gas monitoring points) for the following

parameters as per the programme summarised in Table 5-3.

Table 5-3: Air quality baseline monitoring programme at mine site

Parameter



Sampling locations



Method



Frequency



Analysis



Dust fallout



MIOL Office (Lunsar),

Catholic School, Konta

Bana, Maso, Matukia,

Mafuri, Magbungbu,

Marampa Guest House



Monthly (exposure for

4 weeks)



Sealed buckets

sent to

Mhlathuze

Water (South

Africa)



Particulate

matter (PM10

and PM2.5)



MIOL Office (Lunsar)



Sample

buckets that

were sealed

and

swapped

with new

buckets after

30 days.



Continuously



Mhlathuze

Water (South

Africa)



Sulphur

dioxide (SO2)



MIOL Office, Konta Bana,

Natukia, Mafuri, Magbungbu



Quarterly (3 monthly)

(24-hour exposure

period)



M&L

Laboratory

Services



Nitrogen

dioxide

(NO2)



MIOL Office, Konta Bana,

Matukia, Mafuri, Magbungbu



Radiello

passive gas

monitoring

badges with

absorbent

gas

cartridges.



Quarterly (3 monthly)

(1-hour exposure

period)



M&L

Laboratory

Services



Air quality results were compared to the World Bank/IFC guideline on emissions and ambient

air quality, US EPA standard for air quality monitoring and South African National Standards

(SANS) for dust deposition, as Sierra Leone does not have a standard for air quality.

The measured NO2 and SO2 concentrations are below both IFC and US EPA standards in all

3

locations, except at the MIOL offices in June 2011 were a SO2 concentration of 21.7 µg/m

3

was measured. This slightly exceeds the World Bank/IFC SO2 guideline value of 20 µg/m

3

(but falls below the US EPA standard of 370 μg/m ). The higher SO2 concentrations in

Lunsar, Magbungbu and Mafuri are attributed to higher vehicle circulation in Lunsar town and

the villages and other anthropogenic activities. The NO2 concentrations were very low across

the sample locations. The highest concentrations were in Magbungbu, Mafuri and Matukia

attributed to biogenic release from the burning of sugar cane plantations, the major

3

agricultural activity in the area. The highest NO2 concentration measured was 7.05 μg/m in

June 2011 at the MIOL offices in Lunsar, falling below the World Bank/IFC Guideline of 200

3

3

μg/m and the US EPA standard of 190 μg/m . Baseline SO2 and NO2 levels suggest the level

of these gases in ambient air is low.



U3823_Marampa_ESIS_Final.docx



September 2012

Page 95 of 298



SRK Consulting



Marampa Iron Ore Project ESIS – Main Report



Figure 5.10: Air quality and noise monitoring locations



Eight dust monitors were situated around the study area to determine the spatial coverage of

dust fallout. The fallout results for June to November 2011 (corresponding with the wet

3

season) were consistently below the SANS target level of 300 mg/m /day at all monitoring

locations. Results for December 2011 to March 2012 (corresponding with the dry season)

showed a trend of exceedances of the action limits (and in some cases the alert thresholds) at

U3823_Marampa_ESIS_Final.docx



September 2012

Page 96 of 298



SRK Consulting



Marampa Iron Ore Project ESIS – Main Report

3



almost all locations. Most notable were Konta Bana (where a reading of 5,470 mg/m /day was

3

obtained for December 2011, exceeding the SANS alert threshold of 2,400 mg/m /day),

3

Matukia (where 11,886 mg/m /day was recorded in March 2012, again exceeding the alert

3

threshold), and Mafuri (where 1,408 mg/m /day was recorded in January 2012, exceeding the

3

Action Industrial threshold of 1,200 mg/m /day). These increased dust concentrations could

be attributed to increased traffic or construction in these areas (such as the Magbungbu

monitoring point, where construction for a railway and road was taking place nearby).

PM10 levels were recorded at the MIOL Office in Lunsar between March and April 2012. The

samples indicate daily PM10 concentrations are below both World Bank/ IFC Guideline and

US EPA standards through most of the year. However there were 89 exceedances of 24-hour

3

PM10 guideline concentrations of 50 μg/m during the monitoring period, eight of which

3

exceeded the US EPA standard of 150 μg/m . All exceedances occurred during the dry

season (November 2011 – February 2012), suggesting that dust generating activities

increased during that period, and possibly also the influence of the Harmattan winds, which

occur at this time of year. Average daily PM2.5 concentrations were measured between March

3

and July 2011 (study cut short due to technical errors), and were high (21 to 26 μg/m ) in

3

March and April, exceeding World Bank/IFC Air Quality Guideline of 20 μg/m . This high level

is attributed to increased vehicle entrainment of dust and windblown dust from the roadside,

during the dry season. Samples from May to July 2011 were below the daily guideline levels.

The 24-hour PM2.5 concentrations show 37 instances where the 24-hour World Bank/IFC air

3

quality guideline of 20 μg/m was exceeded, over the 127 days of data recording. The US

3

EPA standard of 35 μg/m was exceeded for 6 instances during the period. The highest

3

concentration during the monitoring period was 50 μg/m recorded on the 9 April 2011.

In summary, the air quality around the Project is of a generally good standard with regard to

NO2 and for the majority SO2 concentrations. Dust fallout and PM10 concentrations show a

strong seasonal trend, are within acceptable levels for international air quality standards

during the wet season but showed exceedances (in some cases exceeding the alert threshold

for dust fallout) during the dry season. The high PM2.5 concentrations indicate that sensitive

human receptors within the study area may be at risk of respiratory diseases as the World

Bank/IFC guideline on air quality was exceeded. As these results were only collected at one

site (MIOL Office, Lunsar), the rural areas closer to the mine site may differ. Due to the

absence of large industrial plants or highways in the area and wind speeds being low, the

main air pollution sources were windblown dust (natural pollution) and vehicle entrainment of

dust. Vehicular movement was higher around Lunsar than other monitoring stations,

evidenced by higher SO2 levels recorded in Lunsar.



5.8



Noise

Noise surveys were carried out to determine background noise levels and to provide input to

predictive noise modelling required to evaluate potential impacts from the Project. The

Project area is made up of acoustically soft ground which absorbs sound waves; however the

low-lying topography lacks barriers to noise propagation. The main existing noise sources are

traffic through Lunsar and the surrounding areas, and community noise (in the villages).

Noise monitoring was conducted by specialists from SRK at four locations, shown in Figure

5.10, in March 2011 (see SD 3 in Volume 3 for the full specialist report). The monitoring sites

were selected to represent different parts of the Project area and were located in village or

town centres to represent sensitive receptor locations. All measurements were conducted



U3823_Marampa_ESIS_Final.docx



September 2012

Page 97 of 298



SRK Consulting



Marampa Iron Ore Project ESIS – Main Report



using Svantek brand Svan 949 model Type-1 sound level meter (“SLM”). The microphone

was covered with a sponge protector to reduce wind noise effects and set up 1.5 m above the

ground. Automatic measurements were taken on an hourly basis over a 24 hour period at

each location. No noise regulations exist in Sierra Leone so the World Bank/IFC noise

guidelines for residential, institutional and educational receptors were used.

Table 5-4 shows the IFC night time noise guidance level was exceeded at all locations, and

the daytime level was exceeded in Makomp and Rogbesseh. The difference in day and night

noise levels appears to be negligible. As no busy highways or industrial establishments are

present in the area, the high noise levels are attributed to community noise. Noise levels

differ in Lunsar as it is a large town with differing community activity patterns. Although Lunsar

is more crowded and active than the villages, the activity is widespread in comparison to small

villages where the activities are concentrated. Rosint is the smallest village with the lowest

population, which may explain the lower noise levels. The results are based on hourly

measurements conducted over 24 hour periods in March 2011 only. Community activities

depend on the hour, day of the week and month so further noise measurements should be

recorded at a different time of year to observe potential variations in baseline levels.

Table 5-4: Baseline noise level measurements March 2011 (dBA)



5.9



Parameter



Period



LA, min



24 hours



IFC Guideline

(exceedances

shown in red)



Lunsar



Makomp



Rogbesseh



Rosint



36.8



31.4



29.8



25.3



LA, 90



24 hours



43.5



42.9



40.0



39.6



LA, eq (24h)



24 hours



49.8



56.0



54.3



50.6



LA, 10



24 hours



51.2



57.9



55.6



53.1



LA, max



24 hours



86.3



93.0



93.9



81.9



LA, day



07:00 - 22:00



55



50.3



57.6



58.0



52.9



LA, night



22:00 - 07:00



45



49.8



53.9



52.6



47.3



Biodiversity

A rapid biodiversity assessment was undertaken by ECOREX Consulting Ecologists between

th

st

st

th

18 and 21 October 2010 (wet season) and 21 and 24 February 2011 (dry season) to

summarise the baseline conditions of the Project area, which is located within the Western

Guinea Lowland Forests terrestrial ecoregion and the Northern Upper Guinea aquatic

ecoregion. A further round of dry season aquatic biomonitoring was conducted by Nepid

Consultants in February 2012. Full copies of both the aquatic biomonitoring and biodiversity

impact assessment reports are included as SD 4 in Volume 3.

IKONOS satellite imagery was used to initially identify and delineate broad habitat types and

land-use patterns within the study area, the boundaries of which were ground-truthed during

the initial field visit. Sampling methods are described in detail in the specialist study reports.

The assessment of terrestrial habitat types and faunal associations included the following

activities:





Vegetation was sampled within each major habitat type using quadrants of 20 x 20 m to

measure presence, cover and abundance.







Mammals were recorded incidentally while surveying vegetation and other faunal groups,

through indirect evidence such as spoor or dung, in conjunction with limited visual or



U3823_Marampa_ESIS_Final.docx



September 2012

Page 98 of 298



SRK Consulting



Marampa Iron Ore Project ESIS – Main Report



audio confirmation.





Birds were sampled using the Timed-Species Count Method, identifying species seen or

heard using binoculars or a digital recorder.







Reptiles were sampled through active searching along transects.



The aquatic study focused on measuring biological receptors (benthic diatoms, aquatic

invertebrates, and fish) that are sensitive to changes in water quality at different temporal

scales, as a measure of aquatic ecosystem health. Data was collected from 16 sampling

sites (including five sites identified for long-term biomonitoring) in and around the Project area

(Figure 5.5 shows locations). The sampling methods for assessing the aquatic receptors

included the following activities:





Assessment of river flow conditions (to assist with habitat classification),







Assessment of water quality (major cations, anions and metals),







Benthic diatoms were assessed using the Specific Pollution Sensitivity Index (SPI),







Benthic aquatic macro-invertebrates were assessed through the Namibian Scoring

System version 2 (NASS2) bio-monitoring method,







Fish were sampled using a 30 x 30 cm hand-net during the November 2010 sampling

round, and seine and double fyke nets during the February 2011 sampling round.

Sampling was supplemented by examination of fisherman’s catches.



The conservation status of species identified was determined using the IUCN Red List of

Threatened Species (IUCN Red List), the Global Biodiversity Information Facility (GBIF)

database, Fishbase, and other reference documents for species in the area (Hawthorne &

Jongkind, 2008; Kingdon, 1997; Van Cakenberghe et al., 2009; Borrow & Demey, 2002; and

Frost, 2010). The presence of critical habitat was determined in accordance with IFC

Performance Standards definitions.



5.9.1



Terrestrial habitats and faunal associations

Six types of terrestrial habitats were defined within the study area; secondary forest/ farmbush

mosaic, rice wetlands, lowland forests (which includes gallery forest and swamp forest),

flooded natural grassland, and secondary savannah. The predominant habitat types are

secondary forest / farmbush and rice wetlands, reflecting the transformed and disturbed

nature of the habitats within the study area.

Photographs of these six habitat types are shown in Figure 5.11 and the spatial distribution is

shown in Figure 5.12. Based on the information available from the surveys, no critical habitat

was identified at the locations sampled during the baseline, with respect to home range,

feeding, breeding or nesting of the species present.

Secondary forest / farmbush: this habitat type covers approximately 75% of the study area

and the present ecological state of this habitat is classified as considerably modified. The

state of regeneration is more advanced within some parts of the study area (i.e. Area 3). The

secondary vegetation is dominated by Oil Palm (Elaeis guineensis) and scattered large

Mango (Mangifera indica), Kapok (Ceiba pentandra) and Gold Coast Bombax (Bombax

buonopozense) trees. Species composition is dominated by widespread species that are

typical colonisers in secondary regrowth.

The invasive exotic species Triffid Weed

(Chromolaena odorata) has become well established in many areas.



U3823_Marampa_ESIS_Final.docx



September 2012

Page 99 of 298



SRK Consulting



Marampa Iron Ore Project ESIS – Main Report



Secondary forest / farmbush



Rice wetland



Gallery forest



Flooded natural grassland



Swamp forest



Secondary savannah



Figure 5.11: Photographs of terrestrial habitats within the study area



This habitat supports the most widespread bird assemblage, with 122 bird species observed

during the field visits (65% of the species observed). The most abundant species were Bluespotted Wood Dove, Common Bulbul, Whistling Cisticola, Pied Crow and Red-eyed Dove.

Rice wetlands: this habitat type covers almost all valleys (approximately 15% of the study

area) and the present ecological state of this habitat is classified as considerably modified.

There are narrow ecotones (regions of transition) between the rice paddies and terrestrial

vegetation that contain remnants of original grass flora, of which Anadelphia leptocoma is

most prominent.



U3823_Marampa_ESIS_Final.docx



September 2012

Page 100 of 298



SRK Consulting



Marampa Iron Ore Project ESIS – Main Report



Figure 5.12: Distribution of terrestrial habitats across the study area



The lack of structural diversity in rice monocultures and the lack of open waterbodies reflects

the fairly low bird assemblage within this habitat (56 species). Ten species of forbs were

identified in the rice wetland habitat, however these are fairly widespread generalist species.



U3823_Marampa_ESIS_Final.docx



September 2012

Page 101 of 298



SRK Consulting



Marampa Iron Ore Project ESIS – Main Report



Flooded Natural Grassland: this habitat type is located adjacent to the swamp forest on the

northern back of the Rokel River and the present ecological state of this habitat is classified

as slightly modified. Anadelphia leptocoma is dominant at the slightly drier, higher-lying

ground. Rhytachne rottboellioides is closely associated with Anadelphia, but occupies the

flooded part of the wetlands. Where patches of open water are present, floating hydrophytes

are common. As the majority of habitats within the study area are highly transformed, this

habitat represents the only patch of untransformed natural grassland.

Lowland forest: this habitat includes all gallery or riparian forest and swamp forest. Gallery

forest is most developed along the banks of the Rokel River in narrow strips (up to 20-30 m).

There are also narrower strips of this gallery forest along other perennial tributaries in the

study area; however it is often fragmented and discontinuous. The present ecological state of

gallery forest is classified as slightly modified. Gallery Forest is characterised by high species

richness and 60% of the plant species found during fieldwork were located in this vegetation

community. Gallery forests have high functional value in terms of providing flood attenuation

and riverbank stabilisation.

Swamp forests are located along a tributary of the Rokel River in Area 3. The species

composition of the swamp forests is similar to that occurring in riparian forest along the Rokel

River. The present ecological state of this habitat is classified as moderately modified; largely

due to removal of vegetation for fuel and small-scale logging. However, the swamp forest

does still have a moderately high functional value, such as providing flood attenuation and

riverbank stabilisation. This habitat connects the larger forest along the Rokel River to the

gallery forests higher up the main tributary.

A total of 64 bird species were observed with the lowland forest habitats (36% of the species

observed). The forest bird species include forest specialists (18 species), forest generalists

(29 species) and forest visitors (17 visitors). Forest specialists are considered to have higher

conservation significance, as these species are unable to adapt to disturbed forest conditions.

Secondary savannah: this habitat type is located in the northern part of Area 3 and the

present ecological state of this habitat is classified as considerably modified. Vegetation

structure is Short Open Woodland (sensu Edwards, 1983) with a dense grass understory. The

absence of Elaeis guineense (Oil Palm), which is an indicator species of former forest

conditions when growing in open “savannah” (Bakshi, 1963), means that this community is

most likely representative of true savannah. Whilst this habitat type only occupies a small

proportion of the study area, it is well represented in large areas between Lunsar and Port

Loko.

Within this habitat bird species richness was found to be high, with 85 species observed. The

bird assemblage within this habitat is distinctive in species composition and supports a

number of species more typical of the Sudan-Guinea savannah biome.



5.9.2



Terrestrial species of conservation significance

During the field visits, the presence of three plant species of conservation significance was

confirmed, all of which are restricted to forest habitat. Based on the habitat types within the

study area, it is likely that other plant species of conservation significance, including three

wetland species, three aquatic species and three forest species, may also be present.

One Near Threatened mammal was confirmed within the study area, the Straw-coloured Fruit

Bat, which can range widely over wooded habitat in the study area. Three other species have

a high-moderate likelihood of occurrence based on their preference for habitats within the



U3823_Marampa_ESIS_Final.docx



September 2012

Page 102 of 298



SRK Consulting



Marampa Iron Ore Project ESIS – Main Report



study area – the Tree Pangolin (found in secondary forest / farmbush), and the Diana Monkey

and Sooty Mangabey (both occurring in lowland forest).

No bird species of conservation significance were observed during the field visits. However,

five near threatened and one data deficient species have a moderate likelihood of occurrence

in the area. Two of these (raptors) are most likely to be associated with over broad grassy

valleys, two species are likely to be associated with edges of dense forest, and the fifth

species is most likely to occur in flooded natural grassland or along grassy edges of rice

wetlands and so could occur anywhere in the drainage lines of the study area.



5.9.3



Aquatic habitats and faunal associations

Five types of aquatic habitats were identified within the study area by Ecorex during their wet

season survey; seasonal valley head wetlands, seasonal mid-slope wetlands, perennial midslope wetlands, perennial upper foothill streams and perennial lower foothill river. However,

following the February 2012 dry season survey by Nepid, due to the absence of flow in rivers

previously classified as perennial, the classification of two perennial habitats was changed to

seasonal, reducing the number of habitats to four. The classification presented below is

therefore the revised classification by Nepid and differs slightly from that presented in the

Ecorex report.

Photographs of these habitat types are shown in Figure 5.13 and the spatial distribution is

shown in Figure 5.14. Based on the information available from the surveys, no critical habitat

was identified at any of the locations sampled during the baseline (due to the fact that the

conservation status of one of the species identified is being downgraded).

Seasonal valley head wetlands: these are low-gradient, stream-source wetlands. The

wetlands within the study area were transformed, mainly by cultivation of rice, however they

were structurally intact. There was no evidence of erosion or incision of the main channels.

The present ecological state of these wetlands is classified as moderately modified. These

wetlands do not provide dry season baseflows, so they are unlikely to be important for

streamflow maintenance. The ecological importance of this aquatic habitat is related mainly

to high numbers of fish from the families Nothobranchiidae and Poecilidae. Within this habitat

11 species of fish were recorded, the most common being the Nothobranchid Epiplatys

lokoensis. This species is classified as Endangered by the IUCN, however it appears to be

unaffected by rice cultivation and may have even benefited from this change in landuse.

Seasonal mid-slope wetlands: these are low-gradient, mid-slope wetlands, usually with a

defined channel and open-canopy riparian margins. The present ecological state of these

wetlands is classified as moderately modified. These wetlands do not provide dry season

baseflows, so they are unlikely to be important for streamflow maintenance. Most of these

wetlands were used for cultivation of rice.



U3823_Marampa_ESIS_Final.docx



September 2012

Page 103 of 298



SRK Consulting



Marampa Iron Ore Project ESIS – Main Report



Seasonal valley head wetland (wet season)



Seasonal mid-slope wetland (wet season)



Perenial lower foothill river



Seasonal upper foothill stream (wet season)



Figure 5.13: Photographs of aquatic habitats within the study area



Their ecological importance is related mainly to high numbers of fish from the families

Nothobranchiidae and Poecilidae. Eleven species of fish were collected in this habitat type, of

which the most common and widespread was the poecilid Poropanchax normani.

During their wet season survey, Ecorex also identified Perennial mid-slope wetlands, most

prominent along the middle and lower reaches of the Baki Stream. Subsequent revision in this

classification by Nepid resulted in the habitat being reclassified as seasonal mid-slope

wetlands. Due to slight differences in habitat characteristics and species makeup, a brief

description of the perennial mid-slope wetlands as originally identified, is provided. Instream

habitats included closed (shaded) and open (sunny), shallow-fast, shallow-slow and deepslow areas, usually with an abundance and high diversity of submerged and emergent aquatic

vegetation.

Their ecological importance is related to the diversity of instream habitats and associated

fauna. Twelve species of fish were recorded within this habitat type, with characteristic

species being barbs (Barbus macrops and B. leonensis) and alestids (Brycinus spp). Most of

these wetlands within the study area had been transformed by deforestation and cultivation of

rice.



U3823_Marampa_ESIS_Final.docx



September 2012

Page 104 of 298



SRK Consulting



Marampa Iron Ore Project ESIS – Main Report



Figure 5.14: Distribution of aquatic habitats across the study area and locations of baseline

and biomonitoring sampling sites



Seasonal upper foothill streams: the lower Morea Stream was the only area classified as a

Seasonal Upper Foothill Stream. The present ecological state of these wetlands is classified

as moderately modified. This stream supports a wide diversity of aquatic habitats, including

stones in and out-of-current, deep pools with bedrock substrate, gravel bars, aquatic

U3823_Marampa_ESIS_Final.docx



September 2012

Page 105 of 298



SRK Consulting



Marampa Iron Ore Project ESIS – Main Report



vegetation and marginal vegetation in and out-of-current. This stream was originally classified

as “perennial” in the Ecorex Biodiversity Impact Assessment Report following the wet season

survey but this classification was revised to “seasonal” following the dry season aquatic

biomonitoring survey by Nepid. Seven species of fish were recorded in the Morea Stream,

with the characteristic species being banded jewelfish (Hemichromis fasciatus) and the

anabantid (Ctenopoma kingsleyae).

Perennial lower foothill river: the Rokel River in the vicinity of the study area is about 130 m

wide, and is classified as a Perennial Lower Foothill River. Instream habitats include deep

pools, rapids, sand bars, backwaters and margins with tree roots.

The Bumbuna

Hydroelectric Facility, located about 90 km upstream, could have a significant impact on the

river, particularly during the dry-season.

A total of 32 species of fish was recorded in the Rokel River during this study. The most

diverse families recorded were cichlids (13 species) and mormyrids (10 species). The high

diversity of fish indicates the river is in excellent ecological health.



5.9.4



Aquatic species of conservation concern

During the field visits, the presence of one species of conservation significance was

confirmed. This is Epiplatys Iokoensis (Endangered), which was found within the seasonal

valley head wetlands. The conservation status of this species is currently being downgraded

based on more recent information regarding this species.

Based on the habitat types within the study area and previous studies within these areas,

other aquatic species of conservation significance may be present. Marcusenius meronai

(Endangered) has been recorded in the Bagbé and Rokel Rivers; Tilapia joka (Vulnerable)

has been recorded in the Rokel River; Sierraia leonensis (Vulnerable) a species endemic to

Sierra Leone; and Scriptaphyosemion roloffi, a species found mainly in the shallow and

stagnant parts of pools, brooks, swamps and small streams in the coastal rain forest, and is

known from the Little Scarcies River drainage system in Western Sierra Leone southward to

the drainage system of the Lower Lofa River in Western Liberia (Lalèyè 2006). A number of

Endemic species are also likely to be present.



5.9.5



Aquatic ecosystem health

The findings of the February 2012 (dry season) aquatic biomonitoring survey are summarised

below. Sampling sites referenced are shown in Figure 5.13.

Water quality: data indicated elevated concentrations of manganese at sampling site A2-2.

The other variables analysed were within recommended limits for drinking water and

protection of aquatic ecosystems.

Diatom analysis: the biological water quality was indicated to be Natural (Category A) at four

of the five sites monitored, and slightly modified at site A3-5, and heavy metal concentrations

to be below thresholds for biological concern.

Aquatic invertebrates: the composition and abundance of aquatic invertebrates varied

greatly amongst sampling sites and seasons, attributed mainly to differences in surface flow.

Limited data regarding existing impacts could be obtained.

Fish: the composition of fish species indicates significant deterioration in ecological

conditions (Category B to category E) at Site A2-2 since the October 2010 sampling round.

This is attributed to disturbance and sedimentation of the stream due to road construction in



U3823_Marampa_ESIS_Final.docx



September 2012

Page 106 of 298



SRK Consulting



Marampa Iron Ore Project ESIS – Main Report



the neighbouring mining concession (see Figure 5.15). Inadequate culvert design in the road

was also cited as a problem in terms of fish passage and sedimentation of rivers.



Excessive sediment in the Morea Stream February 2012.



Poorly constructed culvert with inadequate

capacity - February 2012.



Figure 5.15: Impacts on streams due to road construction on neighbouring concession

area



U3823_Marampa_ESIS_Final.docx



September 2012

Page 107 of 298



SRK Consulting



6



Marampa Iron Ore Project ESIS – Main Report



SOCIO-ECONOMIC BASELINE DESCRIPTION

This Chapter is based on the:





Socioeconomic Baseline Report, Marampa Iron Ore Project, SRK Consulting (UK) Ltd,

February 2012 (SRK 2012ab specialist report in Volume 3, SD8);







Rural Livelihoods Specialist Study: Phase 1 – dry season survey findings, Wild

Resources Ltd, May 2012 (WRL 2012 specialist report in Volume 3, SD8); and







Cultural Heritage Component of the Environmental and Social Impact Assessment,

Marampa, Sierra Leone Nexus Heritage and IFAN, April 2011 (Nexus 2011 specialist

report in Volume 3, SD8).



The baseline studies were conducted in adherence with Sierra Leone legislation and

international good practice guidelines from The World Bank and the International Finance

Corporation (“IFC”) on social assessments. The study area for the baseline included three

areas; Area 1 covers the potential locations of the processing plant, power generators,

auxiliary infrastructure, a tailings storage facility and waste rock dumps; Areas 2 and 3 cover

the geological target zones. Two corridors of approximately 100 m will be used for

transporting the ore from the potential mining areas in Areas 2 and 3 to the processing

infrastructure in Area 1 (Figure 6.1).

Subsequent to the household survey being completed, in March 2011, the Project layout

increased in area and the study areas were amended to accommodate these changes. It was

discovered that Maso and Magbungbu villages, which were added to the list of affected

villages, were not part of the household survey. However as the survey was based on a

sample the findings are considered representative of the Project area villages. Maso and

Magbungbu were included in the sample for the Rural Livelihoods Specialist (RLS) study

survey held in March 2012. The villages covered in the survey for the two studies are

presented in Figure 6.1.



6.1



Approach and methodology

The specialist studies are based on primary and secondary sources of information and data.

Secondary data was collected from the internet existing reports and articles and is referenced

in the footnotes. Primary data was collected directly from community members, local

government and non-government functionaries.

For the socio economic study, data collection methods consisted of a household survey,

individual interviews, village information sheets, stakeholder group interviews and

observations (31 March – 6 April 2011). For the RLS study (phase 1) the data collection

methods consisted of village focus group surveys and interviews; field survey, GPS

recordings and survey of commercial activities related to natural resource use. Primary data

was collected during 14-21 March 2012, in the dry season. The data collection methods,

assumptions and limitations are described in the specialist baseline reports.



U3823_Marampa_ESIS_Final.docx



September 2012

Page 108 of 298



SRK Consulting



Marampa Iron Ore Project ESIS – Main Report



Figure 6.1: Location of villages covered under household survey and rural livelihoods study



U3823_Marampa_ESIS_Final.docx



September 2012

Page 109 of 298



SRK Consulting



6.2



Marampa Iron Ore Project ESIS – Main Report



Population

2



The Port Loko District where the Project is located covers an area of 5,719 km with a

population of approximately 478,000. The Project is located in the Marampa Chiefdom, which

8

has a population of approximately 40,000 (2010) . However, the Project’s area of influence

also covers the, Masimera and Maforki Chiefdoms.



6.2.1



Population in the study area

Population figures for the study area are based on the village survey (Table 6-1).

Table 6-1: Population in the study area villages

Village name



Males



Females



Total

Population



Number of

households



Average

family size



Gbese



120



134



254



23



11



Kalangba



68



65



133



15



9



Katick



171



162



333



35



10



Konta



71



75



146



11



13



Konta Bana



216



187



403



34



12



Konta Lol



19



18



37



7



5



Ma Sesay



4



3



7



2



4



Mafira



53



41



94



15



6



Mafuri



93



85



178



23



8



Magbafat



267



275



542



34



16



Marunku



260



259



519



40



13



Matukia



139



253



392



98



4



Mebesseneh



1208



1227



2435



259



9



Moria



12



5



17



2



9



Rogbaneh



86



84



170



14



12



Rolal c/o Maforay



45



47



92



15



6



Rosint



47



57



104



20



5



Total



2879



2977



5856



647



9



Source: SRK Village survey April 2011



The villages have an average size of 38 households, and the average population is 344.

49.2% of the population are males and 50.8% are female, which is indicative of the larger

number of males killed in the civil war. The household survey indicated that 42% of the

population is below the age of 15, 54% is between the ages of 15 and 64, and 4% is above

the age of 64



6.2.2



Ethnicity

There are 16 ethnic groups in Sierra Leone; the two largest groups are the Mende and the

Temne. The dominant group in the Project area is Temne other groups include Limba,

Mende and Kono. The official language spoken in schools and government administration is

9

English , though a majority of people mainly speak Mende, Temne or Krio. The main religions

are Islam (60%) and Christianity (30%) and indigenous religions (10%).



8

9



As per the records from the Peripheral Health Unit (PHU), Lunsar (interview 5 April 2011)

Britannia Concise Encyclopaedia: Sierra Leone



U3823_Marampa_ESIS_Final.docx



September 2012

Page 110 of 298



SRK Consulting



6.3



Marampa Iron Ore Project ESIS – Main Report



Economy

The main economic activities in the Port Loko District are small scale diamond mining,

subsistence farming, production of charcoal, small businesses and small scale fishing. Table

6-2 presents the number of people engaged in different livelihood strategies across the study

area villages.

Table 6-2: Distribution of livelihood strategies (aggregated for all study villages)

Village



Total persons



Percentage



Agriculture



2095



82%



Charcoal



955



37%



Animal Husbandry



813



32%



Fishing



714



28%



Plantation



227



9%



Beekeeping



183



7%



Herder



153



6%



Hunting



151



6%



Herbalist



52



2%



Artisan



60



2%



Artisanal mining



52



2%



Driver/mechanic



57



2%



Government employee



18



1%



Brewing



25



1%



Commerce/shop/



7



0.30%



Source: SRK household survey April 2011



An overwhelming majority of people are engaged in farming (82%). In most cases other

economic activities are undertaken in addition to farming (hence the overlap in percentages in

the table). Other popular occupations in the study villages are charcoal making (37%), animal

husbandry (32%) and fishing (28%). Further information on the characteristics of different

livelihoods strategies is provided in Section 6.3.1.



6.3.1



Description of livelihoods in the study area

This section, based on the rural livelihoods study (WRL, 2012), presents information on the

nature of livelihood activities in the study area. It is mainly based on the RLS dry season

survey and SRK household survey, and will be further supplemented by a wet season RLS

survey in August 2012.

Agriculture

The sale of cash crops is probably the most readily accessible income for most villagers

however, most farmers keep what they grow for household consumption. Produce can be sold

within the villages, or taken to the daily market in Lunsar or weekly Tuesday market in

Foredugu. Some of the generic problems with marketing agricultural produce include the lack

of transport. Traders apparently visit the villages with vehicles to buy up larger quantities of

produce, usually at relatively low prices and there are also wholesalers based in Lunsar.

The agricultural season begins with preparation of fields in January to March, followed by

planting mainly during April to July. Cutting of trees and charcoal making is usually done in

April before the start of wet season. Harvesting begins in September thus the hungry period



U3823_Marampa_ESIS_Final.docx



September 2012

Page 111 of 298



SRK Consulting



Marampa Iron Ore Project ESIS – Main Report



can last from May to August. The main harvesting goes on till November/December.

The agricultural potential in the Project varies depending on the land type. Topographic relief

in the Lunsar area is subdued, and wide, flat river valleys meander across it. The height

difference of just a few metres makes a significant difference to soil fertility, wetness and

suitability for different crops and farming systems. During focus group discussions it became

apparent that there are complex interactions between the use of different landscape units,

crops and crop varieties as outlined below.





Inland valley swamps: The flat-bottomed valleys, often termed ‘inland valley swamps’,

are characterised by hydromorphic soils with high clay content and low infiltration rates

which, coupled with a shallow gradient, means they are flooded for much of the rainy

season. In-wash of nutrients by the river and from valley sides means soils are relatively

fertile and suited to rice cultivation. In some places (e.g. Masu) the flow and depth of

water is controlled by the installation of contour-bunds. In the narrow, valley-head

wetlands, headwater valleys and contour bunds are not used and different varieties of

rice are utilised to take advantage of natural water levels. In the dry season, the soil is

very difficult to work by hand. Most inland valley swamps are cultivated continuously.

Examples are shown in Figure 6.2.



Perennial inland valley swamp with rice



Irrigated mound gardens in runoff zone at end of

dry season



Figure 6.2: Photographs of different agricultural methods





Runoff zone: This is the narrow zone where the upland slopes meet the flat valley floor

and is called tembe. The soils here are silty and difficult to work when dry. As the flood

waters recede, the soil is thrown up using hoes into mounds (m'bof). These mounds are

used to grow a variety of crops which are usually planted in March and harvested in

June. At the end of the dry season wells are dug into the valley floor to irrigate

vegetables on the mounds while cassava is planted as the rains start. As the water rises,

the mounds keep the crops from becoming waterlogged.







Uplands: Upland areas are generally covered with trees. The interfluves between the

valleys have gravelly clay loam soils which are freely draining, and, are suitable for a

range of perennial and rain-fed crops. The farming cycle on the uplands begins with the

clearance of a parcel of bush towards the end of the dry season (March/April). Trees are

cut at about a metre off the ground and timber removed as needed. Once the rains start

the land is sown with rice. Cassava is one of the commonest upland crops and is the

only crop routinely grown as a monoculture. The main time for sowing in the uplands is

April/May with harvesting in November. If cassava has been planted this may be left for



U3823_Marampa_ESIS_Final.docx



September 2012

Page 112 of 298



SRK Consulting



Marampa Iron Ore Project ESIS – Main Report



up to four years and harvested at need. During the fallow years, there is regeneration of

secondary forest trees and the resulting poles are used to build houses, used as

firewood or turned into charcoal. There is also some differentiation of the uplands. Much

of this area has an over storey of oil palm but there are also groves of fruit trees some of

which are under planted with shade-bearing crops.

A farmer who has access to these landscape units and uses them to full advantage can reap

five harvests of rice a year and ensure a near continuous supply of fresh foodstuffs.

Nevertheless there is a ‘hungry gap’ in August (paya) at the height of the rains when the crops

are growing and the previous harvest has been depleted. Cassava and firewood are sold at

this time

There are at least 26 crops grown in the study villages (WRL 2012), some examples are given

in Figure 6.3. Most are for home consumption but several are also cultivated for sale in

Lunsar. This agro-diversity helps the famers take advantage of the different opportunities

presented to them. The principal staple crops are rice and cassava with a large number of

varieties grown in the area (WRL 2012).



Corn (Maize) and cucumber field



Harvesting palm fruits



Figure 6.3: Photographs of different crops

Commercial farms

A few farmers have capitalised on the opportunity for incomes from farming close to Lunsar

and the markets to become commercial farmers. The commercial crops selling at a good price

are cassava, aubergine, cucumber, pepper, tomato and pineapples. One farmer reported

revenues of Le 200,000 per month and an annual income of over Le 1,000,000 just from

cassava. Pineapples are the most valuable commercial crop and retail at 10,000 each,

because they are considered to be a curative for typhoid. Peppers sell at Le 150,000 a sack.

Livestock

Livestock owned by the surveyed households is summarised in Table 6-3. 78% of the sample

households reported keeping one or more type of livestock. There are dedicated herdsmen,

specifically in Mafira Village, while elsewhere livestock is kept near the homestead and

tended by the women. The average number of animals kept per household is only indicative

as the actual number of animals owned varies according to household.



U3823_Marampa_ESIS_Final.docx



September 2012

Page 113 of 298



SRK Consulting



Marampa Iron Ore Project ESIS – Main Report



Table 6-3: Livestock husbandry in the Project area

Animals



Percentage households

possessing livestock



Average number

livestock per household



Percentage households

selling livestock



Goats



41%



3



34%



Ducks



21%



5



17%



Sheep



36%



3



31%



Chickens



79%



19



68%



Source: SRK household survey April 2011







Poultry: Chickens were observed free-ranging in all villages and are kept for eggs and

meat. Most are for household consumption but some are sold. Poultry cages are made of

woven basketwork, or occasionally of metal. One villager mentioned that the parasitic

disease coccidiosis is a problem. Ducks (and their eggs) were mentioned as being used

in sacrifices in various traditional religious ceremonies.







Sheep and Pygmy goats: Both sheep and goats were seen free-ranging in and around

the study villages. There was little indication of any supplementary feeding, though in

Matukia women mentioned providing rushes as fodder for livestock. To protect crops

from domestic animals, low fences of palm fronds and bamboo are sometimes set up

(Figure 6.4).







Pigs: The only pigs seen were on a demonstration farm in Royail. Six sows and six boars

were being kept for breeding experiments.







Cattle: There were only a couple of observations of cattle in the study villages. The

household survey (SRK 2011) recorded 11 herders in Marunku, 1 in Magbungbu, 6 in

Maforay and 15 in Matukia.







Dogs: Dogs were also seen in most villages, kept either as pets, or occasionally used for

hunting or driving pests from crops. Owners mentioned using herbal ‘charms’ to help

train their dogs to hunt for certain animal species.



Figure 6.4: Photograph of crops fenced against livestock

Fishing

Fishing is a significant activity in the study area and both locally caught fish and marine fish

brought into Lunsar are an important source of animal protein. Although men, women and

children are involved in fishing, each group tends to use a different method and it is the

women who spend most time engaged in this activity (Figure 6.5). Fishing occurs throughout

U3823_Marampa_ESIS_Final.docx



September 2012

Page 114 of 298



SRK Consulting



Marampa Iron Ore Project ESIS – Main Report



the year, though women tend to fish in the dry season and men in the rainy season. The

fishing methods used in the study villages include, nets impoundments, traps, hand lines and

sieves. When small numbers of fish are caught, these are normally destined for family use.

Larger fish, or bigger catches, may be sold fresh in the nearest village, or taken to Lunsar



Impoundments



Fish smoking activity in Gbese Village



Figure 6.5: Photographs of different fishing related activities



Use of wild plants

People in the study villages rely on the resources available in their immediate environment.

This means the houses are made from poles cut from farm bush (fallows), wild foods are

eaten as snacks or as a source of sustenance in times of famine and extensive use is made

of plants in traditional medicine (medicinal use represents 87% of the use of wild plants

recorded, as traditional medicine is the primary source of healthcare in the villages).

Estimating the importance of these resources requires measures of the volume consumed

and whether there are suitable substitutes. Though there are no data on the quantities

required it is possible to make some assumptions based on the nature of the use.





Traditional medicine: Pooling the ECOREX (McCleland & Palmer 2011) and WRL plant

species lists gives a total of 241 plants, of which roughly half are used as medicines

(Figure 6.6). The majority of medicinal plants are obtained from lowland forest, which is

an uncommon habitat in the area and is probably only found within sacred bush. Several

informants reported that the dry season is best for gathering medicinal plants. Honey is

used as a medicine or tonic. Wild honey is collected once a year, at the end of the dry

season (March—April). The typical yield for a hive is 9 - 14 litres. It is sold for Le 5,000

for half a litre. The only medicinal use of animals was a mention of chameleons.







Wild foods: Although the people of the study villages are good farmers they continue to

make use of wild foods, which can be an important contribution to food security

especially if it is available in gaps between crop harvests. In Marunku the women listed

wild foods they collect in the dry season as: Bush yam (wild yam = Dioscorea spp),

Banga or palm cabbage (unopened bud of palms), matanka (probably Sorindeia

juglandifolia), malimbo (unidentified) and blakomba (probably Dialium guineense).







Construction materials: The material culture of the local people was traditionally

entirely derived from local resources (Figure 6.6). Although building materials are

changing many houses, especially those of poorer families, are still made using

traditional materials. In most villages there were houses being made from mud blocks.



U3823_Marampa_ESIS_Final.docx



September 2012

Page 115 of 298



SRK Consulting



Marampa Iron Ore Project ESIS – Main Report



These are made by specialists from outside the village and cost Le 500 each plus food

for the workers. The RLS study lists all the species recorded as being used now or in the

past for house construction (WRL 2012). A more recent innovation is cutting large forest

trees into planks which are then used in building, for furniture and for sale. Exploitation

of these tree species is likely to be unsustainable.



Wild leaves used as malaria medicine



Banana fruit as malaria medicine



Construction material for building a small

house (walls in progress)



Timber board making



Figure 6.6: Photograph of medicinal plants and plants used for construction

Firewood & charcoal

94% of the sample households reported using wood as the energy source for cooking. The

list of species used as firewood includes fruit trees such as guava and mango and indicates

there is pressure on the supply of firewood. A typical upland farm patch yields 10-15 bags of

charcoal. The prices vary from Le10,000 in the village, Le12,000 in Lunsar to Le15,000 in

Freetown. It appears that most of the firewood and charcoal is derived from clearance of

fallow land, making it more sustainable. However, there is some evidence that trees in the

bush (not associated with farm clearance) are also cut to make charcoal.

Hunting and trapping

To facilitate questioning on hunting activities, a small leaflet and flashcards containing images

of 60 species was used. Analysis of the results shows that a small number of species are

caught regularly, with a secondary group of species seen regularly by hunters but caught less

often (RLS study, WRL 2012). During interviews, villagers drew a distinction between

“hunting” and “trapping”. “Hunting” was considered a specialist activity, whilst everybody who

U3823_Marampa_ESIS_Final.docx



September 2012

Page 116 of 298



SRK Consulting



Marampa Iron Ore Project ESIS – Main Report



farmed also “trapped” both as a means of providing food, but also to control crop raiding

pests. Men, women and children are involved in hunting/ trapping to different degrees. Little

evidence of bush meat species was seen during the field visit, which suggested the level of

hunting was low.

Specialist hunters hunt throughout the year, but may be busier during the rainy season if

providing crop protection to other farmers. The majority of the most frequently hunted species,

e.g. Maxwell’s duiker, Brush-tailed Porcupine and Giant Rat can withstand high levels of

hunting pressure. At present, it would appear that there are relatively few guns being used by

hunters in the Marampa area. In Marunku, farmers mentioned paying young men up to

Le100,000 to trap animals on their land. As an indication of the areas that local hunters might

cover during a typical trip, one hunter was asked to carry a GPS tracker unit and to follow his

normal hunting route. He covered approximately 16 km.

The majority of trapping takes place during the rainy season. Trapping is mainly by wirecable snares. Two other types of trap were also seen: a home-made dead-fall wooden boxtrap used to catch Giant Rats and a spring-loaded break-back trap used for smaller rats and

mice (Figure 6.7). Some specialist hunters also use nets and dogs to hunt. It was found that

most trapping of animals takes place to protect farm crops. Crop protection is a critical and

time-consuming task, particularly bird-scaring which involves children of school-going age.

See the RLS study WRL 2012 for more information on hunting and trapping activities.



Dead-fall box trap



Spring break-back traps in market



Figure 6.7: Photographs of different types of traps

Labour

Manual labour is the biggest single input into the farm economy. Labour requirements for

inland valley swamps alone can exceed the labour capacity of farm families and a shortage of

labour was the most frequent complaint from farmers. The villages utilise labour gangs but

with differences in rates paid and descriptions of arrangements. Women also hire men

directly to undertake specialist tasks. It will cost a woman Le25,000 to Le30,000 to have men

cut trees on an upland plot and Le50,000 to have charcoal made for her.

Trade in wild products

With a few exceptions sales of crops are seasonal, so products listed in Table 6-4 are used to

supplement incomes. Other natural resources sold by people in the study are ferrocrete

blocks and sand. Commercialisation of wild resources in the study villages is relatively low.

The only resources that appear to be threatened by over-exploitation are timber trees.

U3823_Marampa_ESIS_Final.docx



September 2012

Page 117 of 298



SRK Consulting



Marampa Iron Ore Project ESIS – Main Report



However, loss of threatened habitats and increasing demand may initiate commercialisation

of medicinal plants, which could result in over-exploitation of this resource.

Table 6-4: Traded wild products

Product



Value



Market channels



Nuts of Cola nitida



Price Le5,000 to –

Le8,000 for 100. Le

30,000 for a ‘load’



Wholesale (sold by the hundreds) from

villages, retailed in local markets. May

reach the ancient pan Saharan trade

network for this product.



Leaves of Hallea stipulosa,

direct or as wrapping for Kola

nuts as traditional wedding gift



Le500 per leaf if sold

individually



Probably sold within Temne cultural group

in Lunsar area



Dried calyx (flower bud scale)

of Xylopia aethiopica used a

tea.



Le2,000 for a handful



Direct retail in Foredugu market. Some

wholesale into national markets via Lunsar.

Sell (available) in dry season.



Fruit of Dialium guineense

cooked with sugar to make a

sweet



Le1,000 for a fistsized lump



Sold in Foredugu market



Poles (2 m long) of

Anisophyllea laurina – 12 poles

in a bundle



bundles of 12 sell for

Le15,000 in Lunsar



Sold in large volumes for building and

scaffolding across Sierra Leone



Firewood – many species –

bundles of sticks



Le6,000 – Le7,000



Charcoal - bag



Le10,000 - Le15,000



Fresh fruit of Sorindeia

juglandifolia and Diospyros

heudelotii

Honey – wild bee hives



Village, Lunsar and national market chains.

Prices depend on market and season

(higher prices in rainy season)

Sold to bring income to poor families



Le5,000 for half litre



Retail in Lunsar and perhaps Foredugu



Sand mining

Sand mining from the Rokel River is a key economic activity (Figure 6.8). It has a high

commercial value due to a demand from the construction sector. Men, women and children

are engaged in different activities contributing towards collecting sand. Each truck load is sold

at between Le300,000 to Le500,000.



Trucks usually take the sand to the markets



Boy collecting sand

Figure 6.8: Photographs of sand mining



6.3.2



Value addition

There is little opportunity to sell most crops in a processed form but there are a few

opportunities for value addition as listed below, with some examples shown in Figure 6.9.



U3823_Marampa_ESIS_Final.docx



September 2012

Page 118 of 298



SRK Consulting



Marampa Iron Ore Project ESIS – Main Report



Palm oil extraction process



Soap for sale in Foredugu market (the

vendor had come from Makene by transport)



Figure 6.9: Photographs of value addition to crops

















Soap making process: To make soap the oil is boiled with caustic soda bought from the

market with Raphia palm leaves. The resultant soap is medium hard soap sold for

Le1,000.







Charcoal: Figures from the farm questionnaires suggest it costs Le25,000 to have trees

cut, Le50,000 for the charcoal burner to turn a farm plot into 10-15 bags of charcoal

which then wholesale for Le10,000 each. This gives a cost of production of Le70,000, for

a return of Le100,000 – Le150,000.

Artisans and specialist skills: There were remarkably few artisans encountered in the

study villages, the skills of those encountered are described in Table 6-5 and some

examples are given in Figure 6.10.







6.4



Food preservation and baking: Drying is an efficient means of preserving perishable

foods especially in the dry season. In the case of chillies, processing did not add any

value. Fresh chillies retailed at Le1,500 per handful and dried retailed at Le1,200 per

handful. Baking can add value however there was no evidence of ovens in the area.

Cassava: Cassava is a crop which perishes quickly therefore much of it is sold

processed. A sack of raw cassava tubers sells for Le20,000, while a sack of raw cassava

turned into fufu sells for Le50,000.

Palm oil: There are two varieties of oil palm; the tall, wild trees are lower yielding but

produce tastier, redder oil preferred by the local people and kept for home consumption.

The short Massankey cultivars produce less desirable oil, which is sold as good quality

kernel oil. The villagers sell the Massankey nuts to people in Lunsar who use them to

make soap. The oil is decanted into yellow gallon containers and sold or stored for

household use.



Land tenure

In Sierra Leone, there are two main systems of land holding: freehold rights in the Western

Area and a customary system in the provinces where land is principally owned and controlled

by families or traditional leaders. In the study area villages customary land tenure rules apply.

According to customary law, chiefdoms and communities hold the ownership of property and

therefore a plot of land can never be owned freehold.

Title to land is vested in families based on ‘first settler’ rights with a small number of families



U3823_Marampa_ESIS_Final.docx



September 2012

Page 119 of 298



SRK Consulting



Marampa Iron Ore Project ESIS – Main Report



controlling land in each village. Family land is vested in the family as a group, although family

land tenure prevails in the area it is locally acknowledged that the Paramount Chief is the

custodian of the land. Family land is allocated to individual family members and can also be

‘lent’ or rented to less privileged families or strangers in need of growing space. Less formal

arrangements, whereby a farmer or a family “borrow” land, were observed.

In the context of resettlement, national policy states that, as much as possible, land disposal

or acquisition should not render a land title holder (including customary land ownership), his

kith, kin and descendants completely landless, save in the case of compulsory acquisition in

the public interest.

Table 6-5: Artisans and specialist skills in the study villages

Craft



Resources used



Markets and prices



Broom

makers



Mid-ribs of young palm fronds (a common and

essentially free resource). The ribs are stripped,

tied into bundles and dried. Made by women and

men.









Lunsar 1,000 Le per broom

Village 500 Le per broom



Wood

carvers



Mortar carved from Yemani (Gmelina arborea) and

pestle from K’bap (unidentified). Carver learnt trade

by watching people make them.







Previously sold but now

made for household use.



Basket

makers



Men weave baskets from Raphia leaf stem for use

by fish sellers, winnows and mats. Also make large

woven granaries (~1.5 m tall x 1 m diameter with

lids) to order.







Baskets 2,000 to 5,000

depending on size

Granary sells for 50,000 Le



Blacksmith



Makes cutlasses from vehicle leaf-springs with

handles made from Holarrina africana and

Samanea dinklagei. Skills passed from father to

son.







Village & Lunsar 20,000 Le

per cutlass



Drum makers



Body of drum made from Yemani (Gmelina

arborea). Skill passed from father to son.







Palm wine

makers



Almost exclusively done by Limba people. Men

work in groups and share equipment. They pay

15,000 Le per month to farmer to tap trees. Taps

put into base of young leaves at top of tree and

emptied twice a day in morning and evening.







Professional

hunters



There is an opportunity for specialist hunters,

especially those with guns, or groups with nets and

trained dogs, to provide pest control on farms on a

contract basis.







Fishermen



In villages on the Rokel river there may well be

specialist fishermen who use the large dugout

canoes and large hand-casting nets to catch fish,

though this equipment may available to everyone.







Sold on commission for

around 20,000 Le for a

drum

Wholesale: Plastic jerry can

sells for 20,000 Le and

costs 13,000 Le to make

giving a profit of 7,000 Le

for ten litres.

Retail in village: Bottle of

palm wine sells for 1,000

Le

Rates seem highly variable

(20,000 – 100,000 Le),

depending on the services

provided. Any animals

caught are kept by the

hunters.

Numerous small traders

were encountered passing

from the fishing villages of

Mbla & Masu, having

purchased fish from

fishermen there.



U3823_Marampa_ESIS_Final.docx











September 2012

Page 120 of 298



SRK Consulting



Marampa Iron Ore Project ESIS – Main Report



Brooms



Wood carvings



Baskets



Drums



A blacksmith in the Konta Village



Fishing nets (a net takes a week to make and

sells for Le 10,000)



Figure 6.10: Photographs of artisanal work



6.5



Living standards

The household survey shows that only 8% of the adult population in the Project area (age 1560) have a stable regular income. The percentages of households in the survey who obtained

income from different sources during the month of April 2011 are presented in Table 6-6.

From this it can be seen that the sale of agricultural/farm produce was an important source of

income in the study villages.



U3823_Marampa_ESIS_Final.docx



September 2012

Page 121 of 298



SRK Consulting



Marampa Iron Ore Project ESIS – Main Report



Table 6-6: Income sources in the study area

Income Source



Percentage of households



Sales of agricultural/farm produce (including livestock)



80%



Self-employment (artisans/trade)



6%



Employment



2%



Remittances



5%



Source: SRK household survey April 2011



6.5.1



Possessions and expenditure

Household possessions are generally limited to basic furniture such as tables, beds,

chairs/stools and items such as radios cell phones and bicycles, which are considered

essential. Table 6-7 shows the average annual household expenditure for the principle items.

The average expenditure on food is 44% of total expenditure. Monetised value of food

produced further increases this percentage reflecting widespread poverty in the study area. It

also shows people are not self-sufficient with regard to food. School fees, clothing, household

energy, agricultural equipment, medical care and transport are also significant expenditure

items.

Table 6-7: Annual household expenditure in the study area

Item



Average cost per

household per

year in Le



Average cost per

household per year in

10

USD



Percentage of

total expenditure



Food



1,836,146



402.8



44.2%



School fees



469,695



103.0



11.3%



Clothing



333,337



73.1



8.0%



Household energy



327,624



71.9



7.9%



Agricultural equipment and inputs



314,796



69.1



7.6%



Medical care



279,914



61.4



6.7%



Transport



227,794



50.0



5.5%



Buildings



158,905



34.9



3.8%



Cellular telephone



77,932



17.1



1.9%



Savings



70,694



15.5



1.7%



Livestock expenses



53,662



11.8



1.3%



Water



3,220



0.7



0.1%



Total



4,153,719



911.3



100%



Source: SRK household survey April 2011



6.5.2



Food Security

The diet of local communities in the study area is based on locally produced staple crops and

locally grown vegetables. Fish is eaten more regularly than meat, which is eaten occasionally

due to its high cost. Decreasing crop yields, an increase in pest related crop failures and

11

reduced availability of food resources from the forest have led to reduced food security . In

the household survey, 83% of households indicated they experience food shortages at some

stage during the year, predominantly during the period July to September.



10

11



Exchange rate 1 USD=4558sll (September 2011)

Food security is considered ranging from 105 kg 157 kg of rice per capita per annum.



U3823_Marampa_ESIS_Final.docx



September 2012

Page 122 of 298



SRK Consulting



6.5.3



Marampa Iron Ore Project ESIS – Main Report



Habitation

People live predominantly in settlements with some scattered housing near the fields for

protecting the farms. Traditional housing consists of clay and earth structures, built with a

thatch roof (18% of survey households had a traditional house – see Figure 6.11). Modern

materials are now often incorporated into the house structures. 17% of survey households did

not have a bathroom. Some houses were in bad condition as observed during the survey.



Typical traditional house



Improved traditional house



Figure 6.11: Traditional houses



6.5.4



Energy sources

The energy source for domestic lighting in the study villages was predominantly paraffin

lamps (71%), battery operated lights (19%) and candles (10%), with about 17% of the people

using a combination of the above three sources.



6.6



Social stratification

Although the majority of the rural population is poor, some stratification exists. There are

traditional elite families who can trace their ancestry (usually through the father's line) to a

warrior or hunter who first settled in an area. These families control and administer land,

people who want to acquire the right to farm must show respect to an elder from this family.

Colonial administrators have historically exacerbated this social stratification.



6.7



Vulnerable groups

Vulnerability is defined here as the inability to generate sufficient resources to meet basic

human needs). The most vulnerable groups include those who cannot work the land (widows,

the elderly and the sick), who have no other means of income generation and no family or

other social support network.



6.8



Health

There are six functional Peripheral Health Unit (“PHU”) in the Marampa Chiefdom. Each PHU

has its own catchment area and together they cover a population of approximately 20,000 (or

50% of the Chiefdom population) including the population living in Lunsar town. The PHU in

Lunsar is headed by nine government staff, a Community Health Officer, Nurse, Maternal and



U3823_Marampa_ESIS_Final.docx



September 2012

Page 123 of 298



SRK Consulting



Marampa Iron Ore Project ESIS – Main Report



Child Aides, Nursing Aides, Vaccinator and Cleaners/Labourers.

The study area is also served by other health institutions in Lunsar town:





The Saint John of God Catholic Hospital (a referral hospital) providing health service to

the region at a nominal cost.







The Baptist Eye Hospital providing specialist services at a nominal cost.



These have a good reputation nationally however the cost of treatment is too high for the

majority of the people in the villages to afford. Marunku is the only village in the study area

that has a health facility and managed by a Nurse and Traditional Birth Attendants (“TBAs”).

Health and hygiene conditions in the study area are generally poor. The household survey

showed that 81% of households deposit their household waste in the areas around their

homesteads. The water quality was observed to be inferior and wells dry out during the dry

season. Villagers often need to walk long distances to fetch water.

According to the PHU in Lunsar, malaria is a leading disease in the chiefdom. Other diseases

prevalent in the area are diarrhoea, pneumonia, clinical malnutrition, anaemia, measles,

typhoid, skin infections, eye infections and hypertension. The incidence of HIV/AIDS has

increased 17 cases in 2011. These 17 cases are receiving treatment from the PHU. STIs are

on the increase in the chiefdom and the PHU records 17-18 cases every month. Table 6-8

lists health problems experienced by local residents during the past six months. These are

based on symptoms identified by the residents and not necessarily based on professional

medical diagnosis.

Table 6-8: Most prevalent health problems in the Project area

Disease



Percentage occurrence



Headache



32%



Malaria



29%



Respiratory Infections



15%



Diarrhoea



9%



Others



9%



Cholera



6%



Source: SRK household survey April 2011



The key challenges identified by this PHU are:





unable to meet the needs of increasing number of patients;







poor salary for staff and TBAs working with the PHU are currently unpaid; and







additional transport needed to increase their outreach and coverage.



Self-medication is widely practiced (Section 6.3.1). Data from the household survey for

medical care sought by people shows that in 80% of the cases contemporary medicine was

used and in 20% traditional healers (Table 6-9). In addition to traditional beliefs, distance and

cost are also deciding factors.

Table 6-9: Consultation of medical services in the study area

Medical Care



Number (and percentage) of people seeking services



Health professional (clinic)



51 (80%)



Local traditional healer



13 (20%)



Source: SRK household survey April 2011

U3823_Marampa_ESIS_Final.docx



September 2012

Page 124 of 298



SRK Consulting



6.9



Marampa Iron Ore Project ESIS – Main Report



Education

The levels of education and literacy are generally low in the study area. Table 6-10

summarises the education level for the population covered by the household survey. During

the study, the importance of education was repeatedly stressed by the local population.

Table 6-10: Educational levels in the study area

Education level



Number of people



Percentage of population



No education (>13 years old)



680



47%



Started but did not complete primary school (>13

years old)



308



21%



Completed primary school (>13 years old)



207



14%



Started but did not complete secondary

education (>18 years)



168



11%



Completed secondary education (>18 years)



91



6%



Tertiary education (>25 years)



17



1%



Total



1471



100%



Source: SRK household survey April 2011



The education sector encounters several challenges, some of which are listed below:





lack of schools–. Children often have to walk long distances to reach school, resulting in

low attendance and large numbers of drop outs;







shortage of trained and qualified teachers;







late or no payment of teachers leading to de-motivation;







dilapidated school buildings and shortage of classrooms, though MIOL has provided

assistance to some local schools (Figure 6.12); and







overcrowded classes.



Broken roof in a classroom



New school build by MIOL in Konta



Figure 6.12: Examples of educational facilities



6.10 Infrastructure

The general infrastructure in the study area is in a poor state of repair. There is no state

provided electricity in the area but mobile phone coverage is good. There are few paved

roads between the villages, and some villages are accessible only by footpath. The area does

benefit from a sealed road to Freetown (Makeni Highway), which provides access to markets

U3823_Marampa_ESIS_Final.docx



September 2012

Page 125 of 298



SRK Consulting



Marampa Iron Ore Project ESIS – Main Report



for buying and selling farm products. The main market for the study area villages is Foredugu

near Lunsar.



6.11 Ongoing governmental and non-governmental programmes

A large number of non-government organisations (NGOs) are working in Sierra Leone. The

Government and private sector combined does not have the capacity to meet basic health,

education and welfare needs. Some of the Government and NGO programmes active in the

study villages are:





grain bank Projects run by GoSL in Gbese Village and by Saint John of Paul Church

Health Centre (a NGO) in Katik Village;







training and seed money to women to encourage micro-credit groups of 10 to 20

members by an International NGO, called BRAC - the credit is usually used for farming

activities and other small business activities; and







prevention of harmful practices against women and girls, specifically Female Genital

Mutilation (“FGM”) by a local NGO called Amazonian Initiative Movement (“AIM”).



6.12 Contemporary social system and practices

Land-use rights and most portable forms of wealth are inherited patrilinealy. Decision making

in the village is done by the chief and the elders of the landowning families. Youth and

women’s’ organisations are consulted in decision making.

The Project could impact differently on men and women. Due to the many socio-economic

disruptions, wars and break-ups of families, gender roles may have become less rigid. An

overall picture from the household data shows that:





women are exclusively involved in cooking, cleaning, tending gardens, selling crops/local

produce, and collection of water, firewood and wild flowers;







men are exclusively involved in cutting trees, clearing farms, making charcoal, building

mounds, hunting and housing construction (and also entitled to own/inherit land); and







both men and women are involved in fishing, managing livestock, land cultivation,

processing oil palm, upbringing of children, decision making and purchasing goods,

however the extent to which these jobs are shared varies by task and by household.



From FGDs it was learnt that some girls are falling pregnant at the age of 13 years. Parents

also complained of changing social values in general and growing indiscipline among the

youth.



6.13 Archaeology and cultural heritage

A rapid archaeological scan was conducted in the Project Area in March 2011 (see Nexus

2011 specialist report in Volume 3, SD8). The ethnographic meetings and interviews resulted

in the identification of 62 cultural heritage sites (49 sacred sites and 13 archaeological sites).

These are shown on Figure 6.13 with detail on each site presented in the specialist study

report.

Every village in the area has one or more ‘sacred bushes’ normally linked to the secret

societies within the villages. Most villages also have a burial ground, and where villages have

both Muslim and Christian inhabitants, there will usually be two cemeteries. In addition there

U3823_Marampa_ESIS_Final.docx



September 2012

Page 126 of 298



SRK Consulting



Marampa Iron Ore Project ESIS – Main Report



are archaeological sites, which the villagers regard as ‘ancestral villages’ and attach great

value to. Local people reportedly feel it is acceptable to relocate and restore the sacred

bushes and cemeteries as long as the right procedures are followed



6.14 Community perceptions: needs and apprehensions

Needs and apprehensions were identified through the stakeholder engagement process, as

well as through interactions between the baseline specialists and the communities.

Development needs and problems in the study area, identified through the focus groups

discussions and household survey, are presented below. The key community needs are:





employment;







assistance with education fees/scholarships for children;







improvement of facilities – health, education and roads;







access to drinking water facilities and electricity;







assistance with agricultural activities, and







poverty alleviation in general.



In general, potentially affected people seemed positive towards the Project. A summary of the

stakeholder apprehensions, as gathered during the baseline survey is presented below.





Fear that community members will be marginalised in terms of job opportunities by

outsiders (many already complained of jobs being given to outsiders).







Concerns about being compensated inadequately for loss of land and damage to crops

during construction activities.







Concerns the Project activities will have a negative impact on drinking water sources in

terms of contamination and/or reduced availability.







Concern the vibrations caused by blasting will damage their houses (some cited their

experiences from the old Delco operations), and







Concern building of further roads will disrupt community access routes or connectivity to

Lunsar and other villages (some people cited how they were already impacted due to the

rail line).



U3823_Marampa_ESIS_Final.docx



September 2012

Page 127 of 298



SRK Consulting



Marampa Iron Ore Project ESIS – Main Report



Figure 6.13: Location of archaeological and cultural heritage sites in the study area



U3823_Marampa_ESIS_Final.docx



September 2012

Page 128 of 298



SRK Consulting



7



Marampa Iron Ore Project ESIS – Main Report



BIOPHYSICAL IMPACT ASSESSMENT

This Chapter describes the biophysical impacts that could occur as a result of the Project.

Socio-economic impacts are described in Chapter 8 and Community Health, Safety and

Security risks in Chapter 9. The impacts have been identified based on consideration of the

information presented in the preceding chapters. To avoid unnecessary repetition of

supporting information, cross referencing to other sections of the report is given where

necessary.

The various impacts identified for the Project, as well as an indication of the Project phase

(construction, operation, decommissioning and post-closure) in which the impact is expected

to occur, are described in the subsections below. The Project phase is indicated by shading

bars at the beginning of each impact description – the darker the shading in the bar, the more

applicable the impact is to that Project phase.

As the Project is phased over two consecutive development stages (Stages 1 and 2, as

described in Chapter 4), the construction phase is assumed to extend in duration through the

operation of Stage 1, until Stage 2 construction has been completed. The entire construction

phase of the Project is therefore expected to last approximately three and a half years (18

months for construction of Stage 1 followed immediately by 18 to 24 months for construction

of Stage 2). In general, operational impacts will commence with Stage 1 and increase in

intensity as production capacity increases through Stage 2, and tail off towards

decommissioning and closure 14 years later.

A summary of issues or concerns as expressed by stakeholders during the information

sharing consultations (Section 3.3.5), and where they are addressed in the various impact

sub-headings below is provided in Table 3-7. These issues were considered when identifying

and rating the importance or value of possible impacts.

Identified impacts are discussed within impact groups (such as Land Transformation or Water

Resources) to organise the discussion and keep it concise. Impact group reference codes

have been assigned to help maintain links between the discussion of impacts in this section

and the environmental management programme in Appendix F. Each impact group

discussion includes the Project activities that may give rise to impacts and, where relevant,

generic information supporting the overall impact group discussion. A summary of the

impacts evaluated in this section, listed per impact group, is given in Table 7-1. As there are

close linkages between a number of the impacts (for example those affecting multiple

receptors) and to avoid repetition, these impacts have been listed and rated in the impact

group most affected, with cross references to the other linked impacts, both within and

between disciplines (biophysical, socio-economic and health and safety).

Table 7-1: Summary of evaluated biophysical impacts

Impact groups



Impact headings







Land

transformation











LT1: Change in land use as a result of mine and related infrastructure limiting

use by local communities

LT2: Disruption of community access routes by mine infrastructure, resulting in

social disruption

LT3: Mine infrastructure and activities resulting in visual intrusion and loss of

‘sense of place’ for local communities

LT4: Loss of topsoil through erosion, decreasing land capability

LT5: Fugitive dust resulting in changes in soil chemistry and agricultural land

capability



U3823_Marampa_ESIS_Final.docx



September 2012

Page 129 of 298



SRK Consulting



Impact groups



Marampa Iron Ore Project ESIS – Main Report



Impact headings









Water resources















Ecology and

biodiversity









WR1: Pit dewatering potentially resulting in reduced groundwater availability to

ecological systems and local communities

WR2: Surface water abstraction affecting downstream users

WR3: Project infrastructure causing altered flow conditions, affecting

downstream users

WR4: Surface water diversions causing potentially changes to flood risk to

adjacent agricultural areas and communities

WR5: Seepage from mining wastes potentially resulting in deteriorated water

quality affecting communities and ecological systems

WR6: Discharge or runoff to surface water potentially resulting in deteriorated

water quality affecting communities and ecological systems

EB1: Site clearance and positioning of Project infrastructure potentially

resulting in habitat loss and fragmentation, and direct loss of fauna and flora

EB2: Soil disturbance facilitating the establishment and spread of invasive

species, affecting indigenous ecosystems

EB3: Project activities potentially resulting in sensory or other disturbance to

wildlife

EB4: Mine infrastructure and activities attracting nuisance species, resulting in

impacts on indigenous ecosystems



As described in Section 3.3.3, the individual impact discussions are generally concluded with

an impact rating table. The header row of the table gives the impact definition. The following

rows present the impact characteristics and significance ratings. The final row presents any

additional management measures identified as required to appropriately control/enhance the

impacts. These would be over and above the inherent management measures incorporated

into the Project design and described in Chapter 4. Where such measures are stipulated, a

rating for the ‘Residual impact’ is provided, assuming these measures are successfully

implemented. Included in the summary table is a confidence assessment, which provides the

reader with an indication of the assurance level placed on the rating process and addresses

the concept of uncertainty. An indication is also given as to whether the impact is reversible

or not.

In addition to mitigation or enhancement measures, there may be a number of good practice

management measures, which are unlikely to change the impact rating but are considered

good international practice for managing that impact. These are listed below the summary

table, where relevant.

The impacts described in this section are based on normal activities expected during the

relevant Project phases (construction, operation, decommissioning and post-closure). Some

impacts may be exacerbated or caused by upset conditions due to natural hazards such as

seismic events or floods, third party interference such as sabotage, equipment failure or

human error. Such events are not considered normal and therefore where relevant the

implications of upset conditions on the identified impacts have been described after the rating

of normal conditions has been presented in the rating table. Such events would be handled

as an emergency or incident as described in Section 11.6.

Although the Project will occur in two development Stages, impacts have been assessed for

Stage 2 (full Project) only, as this stage is expected to result in impacts of greater significance

than Stage 1, due to the increased production throughput and larger overall footprint

disturbed. Where there is some uncertainty regarding impact predictions, such as in situations

where all the relevant detail was not available at the time of the impact modelling (specifically

for water resources, air quality and noise impacts), a generic worst case reasonably

foreseeable scenario has been used. This may result in over-estimation of these impacts, and

additional impact modelling, once more accurate Project-specific information becomes

U3823_Marampa_ESIS_Final.docx



September 2012

Page 130 of 298



SRK Consulting



Marampa Iron Ore Project ESIS – Main Report



available, may be required for instances where the new information differs significantly from

that used for the current impact assessment.



7.1



Land transformation

Development of mine, transportation and associated infrastructure will disturb the land surface

and result in a temporary or permanent change to the land and its capability for other uses.

The Project area is relatively flat and low-lying and generally densely vegetated, either with

cultivated crops or natural vegetation.

Land transformation can occur due to direct modification of the land as the soil is cleared and

moved for construction of Project infrastructure or covered by waste rock dumps, or where

activities associated with the Project (such as access roads, resettlement areas and

expansion of the surrounding residential areas as a result of an influx of job-seekers) affect

land outside the immediate footprint area. The severity and extent of land disturbance may

be increased beyond the directly disturbed footprint by indirect modification due to erosion,

changes in drainage patterns, compaction of soil, chemical spills or leaks, and deposition of

sediments by wind and water, affecting soil chemistry and the ability of the land to be

beneficially used.

Naturally occurring modification of land by wind and rain (erosion) may be exacerbated by

Project related activities, including:





disturbance of the soil surface vegetation and soil crust (for example by vehicle and

equipment use and land clearance for construction) increasing the susceptibility of the

soil to wind and water erosion;







alteration of surface topography by construction of large infrastructure (such as the waste

rock dumps) resulting in changes to the wind and stormwater runoff patterns and

exposure of larger surface areas to wind and water erosion; and







changing the route and hydrology of natural drainage lines (such as stream or

stormwater runoff diversions around Project infrastructure or to create water storage

facilities).



Implementation of good practice measures, such as erosion control and minimising the area

and degree of disturbance, may reduce the spatial scale of the impact; nonetheless a

relatively large area (>2,000 ha) will be subject to permanent change. These measures are

listed in the sections below. Some of the disturbance can be reversed at closure by

rehabilitation of disturbed areas and removal of Project infrastructure with no ongoing use.



7.1.1



LT1: Change in land use as a result of mine and related infrastructure limiting

use by local communities

Construction



Operation



Decommissioning



Post-Closure



The local communities are heavily reliant on the land for their various livelihood strategies and

use the area extensively for subsistence agriculture (including rice cultivation in the

floodplains and cultivation of cassava and tropical species such as oil palm, pineapple and

mango in the upland and secondary forest areas), as well as harvesting of natural resources

(such as wood and wild plants), hunting and fishing. Agriculture is the most significant current

land use and livelihood strategy (practiced by 82% of the population) in the area, and

intercropping methods are used by local farmers to take full advantage of the available

U3823_Marampa_ESIS_Final.docx



September 2012

Page 131 of 298



SRK Consulting



Marampa Iron Ore Project ESIS – Main Report



habitat. Natural vegetation, particularly forest, is also used extensively for the harvesting of

wild herbs (primarily for medicinal uses), firewood, and for cultural purposes.

This impact will begin with the clearing of land for construction of the Project infrastructure,

increasing in magnitude through operation and decreasing post-closure with rehabilitation of

the area, the aim being that communities could eventually resume their use of some of the

land for agriculture or some other useful purpose. The recovery of natural vegetation to

support harvesting of natural resources is likely to require longer periods and is discussed in

Section 7.3.1 (EB1).

The areas that will be directly disturbed through construction of the mine infrastructure,

together with the current land uses of these areas, are indicated in Table 7-2. The total area

directly transformed due to mine surface infrastructure is approximately 2,200 ha, of which

approximately 89% (~1,950 ha) is land currently used for agriculture. This is however an

underestimation of the actual land surface area directly impacted, as it does not account for

access roads, laydown areas and other minor infrastructure.

Table 7-2: Current use of land



12



directly disturbed by mine infrastructure



Current land use



Approximate area permanently modified (ha)



Gallery Forest



1.2



Secondary Savannah



5.5



Urban



7.8



Transformed - Subsistence Cultivation



7.9



Transformed - mining



8.4



Transformed - Oil Palm Plantation



26.2



Transformed - Mango Plantation



120. 0



Rice Wetlands



326.0



Secondary Forest / Farmbush Mosaic



1,452.0



Total agricultural land



1,955.0 (89%)



Loss of agricultural land and habitat for indigenous vegetation - either permanently through

construction of Project infrastructure or temporarily through soil compaction and clearing of

vegetation from surrounding areas for access routes and lay down areas during construction is therefore expected to affect these communities in terms of food security and livelihoods

(discussed further in RL1 and RL4 in Section 8.2). In a number of cases, whole villages will

be directly impacted due to the positioning of Project infrastructure, and relocation of these

villages will therefore be necessary. In other cases, land used by villages will be lost or

otherwise impacted through land acquisition but the villages themselves will not be relocated.

It is estimated that, in general, an area with a radius of approximately 2 km around the village

is used for natural resource uses (WRL, 2012). Impacts relating to relocation and land

acquisition are addressed separately in Section 8.2 (Impacts RL1 to RL4). The loss or

disturbance of sites of cultural heritage (such as sacred bush) is discussed in Section 8.4.1

under impact AC1.

Due to the close association between this impact and Impact RL1 (impoverishment through

loss of shelter, land and communal natural resources) in terms of impacts on communities,

and to prevent double rating, this impact has not been rated in this section. The rating

provided for Impact RL1 in Section 8.2.1 therefore applies. Implementation of the



12



Calculated from Ecorex 2011 report, included as SD4 of Volume 3



U3823_Marampa_ESIS_Final.docx



September 2012

Page 132 of 298



SRK Consulting



Marampa Iron Ore Project ESIS – Main Report



management measures listed for Impact RL1, in addition to the good practice measures listed

below, is recommended to assist communities in adapting to the change and resuming or

adopting new livelihoods more quickly. With rehabilitation, the intention is that the impact will

be partially reversed and the land will once again be made available for use by local

communities (though post-rehabilitation use may differ from pre-mining land use).

Good practice measures recommended include the following:





7.1.2



Develop a Construction Management Plan that includes requirements to:

o



Minimise the footprint area disturbed during construction, operation and

decommissioning of the Project.



o



Minimise the duration of the disturbance by starting rehabilitation as soon as

possible and progressively rehabilitating disturbed areas that are no longer being

used for the Project, and making them available for communities to use.







Prohibit unnecessary off road driving, and use planned and designated access routes

and lay-down areas only.







Review and update the Closure and Rehabilitation Plan periodically to address current

site conditions, community expectations, and the results of ongoing routine monitoring.



LT2: Disruption of community access routes by mine infrastructure, potentially

resulting in social disruption

Construction



Operation



Decommissioning



Post-Closure



Another factor affecting local communities is the disruption of access routes, resulting from

construction of the mine infrastructure blocking these routes. Apart from the beneficiation

plant and staff accommodation village, Project infrastructure, including haul roads, will not be

fenced allowing for a degree of access across Project areas. However, the presence of large

infrastructure such as the TSF, WRD and pits would in itself prevent access or thoroughfare

to areas on the other side of it. In cases where access across infrastructure may still be

possible, safety (in the case of haul roads and other access roads) or ease of crossing (such

as in the case of above ground pipelines) may be compromised.

It is also likely that community members will use the haul roads and other mine access routes

making for easier access to Lunsar and the Makeni Highway. This access would however

increase the safety risk for community members and their livestock due to mine-related traffic

as discussed in Impact TS2.

It is expected mine infrastructure associated with the change in land use will have a negative

impact on community access, particularly for more localised routes used between villages,

and could ultimately impact on community members’ livelihoods and ultimately income

generation. Due to the linkages between this impact and the associated social impacts the

overall effect on communities is evaluated and rated in Section 8.2 (Impact RL2).



U3823_Marampa_ESIS_Final.docx



September 2012

Page 133 of 298



SRK Consulting



7.1.3



Marampa Iron Ore Project ESIS – Main Report



LT3: Mine infrastructure and activities potentially resulting in visual impacts

for local communities

Construction



Operation



Decommissioning



Post-Closure



Visual intrusion and loss of a “sense of place” may occur directly as a result of mine

infrastructure and changes to the landscape (due primarily to vegetation clearing and

construction of the open pits, tailings facility and waste rock dumps). Indirect impacts may

also result from dust blown from exposed surfaces and from blasting creating a plume, as well

as lighting of site infrastructure in an otherwise relatively unlit environment, both of which

could be visible from a considerable distance. Ecological impacts resulting from visual

intrusion are discussed in Section 7.3.3 (Impact EB3) and the impacts on road safety in

particular resulting from dust are discussed in Section 9.3.1 (Impact TS2). Air quality impacts

resulting from dust are discussed separately in Section 9.1 (Impact AQ1).

Non-mining waste such as building rubble and domestic waste, both directly and indirectly

(due to increased population and development in the area) related to the Project, is another

aspect that could result in a negative change in visual character of the area. Although a waste

landfill is planned as part of the Project, indiscriminate dumping of litter and rubble resulting

from secondary developments could contribute to visual degradation of the area on a local

scale.

The scale or intensity of the visual impact may be perceived differently depending on the

sensitivity of the viewer and their location relative to the impact. Sense of place is defined as a

person’s sense of belonging to a place or area. The screening effects of topography or dense,

tall vegetation (such as forest) may reduce the impact slightly, though this is unlikely to have a

significant effect due to the generally flat topography and lack of forested areas in the vicinity

of the mine infrastructure (these are restricted to a small area along the Rokel River close to

the Gafal West waste rock dump).

As the area is not recognised for its scenic beauty or touristic value, combined with the fact

that other mining Projects exist in the area (also impacting on the area’s visual character)

potential viewers are expected to have relatively low sensitivity towards these changes. It is,

however, recognised that the perception of a visual impact is by nature highly subjective and,

where one viewer may consider the impact to be negative, another might perceive the

increased development and lighting of the area positively. For this reason a change to the

sense of place of an area is difficult to rate according to standard methodologies. Although

local people may associate a particular sense of place with the Marampa area, what is difficult

to gauge is the importance people attach to that sense of place and how this will change over

time when the cumulative effects of other Projects in the area are considered, together with

how potential Project benefits may ameliorate any loss.

Visual disturbance and loss of sense of place impacts are difficult to manage and the loss is

theoretically irreversible regardless of post-closure rehabilitation (although this will ameliorate

this impact to some degree). The perception of the area may change over time with people

becoming accustomed to a new sense of place and thus the actual impact is partially

reversed. The closure measures proposed, such as backfilling of the pits with waste rock and

tailings material thereby reducing the height and visibility of the WRD and TSF, removal of

mine infrastructure with no continuing use and rehabilitation of the site will assist in reducing

the impact at closure. The most significant impacts will therefore occur during construction

(especially during clearing of vegetation when dust levels will be highest), operation and

U3823_Marampa_ESIS_Final.docx



September 2012

Page 134 of 298



SRK Consulting



Marampa Iron Ore Project ESIS – Main Report



decommissioning (when additional earth-movement is expected). As the impact involves

differing perceptions by receptors, the confidence in the impact is given as medium.

Due to the relatively degraded current visual nature of the site, local communities are not

expected to be highly sensitive to the impact. Without earnest attention to post-closure

rehabilitation of the area, however, the changes to the landscape will remain visually intrusive

beyond the life of the mine, if not permanently. The development will be visible from outside

the direct Project area (e.g. from roads and villages) and, although it is not possible to hide

the development and associated infrastructure, it may be possible to reduce the negative

visual perceptions associated with the mine and create a more visually harmonious

impression post-closure through rehabilitation.

Impact LT3: Mine infrastructure and activities potentially resulting in visual impacts for local

communities

Impact characteristics



Initial impact



Residual or optimised impact

(taking cognisance of management

measures)



Type (+ / - /neutral)



Negative



Negative



Sensitivity



Low



Low



Receptor

importance or

value



Low



Low



Extent of change /

threshold

compliance



Moderate



Moderate



Magnitude rating



MINOR



MINOR



Duration



Long term



Medium term



Magnitude

description



Timeframe

description



Frequency



-



-



Timeframe rating



LONG TERM



MEDIUM TERM



Spatial Scale



INTERMEDIATE



INTERMEDIATE



CONSEQUENCE RATING



MEDIUM



LOW



PROBABILITY RATING



POSSIBLE



UNLIKELY



SIGNIFICANCE RATING



MEDIUM (-ve)



LOW (-ve)



Reversibility / sustainability



Partially reversible



Confidence



Medium



Management measures





At closure, remove mine infrastructure that does not have a continued use.







Revegetate and landscape the site on closure, to reflect the surrounding topography and

vegetation as much as possible.







Consider the use of screening tools such as dense vegetation where practical and appropriate

to the surroundings.







Clear vegetation in phases so that only those areas required for immediate development are

cleared.







Develop and implement a waste management plan that includes provision for waste resulting

from secondary developments and domestic waste linked to the Project.

Good practice measures:





Paint buildings and structures or use materials with colours that reflect and complement

the natural colour and textures of the surrounding landscape.



U3823_Marampa_ESIS_Final.docx



September 2012

Page 135 of 298



SRK Consulting



7.1.4



Marampa Iron Ore Project ESIS – Main Report







The slopes of the WRD and any other visually intrusive stockpiles should be reduced

during closure to be consistent with the surrounding natural topography.







Use directional lighting in areas operating at night, if communities are affected by

lighting.







Refer to dust control measures under Impact AQ1 (Section 9.1.1).



LT4: Loss of topsoil through erosion, decreasing land capability

Construction



Operation



Decommissioning



Post-Closure



Activities such as vegetation clearing for Project infrastructure, or other damage to vegetation,

particularly groundcovers that bind and stabilise the topsoil, will result in large areas of

exposed topsoil which will be susceptible to erosion through wind and water if not carefully

managed. The soils in the area are broadly characterised as sandy and ferrallitic, typical of

tropical regions, and have a reasonable proportion of fine particles (<0.1 mm in size), making

them moderately susceptible to erosion. Organic content of the soil is overall moderate to high

(due to the dense vegetation cover), but relatively low in cultivated areas (due to harvesting of

crops). As organic content would reduce the soil erosion potential, cultivated areas would

therefore be more prone to erosion. The longer the exposed area is subject to erosive forces,

the more severe the effect. Sloped areas are also more susceptible to erosion through

stormwater runoff, with the secondary impact of sedimentation of surface water resources

(discussed in Section 7.2.6 (Impact WR6). Whilst the study area is relatively flat, the high

annual rainfall and high frequency of severe rain events may also contribute to increased

erosion of disturbed areas. Clearing of vegetation, combined with high winds or heavy rainfall,

would increase the soil’s erosion potential and lead to a reduction in land capability if

appropriate management measures to prevent erosion are not implemented.

Topsoil is essential to support vegetation growth as it harbours the required nutrients as well

as a natural seed bank reflecting its former vegetation cover. It takes many years to develop

and is therefore essentially non-renewable – complete loss of topsoil from an area would

require import of topsoil from another area (preferably with similar vegetation makeup) in

order to support vegetation growth. Loss of topsoil therefore compromises the capability of the

soil to support both agriculture and ecological processes, both of which are important current

land uses for local communities in terms of food security. Without appropriate management

and preservation of topsoil the area would therefore remain sparsely vegetated and not be

suitable for post closure land use (rated below). In addition, it will contribute to dust

generation and visual impacts (discussed under Impacts AQ1 and LT3 in Sections 9.1.1 and

7.1.3), and loss or fragmentation of habitat (discussed under Impact EB1 in Section 7.3.1).

Due to the reliance of local communities on land capability for their livelihoods and food

security, the pre-management magnitude of the impact is rated as moderate. The impact has

the potential to extend beyond the life of the mine as, without the successful implementation

of topsoil maintenance and erosion control measures, loss of topsoil could result in

increasingly negative impacts on land capability and livelihoods in the area. The spatial scale

is restricted to cleared and disturbed areas within the Project footprint. Through appropriate

management via implementation of erosion control measures, such as re-vegetation to retain

and preserve topsoil, the impact significance could be reduced as the topsoil would be

stabilised in a relatively short period of time and loss of topsoil would therefore be less likely.

Although the impact could be largely reversed through the import of topsoil material from

U3823_Marampa_ESIS_Final.docx



September 2012

Page 136 of 298



SRK Consulting



Marampa Iron Ore Project ESIS – Main Report



outside, this is too costly to be a viable solution for large areas and only leads to negative

impacts in the source area.

Impact LT4: Loss of topsoil through erosion, decreasing land capability

Impact characteristics



Initial impact



Residual or optimised impact

(taking cognisance of management

measures)



Type (+ / - /neutral)



Negative



Negative



Sensitivity



Medium



Medium



Receptor

importance or

value



Medium



Medium



Extent of change /

threshold

compliance



Medium



Medium



Magnitude rating



MODERATE



MODERATE



Duration



Long term



Medium term



Magnitude

description



Timeframe

description



Frequency



-



-



Timeframe rating



LONG TERM



MEDIUM TERM



SMALL



SMALL



Spatial Scale

CONSEQUENCE RATING



MEDIUM



MEDIUM



PROBABILITY RATING



POSSIBLE



UNLIKELY



SIGNIFICANCE RATING



MEDIUM (-ve)



LOW (-ve)



Reversibility / sustainability



Partially reversible



Confidence



High



Management measures





Avoid disturbance of slopes or sensitive areas such as drainage areas, where possible.







Implement erosion control measures where steep slopes or large unvegetated areas are

created, or where sensitive areas such as river banks are disturbed.







Inspect disturbed, rehabilitated, and sensitive areas such as river banks affected by Project

infrastructure for visual signs of erosion and/or deposition affecting either the Project’s or

community’s use of the land. If problems are identified, initiate remedial action.







Clear and stockpile topsoil separately from subsoil / fill material, for use during rehabilitation.







Implement rehabilitation and establishment of vegetation cover as soon as possible.

Good practice measures:





Maintain topsoil stockpiles to prevent their erosion or contamination with subsoil or other

materials.







Ensure stockpiled topsoil is used within two years and is not excessively compacted to

preserve a viable seed bank.







Avoid driving over or otherwise compacting or disturbing topsoil.







Design roads, pipeline routes and landscape features to minimise disruption of natural

drainage patterns.



U3823_Marampa_ESIS_Final.docx



September 2012

Page 137 of 298



SRK Consulting



7.1.5



Marampa Iron Ore Project ESIS – Main Report



LT5: Fugitive dust potentially resulting in changes in soil chemistry and

agricultural land capability

Construction



Operation



Decommissioning



Post-Closure



During operations, and to a lesser extent during decommissioning and post-closure, there is

the potential for some finer tailings dust to be mobilised from the TSF (and later from the

Matukia pit, which will be backfilled with tailings) during dry windy conditions (refer to

discussion in Impact AQ1). It is however proposed that a pond will be maintained on the TSF,

preventing the generation of tailings dust from the surface of the TSF. Some of this dust will

be deposited on the land downwind of the tailings storage areas potentially affecting the

physical and chemical characteristics of the soils in the deposition areas.

Meteorological data obtained from the site showed the predominant wind direction to be

South-westerly and consistent throughout the year. Although the area is subject to the

Harmattan winds during the dry season (November to April), the data suggests the region is

shielded from the full effects of these winds, possibly by mountain ranges to the northeast of

the country (for further detail see the Climate and Air Quality Baseline Report in SD 2 of

Volume 3). The most affected areas would therefore be those to the north-east of the Project

area.

The soils baseline study (SD 5 in Volume 3) found soils in the area to be moderately acidic

(pH 4.7 to 5.8), with a low cation exchange capacity (10.5 to 19.7 meq/100g) and dominated

by iron and aluminium. The sediments are predominantly quartz-rich sands and gravels, with

a mildly acidic to circum-neutral pH (5.3 to 6.5 s.u.). Sediment chemistry is dominated by

aluminium, iron and manganese, which reflects the geology of the deposit, and is generally

highly leached, with frequent flushing by water.

Preliminary geochemical ARDML characterisation of the predicted tailings material found

arsenic levels to be elevated above the Geochemical Abundance Index in some samples, but

the metal leaching and acid generation potentials to be negligible in general (for more detail

refer to the full ARDML report in SD 6 of Volume 3).

Windblown tailings deposited on downwind soils will have the potential to increase the

concentration of metals and other constituents in the native soils. However, other sources of

fugitive dust will mix with the windblown tailings, thereby diluting the deposited material.

Changes in the soils downwind of the TSF (and Matukia pit once that is used for tailings

storage) from the deposition of windblown tailings have the potential to result in indirect

impacts to:





storm water runoff quality, thereby affecting aquatic ecosystems and community users

(refer to Impact WR6 in Section 7.2.6); and







agricultural and natural vegetation by direct contact (covering foliage) and metal uptake

via roots.



Runoff from rain events may remobilise tailings dust from the soil and vegetation and

redeposit it in drainage channels where it may accumulate and affect storm water runoff

quality. Plants may be affected if their foliage is covered by dust or metals are transported by

storm water infiltrating into the root zone. However, the plants in the area appear to be

unaffected by existing high fugitive dust levels in the dry season and infiltrating storm water

will be diluted through mixing with storm water unaffected by windblown tailings thereby

reducing the effects of mobilized tailings on overall plant uptake.

U3823_Marampa_ESIS_Final.docx



September 2012

Page 138 of 298



SRK Consulting



Marampa Iron Ore Project ESIS – Main Report



The magnitude of this impact is considered to be minor because, although food security is a

critical issue, the predicted tailings material is relatively innocuous and there are already

elevated dust levels in the area due to existing land uses. Frequency of occurrence would

also be low due to the tropical climate that predominates in the area, with regular rainfall and

low wind speeds for most of the year, which results in relatively low levels of windblown dust.

Without management of dust from the tailings material, the impact could continue at a low

level beyond the life of the mine (if not permanently) and could extend beyond the Project

footprint. Provided rehabilitation of the tailings storage areas is successful and the tailings

material is protected from erosion, mobilisation of tailings material post-closure would be

unlikely, although the process of remobilisation of deposited material may continue after

closure.

Impact LT5: Fugitive dust potentially resulting in changes in soil chemistry and agricultural

land capability

Impact characteristics



Initial impact



Residual or optimised impact

(taking cognisance of management

measures)



Type (+ / - /neutral)



Negative



Negative



Sensitivity



Low



Low



Receptor

importance or

value



Medium



Low



Extent of change /

threshold

compliance



Low



Low



Magnitude rating



MINOR



MINOR



Duration



Long term



Medium term



Magnitude

description



Timeframe

description



Frequency



Low



Low



Timeframe rating



LONG TERM



MEDIUM TERM



INTERMEDIATE



INTERMEDIATE



Spatial Scale

CONSEQUENCE RATING



MEDIUM



MEDIUM



PROBABILITY RATING



POSSIBLE



UNLIKELY



SIGNIFICANCE RATING



MEDIUM (-ve)



LOW (-ve)



Reversibility / sustainability



Irreversible



Confidence



Medium



Management measures





Implement dust control measures, such as wetting down and maintaining a pond at the tailings

storage areas.







On closure, put in place measures (such as revegetation) to ensure continued erosion control

of the tailings material.

Good practice measures:





Using data collected during the monitoring programme to develop a Soils Management

Plan to monitor the effects of blowing tailings dust on soils and determine whether further

management measures may be required to mitigate impacts from windblown tailings.

The plan should determine:

o



expected incremental increases in metals and effects of dilution;



o



extent and effects of remobilisation;



U3823_Marampa_ESIS_Final.docx



September 2012

Page 139 of 298



SRK Consulting



7.2



Marampa Iron Ore Project ESIS – Main Report



o



potential eco-toxicological effects; and



o



removal standards if needed.



Water resources

Although impacts to water resources are traditionally assessed in environmental impact

assessments, water resources themselves are not actual receptors and are rather pathways

to receptors or water users. In-keeping with the norm, impacts on water resources are

considered and assessed in this report but often the significance of the intrinsic changes to

water resources themselves can only be interpreted meaningfully in conjunction with

consideration of the affected receptors.

Human water resource users in the Project area include local communities using groundwater

as their primary source of drinking water and other domestic uses as well as the use of

wetland ecosystems for the cultivation of rice and fishing. Climatic data for the area indicates

a clear wet season extending from May to November and a dry season between December

and April, when evapotranspiration exceeds rainfall. Availability of water resources would

therefore be particularly important for local communities during the dry period.

Ecological receptors include the flora and fauna associated with the aquatic habitats of the

rivers and wetlands as well as the riparian habitats along the banks of the rivers. Aquatic

habitats in general are expected to be sensitive to change, especially to changes in turbidity

and sediment loads, and the majority of surface waters have little or no ability to resist

changes to pH from any acid inputs because of a low buffer capacity (Section 5.5.3). Larger

rivers, where dilution plays a role, may be more tolerant to minor changes.

The impacts assessed can be divided into two categories – those affecting the flow and

availability of water resources and those affecting its quality (via discharges from the mine

and related activities).

Impacts affecting water flow and availability can be caused by:





pit dewatering (Impact WR1);







surface water abstraction (Impact WR2);







mine infrastructure causing changes to flow (Impact WR3); and







surface water diversions altering flood risk in the surrounding area (Impact WR4).



A preliminary water balance established for the Project indicates that, on an annual basis, the

3

3

plant make-up water averages approximately 62,000 m /day with 50,000 m /day derived from

3

surplus tailings water and the remainder (approx. 12,000 m /day) derived from either pit

dewatering and/or abstraction of surface water from the Rokel River.

Discharges to water resources can result from various activities - they can arise directly from

point source activities or indirectly from diffuse sources. A point source release generally

refers either to a controlled release of wastewater into the environment or to an uncontrolled

release arising from an accident or incident (such as a pipeline breakage or a truck

overturning). Potential impacts arising from point source releases include the following:





deterioration in water quality, reducing its potential for utilisation by downstream users;

and







damage to aquatic ecosystems due to substances contained in the released material.



Diffuse pollution occurs over a larger area and is generally more difficult to control than point

source pollution. Examples include seepage of process water and surface runoff from mine

wastes, such as the TSF, WRDs and low-grade ore stockpiles (Impact WR5).

U3823_Marampa_ESIS_Final.docx



September 2012

Page 140 of 298



SRK Consulting



Marampa Iron Ore Project ESIS – Main Report



The impacts that could arise as a result of mine-related pollution are dependent on the type of

contaminant contained in the water and thus released. Different users also have different

sensitivities to potential pollutant levels. In this case, ‘users’ refers to both human use of

water (for domestic, agricultural or industrial purposes) and ecological use.

Impacts on water resources were modelled based on a range of parameters measured during

the water monitoring programme established for the Project, hydrogeological data from Coffey

Geotechnics Limited and data from geochemical investigations by SRK. The modelling results

and methodologies are described in further detail in the specialist report in SD 7 of Volume 3.



7.2.1



WR1: Pit dewatering potentially resulting in reduced groundwater availability to

ecological systems and local communities

Construction



Operation



Decommissioning



Post-Closure



Pit dewatering to ensure dry working conditions for the mine and assist with slope stability will

be required to manage rainfall runoff and groundwater inflow. Dewatering is likely to be

achieved through a combination of perimeter groundwater abstraction wells and in-pit sump

pumping. It may however reduce the availability of this resource to other users through

drawdown of the groundwater surface surrounding the pit. In this case, ‘users’ refers to both

human use of water (for domestic, agricultural or industrial purposes) and ecological use. The

significance of groundwater drawdown is a function of the extent and duration of drawdown

and the presence of receptors (ecological and human) within the zone of influence.

Groundwater levels in the area mimic topography; further detail on the hydrogeology of the

Marampa area is provided in Section 5.5.1. Mine inflows are dictated by both direct rainfall

and groundwater inflows to the open pits. For the Matukia pit, groundwater inflows are

3

predicted to be in the order of 9,000 m /day and surface water inflows are predicted to be

3

33,000 m /day (Coffey, 2011). These figures are for one pit only, and indicate a range of

flows based on seasonal conditions. Pit dewatering requirements are dominated by the high

surface water inflows (during the wet season); however given the high groundwater yields,

groundwater drawdown will occur as a result of pit dewatering.

The extent of groundwater drawdown has been modelled by SRK for the Gafal and Matukia

13

pits based on the input parameters provided in the Coffey Phase 1 Study Groundwater

Assessment Report (2011). The analytical model predicts drawdown at the end of Stage 2 of

mine development for Gafal West and Matukia pits. Due to uncertainties regarding pit

geometry and mining schedules, the following assumptions have been made in the modelling

to ensure a conservative approach is maintained in the calculations:





both pits will reach a final depth of 280m below ground surface (bgs);







the unsaturated zone extends to 11mbgs at Gafal West and 7mbgl at Matukia;







hydraulic properties of the bedrock are uniform throughout the full thickness of the pit;

and







the lifetime of each pit is 13 years.



Preliminary estimates (taking into account the likely hydraulic properties of the rock, pit

geometry and duration) predict the impact will be limited to villages located within 1000 m of

the proposed pits. As would be expected, impacts are predicted to be greatest in the villages



13



Rotret and Mafuri pits were not included in Cofey’s Phase 1 assessment



U3823_Marampa_ESIS_Final.docx



September 2012

Page 141 of 298



SRK Consulting



Marampa Iron Ore Project ESIS – Main Report



located closest to the pits. Excluding villages proposed for relocation, these would be Rotret

(260 m from the Gafal pit) and Makump and Gbila (520 m and 570 m from the Matukia pit

respectively). The estimated drawdown ranges from 67 - 100 m at Rotret, 12 – 18 m at

Makump and 8 – 12 m at Gbila village, indicating an exponential increase in drawdown closer

to the pit.

The drawdown estimations are highly sensitive to changes in hydraulic properties, pit

geometry and mining life. Given the current uncertainties regarding these properties further

hydrological test work will be undertaken to better constrain the hydraulic properties at

Marampa, thus enabling a more robust prediction of likely drawdown around the pits.

Local villages rely on groundwater abstraction, via water supply wells and boreholes, as part

of their water supply. In many villages however this supply diminishes or completely ceases

during the dry season or the wells are no longer functional and villagers resort to the use of

surface water resources (involving walking to the nearest supply area and carrying the water

back to the village) for drinking and other domestic purposes. The levels of drawdown

predicted could therefore potentially significantly impact on groundwater availability to these

villages, as well as surface water resources and wetland ecosystems in the area that are

supplemented by groundwater, particularly in the dry season. The impact would affect both

domestic and agricultural users, as well as fishing, thereby affecting food security in the area.

As many villages in the area already suffer from limited or no access to groundwater during

the dry season, and the impact is likely to diminish their nearby available surface water

resources as well, local communities are likely to be highly sensitive to a further reduction in

water availability, the pre-management magnitude of the impact is considered to be major.

The impact would last for the life of the mine until decommissioning, when pit dewatering will

cease and groundwater levels will presumably return to pre-mining levels, though this is likely

to take a significant amount of time. Based on predicted pit inflows for the life of mine,

preliminary estimations show that it will take up to 200 years for the pit lake to recover and

reach an equilibrium with the surrounding groundwater. Through appropriate management

(provision of water to affected villages) this impact could be relatively easily reduced to

insignificant. Due to the high reliance on assumed input parameters the confidence in the

significance is low.

Impact WR1: Pit dewatering potentially resulting in reduced groundwater availability to

ecological systems and local communities

Impact characteristics



Initial impact



Residual or optimised impact

(taking cognisance of management

measures)



Type (+ / - /neutral)



Negative



Negative



Sensitivity



High



Medium



Receptor

importance or

value



High



Medium



Extent of change /

threshold

compliance



High



Medium



Magnitude

description



Timeframe

description



Magnitude rating



MAJOR



MODERATE



Duration



Medium term



Medium term



Frequency



-



-



Timeframe rating



MEDIUM TERM



MEDIUM TERM



SMALL



SMALL



Spatial Scale



U3823_Marampa_ESIS_Final.docx



September 2012

Page 142 of 298



SRK Consulting



Marampa Iron Ore Project ESIS – Main Report



Impact WR1: Pit dewatering potentially resulting in reduced groundwater availability to

ecological systems and local communities

CONSEQUENCE RATING



MEDIUM



MEDIUM



PROBABILITY RATING



DEFINITE



UNLIKELY



SIGNIFICANCE RATING



MEDIUM (-ve)



LOW (-ve)



Reversibility / sustainability



Reversible



Confidence



Low



Management measures





Provide affected villages with adequate water supply (including for irrigation of crops).







Consider installation of new wells / maintenance or repairs to existing village wells.







If necessary, make alternative wetland areas available for rice cultivation.



7.2.2



WR2: Surface water abstraction affecting downstream users

Construction



Operation



Decommissioning



Post-Closure



3



A preliminary water balance established for the Project, indicates approximately 8,000m of

make-up water per day would only be required during the dry season (to supplement recycled

process water and stormwater collected in the TSF settlement ponds). This make-up water

will be pumped directly from the Rokel River at a location south of the beneficiation plant.

Once the Project is operational it is anticipated that containment, controls and mine dewater

input will provide routine closed cycle use with top-up from the river supply if and when

required.

Water abstracted directly from rivers has the potential to reduce the volumes of annual flow,

change the seasonal distribution of flows through the year and increase the length of low flow

periods. A qualitative assessment of the impact of abstraction from the Rokel River on flow

rate has been made by SRK based on baseline data and the abstraction rates estimated in

the preliminary mine water balance provided by MIOL.

Under high flow conditions, the abstraction proposed is likely to be negligible compared to the

likely flow rates in the river. Assessment of the low flow conditions in the Rokel River reveals

3

the lowest average flow rate near the Project area during the dry season is 6.1m /s (around

March). The maximum abstraction rate for make-up water for the mine is estimated to be

3

0.35m /s, or 5.7% of the available river flow at the driest recorded conditions (worst case). In

terms of constraints on the flow downstream where it might support communities (e.g. for

irrigation and drinking) and aquatic ecosystems, the impact of such a reduction is likely to be

negligible taking into account contribution to flow from elsewhere in the catchment (outside

the concession). This preliminary prediction will be confirmed based on further monitoring of

the Rokel River and once abstraction needs for operation are confirmed.

Due to the relatively small proportion of river flow abstracted, the impact is expected to be

minor but would extend for the life of the mine, albeit at a low frequency (only in the dry

season). As the abstraction is unlikely to impact on downstream users the impact is

considered to be of low significance and no management measures are required. Good

practice measures are however listed.



U3823_Marampa_ESIS_Final.docx



September 2012

Page 143 of 298



SRK Consulting



Marampa Iron Ore Project ESIS – Main Report



Impact WR2: Surface water abstraction affecting downstream users

Impact characteristics



Initial impact



Residual or optimised impact (taking

cognisance of management

measures)



Type (+ / - /neutral)



Negative



-



Sensitivity



Low



-



Receptor

importance or

value



Low



-



Extent of change /

threshold

compliance



Low



-



Magnitude rating



MINOR



-



Duration



Medium term -



-



Frequency



Low



-



Timeframe rating



MEDIUM TERM



-



INTERMEDIATE



-



Magnitude

description



Timeframe

description



Spatial Scale

CONSEQUENCE RATING



MEDIUM



-



PROBABILITY RATING



UNLIKELY



-



SIGNIFICANCE RATING



LOW (-ve)



-



Reversibility / sustainability



Reversible



-



Confidence



High



-



Good practice measures:



7.2.3







Minimise the abstracted volume, as far as practicable.







Monitor either river stage or flow for the life of the mine to detect any negative impacts to

river flow.



WR3: Project infrastructure causing altered surface water flow conditions,

affecting downstream users

Construction



Operation



Decommissioning



Post-Closure



The positioning of Project infrastructure will in some cases lead to changes in stormwater

runoff regimes over the site, affecting catchment characteristics and responses. The changes

that could arise are as follows:





Alteration to catchment area and characteristics (topographical, land use, slopes)







Potential alteration in catchment response time and peak flow in rivers and streams

associated with reduced catchment areas and altered characteristics



Proposed stormwater management measures at the main mine infrastructure (WRD, TSF and

open pits) are described in Chapter 4, and consist mainly of stormwater settlement ponds (to

collect water from the WRD and area surrounding the pits). Due to the surrounding

topography, stormwater will naturally be directed away from the TSF and additional

stormwater management at this site will not be required.

In addition to this, a number of streams run through the area of the proposed Mafuri and Gafal

pits (see Figure x). To accommodate pit development, significant alteration of the drainage

network via the diversion of the Kagbu River will be required. The river will also be impounded

U3823_Marampa_ESIS_Final.docx



September 2012

Page 144 of 298



SRK Consulting



Marampa Iron Ore Project ESIS – Main Report



upstream of the pit area to create a water storage reservoir, the spillway for which will serve

as an outflow into the above-mentioned diversion. Preliminary diversion plans are

summarised in Section 4.2.2 and described in more detail in the preliminary Surface Water

Management Plan for the Project (Mining Solutions, 2012), which is included as Appendix E.

The stream diversion and water storage reservoir are expected to cause the most significant

impacts on stream flow conditions resulting from the Project, particularly affecting downstream

catchments and river flow, as described below and illustrated on Figure 7.1.

Assessment method

A qualitative (and where possible quantitative) assessment of changes to surface flow

conditions was performed by SRK using data gathered as part of the baseline water

resources study and other relevant reports produced for the Project, as follows:





Reduction in catchment areas quantified using ArcGIS;







Expected changes in catchment characteristics modelled (using hydrologic engineering

centre’s river analysis system (HEC-RAS)) and assessed based on the surface water

management plan (Mining Solutions, 2012); and







1 in 100 year peak flows calculated (based on rainfall extremes, in the absence of

monthly average flow estimates).



The results indicate that sub-catchment areas will be reduced (due to the footprint of the mine

pits), but the increase in compacted or impermeable surfaces (through construction of roads,

buildings, WRD and any other hard surfaces) would cause an increase in runoff rates. These

catchment alterations will result in changes to the rivers’ response to rainfall events, with a

likely increased susceptibility to flooding. The predicted net effect on river peak flow (for a 1 in

100 year rainfall event) will be a reduction in 26 of the 36 sub-catchments in the area (see

Table 7-3), which will be most significant in the subcatchments directly downstream of the

water storage reservoir and stream channel diversion around the Mafuri pit (as described in

Section 4.2.2, and shown relative to the subcatchments and flow directions in Figure 7.1). The

locations of the various catchments and subcatchments are shown on Figure 5.5.

The diversion spillway controlling flow will result in a reduction in flow in subcatchments KA10,

2

KA17 and KA18. In KA17 this reduction (due to a decrease in catchment size from 46.1 km

2

to 0.6 km (99%)) is predicted to be as much as 97% (at 100 year peak flow – under average

flow this is likely to be significantly less). A significant increase in peak flow (81%) is predicted

2

2

in subcatchment KA8 only due to an increase in catchment size (from 2.2 km to 44.1 km

(95%)) resulting from the proposed stream diversion flowing into this subcatchment.

Subcatchments in other parts of the Project area are also predicted to show significant

reductions in peak flow (up to 83%, as shown in Table 7-3) due to the positioning of Project

infrastructure, reducing catchment area.

In most cases the predicted proportional reduction in catchment area and peak flow are

similar. Changes to flow under average or low flow conditions have however not been

determined (due to lack of monthly flow estimates), but are expected to be significantly less

than the 100 year peak flow.



U3823_Marampa_ESIS_Final.docx



September 2012

Page 145 of 298



SRK Consulting



Marampa Iron Ore Project ESIS – Main Report



Table 7-3: Predicted changes to 1 in 100 year peak flows and catchment areas for subcatchments in the Project area

14



Sub-catchment

KA1

KA2

KA3

KA4

KA5

KA6

KA7

KA8

KA9

KA10

KA11

KA12

KA13

KA14

KA15

KA16

KA17

KA18

BA1

BA2

BT1

BT2

BT3

BT4

BT5

BT6

BN1

BN2

BN3

BN4

BN5

RL1

RL2

RL3

RL4

RL5



Maximum predicted increase/decrease (%)

Area (%)

Peak flow (%)

- 15.6

- 16.8

No change

No change

No change

No change

No change

No change

No change

No change

No change

No change

- 65.0

- 65.0

+ 95.0

+ 81.4

- 10.2

- 11.1

- 8.4

- 62.1

No change

No change

- 6.5

- 7.1

- 3.6

- 3.9

- 2.8

- 3.1

- 2.6

- 2.9

- 4.5

- 5.0

- 98.6

- 97.3

- 7.6

- 72.7

- 16.8

- 18.0

- 9.3

- 10.2

- 83.3

- 83.3

- 65.8

- 66.5

No change

No change

No change

No change

- 8.4

- 9.3

- 6.9

- 7.6

- 68.0

- 69.7

- 53.2

- 55.8

- 41.0

- 43.6

- 45.3

- 48.2

- 36.1

- 38.4

- 66.7

- 66.7

- 68.4

- 69.8

- 61.2

- 63.9

- 5.0

- 5.3

No change

No change



Expected impact on other users

The above-mentioned changes in river peak flow could impact on both human and ecological

users downstream. Decreases in flows could affect water availability to villages downstream,

particularly those in the area of the Gafal and Mafuri pits due to the stream diversion and

water storage reservoir as discussed above. However, most of the villages in this area will be



14



Indicated by a + (increase) or – (decrease)



U3823_Marampa_ESIS_Final.docx



September 2012

Page 146 of 298



SRK Consulting



Marampa Iron Ore Project ESIS – Main Report



relocated to accommodate the pits, and those remaining are located close to the Rokel River,

which it is assumed would provide an alternative surface water resource if necessary. Due to

the size of the Rokel River, and the fact that changes to the flow in the Kagbu River under low

and average flow conditions at its confluence with the Rokel are likely to be minor, impacts on

flow in the Rokel River are considered to be minimal. This will be further assessed and

confirmed quantitatively once a further wet season survey (including monitoring of river flow)

has been conducted.

The most significant impact is expected to be on aquatic ecosystems in the area, due to

habitat loss and/ or alteration caused by the stream diversion. In-stream habitats will be lost

from the sections of the streams to be diverted from their natural flow path (approximately 600

m). Most of the affected aquatic ecosystems are seasonal midslope wetlands, and are

classified as moderately modified (mainly due to transformation for rice cultivation) and of lowmedium ecological importance (Nepid, 2012). Despite the relatively limited diversity of

instream habitats, they are characterised by a high diversity of taxa, particularly fish species

(Ecorex, 2011); therefore the stream diversions will need to include key habitat features to

maintain fish populations during the dry season. A recent decline in fish populations in the

area was however observed during the Nepid 2012 dry season survey, and could be

attributed to existing disturbance (possibly caused by construction linked to other Projects in

the area).

Downstream of the Mafuri pit, the diverted section will reconnect to a tributary of the Kagbu

River, which will also be affected due to altered stream flow as described above. The impact

will therefore extend beyond the mine footprint area.

Although the pits will be backfilled post-closure, much of the other mine infrastructure will

remain in place (including the stream diversion and water storage reservoir). The changes to

flow dynamics are therefore considered to be permanent. Management measures are

recommended to reduce the likelihood of the impact (through replacement of instream

habitats lost) and reduce its significance. Additional studies to determine the impact under low

and average flow conditions are required, and the confidence of the impact rating is therefore

medium.

Changes to flood risk for surrounding areas due to the above-mentioned water diversion and

impoundment is discussed and rated separately in Impact WR4 (Section 7.2.4). Increases in

erosion potential associated with increased runoff rates are discussed under Impact LT4

(Section 7.1.4), and the resultant increased sedimentation of surface waters (affecting

ecological systems) is discussed under Impact WR6 (Section 7.2.6).



U3823_Marampa_ESIS_Final.docx



September 2012

Page 147 of 298



SRK Consulting



Marampa Iron Ore Project ESIS – Main Report



Figure 7.1: Catchment areas affected by surface water diversion and storage infrastructure, indicating flow directions



U3823_Marampa_ESIS_Final.docx



September 2012

Page 148 of 298



SRK Consulting



Marampa Iron Ore Project ESIS – Main Report



Impact WR3: Project infrastructure causing altered flow conditions, affecting downstream

users

Impact characteristics



Initial impact



Residual or optimised impact

(taking cognisance of management

measures)



Type (+ / - /neutral)



Magnitude

description



Timeframe

description



Negative



Negative



Sensitivity



High



Medium



Receptor

importance or

value



Medium



Medium



Extent of change /

threshold

compliance



High



Medium



Magnitude rating



MAJOR



MODERATE



Duration



Long term



Long term



Frequency



-



-



Timeframe rating



LONG TERM



LONG TERM



Spatial Scale



INTERMEDIATE



INTERMEDIATE



CONSEQUENCE RATING



HIGH



MEDIUM



PROBABILITY RATING



DEFINITE



POSSIBLE



SIGNIFICANCE RATING



HIGH (-ve)



MEDIUM (-ve)



Reversibility



Irreversible



Confidence



Medium



Management measures





Implement erosion control measures listed in LT4.







Design surface water diversion channels to mimic the natural instream habitat as closely as

possible, and rehabilitate using indigenous vegetation. 







Include key instream habitat features, such as deeper pools, to maintain fish populations during

the dry season in stream diversion channels.

Good practice measures:



7.2.4







Avoid disturbance of drainage lines and riparian zones where possible, through careful

routing of roads and servitudes.







Use semi-permeable materials where possible in preference to impermeable materials

for surfaces such as roads and paving.







Monthly average flow for each river should be measured for at least a year, and used to

determine impacts during non-peak river flow.



WR4: Surface water diversions potentially causing changes to flood risk to

adjacent agricultural areas and communities

Construction



Operation



Decommissioning



Post-Closure



When changes to a river’s course are made (such as the proposed stream diversion to

accommodate the Mafuri and Gafal pits), this can alter its flow regime local to that diversion

and impacts may occur either upstream or downstream relative to that alteration. In the case

of the Kagbu River Diversion (also referred to as the Mafuri West Diversion), the change in

U3823_Marampa_ESIS_Final.docx



September 2012

Page 149 of 298



SRK Consulting



Marampa Iron Ore Project ESIS – Main Report



direction of flow and slope and the impact this has on flood risk of the surrounding area have

been assessed (through hydraulic modelling by SRK) both upstream and downstream of the

diversion itself.

For this particular diversion the likely risk areas are:





Immediately upstream of the diffluence (upstream connection), where some backing up

of water could occur as a result of the rather sharp change in direction of flow caused by

the diversion.







Downstream of the confluence (downstream connection), where the change in flow

direction and likely change in bed slope as the diversion re-joins the old river alignment

may result in scour of the left bank and some degree of eddying.







Along the diversion itself, given its close proximity to the Mafuri Pit West (within 50m).



As no specific details for the design of a flow control structure (weir, spillway or sluice) are

available at this stage in planning, various assumptions were made when modelling potential

impacts, including that flow through the diversion is controlled by the geometry of the new

diversion channels. Flood routing and peak outflow through the water storage reservoir were

calculated, and used as input for the hydraulic modelling.

Due to the significant increase in catchment area and peak flow of catchment KA8 resulting

from the stream diversion (as described in Impact WR3), the area with the greatest flood risk

is predicted to be the middle to lower reaches of the diversion. Due to the river size however,

change in water level (and therefore flood risk) downstream of the diversion is likely to be low.

The HEC-RAS modelling results predict that during a 1 in 100 year flood the water will remain

within the banks of the diversion channel, although water level will increase (by 0.31 – 0.59 m)

downstream of the diversion. As the modelling is based only on preliminary design data,

revised modelling will be required to confirm these results once the design has been finalised.

Other subcatchments in the area could also be affected by the diversion (as discussed in

Impact WR3 and illustrated on Figure 7.1) but this will be by way of reduced flows and

therefore will reduce flood risk in these catchments.

Almost all valleys within the Project area are cultivated, mostly with different varieties of rice.

2

The water storage reservoir created will cover a surface area of approximately 400,000 m

and although much of this area is currently river, it will also extend into areas currently used

for subsistence agriculture (rice paddies and small patches of mango plantation). However as

villages in the area will be relocated it is uncertain whether these areas would still be used for

agriculture as the villages may seek to cultivate areas closer to the new village locations (still

be determined). The impact on livelihoods associated with loss of access to land and natural

resources is discussed in Impact LT1 (Section 7.1.1), and rated in Impact RL1 (Section 8.2.1).

Flooding is one of the most common natural disasters affecting Sierra Leone, and between

1980 and 2010 affected approximately 200,000 people (EM-DAT, 2012). It is therefore

expected that local communities will be sensitive to an increased flood risk. The relatively flat

topography of the study area and location of villages close to rivers (supporting access to

water and use of floodplains for agriculture) both support the notion that local communities are

highly susceptible to flooding. However, as most villages in the immediate downstream area

of the diversion will be relocated due to positioning of the mine pits, impacts on local

communities are considered to be unlikely. Although the stream diversion is likely to be a

permanent feature, the frequency of occurrence of the impact would be low (i.e. during flood

events only). No management measures are proposed.



U3823_Marampa_ESIS_Final.docx



September 2012

Page 150 of 298



SRK Consulting



Marampa Iron Ore Project ESIS – Main Report



Impact WR4: Surface water diversions potentially causing changes to flood risk to adjacent

agricultural areas and communities

Impact characteristics



Initial impact



Residual or optimised impact

(taking cognisance of management

measures)



Type (+ / - /neutral)



Magnitude

description



Timeframe

description



Negative



Negative



Sensitivity



Medium



-



Receptor

importance or

value



Medium



-



Extent of change /

threshold

compliance



Medium



-



Magnitude rating



MODERATE



-



Duration



-



-



Frequency



Low



-



Timeframe rating



LOW FREQUENCY



-



Spatial Scale



INTERMEDIATE



-



CONSEQUENCE RATING



MEDIUM



-



PROBABILITY RATING



UNLIKELY



-



SIGNIFICANCE RATING



LOW (-ve)



-



Reversibility



Irreversible



-



Confidence



Medium



-



Good practice measures:



7.2.5







Implement erosion / sedimentation control measures listed in Impacts LT4 and WR7 in

and around diversion channels.







Include flood risk in the Emergency Response and Preparedness Plan and raise

awareness with potential affected communities of the risks and what to do in the event of

a flood.







Update the preliminary water management plan.



WR5: Seepage from mining wastes potentially resulting in deteriorated

groundwater quality affecting communities and ecological systems

Construction



Operation



Decommissioning



Post-Closure



Groundwater quality has the potential to be negatively impacted due to seepage of process

water from mine wastes at the following locations:





waste rock dumps







tailings storage facility







low-grade ore stockpiles



Seepage may occur directly from these facilities or from their associated storm water control

facilities, and infiltrate through the soil into the underlying groundwater system, where it would

spread through the aquifer. Regional groundwater flow in the area is to the southwest, so any

seepage entering the groundwater is most likely to affect users to the southwest of the

source. Pit dewatering (as discussed in Impact WR1) may also affect the spread of the

seepage-affected groundwater during mining and the post-mining recovery stage, causing

U3823_Marampa_ESIS_Final.docx



September 2012

Page 151 of 298



SRK Consulting



Marampa Iron Ore Project ESIS – Main Report



groundwater in the vicinity of the pits to flow towards the pits. Seepage to groundwater

occurring within the cone of depression for each pit (estimated to extend up to 1 km from each

pit, which includes most of the WRDs), is therefore likely to be drawn into the pits. Dilution

effects reduce the concentrations of constituents from the seepage, but even so these could

potentially negatively impact on groundwater users in terms of deteriorated water quality.

Many local villages use groundwater drawn from village wells as their primary source of

potable water. Deteriorated water quality could therefore potentially impact negatively on the

health of local communities. At closure, the TSF and WRDs will continue to be sources of

seepage as they are permanent features. These aspects are briefly examined below and

qualitatively evaluated based on planned design concepts and the results of geochemical

investigations conducted to date.

Waste rock dumps and ore stockpiles

Geochemical investigations have been completed on waste rock samples from the four pits,

as well as the expected ore, concentrate and tailings materials. These reveal low potential for

acid generation. Leaching of metals from the waste rock is considered unlikely, and as

discussed above, the WRDs generally fall within the cone of depression surrounding the pits.

TSF

Geochemical characterisation of the tailings material indicates it is unlikely to generate acidity,

but will also have limited buffering capacity. Net acid generation (NAG) test leachate analysis

of tailings samples also revealed little potential for leaching of iron or trace metals from the

metallurgical samples. A decant system and under drainage will be constructed in the TSF to

recover supernatant water from consolidation of the tailings material. This system will also

reduce the potential for seepage losses to soil and groundwater.

Based on the discussion above no significant impacts on groundwater quality in the area are

expected to result from seepage from mine wastes, and no management measures are

therefore proposed. Due to the inherent design measures listed above and the low likelihood

of metal leaching or acid generation from the sources examined, seepage from mining wastes

is unlikely to occur. The potential for the impact to occur would however last beyond the life of

the mine if not permanently as (apart from the ore stockpiles) these sources will remain on the

site, and any contaminated groundwater would affect villages beyond the Project footprint.

Further geochemical characterisation of the expected waste rock and tailings material is

however required to confirm the preliminary findings.



U3823_Marampa_ESIS_Final.docx



September 2012

Page 152 of 298



SRK Consulting



Marampa Iron Ore Project ESIS – Main Report



Impact WR5: Seepage from mining wastes potentially resulting in deteriorated water quality

affecting communities and ecological systems

Impact characteristics



Initial impact



Type (+ / - /neutral)



Magnitude

description



Timeframe

description



Residual or optimised impact

(taking cognisance of management

measures)



Negative



-



Sensitivity



Low



-



Receptor

importance or

value



Low



-



Extent of change /

threshold

compliance



Low



-



Magnitude rating



MINOR



-



Duration



Long term



-



Frequency



-



-



Timeframe rating



LONG TERM



-



Spatial Scale



INTERMEDIATE



-



CONSEQUENCE RATING



MEDIUM



-



PROBABILITY RATING



UNLIKELY



-



SIGNIFICANCE RATING



LOW (-ve)



-



Reversibility / sustainability



Irreversible



-



Confidence



Medium



-



Good practice measures:





7.2.6



Further geochemical characterisation of expected waste rock and tailings material to

confirm preliminary findings.



WR6: Discharges or runoff to surface water potentially resulting in deteriorated

water quality affecting communities and ecological systems

Construction



Operation



Decommissioning



Post-Closure



Impacted discharge waters i.e. mine site run-off that potentially has low (acidic) pH or

contains elevated levels of naturally occurring metals or sediment has the potential to be

generated in the following areas:





discharge of excess water from open pit dewatering;







drainage from waste rock dumps;







drainage from the tailings storage facility;







stormwater runoff from exposed surfaces; and







accidental spills (e.g. from pipelines or during transportation).



Each of these is briefly discussed below and qualitatively evaluated based on planned design

concepts. The most significant impact to surface water quality however is expected to arise

from mobilisation of soils from exposed surfaces during mining activities at all stages of the

Project, and may also be associated with the effluent discharges listed above.



U3823_Marampa_ESIS_Final.docx



September 2012

Page 153 of 298



SRK Consulting



Marampa Iron Ore Project ESIS – Main Report



Discharge of excess water from pit dewatering

The excess water from open pit dewatering will be pumped to settlement ponds before

release to the natural watercourses draining to the Rokel River, with a proportion directed to

the TSF during the dry season. Further monitoring and characterisation of groundwater

chemistry in the vicinity of the pits is being undertaken but, based on currently available data,

there are no specific contaminants of concern.

Drainage from waste rock dumps

Drainage channels will be constructed around waste rock dumps and through the waste dump

slopes, as necessary, to direct the surface water flow to the settlement ponds. The settled

water in the ponds will be released to the environment with regular water quality tests

performed to monitor the quality of the discharge. If the water in the pond exceeds the agreed

water quality standards, it will be contained until it complies or be redirected to the TSF if it

cannot meet the required standards.

Drainage from the TSF

A decant system and under drainage will be constructed in the TSF to recover supernatant

water from consolidation of the tailings material. This system will also reduce the risk of

embankment failure. Water collected in the under drainage system will be pumped back to

the plant for re-use during processing. An emergency spillway will also be installed as part of

the TSF design to manage discharge under emergency conditions, should this be needed (to

ensure the safety of the dam wall – refer to Impact OH2 in Chapter 0).

Stormwater runoff from exposed surfaces

Leaching of metals from exposed soils (via stormwater runoff) may cause chemical changes

to surface water systems. The mobile constituents are those that can be easily removed from

the soil via rainfall and flood waters, and include both metal ions and soil nutrients. Shortterm leaching tests conducted on the soil samples indicate low levels of leaching, with the

exception of iron and zinc that are mobile constituents and may be leached from the soils.

Accidental spills

There is a risk of uncontrolled release of ore, waste rock or tailings material, or domestic

wastewater (e.g. from the accommodation camp) to surface water resources arising from an

accident or incident during transportation of waste or materials on the site (such as a pipeline

breakage or a truck overturning). Geochemical characterisation of these materials is

discussed above, and provided standard precautionary measures are in place (such as

secondary encasement of pipelines crossing watercourses and enforcement of safe driving

practice); this impact is not considered to be significance. Product export outside the mine site

has not been assessed in this ESIA.

Mobilisation of soils in stormwater runoff

Vegetation stripping and ground exposure makes the soils prone to erosion. Stormwater

runoff from disturbed areas may pick up fine particles and other pollutants (such as mobile

constituents) which may be discharged into down-gradient surface waters. Changes to

surface water flow regimes resulting from changes to stormwater patterns are discussed

under Impact WR3. The impact on land use potential as a result of loss of topsoil through

erosion is discussed and rated under Impact LT4 (Section 7.1.4). The discussion below will

therefore focus on impacts on surface water resources due to increased sedimentation.

U3823_Marampa_ESIS_Final.docx



September 2012

Page 154 of 298



SRK Consulting



Marampa Iron Ore Project ESIS – Main Report



Mobilisation of soils is likely to be greatest during the construction phase, as a result of land

modification necessary for the construction of the mine pits and associated surface

infrastructure. Impacts associated with disturbance of soils are considered to be lower during

the operational and closure phases than during construction as exposed ground areas will be

minimal, haulage roads will be sealed and traffic movements restricted, stockpile areas

stabilised and topsoil reinstated following remediation. Site works during closure for

remediation and rehabilitation of the site will result in some exposure of ground areas, but this

will be on a much smaller scale than during construction and areas will be re-vegetated.

Particularly due to the high rainfall during the wet season, effective drainage networks will be

required to manage stormwater around mine infrastructure. The water management plan for

the mine will be further developed to provide a strategy for segregating impacted and nonimpacted (clean) water. Storm water settlement ponds will form part of the drainage network

to collect impacted water runoff from the mine infrastructure. During normal operations, the

sediment ponds will be cleaned out during the dry season, with the collected sediment placed

on the waste dumps for long term storage.

Summary

Baseline surface water quality in the area is characterised by low metal concentrations, and

moderately acidic to near-neutral pH, with little or no buffering capacity against acid inputs.

Different users also have differing sensitivities to pollutant levels. In this case, both human

users of water (for domestic, agricultural or industrial purposes) and downstream ecological

systems could be impacted by decreased water quality, causing negative health effects. Due

to the inherent design measures in place, and the relatively inert nature of the impact sources,

chemical pollution of surface water resources is considered to be unlikely and of minor

significance. Sedimentation is therefore considered to be the most significant impact relating

to surface water quality, in some cases making it unsuitable for domestic use, and is the

impact rated below. As the impact is most likely to occur during the rainy season when

groundwater levels are elevated however, domestic users are likely to have access to other

water sources, reducing the significance of the impact on them.

Impacts on aquatic ecosystems could however be significant, affecting filter feeding

organisms, aquatic vegetation (through reduced light penetration), and predator-prey

interactions (through reduced visibility). Increased turbidity and siltation is considered to be

the most significant threat to aquatic ecosystems in the area resulting from the Project.

Current turbidity levels in local streams are low, resulting in good natural light levels

penetrating the water column. Although ecological habitats in the Project area are classified

as moderately modified, abundance and diversity of submerged aquatic vegetation and fish

species are high, including some species of conservation concern. Impacts on aquatic

organisms would in turn affect local communities in terms of decreased stocks and quality of

fish and other organisms harvested from local watercourses.

Downstream ecological systems in particular are likely to be highly sensitive to this impact,

which is likely to extend in duration until decommissioning has been completed and the area

has been rehabilitated. With effective management (primarily via erosion control mechanisms)

however, the impact would be unlikely to occur, reducing its significance rating to low.



U3823_Marampa_ESIS_Final.docx



September 2012

Page 155 of 298



SRK Consulting



Marampa Iron Ore Project ESIS – Main Report



Impact WR6: Discharge or runoff to surface water potentially resulting in deteriorated water

quality affecting communities and ecological systems

Impact characteristics



Initial impact



Residual or optimised impact

(taking cognisance of management

measures)



Type (+ / - /neutral)



Magnitude

description



Timeframe

description



Negative



Negative



Sensitivity



High



High



Receptor

importance or

value



High



High



Extent of change /

threshold

compliance



High



High



Magnitude rating



MAJOR



MAJOR



Duration



Medium term



Medium term



Frequency



-



-



Timeframe rating



MEDIUM TERM



MEDIUM TERM



Spatial Scale



INTERMEDIATE



INTERMEDIATE



CONSEQUENCE RATING



MEDIUM



MEDIUM



PROBABILITY RATING



DEFINITE



UNLIKELY



SIGNIFICANCE RATING



MEDIUM (-ve)



LOW (-ve)



Reversibility / sustainability



Irreversible



Confidence



High



Management measures





Plan and implement a comprehensive erosion control programme, including erosion and dust

control measures listed in Impacts LT4 and AQ1.







Use sedimentation control techniques such as installation of straw bales buffers in drainage

lines downstream of potential sources of increased sediment load.







Implement a Water Management Plan for the site.







Implement a comprehensive Rehabilitation and Closure Plan, which includes rehabilitation of

the backfilled pits, WRD and TSF to prevent post-closure discharge, and revegetation to

ensure continued erosion control.







Where practicable, separate clean and “dirty” (i.e. with elevated levels of contaminants)

stormwater and handle to two categories differently.







Ensure clean water is piped to the outlet point and not allowed to flow freely where it may

cause erosion.

Good practice measures:





Avoid construction activities in the Bankasoka River catchment area (northern portion of

the TSF area), which is ecologically sensitive.







Implement a water quality monitoring programme (continuing post-closure) to detect

changes to surface water quality and take the required remediatory actions.







Implement a surface water biomonitoring programme (as

recommendations) to monitor effects on aquatic ecosystems.







Implement a spill management programme, which includes preventive measures such as

secondary containment of pipelines crossing water courses and bunding of hazardous

liquids stored on site.



U3823_Marampa_ESIS_Final.docx



per



the



specialist



September 2012

Page 156 of 298



SRK Consulting



7.3



Marampa Iron Ore Project ESIS – Main Report



Ecology and biodiversity

Many of the aspects discussed above which cause impacts to land and water can cause

impacts on natural habitats as well, thereby affecting the ecology and biodiversity of the mine

footprint and surrounding areas (including aquatic habitat). This includes the following:





Temporary or permanent surface disturbance (including clearing of vegetation) for

construction of Project infrastructure, resulting in direct loss of faunal and floral

communities, and proliferation of alien invasive species;







Haul roads, fences, pipelines or other barriers to movement, resulting in habitat

fragmentation;







Dewatering of pits resulting in groundwater drawdown, affecting wetland and other

habitats;







Noise and vibrations from equipment and blasting, disturbing fauna;







Illumination of Project infrastructure, disturbing fauna;







Fugitive dust from Project activities, affecting vegetation and fauna (including aquatic

species);







Surface water abstraction or diversion, affecting availability to downstream aquatic

habitats;







Change in chemical characteristics of water bodies due to discharges;







Human population influx to the area, resulting in increased pressure on natural

resources;







Decommissioning, reprofiling and rehabilitation of the mine footprint area



Impacts on ecology and biodiversity include direct loss of fauna and flora, both at the

individual and community levels as well as fragmentation, modification or loss of habitat, and

indirect impacts through various types of disturbance, pollution or sedimentation of water

courses. As much of the study area is already transformed, predominantly through

subsistence agriculture and previous mining activity in the area, this is taken into account in

the rating of the impacts described below. Impacts on both terrestrial and aquatic

environments have been assessed.



7.3.1



EB1: Site clearance and positioning of Project infrastructure potentially

resulting in habitat loss and fragmentation, and direct loss of fauna and flora

Construction



Operation



Decommissioning



Post-Closure



Habitat loss as a result of the Project is likely to occur through:





direct modification of land through site clearance for Project infrastructure, as discussed

under Impact LT1 (Section 7.1.1);







indirect modification of land adjacent to cleared areas, resulting in habitat loss due to

anthropogenic effects and erosion (discussed under Impact LT4 in Section 7.1.4); and







indirect loss of wetland habitats through pit dewatering as discussed under Impact WR1

(Section 7.2.1).



In addition to permanent changes to certain footprint areas within the mine area, there will be

temporary disturbance during construction (and to a certain extent during decommissioning)

of areas for laydown / storage of materials, access tracks and a construction camp. The

location and extent of these areas have not yet been determined. Impacts on communities as

U3823_Marampa_ESIS_Final.docx



September 2012

Page 157 of 298



SRK Consulting



Marampa Iron Ore Project ESIS – Main Report



a result of loss of agricultural land, areas for hunting, fishing and harvesting or a reduction in

land capability is discussed and rated separately under Impact RL1 (Section 8.2.1).

Terrestrial habitats and species of conservation concern

A number of the terrestrial habitat types identified and described in Section 5.9.1 will be

affected by Project infrastructure. Some of these habitats (primarily gallery forest but also

swamp forest and flooded grassland) are considered to be of high functional value due to their

potential for high biodiversity, threatened species and present ecological state. However very

little of these habitat types (only a small area of gallery forest) were identified within the direct

mine footprint area. As no endangered or critically endangered terrestrial species were

confirmed or are likely to occur within the study area, however, the habitat is not considered to

be of critical conservation importance. The areas of each habitat type lost due to direct

disturbance and construction of the major mine site infrastructure is shown in Table 7-4.

A large proportion of the study area (including wetlands) is already transformed due to

subsistence agriculture and shows secondary vegetation re-growth. The diversity of terrestrial

mammals is therefore limited in the area. Only the lowland forest along the Rokel River

(consisting of gallery and swamp forest, the indigenous habitat type) is of conservation

concern, both due to its extremely limited distribution (covering less than 0.1% of the Project

study area in excess of 40,000 ha), and the diversity of species it supports (including wild

plants used by local communities). Of these, three plant species of conservation significance,

one near-threatened mammal and two primate species are present in the gallery forest

increasing the significance of the impact of loss of this habitat. Some of this habitat will be

directly impacted and indirect impacts associated with changes to hydrogeological regimes

are also possible (Impact WR3).

Table 7-4: Area of each habitat type directly impacted by the Project

Natural habitat type



Area directly impacted (ha)



Flooded natural grassland



0



Gallery forest



1.25



Rice wetlands



3,949.15



Secondary forest / farmbush mosaic



35,431.29



Secondary savannah



75.52



Swamp forest



0



Rivers



0



One of the major secondary impacts resulting from vegetation clearance and land disturbance

is erosion – both of topsoil, which is discussed under Impact LT4 (Section 7.1.4), as well as

erosion along river banks, resulting in further loss of riparian habitat. For this reason it is

particularly important that the lowland forest found in narrow strips along the river banks, and

providing flood attenuation and bank stabilisation, is not disturbed. This habitat type is

however limited in the study area to a very small area along the northern bank of the Rokel

River, close to the Rotret WRD, another area west of the Rotret WRD, and an isolated area

where the TSF is planned to be located. Except for the TSF, these fall outside the direct mine

site footprint.

Habitat fragmentation as a result of the positioning of Project infrastructure and other areas of

disturbance is likely to affect movement of fauna between areas for activities such as

breeding and foraging or hunting for food and could result in injury or death through crossing

infrastructure such as roads.

U3823_Marampa_ESIS_Final.docx



September 2012

Page 158 of 298



SRK Consulting



Marampa Iron Ore Project ESIS – Main Report



The area supports a wide diversity of bird species, particularly in the secondary forest /

farmbush, which is widespread throughout the study area. Birds are likely to move away from

the area and settle in similar habitat nearby once land disturbance begins. In the case of the

lowland forest habitat that supports a large number of bird species (18 of which are forest

specialists), similar habitat is extremely limited in the surrounding area. What is present in the

area is generally close to mine infrastructure (mainly the Rotret waste rock dump) and

therefore subject to sensory disturbance (discussed in Impact EB3 (Section 7.3.3)) possibly

making it a less attractive habitat for most species. Secondary savannah habitat also supports

high biodiversity of bird species. This habitat type is restricted to a small area in the Project

area and will be partially lost due to construction of the Mafuri pit.

Land disturbance and clearing of vegetation will lead to a localised reduction in food and

habitat for mammals, birds and herpetofauna (reptiles and amphibians). Although much of the

fauna would migrate from the area to adjacent undisturbed areas, accidental death of some

small mammals and reptiles that are not able to move away prior to preliminary earthworks is

expected.

The closure phase is seen as an opportunity to re-establish vegetation consistent with the

surrounding area. However, rehabilitation of disturbed areas will require ongoing maintenance

(such as watering, erosion control and control of alien invasive vegetation) until the vegetation

is established and sufficient groundcover has been achieved. Rehabilitation of the site would

also be expected to encourage displaced fauna species to return to the area with time,

however a return to the pre-mining ecological state (particularly in forest areas) is unlikely.

The permanent features left after mining, such as the waste rock dumps and pits, provide a

different habitat to that found pre-disturbance and may encourage slightly different

ecosystems to form.

Aquatic habitats and species of conservation concern

As stated in Impact WR1 (Section 7.2.1), groundwater drawdown associated with pit

dewatering may desiccate and thereby reduce the extent of wetland ecosystems within the

area surrounding the pits (up to 1000 m radius for the Matukia and Gafal pits). Wetland

habitat in the study area is important both for agriculture (rice cultivation), covering almost all

wetland areas, as well as for supporting indigenous species in habitats such as the flooded

natural grassland, swamp and gallery forest habitats. The Rokel River and its associated

riparian forest are considered to be the areas of highest conservation importance, due to the

species they host. The loss of rice cultivation areas will impact on local communities in terms

of food security and is rated in Impact WR1 (Section 7.2.1). The five aquatic habitat types

identified in the study area are classified as modified, but the high fish diversity in the Rokel

River indicates it to be in good ecological health and thus vulnerable to indirect impacts from

changes in the hydrogeological regime. The seasonal valley head wetlands (used mainly for

rice cultivation) host high numbers of fish, including species of conservation concern. Two

vulnerable, one near-threatened and one endangered species, Epiplatys lokoensis, were

recorded in the Project area. The conservation status of E. lokoensis is however pending

downgrading from its current status of “Endangered” to “Vulnerable” (Ecorex, 2011).

Summary

Much of the area is no longer ecologically pristine, and no terrestrial species or habitats of

critical conservation importance are present in the area. However, due to the presence of a

number of fish species of conservation importance, aquatic habitats in the area are

U3823_Marampa_ESIS_Final.docx



September 2012

Page 159 of 298



SRK Consulting



Marampa Iron Ore Project ESIS – Main Report



considered to be of conservation importance (though due to the above-mentioned downgrade

in conservation status, this would not be critical). The impact is therefore considered to be of

moderate magnitude. Without successful rehabilitation much of the area will remain

ecologically impacted beyond the life of the mine, if not permanently. Loss of individuals and

habitats will be unavoidable, but is unlikely to significantly affect the ecology outside the area

surrounding the Project footprint as the individuals are not highly endemic or specific to a

particular area with the exception of the bird species associated with the gallery forest.

Effective management (primarily via minimising the disturbance footprint, especially of

sensitive areas) could decrease the probability and extent of the impact, thereby decreasing

its significance. Due to some uncertainty in the robustness of the ecological system to

respond to these changes, the confidence in the rating is given as medium.

Impact EB1: Site clearance and positioning of Project infrastructure potentially resulting in

habitat loss and fragmentation, and direct loss of fauna and flora

Impact characteristics



Initial impact



Residual or optimised impact

(taking cognisance of management

measures)



Type (+ / - /neutral)



Magnitude

description



Timeframe

description



Negative



Negative



Sensitivity



Medium



Medium



Receptor

importance or

value



Low



Low



Extent of change /

threshold

compliance



Low



Low



Magnitude rating



MINOR



MINOR



Duration



Long term



Long term



Frequency



-



-



Timeframe rating



LONG TERM



LONG TERM



Spatial Scale



INTERMEDIATE



SMALL



CONSEQUENCE RATING



MEDIUM



MEDIUM



PROBABILITY RATING



DEFINITE



UNLIKELY



SIGNIFICANCE RATING



MEDIUM (-ve)



LOW (-ve)



Reversibility / sustainability



Partially reversible



Confidence



Medium



Management measures





Where possible adjust positioning of Project infrastructure during planning to avoid gallery

forest and wetland habitats.







Clear vegetation in phases working progressively in one direction so that fauna have an

opportunity to move to adjacent areas.







Stockpile topsoil and manage topsoil clearing as per the recommendations listed in Impact

LT4, for use during rehabilitation.



U3823_Marampa_ESIS_Final.docx



September 2012

Page 160 of 298



SRK Consulting



7.3.2



Marampa Iron Ore Project ESIS – Main Report



EB2: Soil disturbance facilitating the establishment and spread of invasive

species, potentially affecting indigenous ecosystems

Construction



Operation



Decommissioning



Post-Closure



Clearing or disturbance of vegetation and soil for construction of the mine and associated

infrastructure will result in these areas being vulnerable to erosion (discussed in Impact LT4 in

Section 7.1.4) as well as to infestation by exotic (or alien – i.e. introduced from elsewhere)

and invasive vegetation species. Due to their rapid growth and general resilience, exotic

invasive vegetation tends to proliferate in disturbed areas preventing or retarding growth of

indigenous vegetation through competition for sunlight, nutrients, space and water. Once

established, they seed quickly and multiply rapidly, establishing a seed bank in the soil. Not

being indigenous to the area they are often resistant to indigenous biological control

organisms and unpalatable to local fauna. Exposed or disturbed soil therefore presents an

ideal opportunity for exotic invasive species growing in the vicinity or brought in from outside

to spread and proliferate.

For a species to proliferate it would generally need to already be established in the

surrounding area. The ecological baseline assessment found significant patches of secondary

forest to be infested with the aggressively growing exotic species, Chromlaena odorata (Triffid

Weed), which is native to North America (see Figure 7.2). This species easily spreads to

adjacent vegetation, smothering the plants around it and preventing successful recruitment of

forest canopy species, thereby preventing the recovery of secondary forest to its climax

ecological state. It is therefore considered to be one of the major threats to biodiversity in the

area and is reported to have become well established in secondary vegetation particularly in

the southern parts of the Project area, but was also found in Savannah and Swamp Forest

areas (Ecorex, 2011).

It is likely that, without adequate management, areas cleared of vegetation or disturbed

(primarily during construction and to a lesser extent during decommissioning) will become

infested by this species, exacerbating the current problem with alien infestation. Soil erosion

and other impacts leading to decreased land capability would also indirectly contribute to the

growth of exotic invasive vegetation by retarding the growth of the current vegetation cover.

Other development in the area would also increase the likelihood of this impact.

As much of the area is already disturbed and the majority of the vegetation is no longer

ecologically pristine, as well as the fact that no habitats of critical conservation importance are

present in the area, the impact is expected to be of moderate magnitude. Without

management, the invasive vegetation would continue to spread and proliferate within the

disturbed areas beyond the life of the mine. Effective management would minimise the spread

of invasive alien vegetation, and decrease the significance of the impact to low.



U3823_Marampa_ESIS_Final.docx



September 2012

Page 161 of 298



SRK Consulting



Marampa Iron Ore Project ESIS – Main Report



Figure 7.2: The invasive alien plant Chromlaena odorata (Triffid Weed)

Impact EB2: Soil disturbance facilitating the establishment and spread of invasive species,

potentially affecting indigenous ecosystems

Impact characteristics



Initial impact



Residual or optimised impact

(taking cognisance of management

measures)



Type (+ / - /neutral)



Negative



Negative



Sensitivity



Moderate



Moderate



Receptor

importance or

value



Low



Low



Extent of change /

threshold

compliance



Moderate



Low



Magnitude rating



MODERATE



MINOR



Duration



Long term



Long term



Frequency



-



-



Timeframe rating



Magnitude

description



Timeframe

description



LONG TERM



LONG TERM



Spatial Scale



SMALL



SMALL



CONSEQUENCE RATING



MEDIUM



MEDIUM



PROBABILITY RATING



POSSIBLE



UNLIKELY



SIGNIFICANCE RATING



MEDIUM (-ve)



LOW (-ve)



Reversibility / sustainability



Reversible



Confidence



High



Management measures





Implement an alien plant control management programme, including training of personnel to

implement the programme.







Implement rehabilitation as soon as possible, and monitor rehabilitated areas for growth of

invasive species.







Implement good practice measures listed in Impact LT1 to minimise the disturbed area.







Implement erosion control measures as listed in Impact LT4.







Remove invasive alien plants before they bear seed and dispose of removed plants

appropriately.



U3823_Marampa_ESIS_Final.docx



September 2012

Page 162 of 298



SRK Consulting



7.3.3



Marampa Iron Ore Project ESIS – Main Report



EB3: Project activities resulting in sensory or other disturbance to wildlife

Construction



Operation



Decommissioning



Post-Closure



The Project will result in a number of potential disturbances to species which may exacerbate

the effects of loss of fauna and habitat as well as habitat fragmentation (discussed in Impact

EB1). These disturbances include increased noise, vibrations, light, dust and a general

increase in human and vehicular activity in the area increasing accidental road kill (discussed

in Impact TS2) and hunting. As the operations will run for 24-hours a day, the disturbances

will be continuous, affecting both diurnal and nocturnal wildlife, and will extend from

construction until decommissioning.

Increases in noise/vibration through blasting or the operation of mining equipment and light

may act as a source of sensory disturbance to birds, herpetofauna, mammals and insects.

Sensory disturbances may result in temporary avoidance of the area, disruption of feeding

and breeding patterns or permanent displacement of individuals from the area. Although

disturbance may result in a loss of fauna around the mine site, mobile animals are likely to

move to adjacent replacement areas. For generalist species this is not expected to present a

problem. However for habitat-specific species (such as forest endemics) the availability of

suitable habitat nearby may be a limiting factor which could result in loss of those species to

the area. Changes in species distribution could put pressure on the resources and resident

species of surrounding habitats, but as densities of wildlife in the area are already low (due to

disturbance) this is not expected to pose a significant impact. Note that light sources can also

be an attractant (Impact EB4) to insects and their predators.

Project activities during construction and operations will result in increased background dust

concentrations and emissions from vehicles and other sources (extent of air quality impacts

are discussed in Impacts AQ1 and AQ2). Increased dust deposition on vegetation reduces

the photosynthetic capacity of plants and may limit growth and reproductive capacity leading

to a decrease in population sizes and potential loss of species, this can be particularly critical

for food crops. However, due to high background dust levels in the receiving environment in

the dry season, particularly along unpaved roads, the vegetation is likely to be well-adapted to

dust and it is unlikely to represent a significant impact.

The Project area is already disturbed – Lunsar town borders on the area and villages are

scattered throughout, with their associated livelihood practices such as subsistence farming,

fishing and hunting; the Makeni highway and the railway to Pepel pass through the area; and

two other mines are in operation in relatively close proximity. Hunting and trapping of wildlife

already occurs, possibly contributing to the near absence of larger mammals. Improved

access to the site (through access roads and other infrastructure providing access through

dense vegetation) and more human activity in the area as a result of the Project may indirectly

increase the incidence of hunting. However there are few species of conservation concern,

and those that are present are unlikely to remain in the area. It is however strongly

recommended that the remaining forest areas are protected from further disturbance (perhaps

as formal conservation areas, in consultation with local communities) and mining activities

close to these areas are minimised.

Since much of the area is already disturbed, faunal densities are already low and there are

few faunal species of conservation concern, the magnitude of the impact is rated as minor.

U3823_Marampa_ESIS_Final.docx



September 2012

Page 163 of 298



SRK Consulting



Marampa Iron Ore Project ESIS – Main Report



Disturbances directly related to the Project are likely to decrease during decommissioning,

and be largely reversed following closure of the site. Long term impacts are therefore not

expected. The disturbance will however be inevitable and will extend beyond the Project

footprint to adjacent areas. Due to its low significance, no management measures are

proposed, but the implementation of the good practice measures listed is recommended.

Impact EB3: Project activities resulting in sensory or other disturbance to wildlife

Impact characteristics



Initial impact



Type (+ / - /neutral)



Magnitude

description



Residual or optimised impact

(taking cognisance of management

measures)



Negative



-



Sensitivity



Low



-



Receptor

importance or

value



Low



-



Extent of change /

threshold

compliance



Low



-



Magnitude rating



MINOR



-



Duration



Medium term



-



Frequency



-



-



Timeframe rating



MEDIUM TERM



-



Timeframe

description



Spatial Scale



INTERMEDIATE



-



CONSEQUENCE RATING



LOW



-



PROBABILITY RATING



DEFINITE



-



SIGNIFICANCE RATING



LOW (-ve)



-



Reversibility / sustainability



Reversible



-



Confidence



High



-



Good practice measures:





Develop and implement a Wildlife and Habitat Management Plan that:

o



protects gallery and swamp forest areas from disturbance (see Figure 5.12);



o



provides awareness training to staff and contractors on: prevention of injury of

animals; identification of likely species found on site (and those of conservation

concern); identifications of animal hazards (such as venomous snakes); and

what to do if dangerous animals are encountered;



o



requires personnel to report kills of species of conservation concern to the mine’s

Environment Management team, who may investigate the incident;



o



encourages personnel to report sightings of wildlife of conservation importance to

the mine’s Environment Management team; and



o



allows for the monitoring and, if necessary, eradication of any invasive species

occurring on site or in surrounding disturbed areas.



U3823_Marampa_ESIS_Final.docx



September 2012

Page 164 of 298



SRK Consulting



7.3.4



Marampa Iron Ore Project ESIS – Main Report



EB4: Mine infrastructure and activities attracting nuisance species, potentially

resulting in impacts on indigenous ecosystems

Construction



Operational



Decommissioning



Post-Closure



The Project infrastructure will provide new habitat opportunities for fauna. For example,

buildings will provide shade and nesting opportunities for small fauna and birds, water storage

areas will be an attractant particularly in the dry season, light will attract insects (and their

predators) and waste disposal areas have the potential to provide a food source to scavenger

animals such as rodents. However, these attractive nuisances are being created in a

hazardous environment and will expose fauna to risks.

Domestic waste such as food waste will be produced by the mine site and the

accommodation camp and disposed in a landfill area on site which will attract (and pose a

potential danger to scavenger animals such as rodents, birds and foxes (and possibly

domestic dogs, pigs and goats from nearby villages) if not managed. As a minimum, regular

and thorough waste compaction, ensuring wastes are completely covered with soil or other

inert material after deposition and fencing of the landfill will be required to keep the presence

of scavengers to a minimum.

Construction and operation will result in 24-hour illumination of the mine site. Insects may be

attracted to the lights at night and this may attract bats to the area which may be vulnerable to

drowning in water storage facilities. Water storage facilities may also provide additional

breeding areas for mosquitoes increasing their prevalence (and (in theory) potentially also the

prevalence of malaria) in the area.

The habitat opportunities described above will attract specific species towards the site and will

increase the exposure of these animals to hazardous environments or situations, such as

toxic water and moving machinery or drowning. This can have implications on local

ecosystems with an increase in scavenger animals and their predators, however as there is

already existing disturbance in the area the ecosystems are unlikely to be significantly

affected. New habitat opportunities may result in a change to the diurnal and nocturnal

species composition in the area and could, in theory, result in an increase in animal deaths

due to the hazards present. Even with proposed management measures, the risk of animal

deaths will be difficult to control but will cease on closure.

Any impacts will be restricted to the Project footprint and adjacent disturbed areas. As there is

already other developments (creating other sources of attractive nuisance) in the area and

species are likely to move away from the area (and therefore are unlikely to be at risk), the

magnitude of the impact is rated as minor. Negative impacts that can be directly related to the

Project (and not secondary development in the area) would predominantly occur during

operation of the site, and will largely cease on decommissioning. Negative impacts are not

considered to be of high significance and would be unlikely to occur with effective

implementation of the management measures listed.



U3823_Marampa_ESIS_Final.docx



September 2012

Page 165 of 298



SRK Consulting



Marampa Iron Ore Project ESIS – Main Report



Impact EB4: Mine infrastructure and activities attracting nuisance species, potentially

resulting in impacts on indigenous ecosystems

Impact characteristics



Initial impact



Residual or optimised impact

(taking cognisance of management

measures)



Type (+ / - /neutral)



Magnitude

description



Timeframe

description



Negative



Negative



Sensitivity



Low



Low



Receptor

importance or

value



Low



Low



Extent of change /

threshold

compliance



Low



Low



Magnitude rating



MINOR



MINOR



Duration



Medium term



Medium term



Frequency



-



-



Timeframe rating



MEDIUM TERM



LONG TERM



Spatial Scale



SMALL



SMALL



CONSEQUENCE RATING



MEDIUM



MEDIUM



PROBABILITY RATING



POSSIBLE



UNLIKELY



SIGNIFICANCE RATING



LOW (-ve)



LOW (-ve)



Reversibility / sustainability



Reversible



Confidence



Medium



Management measures





Develop and implement a waste management plan that accommodates all waste types

produced on site, particularly food waste.







Manage the landfill site in accordance with good practice standards, including access control

and fencing.







Monitor the incidence of drowning in water storage facilities and implement preventive

measures if required.







If required, a pest control programme should be implemented, and should include monitoring of

accidental death of non-pest species. Should the use of rodent control measures be required,

the use of natural predators, for example raptors should be considered, and pesticides that bioaccumulate should be avoided.



U3823_Marampa_ESIS_Final.docx



September 2012

Page 166 of 298



SRK Consulting



8



Marampa Iron Ore Project ESIS – Main Report



SOCIO-ECONOMIC IMPACT ASSESSMENT

As stated in Section 3.3.3 social issues are often unavoidable and the mitigation strategies

are generally geared towards managing a social change process. Successful management of

a potentially negative social issue usually presents opportunities for social development and

improvement in the quality of life of local people. The economic benefits to the community

which can be generated by large scale Projects are the key motivations for the community to

support the Project. Furthermore, unlike environmental management plans, social

management plans have a twofold objective, first aiming at mitigation of negative impacts and

secondly aiming at improvement of standard of living.

The potential socio economic impacts (both positive and negative), have been grouped in the

categories as shown in Table 8-1.

Table 8-1: Summary of evaluated social impacts

Impact ED1: Employment generation by the Project resulting in increased standard of

living for the local community

Impact ED2: Employee training leading to skills development in the local community

Economic development



Impact ED3: Increase in government income (from taxes and royalty on mining)

potentially leading to social development in the Project area

Impact ED4: Opportunities for local suppliers and contractors leading to economic

growth

Impact RL 1: Impoverishment through loss of shelter, land and communal natural

resources



Resettlement and loss of

land and social and natural

resources



Impact RL2: Changes to community access as a result of the Project potentially

affecting livelihoods, access to communal social services and infrastructure and

community cohesion

Impact RL3: Added pressure on limited host community resources, potentially resulting

in food insecurity and malnutrition

Impact SO1: Influx of job seekers causing increased pressure on government services

and infrastructure, potentially resulting in reduced standard of living



Social order



Impact SO2: Increase in social ills/problems

Impact SO3: Real or perceived unequal distribution of Project benefits leading to social

tension



Archaeology and cultural

heritage



Impact AC1: Disturbance to sacred bushes and cemeteries leading to loss of

community’s access cultural resources



Decommissioning and

closure



Impact DC1: Closure of mine leading to economic decline



As discussed in Chapter 4, potential socio-economic impacts resulting from export activities

and the transport of product (and supplies) are not included in this assessment.

Explanatory notes on the description and rating of the impacts in Chapters 8 is provided in the

introductory text in Chapter 7. Potential impacts of the Project on the health and safety of

communities in the vicinity of the Project are described in Chapter 9.



8.1



Economic development

The economic benefits of the Project can be classified as direct, indirect and induced impacts.

These are described below:





direct impacts – the immediate economic benefits (jobs and development Projects,

revenue paid to the government) generated by the Project;







indirect impacts – the production, employment and income changes occurring in



U3823_Marampa_ESIS_Final.docx



September 2012

Page 167 of 298



SRK Consulting



Marampa Iron Ore Project ESIS – Main Report



businesses that supply inputs or provide services to the Project; and





8.1.1



induced impacts –the effects of spending by the employees working directly and

indirectly for the Project on the local economy.



ED1: Employment generation by the Project resulting in increased standard of

living for the local community

Construction



Operation



Decommissioning



Post-Closure



The Project area is characterised by a lack of formal employment opportunities and

widespread poverty (Section 6.5). The creation of jobs is regarded by the local population as

the most important positive impact. Although a second mining development (by London

Mining) is also underway in the Project area, there is still a significant gap between the

availability and demand for jobs.

The Project will require a labour force of up to 700 (peak estimate) during construction (over a

15

3 to 3.5 year period). About 60% are expected to be labour, which can be sourced locally .

The specialist construction workers are likely to be sourced outside of Sierra Leone due to the

lack of skilled workers in-country (and competition for local skilled labour between mine

developments).

The Project will require a work force of up to 550 during the operational phase (15 years).

The skill levels needed in this phase will be higher than during the construction phase. Hence

it will be difficult to find suitably qualified Sierra Leoneans and therefore it is expected that the

number of expatriate employees will initially be relatively high. The number of expatriates will

reduce over the life of the mine as Sierra Leonean staff will be trained to take over skilled jobs

and management roles. The increased capacity of the national staff will be an added benefit

of the Project.

Formal jobs with regular and stable incomes will result in greater financial security for those

employed and their families. In the extended family structure typical of rural Sierra Leone

each employed person supports a large number of dependents.

The formal jobs at the Project are expected to be well paid in comparison to existing wage

levels in the area. The security and stability gained from a formal job may lead to an

improvement in nutritional/health status, investment in children’s education, investment in

income generating assets and general quality of life. However, increased income, if not used

constructively, can lead to short term gratification (such as drinking and gambling, often linked

to conflicts and divorce) instead of investment in the future. Workers may therefore need

training and support in the area of income management and life skills.

The Project will generate indirect jobs, businesses and livelihood opportunities in the ancillary

sector. These may include services and supplies directly to the Project or on account of

additional spending by the Project workers. SRK’s experience on other mining Projects in

developing countries and in Africa has shown that the ‘employment multiplier effect’ can vary

from 1.5 to 9 depending on macroeconomic factors. Assuming an average multiplier of four,

every direct job created by the Project can result in three additional jobs. Hence the Project

can result in 2,100 additional jobs during construction and 1,650 additional jobs during

operations, contributing to the national job sector as a whole.



15



Local here refers to the directly and indirectly affected villages and Lunsar town.



U3823_Marampa_ESIS_Final.docx



September 2012

Page 168 of 298



SRK Consulting



Marampa Iron Ore Project ESIS – Main Report



If not managed appropriately however, the employment opportunities at the Project have the

potential to:





lead to community resentment against the Project leading to conflict;







become the cause of inter and intra village conflict on the issue of job distribution (further

discussed under Impact SO3); and







be a major pulling factor for the in-migration of job-seekers potentially leading to a series

of other social problems (Impact SO1).



To avoid potential negative consequences, positive impact measures (see enhancement

measures proposed below) will focus on increasing local employment opportunities, and

ensuring a fair and transparent recruitment strategy. In the table below the impact has been

evaluated for the operational phase, as the benefit in terms of increased standard of living will

be measurable mainly due to the sustained benefits of regular income over a relatively long

period of time.

Employment opportunities created by the Project will cease to exist at the end of the

operational phase (see Impact DC1) hence the benefit of the increased standard of living will

not be sustainable without the enhancement measures in place. Appropriate management

measures (during employment and retrenchment) and community development programmes

can mitigate against the standard of living dropping to a pre Project level. However the

outcomes of such programmes are difficult to guarantee and hence the confidence rating of

the mitigation is medium.

Impact ED1: Employment generation by the Project resulting in increased standard of living

for the local community

Impact characteristics



Initial impact



Residual or optimised impact

(taking cognisance of management

measures)



Type (+ / - /neutral)



Positive



Positive



Sensitivity



High



High



Receptor

importance or

value



High



High



Extent of change /

threshold

compliance



Low



Medium



Magnitude rating



MODERATE



MODERATE



Duration



Medium term



Long term



Magnitude

description



Timeframe

description



Frequency



-



-



Timeframe rating



MEDIUM TERM



LONG TERM



INTERMEDIATE



INTERMEDIATE



Scale

CONSEQUENCE RATING



MEDIUM



HIGH



PROBABILITY RATING



DEFINITE



DEFINITE



SIGNIFICANCE RATING



MEDIUM (+ve)



HIGH (+ve)



Reversibility/sustainability



Partially sustainable



Confidence



High



U3823_Marampa_ESIS_Final.docx



September 2012

Page 169 of 298



SRK Consulting



Marampa Iron Ore Project ESIS – Main Report



Impact ED1: Employment generation by the Project resulting in increased standard of living

for the local community

Enhancement measures





Develop a local employment strategy giving preference to local candidates, provided they meet

the required eligibility criteria.







Develop a fair and transparent local recruitment plan







Require contractors (by means of their contract) to give preference to local employees,

provided they meet the required eligibility criteria.







Organise training for workers on management of household incomes.







Develop a programme for gradual ‘indigenisation’ of the workforce. This includes a general and

technical skills training programme







Develop and implement a construction and operational phase stakeholder engagement plan

(SEP). As part of this SEP document and disclose the recruitment process to manage

community expectations (also related to Impact SO2).



Good practice measures:



8.1.2







Give preference to people directly affected by land acquisition to reduce the magnitude

of impacts described in Section 8.2, and







develop a programme of training prior to Project start up to maximise potential for local

employment.



ED2: Employee training leading to skills development in the local community

Construction



Operation



Decommissioning



Post-Closure



Education and skills levels in the Project area are low (Section 6.9). There is limited exposure

of the local population to modern technology, technical skills and a formal employment culture

(for instance safe working practices). The Project workforce (including local people and other

Sierra Leone nationals) will receive both formal and informal training, gaining them skills and

competences in different work streams relevant to the Project (Section 4.9.3). The acquired

skills will enhance their opportunities to gain alternative employment after mine closure. It is

also likely that some of the skills acquired at the workplace, such as health and safety

measures, financial management, communication and interpersonal skills will be transferred

to a certain extent, to domestic and personal settings leading to an enhanced quality of life.

During construction, training will be limited to on-the-job training and safety briefs. Systematic

training including technical training will be organised mainly for the operations workforce. It is

expected that with enhancement measures the benefit of training will sustain beyond the

Project life. However the confidence in the prediction of optimised impact is medium as it is

difficult to fully ascertain the ability of workers to benefit from training.



U3823_Marampa_ESIS_Final.docx



September 2012

Page 170 of 298



SRK Consulting



Marampa Iron Ore Project ESIS – Main Report



Impact ED2: Employee training leading to skills development in the local community

Impact characteristics



Initial impact



Residual or optimised impact

(taking cognisance of management

measures)



Type (+ / - /neutral)



Positive



Positive



Sensitivity



High



High



Receptor

importance or

value



High



High



Extent of change /

threshold

compliance



Low



Medium



Magnitude rating



MODERATE



MODERATE



Duration



Medium term



Long term



Magnitude

description



Timeframe

description



Frequency



-



-



Timeframe rating



MEDIUM TERM



LONG TERM



INTERMEDIATE



INTERMEDIATE



Scale

CONSEQUENCE RATING



MEDIUM



HIGH



PROBABILITY RATING



DEFINITE



DEFINITE



SIGNIFICANCE RATING



MEDIUM (+ve)



HIGH (+ve)



Reversibility/sustainability



Sustainable



Confidence



Medium



Enhancement measures





Prepare and implement a training and skills development plan for ongoing skills development

of the Project workforce including contractors’ personnel.







Support a ‘vocational training programme’ to assist local people to qualify for semi-skilled

positions.







Encourage workers to introduce the learned skills and practices in their homes.



Good practice measures:





8.1.3



Continue technical and financial support to educational institutions and students.



ED3: Increase in government income (from taxes and royalty on mining)

potentially leading to social development in Project area

Construction



Operation



Decommissioning



Post-Closure



Sierra Leone is a candidate country for membership of the Extractive Industry Transparency

Initiative (EITI). The EITI promotes transparency in flow of revenue from industry to the

government to enhance utilisation of revenues for sustainable development in local

communities affected by Projects. It is therefore expected that part of the revenue earned

from the Project will be used by the Government for social development in the vicinity of the

Project.

The Government of Sierra Leone is expected to earn revenue from the Project as a result of

taxation on profits, excise duties on imports, payroll taxes and value added tax. The

increased government income, if allocated back to the Port Loko District for development,

may to lead to enhanced social infrastructure and services. However the Project has no

U3823_Marampa_ESIS_Final.docx



September 2012

Page 171 of 298



SRK Consulting



Marampa Iron Ore Project ESIS – Main Report



control over this benefit as the allocation of government spending will be determined by the

Government of Sierra Leone. To increase the probability of this benefit materialising the

Project should focus on liaison with the government at the local and national levels to support

the implementation of EITI principles.

Impact ED3: Increase in government income (from taxes and royalty on mining) potentially

leading to social development in Project area

Impact characteristics



Initial impact



Residual or optimised impact

(taking cognisance of management

measures)



Type (+ / - /neutral)



Magnitude

description



Timeframe

description



Positive



Positive



Sensitivity



High



High



Receptor

importance or

value



High



High



Extent of change /

threshold

compliance



Medium



Medium



Magnitude rating



MODERATE



MODERATE



Duration



Medium



Medium



Frequency



-



-



Timeframe rating



MEDIUM TERM



MEDIUM TERM



Scale



SMALL



SMALL



CONSEQUENCE RATING



MEDIUM



MEDIUM



PROBABILITY RATING



UNLIKELY



POSSIBLE



SIGNIFICANCE RATING



LOW (+ve)



MEDIUM (+ve)



Reversibility/sustainability



Not sustainable



Confidence



Low



Good practice measures:



8.1.4







disclose information on Project’s payment to government to the local communities and

other interested stakeholders as part of the SEP, and







liaise with government to promote the use of revenue from the Project in the Project’s

area of influence for local development.



ED4: Opportunities for local suppliers and contractors leading to local

economic growth

Construction



Operation



Decommissioning



Post-Closure



The construction of the mine and associated infrastructure will require a capital investment of

about USD 2.4 billion during the construction phase, whereas the operational cost is estimated

to be approximately USD 9.5 billion. Over the life of mine this translates to approximately

USD 12 billion. This spending provides economic opportunities for suppliers of equipment,

goods and services. The supply market in Sierra Leone is currently not capable to meet the

demands of this type and scale of Project. Hence the Project is unlikely to source the majority

of goods and services from within Sierra Leone, with the exception of consumables such as

fuel, food and stationary. Where possible however, additional goods should be sourced within

Sierra Leone which would lead to economic growth at local and the national levels.

U3823_Marampa_ESIS_Final.docx



September 2012

Page 172 of 298



SRK Consulting



Marampa Iron Ore Project ESIS – Main Report



The probability of this benefit from occurring will depend on the Project’s efforts to increase

engagement of local suppliers by implementing the measures listed below in the table. The

local purchase opportunities will be greatest in the construction phase, will diminish and

stabilise during the operational phase and may continue into the decommissioning phase. The

benefit will cease to exist after closure. Confidence in this benefit materialising is medium as

there is limited capacity in Sierra Leone to meet the needs of the Project.

Impact ED4: Opportunities for local suppliers and contractors leading to stimulation of local

economic growth

Impact characteristics



Initial impact



Residual or optimised impact

(taking cognisance of management

measures)



Type (+ / - /neutral)



Magnitude

description



Timeframe

description



Positive



Positive



Sensitivity



High



High



Receptor

importance or

value



High



High



Extent of change /

threshold

compliance



Low



Medium



Magnitude rating



MINOR



MINOR



Duration



Medium term



Medium term



Frequency



-



-



Timeframe rating



MEDIUM TERM



MEDIUM TERM



Scale



EXTENSIVE



EXTENSIVE



CONSEQUENCE RATING



MEDIUM



MEDIUM



PROBABILITY RATING



UNLIKELY



POSSIBLE



SIGNIFICANCE RATING



LOW (+ve)



MEDIUM (+ve)



Reversibility/sustainability



Not sustainable



Confidence



Medium



Enhancement measures





Identify the types of goods and services required and those that can be sourced from within

Sierra Leone.







Develop a procurement programme to maximise the use of local suppliers.



Good practice measures:





8.2



Develop a supplier and contractor database, along with a process to review, monitor and

strengthen capabilities of local suppliers and contractors.



Resettlement and loss of land, social and natural resources

The Project’s foot print area at the mine site (open pits, TSF, WRD, processing areas and

haul roads) is estimated to be at least 1,900 Ha. This area is currently in use by local

residents for village settlements (housing and social infrastructure), farming (permanent and

shifting), collection of wild plants, charcoal production, grazing, fishing and hunting.

Although the location of the Project facilities have been designed to minimise direct impacts

on existing villages it will lead to displacement of 10 villages (namely Marunku, Magbungbu,



U3823_Marampa_ESIS_Final.docx



September 2012

Page 173 of 298



SRK Consulting



Marampa Iron Ore Project ESIS – Main Report



Konta, Gbese, Mafuri, Rosint, Ma Sesay, Maso, Rolal c/o Gafal and Matukia). These villages

will lose houses and community structures, access to farmland, plantations, irrigation

structures, roads and other land based resources. These villages will therefore need to be

resettled and compensated in accordance with the Resettlement Action Plan (RAP) based on

the Resettlement Framework presented in Appendix D.

In addition to this, 13 other villages (namely Makel, Mafira, Magbafat, Rolal c/o Mafuri,

Monbaia, Konta Bana, Konta Lol, Manonko, Molumpo, Royail, Kalangba, Royema and

Matoko) on the peripheries of the footprint area may not need to be resettled but may face

impacts due to loss of land, access to natural resources and loss of social support networks

resulting from relocation of neighbouring villages. These villages may also need to be

considered in the RAP.

Sacred sites and grave sites within the Project footprint area will also require relocation (see

Impact AC1).

In the absence of mitigation measures, physical and or economic displacement can result in

long-term impacts on the social and economic wellbeing of affected populations. Therefore

mitigation measures will be planned for the management of the following potential impacts:





relocation of households (Impact RL1)







loss of income and livelihood opportunities (Impact RL1);







reduced access to communal facilities such as wells, irrigation works, schools, and

health clinics) (Impact RL2);







breakdown of social support networks such as access to farm labour and credit (impact

RL3); and







loss of sacred sites (see Impact AC1).



Resettlement of affected households to a new area could result in positive and negative

16

impacts on the host community (if applicable) or communities close to the resettled villages..

These would need to be assessed once resettlement sites are identified (Impact RL4)



8.2.1



RL1: Impoverishment through loss of shelter, land and communal natural

resources

Construction



Operation



Decommissioning



Post-Closure



Preliminary assessment of the potentially impacted population reveals that:





10 villages, comprising of 162 households (or 1,780 people) will require replacement

housing and access to alternative land for farming and collection of natural resources to

sustain their livelihoods; and







an additional 13 villages, comprising of 270 households (or 2,936 people), who are

affected by partial loss of land used for farming and collection of natural resources, will

require replacement land and access to communal natural resources for sustaining their

livelihoods.



In total approximately 432 households (4,716 people) will lose some access to land based

resources. In addition, some absentee landowners, who live in Freetown, may also be

impacted by the land acquisition process.



16



Who is receiving the resettled people.



U3823_Marampa_ESIS_Final.docx



September 2012

Page 174 of 298



SRK Consulting



Marampa Iron Ore Project ESIS – Main Report



The RLS study shows that there could be possible impacts on communities further away from

the directly impacted villages due to changes to flood regimes and traders dependant on the

supply of products from displaced villages.

The impacts will occur during the construction phase. However their effects can be long term

if not mitigated against. The impacts will be mitigated using a resettlement programme that

includes:





provision of improved standard replacement housing and community structures , in

consultation with the affected local communities;







compensation for land in the form of cash or preferably in the form of replacement land

for long term sustainability of livelihoods;







cash compensation for loss of any standing crops, plantations and trees;







assistance for redevelopment of farms and plantations on new land; and







livelihood restoration for people facing loss of income or livelihood opportunities.



Special attention will be needed in the RAP for the issues listed below:





Due to depletion of natural resources and sub-optimal methods of farming, food

insecurity is an issue in the area, with households lacking adequate food supplies for

between one and four months every year (Section 6.5). Hence the mitigation measures

will need to focus on alternative livelihood options (such as employment by the Project)

and improving farming methods. Some communal resources, such as palm oil trees (for

palm wine trapping or commercial harvesting) are leased to people outside the identified

villages. Hence the mitigation measures will need to consider the impact on people

potentially affected due to severance of such leasing arrangements.







Replacing access to communal natural resource areas with areas of similar value will be

difficult due to general depletion of natural resources in the larger area. Loss of wild

plants, which are largely restricted to degraded patches of communal forest (protected in

the form of sacred bush), would impact on the traditional system of medicine and could

be difficult to replace.



Hence a combination of mitigation measures will be needed to compensate for loss of access

to natural resources. These will need to be explored with the affected people, but could

include: planting of medicinal plants, providing support to farmers and exploring alternative

livelihood options with an objective to enhance food security.

Impact RL1: Impoverishment through loss of shelter, land and communal natural resources

Impact characteristics



Initial impact



Residual or optimised impact

(taking cognisance of management

measures)



Type (+ / - /neutral)



Magnitude

description



Negative



Negative



Sensitivity



High



High



Receptor

importance or

value



High



High



Extent of change /

threshold

compliance



High



Low



Magnitude rating



MAJOR



MODERATE



U3823_Marampa_ESIS_Final.docx



September 2012

Page 175 of 298



SRK Consulting



Marampa Iron Ore Project ESIS – Main Report



Impact RL1: Impoverishment through loss of shelter, land and communal natural resources

Timeframe

description



Duration



Permanent



Short to Medium term



Frequency



-



-



Timeframe rating



LONG TERM



MEDIUM TERM



Scale



SMALL



SMALL



CONSEQUENCE RATING



HIGH



MEDIUM



PROBABILITY RATING



DEFINITE



DEFINITE



SIGNIFICANCE RATING



HIGH (-ve)



MEDIUM (-ve)



Reversibility



Reversible



Confidence



High



Mitigation measures





Prepare a Resettlement Action Plan (RAP) in agreement with affected population, the

Paramount Chief and key government and non-government stakeholders as per the RF

(Appendix D). The plan should provide details of:







affected people;







entitlements (cash or preferably in the form of replacement land for long term sustainability of

livelihoods);







cash compensation for loss of any standing crops, plantations and trees;







assistance for redevelopment of farms and plantations on new land;







provision of improved replacement residential and community structures as per the preference

of local communities.







Build alternative access routes in consultation with users of affected routes.







Undertake a community development programme for people facing loss of livelihood

opportunities.







Iteratively consult with affected people to identify and resolve their issues in a timely manner.







Implement a grievance mechanism for identification of resettlement related issues and address

them in a timely manner.







Undertake post resettlement monitoring of affected parties to timeously detect issues and take

action if necessary.



Good practice measures:





8.2.2



Preferentially employ eligible members from directly affected families.



RL2: Changes to community access as a result of the Project potentially

affecting livelihoods, access to communal social services and infrastructure

and community cohesion

Construction



Operation



Decommissioning



Post-Closure



Local communities live in small villages scattered throughout the Project area many of which

are only accessible on foot. Close social linkages exist between these villages, as well as

linkages through trade and shared natural resource use. Community members therefore

travel on foot on a regular basis between villages, water access points, farming, fishing,

hunting or harvesting areas, places of community service (schools, clinics) and areas of

cultural importance (such as sacred bush). Due to the dense vegetation, many of these

U3823_Marampa_ESIS_Final.docx



September 2012

Page 176 of 298



SRK Consulting



Marampa Iron Ore Project ESIS – Main Report



routes are not visible from aerial photographs of the area. The most direct and easiest access

routes would preferentially be used and in many cases the use of alternative available routes

would add significantly to the journey time and effort which, in turn, would cut into time

available for other livelihood practices. In some cases, positioning of Project infrastructure

may intersect these preferred routes blocking or disrupting access.

The communal social infrastructure available to villagers mainly comprises facilities such as

schools, health centres, churches, grain banks, hand pumps and access roads. Land

reduced by the Project would lead to loss of communal social infrastructure in the 10 directly

affected villages, although this is mitigated by resettlement of those villages.

The RAP will plan for replacement of lost facilities at the relocation sites, which should

improve the affected people’s standard of living. Making an inventory of impacted

infrastructure and planning for their replacement will be part of the RAP (Impact RL1).

Relocation of some facilities that have a larger catchment area (such as the Health centre in

Marunku) could also impact several neighbouring villages currently using the facility. This

aspect may need to be assessed during the resettlement planning process and included in

the mitigation measures. Given the Project area is characterised by a low density of social

infrastructure, the resettlement programme will provide an opportunity for net improvement in

the situation. Hence it is reasonable to expect that the post mitigation the impact would be

minor, last for a shorter duration and be reversible.

Displaced communities (and to a lesser extent the villages left behind) that are relocated too

far from their present location can also be affected by a loss of non-tangible community

resources such as: reciprocal labour sharing arrangements (usually spread across 3-4

villages), links with traders and access to social networks (neighbours, friends, relatives) that

form the social support within the village community. To mitigate loss of social networks,

consideration will be given to relocation of certain households so as to preserve the social ties

and networks and reduce the potential severity and duration of the impact. As with Impacts

RL1 this aspect will be further investigated during RAP process and addressed through

identification of measures using community knowledge and preferences.

Due to the local communities’ reliance on access routes between villages and other areas, the

pre-management magnitude of the impact is rated as moderate. The impact will be felt

beyond the life of the mine, if not permanently, and will affect communities beyond the direct

Project footprint area, either directly or indirectly, through disruption or loss of connectivity

with areas outside the village that are commonly frequented. Through appropriate

management, the impact significance could be reduced as communities would be assisted by

way of developing suitable route alternatives, having alternative facilities provided and the

period of route disruptions could be minimised. Positive impacts resulting from the provision of

safe and easy new access routes together with a reduction in travel time and vehicle

maintenance costs (through the improvement in road condition) would also contribute to the

reduction in significance of this negative impact. As the impact relates to communities

perceptions of the change, the confidence in the rating is given as medium.



U3823_Marampa_ESIS_Final.docx



September 2012

Page 177 of 298



SRK Consulting



Marampa Iron Ore Project ESIS – Main Report



Impact RL2: Reduced access to communal social services and infrastructure

Impact characteristics



Initial impact



Residual or optimised impact

(taking cognisance of management

measures)



Type (+ / - /neutral)



Negative



Negative



Sensitivity



High



Low



Receptor

importance or

value



High



Medium



Extent of change /

threshold

compliance



High



Low



Magnitude rating



MAJOR



LOW



Duration



Long term



Short term



Magnitude

description



Timeframe

description



Frequency



-



-



Timeframe rating



LONG TERM



SHORT TERM



SMALL



SMALL



Scale

CONSEQUENCE RATING



HIGH



LOW



PROBABILITY RATING



DEFINITE



POSSIBLE



SIGNIFICANCE RATING



HIGH (-ve)



LOW (-ve)



Reversibility/Sustainability



Reversible and potentially sustainable



Confidence



Medium



Mitigation measures





Implement measures under Impact RL1 relating to resettlement planning.







Provide safe crossing points across or around mine infrastructure where existing tracks are

affected.







Liaise with the affected communities to determine alternate routes around mine area that

cannot be crossed.







Maintain the selected bypass roads in the vicinity of the mine operations for the duration of the

life of the operation.







At closure, liaise with communities to determine if previous routes should be restored.



8.2.3



RL3: Added pressure on limited host community resources potentially

resulting in food insecurity and malnutrition

Construction



Operation



Decommissioning



Post-Closure



The communities at the host site may experience added pressure on land and natural

resources due to the increase in population on account of relocation of Project affected

people. To mitigate this potential impact the resettlement plan would assess the host site in

terms of potential shortage of food resources, increased pressure on social infrastructure and

other community resources that can lead to impoverishment in the host community.

The host community may also experience positive impacts from influx of resettled people for

instance local businesses may increase their customer base.

The scale, intensity and nature of impacts (both positive and negative) will depend on the

characteristics of the host site in terms of its impact bearing capacity and ability to



U3823_Marampa_ESIS_Final.docx



September 2012

Page 178 of 298



SRK Consulting



Marampa Iron Ore Project ESIS – Main Report



accommodate population influx. Other determining aspects could be the number of host sites

chosen, magnitude of population to be resettled at each site, all of which have not currently

been identified. It is therefore not feasible to further describe and evaluate this impact at this

stage. Impacts on the host site will be assessed and appropriate management measures

designed as part of the RAP process.



8.3



Social order

The Project is expected to create changes in the existing social systems and practices. One

of the main potential impacts on the existing social order may be is the sudden increase in

population caused by arrival of Project workers and speculative job seekers driven by direct

and indirect employment and business opportunities. The inflow of workers (and associated

migration) is expected to start and peak in the construction phase with the start of

construction activities. The influx of job seekers during operations is expected to slow down.

The potential impacts and risks associated with increase in population are further described in

Sections 8.3.1 and 8.3.2. By identifying and understanding these changes the Project would

have the opportunity to mitigate the negative impacts on affected communities.



8.3.1



SO1: Influx of job seekers causing increased pressure on government services

and infrastructure, potentially resulting in reduced standard of living

Construction



Operation



Decommissioning



Post-Closure



The economic opportunities created by the Project are expected to lead to an influx of

workers and job seekers. With the ongoing development of the London Mining Project in the

immediate vicinity, some in-migration has already taken place. With the start of the Project,

Lunsar town and surrounding areas could potentially be perceived as employment hotspots

increasing further in-migration. This has been observed as a phenomenon at recent Projects

in rural Sierra Leone (for instance AML’s Tonkolili Iron Ore Project).

Currently the local communities perceive in-migration and growth of human settlements as a

positive indicator because it represents growth in the consumer base. In the long term

however, the increase in population due to in-migration can exacerbate secondary impacts,

contributing to deterioration in standard of living. These include;





pressure on local social infrastructure;







pressure on natural resources (which are already rapidly depleting);







increase in the cost of living; and







encroachment on the limited Project related opportunities for unskilled labour by

immigrants leading to resentment among the local community members (this aspect is

further discussed under Impact SO3).



All the above factors can cause a build-up of resentment among the community ultimately

manifesting as conflict.

The Project cannot keep people from moving into the area. However, indirect measures to

pre-empt and discourage the flow of migrants into the area can be employed. A preferential

local recruitment and procurement policy may discourage potential in-migrants from moving

into the area. Nevertheless some in-migration will still take place and will add pressure on

existing resources. The Project could provide support to the government to build additional

infrastructure, as well as to local NGOs to deal with any potential social issues emanating

U3823_Marampa_ESIS_Final.docx



September 2012

Page 179 of 298



SRK Consulting



Marampa Iron Ore Project ESIS – Main Report



from increases in population (Impact SO2).

Population influx is an indirect impact and the Project has limited control on the outcome of

mitigation measures, hence the confidence in residual impacts ratings is medium.

Impact SO1: Influx of job seekers causing increased pressure on government services and

infrastructure, potentially resulting in reduced standard of living

Impact characteristics



Initial impact



Residual or optimised impact

(taking cognisance of management

measures)



Type (+ / - /neutral)



Negative



Negative



Sensitivity



Medium



Medium



Receptor

importance or

value



Medium



Medium



Extent of change /

threshold

compliance



Medium



Low



Magnitude rating



MODERATE



MINOR



Duration



Long term



Medium term



Frequency



-



-



Timeframe rating



Magnitude

description



Timeframe

description



LONG TERM



MEDIUM TERM



Scale



SMALL



SMALL



CONSEQUENCE RATING



MEDIUM



LOW



PROBABILITY RATING



DEFINITE



POSSIBLE



SIGNIFICANCE RATING



MEDIUM (-ve)



LOW (-ve)



Reversibility



Partially reversible



Confidence



Medium



Mitigation measures





Encourage local recruitment and procurement (see Impact ED1 and ED4).







Encourage local communities to use the grievance procedure for resolving their concerns.



Good practice measures:





8.3.2



Facilitate joint planning with other industries, local government, Paramount Chief and

other stakeholders to minimise speculative migration.



SO2: Increase in social ills/problems

Construction



Operation



Decommissioning



Post-Closure



The presence of Project workers (including expatriates and workers from other parts of Sierra

Leone) and influx of speculative job seekers (predominantly single males) may result in an

increase in the following social ills typically seen in other mining Projects in developing

countries:





increases in crime such as theft and robbery due to income and economic disparity

between mine workers and others;







increases in alcohol and drug abuse, which is sometimes associated with an increase in

violence;



U3823_Marampa_ESIS_Final.docx



September 2012

Page 180 of 298



SRK Consulting



Marampa Iron Ore Project ESIS – Main Report







increases in prostitution and promiscuous sexual activities due to presence of single

males with disposable incomes (as a consequence, a potential increase in

communicable diseases (including TB, HIV and other STDs) among the local population

and Project workers (Impact SR2); and







erosion of traditional cultural values.







To prevent or mitigate the above problems the Project will:







aim to prevent economic disparity by maximising local people’s participation in the

Project workforce and provide access to other benefits implemented through community

development programmes (through measures under Impact ED1); and







support education and awareness programmes for workers and community members

that would cover topics such as: life skills for responsible use of increased incomes;

prevention measure against communicable diseases; cultural sensitivity for expatriates

and visitors; and conflict management for local leaders.



If not managed the impacts would start manifesting in the construction phase and continue

beyond the Project life. With a combination of the mitigation measures listed above the extent

and duration of the impacts can be reduced as shown in the ratings table. However the

ratings after mitigation are made with medium confidence, since it is difficult to make firm

predictions about behavioural change as a result of information campaigns.

Impact SO2: Increase in social ills/problems

Impact characteristics



Initial impact



Residual or optimised impact

(taking cognisance of management

measures)



Type (+ / - /neutral)



Magnitude

description



Timeframe

description



Negative



Negative



Sensitivity



High



Medium



Receptor

importance or

value



High



Medium



Extent of change /

threshold

compliance



Moderate



Low



Magnitude rating



MODERATE



MINOR



Duration



Long term



Medium term



Frequency



-



-



Timeframe rating



LONG TERM



MEDIUM TERM



Scale



SMALL



SMALL



CONSEQUENCE RATING



MEDIUM



LOW



PROBABILITY RATING



DEFINITE



POSSIBLE



SIGNIFICANCE RATING



MEDIUM (-ve)



Confidence



LOW (-ve)

Partially reversible



Reversibility



Medium



U3823_Marampa_ESIS_Final.docx



September 2012

Page 181 of 298



SRK Consulting



Marampa Iron Ore Project ESIS – Main Report



Mitigation measures





Undertake awareness and educational campaigns (directly or through existing institutions) for

prevention of social ills.







Provide employees and visitors to the site with cultural awareness training.







Provide assistance to the local health department (and NGOs) to strengthen programmes for

control of communicable diseases.







Implement the management measures given under Impact SO1.



8.3.3



SO3: Real or perceived unequal distribution of Project benefits potentially

leading to social tension

Construction



Operation



Decommissioning



Post-Closure



Some discontent due to perceived unequal distribution of jobs, development aid benefits and

unfulfilled expectations been raised by areas of the community. Further tensions may arise in

the local community as the Project moves into the implementation phase. Some of the

specific triggers for such tension are likely to be:





real or perceived unfair compensation for land and assets (tangible and non-tangible);







real or perceived unfair recruitment policy and/or practices;







encroachment by outsiders/in-migrants depriving the local workers and affected people

of job opportunities;







potential corruption of local leaders and Project staff influencing recruitment;







real or perceived unfair procurement and supply practices;







real or perceived unfair access to the Project’s social development Projects; and







increased economic disparities between those with jobs and those without.



Mitigation of the potential impacts will include:





management of people’s expectations and perceptions during the resettlement through

effective implementation of the RAP focused consultation meetings;







an appropriate and transparent grievance mechanism; and







a local employment policy and transparent recruitment strategy.



Without mitigation measures it is expected that the frequency of unresolved complaints would

be high, this can be brought down to low frequency by an active grievance mechanism and

effective implementation of the measures for maximising the participation of locals in the jobs

(Impact ED1) and decreasing the in-migration (Impact SO1) which would further minimise

grievances and conflicts. Overall the mitigation measures also aim to reduce the extent and

severity of the impacts, the majority of which are reversible if managed diligently.



U3823_Marampa_ESIS_Final.docx



September 2012

Page 182 of 298



SRK Consulting



Marampa Iron Ore Project ESIS – Main Report



Impact SO3: Real or perceived unequal distribution of Project benefits potentially leading to

social tension

Impact characteristics



Initial impact



Residual or optimised impact

(taking cognisance of management

measures)



Type (+ / - /neutral)



Magnitude

description



Timeframe

description



Negative



Negative



Sensitivity



High



High



Receptor

importance or

value



High



High



Extent of change /

threshold

compliance



High



Moderate



Magnitude rating



HIGH



MODERATE



Duration



-



-



Frequency



High frequency



Low frequency



Timeframe rating



HIGH



LOW



Scale



SMALL



SMALL



CONSEQUENCE RATING



HIGH



MEDIUM



PROBABILITY RATING



DEFINITE



POSSIBLE



SIGNIFICANCE RATING



HIGH (-ve)



MEDIUM (-ve)



Reversibility



Reversible



Confidence



High



Mitigation measures





Maintain transparency in the recruitment process.







Maintain regular communication with local communities and other stakeholders to minimise

tensions.







Maintain and monitor grievance mechanism for timely resolution of community grievances.







Implement measures under Impacts SO1, ED1 and ED4 to minimise population influx.



8.4



Archaeology and cultural heritage



8.4.1



AC1: Possible disturbance to sacred bushes and cemeteries leading to loss of

community’s access to cultural resources

Construction



Operation



Decommissioning



Post-Closure



Acquisition of land, for the Project resulting in relocation of 10 villages, will cause the loss of

access to sacred bushes and burial grounds, which play an important role in the cultural life of

the local population. Loss of access to and potential destruction of the sacred bushes may

negatively impact on people’s emotional wellbeing.

To mitigate the impact, the sacred bushes and burial grounds will require relocation near

resettlement site(s). The cultural specialist study (Section 6.13) indicates local people feel it is

acceptable to relocate and restore the sacred bushes and cemeteries as long as the right

procedures are followed. The relocation process will be part of the RAP and will be preceded

by sufficient formal consultation with sacred society members (both male and female) on the

rituals needed for transfer of sacred qualities to the relocation site, and the botanical

requirements for selection of the new sacred bush sites. The exact numbers of sacred bushes

U3823_Marampa_ESIS_Final.docx



September 2012

Page 183 of 298



SRK Consulting



Marampa Iron Ore Project ESIS – Main Report



and cemeteries will be estimated as part of the census conducted during the resettlement

planning process.

There is evidence of the presence of archaeological remains of ancestral villages in the area.

However the reconnaissance study does not provide any evidence of the presence of sites of

sufficient importance as to merit preservation. Nevertheless a chance find procedure will be

put in place for the areas disturbed by construction activities. Additional management

recommendations may be identified through the RAP process.

If mitigation measures are implemented the severity and duration of the impact on cultural

sites will be significantly reduced. However there is no guarantee that the new sacred sites

will fully replace the historically spiritual value of the original sites hence the impact is only

partially reversible.

Impact AC1: Possible disturbance to sacred bushes and cemeteries leading to loss of

community’s access to cultural resources

Impact characteristics



Initial impact



Residual or optimised impact

(taking cognisance of management

measures)



Type (+ / - /neutral)



Magnitude

description



Timeframe

description



Negative



Negative



Sensitivity



High



Medium



Receptor

importance or

value



High



Medium



Extent of change /

threshold

compliance



Major



Low



Magnitude rating



MAJOR



MODERATE



Duration



Long term



Short term



Frequency



-



-



Timeframe rating



LONG TERM



SHORT TERM



Scale



SMALL



SMALL



CONSEQUENCE RATING



HIGH



LOW



PROBABILITY RATING



DEFINITE



POSSIBLE



SIGNIFICANCE RATING



HIGH (-ve)



LOW (-ve)



Reversibility



Partly Reversible



Confidence



High



Mitigation measures





Implement measures in Impact RL1 regarding protection of natural resources.







Record mythological stories associated with specific sacred sites as part of their relocation.



8.5



Decommissioning and closure

As the Project is likely to be a key contributor to the local economy (and to some degree

national economy) over a period of at least 15 years, its closure may cause economic decline

with impacts on the retrenched workers, the local society and the local economy.



U3823_Marampa_ESIS_Final.docx



September 2012

Page 184 of 298



SRK Consulting



8.5.1



Marampa Iron Ore Project ESIS – Main Report



DC1: Closure of the mine leading to economic decline

Construction



Operation



Decommissioning



Post-Closure



Closure of the mine will lead to loss of income for the workers (with accompanying decline in

their purchasing power), the secondary industries dependent on the mine and loss of revenue

for the government. The loss of business in the secondary and support industry will also lead

to further job losses and impact on the economy. Thus there is a correlation between loss of

income and economic slowdown, one exacerbating the other. As it is difficult to predict the

socio economic environment in which the mine closure will take place, the Project would start

planning for the closure phase three to five years in advance.

Other closure related impacts could include:





out-migration of skilled workers from the Project area leading to erosion of the local skills

and consumer base and impacting on the local business sector; and







psychological impacts on individuals manifesting in depression, apathy, helplessness

and a sense of inadequacy.



Closure of the mine will also result in a reduction in the revenue base of the government

leading to a reduction in the allocation of funds for provision of social infrastructure and

services with a corresponding deterioration in quality of life.

A more detailed assessment of potential impacts from the Project’s closure will be identified

during closure planning However key mitigation strategies are expected to include:





allocation of closure funds at least 3 years prior to closure of the Project;







retraining of retrenched workers;







sustainable livelihoods programme for the local community;







counselling support for community members and staff; and







handover of any suitable social infrastructure and services provided by the Project.



The mitigation measures of the closure plan aim at building the capacity of the community to

adapt to the changes caused by Project closure and to sustain some of the economic benefits

created by the Project. The confidence in assessing the impacts, mitigation measures and the

residual impact is medium due to the premature nature of the assessment.

Impact DC1: Closure of mine leading to economic decline

Impact characteristics



Initial impact



Residual or optimised impact

(taking cognisance of management

measures)



Type (+ / - /neutral)



Magnitude

description



Timeframe

description



Negative



Negative



Sensitivity



High



High



Receptor

importance or

value



High



High



Extent of change /

threshold

compliance



Major



Moderate



Magnitude rating



MAJOR



MAJOR



Duration



Long term



Short to medium term



Frequency



-



-



Timeframe rating



LONG TERM



SHORT TO MEDIUM TERM



U3823_Marampa_ESIS_Final.docx



September 2012

Page 185 of 298



SRK Consulting



Marampa Iron Ore Project ESIS – Main Report



Impact DC1: Closure of mine leading to economic decline

Scale



SMALL



SMALL



CONSEQUENCE RATING



HIGH



MEDIUM



PROBABILITY RATING



DEFINITE



POSSIBLE



SIGNIFICANCE RATING



HIGH (-ve)



MEDIUM (-ve)



Reversibility



Partly Reversible



Confidence



Medium



Mitigation measures





Conduct an independent social impact assessment prior to closure.







Develop a social closure plan including the following:

o

design and implement a retrenchment policy and strategy in consultation with workers

and other stakeholders; and

plan for post-Project sustainability of community development activities.



o





Allocate funds (in advance) for implementation of the social closure plan.







Re-train workers for increasing their chances for re-employment elsewhere after Project

closure.







Conduct stakeholder consultations on closure issues as part of the ongoing stakeholder

engagement process.



Good practice measures:





Consider re-training of staff (voluntary training after hours) so they build skills to work in

other sectors following closure of the mine.







Promote and support building the capacity of local suppliers to diversify their customer

base and move beyond the Project area.



U3823_Marampa_ESIS_Final.docx



September 2012

Page 186 of 298



SRK Consulting



9



Marampa Iron Ore Project ESIS – Main Report



COMMUNITY HEALTH, SAFETY AND SECURITY IMPACT

ASSESSMENT

This section covers health, safety and security impacts on communities as a result of the

Project, and includes “nuisance” impacts as well as health impacts and safety/security issues

posing a physical risk of injury, if not fatality, to the public (and in some cases also livestock

and wildlife).

Nuisance impacts include those that do not result in direct and proven consequences to

human health, but are nonetheless generally considered to be unpleasant (such as small

increases in ambient noise or unpleasant odours). Health impacts in contrast could potentially

cause harm to human health and include air quality issues and exposure to communicable

diseases.

Security impacts can include matters arising from conflict between communities and also

those arising from the use of security at the mine.

Usually safety issues or hazards would occur on an infrequent basis, as a result of an

accident or unexpected event. Unexpected events that may lead to health and safety risks for

local communities include:





Road accidents;







Engineering structural failure;







Accidental spillage of hazardous or toxic materials;







Uncontrolled fires;







Fly rock due to blasting; and







Human error.



The most significant Project hazards are discussed in more detail under Section 9.5.

Because of the number of variables affecting the consequence and probability of such events,

accurate significance rating of possible impacts should the risk materialise is not possible.

Significance ratings have therefore been provided for impacts only (Sections 9.1 to 9.4), and

not for hazards. Explanatory notes on the description and rating of the impacts are provided in

the introductory text in Section 7.

Impacts on villages that are proposed to be relocated due to positioning of Project

infrastructure (as listed in Section 8.2) have not been assessed. The impact ratings provided

therefore apply only to those villages that will not be relocated. Each event must be evaluated

on an individual basis, in accordance with the Company’s standard event reporting system.

For the purposes of this assessment it is assumed health, safety and security risks to

employees of the Project, both during construction and operations, will be addressed through

an occupational health and safety plan, and are therefore not included in the discussion

below. The Project developers will also prepare an Emergency Preparedness, Response and

Recovery Plan (EPR&R) to identify and prevent potential emergency situations, plan

responses and recovery from emergency events (Section 11.6).



U3823_Marampa_ESIS_Final.docx



September 2012

Page 187 of 298



SRK Consulting



Marampa Iron Ore Project ESIS – Main Report



Table 9-1: Summary of evaluated community health and safety impacts or risks

Impact groups



Impact headings



Air quality









Noise and vibration









Traffic safety



Security/Social risks



Other hazards

potentially resulting

in injury



















9.1



AQ1: Dust emissions causing nuisance and health impacts on local communities

NV1: Blasting causing air overpressure and vibrations, resulting in disturbance of

local communities

NV2: Operation of mining equipment and vehicles resulting in increase in

background noise levels for local communities

TS1: Increase in Project-related traffic on local and national roads causing increased

wear and tear and risk of road accidents

TS2: Use of mine site roads by local communities causing increased safety risks due

to road accidents

SR1: Risk of human rights abuses due to conflict with communities

SR2: Increased exposure to communicable diseases due to an influx of workers,

resulting in a deterioration in public health

OH1: Blasting, resulting in fly rock

OH2: Community exposure to toxic or hazardous substances

OH3: Fire or explosions due to storage of explosives and use of combustible

materials

OH4: Failure of the TSF



Air quality

As in the case of water resources, impacts on air quality are traditionally assessed in

environmental impact assessments, although the air itself is not the receptor but merely the

pathway by which the source of the impact would reach the receptor (in this case humans

breathing in the air). Impacts on air quality are considered and assessed in this report, and

are interpreted in terms of the relevant international guidelines considered appropriate by the

specialist, in conjunction with consideration of the potentially affected receptors. The focus of

this impact assessment is on public health issues potentially resulting from Project-related

releases to the air. Therefore, with the exception of the accommodation camp, ambient air

quality inside the mine footprint area has not been included in this assessment. The health of

workers inside the mine site boundary is regulated by Sierra Leone and international

occupational health and safety standards and guidelines.

Air pollutant emissions take place in particulate and gaseous forms. Gaseous pollutants

emitted by the Project are mainly sulfur oxides (SOx) and nitrogen oxides (NOx). Lesser

pollutant emissions may include carbon monoxide, volatile organic compounds and unburned

hydrocarbons. Particulate matter (PM) refers to airborne particles, and includes dust, smoke

and soot. PM is defined by size, with coarse particles being between 2.5-10 microns, fine

particles less than 2.5 microns, and ultrafine particles less than 0.1 microns in aerodynamic

diameter. PM below 10 µm (PM10) is referred to as inhalable particulates, and also includes

the PM2.5 fine particulates.

Based on the Project as described in Chapter 4, dust (PM10, PM2.5 and dust fallout) is

considered to be the main potential pollutant of concern and has therefore been assessed in

this study. While gases such as SO2 and NO2 have also been identified as potential

pollutants, they are considered to be minor pollutants that are unlikely to have a major impact

on the Project environment. Dispersion of these gasses therefore has not been modelled, and

impacts relating to them have not been assessed.

PM may have adverse effects on humans such as respiratory illnesses (asthma and

bronchitis) or cardiovascular diseases. PM2.5 can be breathed deep into the lungs, and

therefore presents higher health risks. PM can also affect vegetation in two ways, namely, by

inhibiting the plant’s photosynthetic properties by coating the leaves thereby blocking light



U3823_Marampa_ESIS_Final.docx



September 2012

Page 188 of 298



SRK Consulting



Marampa Iron Ore Project ESIS – Main Report



penetration. Secondly, from the deposition onto soils of various metals in the particulate

matter which are absorbed by vegetation thereby hindering plant growth. The uptake of

metals by plants has the potential to contaminate vegetables and fruit that may be consumed

by humans and animals. Impacts on vegetation are discussed under impact LT4 however and

are not included in the impact assessment below. Disturbance of wildlife resulting from dust

generation is rated under impact EB3 (Section 7.3.4). Increased dust emissions in the area of

unpaved roads (such as haul roads) will reduce visibility for drivers and pedestrians on these

roads, contributing to traffic safety risks, which are discussed and rated in impact TS2

(Section 9.3.2).

PM2.5 can be generated both as a primary and secondary pollutant. Primary pollutants are

those directly emitted into the atmosphere, for example power generation and mobile

equipment generate PM2.5 as a result of combustion processes. Secondary pollutants form

through physico-chemical reactions such as phase change, adsorption on solids, chemical

reactions etc. PM2.5 has extended atmospheric residence times (days to weeks) and

therefore can be transported long-ranges (100’s to 1,000’s km). In contrast, the coarse

particulates have short residence times (minutes to hours) and are removed within short

ranges (1 to 10’s km) via dry deposition.



9.1.1



AQ1: Dust emissions causing nuisance and health impacts on local

communities



Construction



Operation



Decommissioning



Post-Closure



Potential sources of dust resulting from the Project include the following:





Drilling and blasting;







Fugitive dust from grading, mining and waste material handling and storage;







Wind erosion of areas disturbed or cleared during construction and decommissioning;







Wind erosion of tailings material; and







Road dust caused by vehicle movement on unpaved roads (vehicle entrainment).



Materials handling, wind erosion (e.g. from the TSF and waste rock dumps) and vehicleentrainment of dust from unpaved roadways are expected to be the main sources of dust in

the area during operation of the mine.

Changes to air quality resulting from the Project and compliance with the relevant ambient air

quality standards and guidelines were assessed and modelled by specialists from SRK (SA)

using dispersion modelling software. Predicted maximum daily and annual average

concentrations for PM10, PM2.5, and TSP were simulated using the US-EPA approved

AERMOD (AMS/EPA Regulatory Model) model.

Worst case predicted concentrations of PM10, PM2.5 and TSP resulting from the operation of

the mine were then determined and mapped (via concentration contours or isopleths) for the

17

surrounding area, and compared against the World Bank (WB) IFC guidelines , the US EPA

standards for ambient air quality and the South African National Standards (SANS 1929:2005)

for dust deposition. Dust deposition is a measure of nuisance dust and exceedances of the

SANS 1929:2005 guideline levels suggests an increase in nuisance levels for the various

defined categories. The South African standard was selected for the impact assessment as it



17



As published in the Environmental, Health and Safety General Guidelines document of 2007



U3823_Marampa_ESIS_Final.docx



September 2012

Page 189 of 298



SRK Consulting



Marampa Iron Ore Project ESIS – Main Report



has been designed to accommodate areas close to mines. Further detail on these standards

and the modelling and assessment of impacts on air quality are provided in the Air Quality

Impact Assessment Report included in SD2 of Volume 3.

Source emissions

Source emission data modelling predicted the sources responsible for the highest dust

emissions after mitigation to be unpaved roads, followed by the tailings storage facility

(assuming one third dry beach) and the active operational areas of the waste rock facility. The

open pits were excluded as a potential dust source as they were confirmed (through

additional modelling for three different pit depths) to be an insignificant contributor to dust

emissions for the Project. This is due to the topography of the area, and the finding that dust

generated would remain within the pit and not rise above ground level. Crushing and grinding

were not included in the dispersion modelling as dust generation from these activities is

considered to be negligible. Similarly, drilling and blasting were also not included as they

would be non-routine and short-term activities. Construction, decommissioning and postclosure phase dust emissions also were not included as they are considered to make a minor

contribution to air emissions (due to their relatively short-term nature in the case of

decommissioning and construction phases).

Due to the highly seasonal nature of rainfall in the area (with approximately six months of the

year falling in the dry season), dust generation is also expected to follow a seasonal trend (as

the baseline monitoring results described in Section 5.7 have shown). Dust emissions

(predicted maximum daily and annual average concentrations for PM10, PM2.5, and TSP) were

modelled for two scenarios during mine operation, to predict the impact before and after the

implementation of management measures (such as wetting down or use of chemical dust

suppressants on unpaved roads).

It is noted that the scenarios model what can be considered worst case environmental

conditions in terms of dust generation (i.e. during the dry season, under windy conditions),

which in reality are likely to be relatively rare. A conservative approach was also taken with

regard to the predictions of average 24-hour concentrations – the highest average

concentration over the three-year simulation period has been used for the assessment. The

th

98 percentile values are reported for predicted PM10 concentrations, as per accepted

statistical methodology, to exclude anomalous concentrations.

Dispersion modelling results

Ambient ground level concentration isopleths for PM10 before and after successful

implementation of mitigation measures are shown in Figure 9.1 and Figure 9.2 and represent

interpolated values from the concentrations predicted by the AERMOD model. Similar

isopleths for PM2.5 and dust fallout concentrations are included in the Air Quality Impact

Assessment report (SRK, 2012), included in SD2 of Volume 3.

Predicted maximum concentrations of PM10, PM2.5 and dust fallout at local villages before

and after implementation of mitigation measures are shown in Table 9-2 with exceedances of

the relevant guideline levels highlighted. Villages that are planned to be relocated (due to

positioning of Project infrastructure) are highlighted in bold text, and have been excluded from

the impact assessment and rating. The results reveal a reduction in predicted dust emissions

by approximately 50% when management measures are implemented.

As expected, the maximum predicted dust (PM10, PM2.5 and dust fallout) concentrations are

predicted to occur around the mine activities and decrease with distance from these sources.

U3823_Marampa_ESIS_Final.docx



September 2012

Page 190 of 298



SRK Consulting



Marampa Iron Ore Project ESIS – Main Report



With management measures in place, PM10 emission concentrations resulting from the

Project are predicted to remain below 150 µg/m³ (the US EPA guideline level) at all local

villages except Mafuri and Royail Kalagba, both of which are scheduled for relocation, though

the more stringent World Bank guideline is exceeded for a number of locations (note that the

World Bank Guideline, which is based on World Health Organisation guidelines, also includes

interim guidelines which are less stringent). PM2.5 emission concentrations are predicted to

remain below 20 µg/m³ (the World Bank guideline level) at all villages except for Royail

Kalagba, and dust fallout concentrations are predicted to be below 300 mg/m2/day (the SANS

1929:2005 target level) at all villages except those scheduled for relocation, as well as Konta,

where a slight exceedance of the residential limit is predicted, and Magbafat, where the target

level may be exceeded.

Cumulative concentration was calculated by adding the maximum 24-hour baseline monitored

concentration at a point (as described in Section 5.7) to the maximum concentration (with

mitigation measures implemented) predicted to result from the operation of the Project. The

cumulative PM10 concentration at the MIOL site office is 117.1 µg/m³, and the PM2.5

concentration is 23 µg/m³, both of which fall above the World Bank/IFC guideline but below

the US EPA guideline levels. As PM concentration was not monitored at other locations in the

Project area, quantitative predictions of cumulative concentrations cannot be provided.

Predicted cumulative dust fallout concentrations were calculated for eight dust fallout

monitoring locations (see Air Quality Impact Assessment Report in SD2 of Volume 3 for

results). The SANS 1929:2005 target limit was exceeded at all monitored locations except the

MIOL site office in Lunsar. The residential limit was exceeded at Konta Bana, Matukia and

Mafuri, the latter two of which will be relocated, as well as Maso, where the industrial limit will

be exceeded. It is noted however that average daily monitored concentration at Konta Bana

already exceeds this limit, and the predicted additional contribution due to the mine is less

than 10%. At the Catholic School (in Lunsar), the relative contribution predicted to result from

the mine is also less than the baseline contribution by approximately 50%.



U3823_Marampa_ESIS_Final.docx



September 2012

Page 191 of 298



SRK Consulting



Figure 9.1: Maximum predicted 98

without management



Marampa Iron Ore Project ESIS – Main Report



th



percentile PM10 concentrations over the Project area,



U3823_Marampa_ESIS_Final.docx



September 2012

Page 192 of 298



SRK Consulting



Marampa Iron Ore Project ESIS – Main Report



th



Figure 9.2: Maximum predicted 98 percentile PM10 concentrations over the Project area, with

management

U3823_Marampa_ESIS_Final.docx



September 2012

Page 193 of 298



SRK Consulting



Marampa Iron Ore Project ESIS – Main Report



Cumulative concentrations are useful for providing an indication of the relative contributions of

baseline and predicted concentrations to ambient air quality, as well as for determining

ambient air quality as experienced by the receptor, regardless of the source. However, as

cumulative concentration is reliant on data obtained from monitoring at points on site, and

takes into account sources of dust other than the Project, the impact on air quality has been

assessed based on the predicted maximum concentrations at local villages rather than

cumulative concentrations.

The specialist report concluded that the dust dispersion results showed the TSF and WRD to

be well located with regard to air quality impacts, as the topography of the surrounding area

will reduce the likelihood of windblown dust from these sources affecting local villages. The

locations of the haul roads (predicted to be the main sources of dust) are also concluded to be

suitable provided mitigation measures are implemented to prevent vehicle entrainment of

dust.

Table 9-2: Predicted 24-hour dust concentrations at local villages



18



Predicted 24 hour concentrations

98th

Percentile

PM10

concentration (µg/m³)



Maximum

PM2.5

concentration (µg/m³)



Maximum Dust

concentration

2

(mg/m /day)



Before mgt



Post-mgt



Before mgt



Post-mgt



Before mgt



Post-mgt



Gbalan



226.4



113.0



29.9



8.6



477.9



228.4



Gbese



249.9



124.0



31.4



9.9



425.3



154.7



Konta



253.3



126.4



28.1



14.8



1229.4



614.4



Konta Bana



56.3



26.0



12.4



4.2



132.4



50.6



Konta Lol



56.5



27.6



12.8



4.5



119.0



51.5



Lunsar



129.5



63.3



20.4



7.0



212.3



91.1



Ma Sesay



290.3



143.4



43.7



5.4



5070.9



275.2



Mabesseneh



122.8



60.6



18.2



6.2



241.4



99.3



Mafira



98.3



48.5



13.7



4.2



356.1



77.7



Mafuri



334.5



166.9



46.1



5.1



534.0



309.0



Magbafat



261.5



129.3



36.7



16.6



1123.9



524.2



Magbungbu



64.0



31.1



13.3



4.4



4548.2



98.0



Makel



105.8



52.2



16.4



7.0



763.6



266.9



Makindo



294.5



146.1



36.8



9.4



440.3



179.8



Makump



178.1



86.9



24.1



10.9



510.6



248.9



Manonko



56.7



25.1



22.3



4.5



440.6



69.0



Masetle



173.8



86.1



23.7



7.9



275.7



121.3



Maso



211.6



102.8



31.3



3.8



4443.5



493.0



Matinkani



49.7



22.0



16.9



4.0



176.0



50.6



Matukia



84.7



40.2



14.5



5.3



213.0



91.3



Mayepeh



170.0



84.7



21.7



4.2



213.0



88.3



Mayoka



132.9



66.3



16.8



2.9



143.9



63.8



Village



18



fallout



Villages planned to be relocated due to positioning of Project infrastructure are indicated in bold text



U3823_Marampa_ESIS_Final.docx



September 2012

Page 194 of 298



SRK Consulting



Marampa Iron Ore Project ESIS – Main Report



Predicted 24 hour concentrations

98th

Percentile

PM10

concentration (µg/m³)



Maximum

PM2.5

concentration (µg/m³)



Maximum Dust

concentration

2

(mg/m /day)



Before mgt



Post-mgt



Before mgt



Post-mgt



Before mgt



Post-mgt



Molumpo Marampa



157.4



78.1



22.1



7.2



486.3



221.1



Monbaia



172.9



86.1



21.6



2.2



91.5



39.6



Rofunk



101.4



50.3



13.9



1.5



72.4



28.1



Rogbaneh



31.4



14.9



9.6



2.8



73.1



30.6



Rolal c/o Gafal



74.6



34.3



18.1



5.9



284.4



87.3



Rolal c/o Mafuri



182.9



91.3



22.9



2.1



118.4



44.6



Rosint c/o Mafuri



264.4



131.1



38.2



6.8



403.2



118.3



Royail Kalagba



539.8



268.2



64.3



31.1



3078.2



1533.4



Royema Marampa



105.1



48.3



20.5



7.7



779.6



133.3



Applicable

guideline



PM10 (µg/m³)



PM2.5 (µg/m³)



Dust fallout (mg/m /day)



>50



>25



Not specified



>150



>35



Not specified



Village



World Bank / IFC



19



US EPA



SANS 1929:2005



Not specified



fallout



2



300

(Target )



1,200

(Industrial)



600

(Residential)



2,400

(Alert)



The worst-case dust concentrations reported are highly conservative estimates, and the

actual concentrations generated will (under normal operating conditions) be much lower – this

has been considered in the assessment of signficance. Without management, the guideline

limits will be exceeded at most villages directly surrounding the Project site, resulting in

potential nuisance or health impacts on the inhabitants. However the management proposed

by MIOL should decrease the extent and likelihood of dust generation, so recommended limits

are likely to be met at almost all villages except those to be relocated (which have therefore

been excluded from the impact significance rating). The impact will continue until the site has

been rehabilitated post-closure, and will affect receptors within a radius of up to a few

kilometres.



19



The World Bank Standards are based on the World Health Organisation Air Quality Guidelines Global Update, 2005. As well

as the overall guideline of 50 for PM10, the guidelines include interim targets at 75, 100 and 150. For PM2.5 the interim targets

are 37.5, 50 and 75.



U3823_Marampa_ESIS_Final.docx



September 2012

Page 195 of 298



SRK Consulting



Marampa Iron Ore Project ESIS – Main Report



Impact AQ1: Dust emissions causing nuisance and health impacts on local communities

Impact characteristics



Initial impact



Residual or optimised impact

(taking cognisance of management

measures)



Type (+ / - /neutral)



Negative



Negative



Sensitivity



High



High



Receptor

importance or

value



High



High



Extent of change /

threshold

compliance



High



Moderate



Magnitude rating



MAJOR



MAJOR



Duration



Medium term



Medium term



Magnitude

description



Timeframe

description



Frequency



Low



Low



Timeframe rating



MEDIUM TERM



MEDIUM TERM



INTERMEDIATE



INTERMEDIATE



Spatial Scale

CONSEQUENCE RATING



MEDIUM



MEDIUM



PROBABILITY RATING



DEFINITE



UNLIKELY



SIGNIFICANCE RATING



MEDIUM (-ve)



LOW (-ve)



Reversibility



Partially reversible



Confidence



Medium



Management measures





Refer to the erosion control measures listed under Impact LT4.







Maintain or reduce vehicle speeds on unpaved roads to 40 km/hr, especially on roads passing

near villages.







Implement dust suppression measures in areas close to receptors, such as wetting, use of

chemical dust suppressant and / or paving, on roads with high vehicular activity (e.g. haul

roads).







Control dust emissions on ore stockpiles through use of water spraying and/ or wind breaks.







Use dust suppression measures such as rock cladding or grassing, on the side walls of the

TSF and other exposed built up areas.







Minimise the dry beach area of the TSF and wet the TSF surface if monitoring results indicate

dust generation from this source.







Minimize lengths of access roads and eliminate unnecessary traffic.



Good practice measures:



9.2







Investigate and respond to any air quality complaints picked up by the Grievance

Mechanism.







Provide site workers with appropriate Personal Protective Equipment (PPE), and

implement standard international occupational health and safety procedures.







Limit vehicle idling and keep vehicles well maintained.



Noise and vibrations

An assessment of the noise and vibrations predicted to result from the Project was

undertaken by Eddie Jewell Acoustics, using diurnal and nocturnal baseline noise monitoring



U3823_Marampa_ESIS_Final.docx



September 2012

Page 196 of 298



SRK Consulting



Marampa Iron Ore Project ESIS – Main Report



data collected at four villages in the Project area by a noise expert from SRK (Turkey).

Meteorological data for the Project area was obtained from an automated weather station at

the MIOL office Lunsar, as described in Section 5.8. The methodology used and findings of

the baseline noise study are summarised in Section 5.8, and full copies of the baseline and

the impact assessment reports are included in SD3 of Volume 3.

Potential sources of noise and vibrations resulting from the Project include the following:





Mining equipment







Construction equipment (also used during decommissioning)







Processing equipment







Materials handling







Drilling and blasting







Pumps (e.g. for water supply)







Power generation equipment (HFO generators)







Vehicle related noise and vibrations (construction and operation)



Although the primary receptors for noise and vibrations will be staff working at the mine, this is

an occupational health and safety issue and therefore has not been included in the impact

assessment. The use of the appropriate Personal Protective Equipment (PPE) by mine site

workers is however recommended. The identified receptors for the purposes of the impact

assessment are therefore the local villages in the Project area.

In the absence of applicable guidelines or standards specific to Sierra Leone, the assessment

of impacts on these villages has been made in accordance with the following references and

standards, which are internationally accepted and used:





The IFC Environmental, Health and Safety Guidelines – Section 1.7: Noise;







Australian Standard (AS) 2187:2-2006 Explosives – Storage and use – Part 2: Use of

explosives;







ISO9613-2:1996 Acoustics – Attenuation of sound during propagation outdoors – Part 2:

General method of calculation.



Where the degree of Project detail required for accurate prediction of impacts has not been

available, reasonable assumptions have been made (particularly with regard to blasting),

which may result in overly conservative assessment of potential noise impacts. It is noted also

that a number of villages will be relocated due to positioning of the Project infrastructure. As

expected, given their close proximity to the impact sources, these villages would be the most

severely impacted by noise and vibrations, as reported in the Noise Impact Assessment

report (Eddie Jewell Acoustics, 2012) in SD3 of Volume 3. However, as they will be relocated,

impacts on these villages have not been included in the assessment.



9.2.1



NV1: Blasting causing air overpressure and vibrations, potentially resulting in

disturbance of local communities

Construction



Operation



Decommissioning



Post-Closure



Blasting for construction (earth works) and operations (mining) results in noise, air

overpressure (transient air transmitted sound pressure waves moving outwards from an

exploding charge) and vibrations that cannot be confined to the site, and may be experienced

over large areas. As blasting is an occasional activity it does not affect the ambient noise

limits evaluated, but can be disturbing to local communities with short-term noise exceeding

U3823_Marampa_ESIS_Final.docx



September 2012

Page 197 of 298



SRK Consulting



Marampa Iron Ore Project ESIS – Main Report



10 dB(A). Although each incident is short term in nature, the repetitiveness of the impact may

give rise to complaints if not managed sensitively. The subjective reaction to a single

disturbing event will depend on the activities being undertaken by the receptor and the

manner in which the programme for blasting events is communicated to identified receptors.

For example, a large blasting event at night time may give rise to complaints, where at any

other time it would be accepted.

The Australian Standard, AS 2187:2-2006, sets limits for ground vibration and air

overpressure from blasting activities, separating them into two categories; those causing

human discomfort and those with the potential for causing damage to structures. For the

purposes of this assessment, criteria relating ground vibration and air overpressure which

causes human discomfort have been used, as these levels are generally less than those likely

to cause damage to structures. Apart from the villages that are to be relocated, it is also

considered unlikely that there are substantive buildings or structures close to the mine site.

Impacts on structures in the area resulting from blasting for the Project are therefore

considered to be insignificant. These criteria specify a peak particle velocity (PPV) of 5 mm/s

for 95% of blasts, and air overpressure not exceeding 115 dBL for 95% of blasts. AS 2187:22006 cautions however that air overpressure and vibrations within these levels may still be

noticeable, but are likely to be tolerated. As such, the impacts on local inhabitants are

expected to be related specifically to annoyance (and therefore complaints) rather than

detrimental health impacts. Disturbance of wildlife and domestic animals resulting from

blasting are assessed in Impact EB3.

The level of ground vibration is measured by the Peak Particle Velocity (PPV) and is directly

related to the size of the blast and the distance from the blast - the closer to the blast the

greater the vibration. Human sensitivity to vibration varies significantly between individuals,

though a person will generally become aware of blast induced vibration at PPV levels of

around 0.15 mm/s. Individuals have been found to be poor at distinguishing between

vibrations of differing magnitudes. Air overpressure is reported as decibels (linear) or dBL, as

opposed to sound pressure level, which is reported as decibels (dB) a logarithmic unit.

At the time of writing, specific details regarding the proposed blasting regime required to

accurately calculate air overpressure and ground vibration are not available. As such, an

indicative assessment of the maximum permissible mass charge per delay at each of the

mine pits was undertaken (see Impact Assessment Report in SD3 of Volume 3 for results),

making reasonable assumptions, and refinement of the predictions is recommended once the

required detail is available. It should be noted that the nearest noise sensitive receptors

selected as part of the assessment for each pit exclude the villages proposed for relocation.

Based on the calculated maximum permissible mass charge per day, air overpressure and

ground vibration could be determined for the villages surrounding each pit, and assessed

against the AS 2187:2-2006 limits.

The assessment concluded that the ground vibration and air overpressure at local villages

(except those to be relocated) will not exceed the AS 2187:2-2006 criteria when the maximum

permissible mass charge per delays, detailed in the Impact Assessment Report (SD3 in

Volume 3), are adhered to.

Blasting disturbances will occur throughout operation and during daytime only, and at a lower

level during construction, and are not reversible. However, the degree of annoyance may

decrease over time as people become accustomed to the blasting. Although the effects of

blasting will extend to villages outside the direct Project footprint (i.e. those that will not be

U3823_Marampa_ESIS_Final.docx



September 2012

Page 198 of 298



SRK Consulting



Marampa Iron Ore Project ESIS – Main Report



relocated), these are unlikely to constitute a negative impact on residents of these villages, as

demonstrated by the air overpressure and ground vibration levels predicted (see the Impact

Assessment Report in SD3 of Volume 3). Due to the low significance of the impact, no

management measures are proposed, but a number of good practice measures are

recommended. It is noted however that as Project-specific detail was not available at the time

of the assessment, confidence in the prediction is low and more detailed assessment is

recommended to confirm the results reported, prior to actual blasting.

Impact NV1: Blasting causing air overpressure and vibrations, potentially resulting in

disturbance of local communities

Impact characteristics



Initial impact



Residual or optimised impact

(taking cognisance of management

measures)



Type (+ / - /neutral)



Negative



-



Sensitivity



Medium



-



Receptor

importance or

value



Medium



-



Extent of change /

threshold

compliance



Medium



-



Magnitude rating



MODERATE



-



Duration



Medium term



-



Frequency



Medium



-



Magnitude

description



Timeframe

description



MEDIUM TERM



-



Spatial Scale



Timeframe rating



INTERMEDIATE



-



CONSEQUENCE RATING



MEDIUM



-



PROBABILITY RATING



UNLIKELY



-



SIGNIFICANCE RATING



LOW (-ve)



-



Reversibility / sustainability



Irreversible



-



Confidence



Low



-



Good practice procedures:





Re-assess impacts once detail regarding blasting regime is available.







Monitor initial blasting to ensure compliance with specified air overpressure and vibration

criteria.







Schedule blasting outside of hours when people are most disturbed by noise (such as at

night).







Inform local communities of blasting timetable in advance and provide adequate notice of

when blasts are required outside of the planned schedule.







Maintain records of each blast (including location of blast holes, design, measured

overpressure and vibration)



U3823_Marampa_ESIS_Final.docx



September 2012

Page 199 of 298



SRK Consulting



9.2.2



Marampa Iron Ore Project ESIS – Main Report



NV2: Operation of mining equipment and vehicles potentially resulting in

increase in background noise levels for local communities

Construction



Operation



Decommissioning



Post-Closure



The increase in ambient noise levels resulting from operation of vehicles and mining

equipment could cause disturbance to sensitive receptors (villages in the Project area). As the

increase in ambient noise levels during construction and decommissioning is expected to be

less than that for operations (due to significantly lower levels of mobile equipment activity), the

impact predictions were not conducted for these phases. The most significant sources of

noise during operation will be mining equipment, vehicles, and blasting. The pits, primary

crushers and waste rock dumps are areas expected to contribute the most to noise impacts.

Noise impacts on the inhabitants of local villages have been assessed qualitatively via

predictive modelling of the increase in ambient noise levels expected to result from the abovementioned Project-relates sources, for mining rates of 45 to 100 Mtpa (i.e. up to the maximum

proposed rate). As noise generation is directly dependent on mining rate, with lower mining

rates resulting in lower noise impacts, only results relating to mining at a rate of 100 Mtpa are

included in this impact assessment.

Brüel & Kjær Predictor environmental noise prediction software was used for the modelling,

taking into account factors that may influence noise attenuation such as geometrical

divergence (which includes distance), atmospheric conditions, topography, weather conditions

and screening (incorporating pit depth). A conservative approach was adopted in the

characterisation of these factors, as well as certain assumptions regarding operation (such as

that all pits will be mined, and all machinery will be operated, simultaneously), resulting in

what may be considered a worst case scenario with regard to the increase in ambient noise.

Noise contour maps (shown in Figure 9.3 and Figure 9.4) were created to show the

distribution and magnitude of potential noise impacts over the Project area, relative to local

villages and the mine infrastructure. The predictions are reported to be accurate to ±3 dB for

distances up to 1000 m from the source.

The predicted A-weighted broadband sound pressure levels (LAeq) at local villages during

daytime and night time were assessed relative to the IFC noise guideline levels. According to

these guidelines, a noise source should not result in a maximum increase in background

noise levels of 3 dB, and noise emissions from the proposed mine should be equal to or less

than the existing ambient noise level, at the nearest noise sensitive receptor, up to the criteria

stated. These criteria, outlined in WHO Guidelines for Community Noise (1999), which have

been derived based on research on health impacts resulting from noise emissions, specify a

LAeq of up to 55 dB during the day or 45 dB at night in residential, institutional or educational

areas (the appropriate category for the local villages).

Noise impacts on local communities are usually experienced as an annoyance, especially

when they occur during the night, when they may disturb sleep, resulting in stress and other

related health impacts. The increase in ambient noise can be expected to be experienced by

local communities as follows:





increase of 3 dB(A): a person with average hearing will just be able to detect this;







increase of 5 dB(A): community reaction to the increase in noise may be expected;







increase of 10 dB(A): corresponds to doubling of the subjective loudness of noise and

community would consider this ‘disturbing’.



U3823_Marampa_ESIS_Final.docx



September 2012

Page 200 of 298



SRK Consulting



Marampa Iron Ore Project ESIS – Main Report



Figure 9.3: Noise contour map at day time for 100 Mtpa mining rate, relative to local villages



U3823_Marampa_ESIS_Final.docx



September 2012

Page 201 of 298



SRK Consulting



Marampa Iron Ore Project ESIS – Main Report



Figure 9.4: Noise contour map at night time for 100 Mtpa mining rate, relative to local villages



Impacts on mine workers are not included in this impact assessment. However, the close

proximity of workers to noise emission sources could lead to exposure above threshold levels

for health and safety for periods which are longer than recommended, potentially resulting in

direct health impacts through impairment of hearing. Therefore, mine workers should be

U3823_Marampa_ESIS_Final.docx



September 2012

Page 202 of 298



SRK Consulting



Marampa Iron Ore Project ESIS – Main Report



provided with suitable PPE in the form of ear protection (plugs, muffs etc.,) based on the

nature of the emission sources (frequency, duration, etc.) to prevent long term degeneration

of hearing.

The noise impact predictions (as shown in Figure 9.3 and Figure 9.4) indicated that the day

and night time maximum noise level criteria (as per the IFC guidelines) will be met at all local

villages, except for a few that have already been identified for relocation (generally due to

proximity to the proposed pits or infrastructure). Of the villages proposed for relocation, night

time noise levels for Ma Sesay, Mafuri, Maso, Matukia, Rosint c/o Mafuri, Royail Kalagba and

Konta, and daytime noise levels for Ma Sesay, Mafuri, Maso and Matukia are predicted to

exceed the IFC noise guideline levels (by between 0.1 and 21.9 dB(A) – see Impact

Assessment Report in SD3 of Volume 3 for details).

This impact is not reversible but will cease post-closure. Due to uncertainties and

assumptions made regarding certain details of the Project description required for the impact

modeling, the confidence of the impact rating is rated as medium. Although no formal

management measures are required, it is recommended that good practice measures, as

outlined below, are adopted to ensure as minimal impact on the receptors as is practical.

Impact NV2: Operation of mining equipment and vehicles potentially resulting in increase in

background noise levels for local communities

Impact characteristics



Initial impact



Residual or optimised impact

(taking cognisance of management

measures)



Type (+ / - /neutral)



Negative



-



Sensitivity



Low



-



Receptor

importance or

value



Low



-



Extent of change /

threshold

compliance



Low



-



Magnitude rating



MINOR



-



Duration



Medium term



-



Frequency



-



-



Timeframe rating



MEDIUM TERM



-



Spatial Scale



INTERMEDIATE



-



CONSEQUENCE RATING



LOW



-



PROBABILITY RATING



POSSIBLE



-



SIGNIFICANCE RATING



LOW (-ve)



-



Reversibility / sustainability



Irreversible



-



Confidence



Medium



-



Magnitude

description



Timeframe

description



Good practice measures:





Maintain vehicles and equipment in accordance with manufacturer’s instructions to

minimise noise.







Avoid unnecessary revving of engines and switch off equipment when it is not required.



U3823_Marampa_ESIS_Final.docx



September 2012

Page 203 of 298



SRK Consulting



9.3



Marampa Iron Ore Project ESIS – Main Report







Start up vehicles and plant sequentially rather than simultaneously.







Fit vehicles with broadband reversing alarms.







Undertake standardised noise measurements on major items of equipment upon delivery

to provide a noise reference against which regular checks can be compared.







When plant equipment is due for replacement, the replacement equipment should have a

sound power level equal to or less than the plant that it is replacing.







Plan for operating times of noisy activities to be outside of hours when people are most

disturbed by increased noise levels (such as at night).







Promptly investigate and respond to any noise complaints picked up by the Grievance

Mechanism.







Routine noise monitoring should be carried out at the surrounding receptors, and records

thereof maintained.







Keep haul routes well maintained and avoid steep gradients.







Minimize the drop height for materials.



Traffic safety

The nature of the mining operation at this site, and the means of transportation of the

processed ore (rail only in Stage 1, and a combination of rail and slurry pipeline in Stage 2)

means that potential impacts from Project related traffic on local road networks will mainly be

concentrated in, and will peak during, the construction and decommissioning phases of the

mine. These are the periods when construction and infrastructure engineering traffic will have

most impact on the local public road network. Transportation of fuel supply to the mine will be

via road tankers, but as this will be managed by a third party it has been excluded from the

assessment of impacts in this ESIA. As most staff will either be housed on the mine site (at

the accommodation camp) or will be sourced locally from Lunsar or surrounding villages,

large volumes of traffic commuting daily to and from the site are not expected.

Impacts relating to traffic safety during the operational phase will primarily be associated with

mobile equipment travelling on mine site roads (such as haul roads), and contractor traffic

visiting the site, the day to day movements of site staff and freight and service vehicles on

local roads. Although the haul route for the loaded ore transportation trucks from the pits to

the beneficiation plant will cross the route of the Makeni highway at two points, this will be

affected by the construction of multi-plate arch culverts for the haul roads to pass under the

highway as described in Section 4.8.1. As a result, mine site traffic will not come into direct

conflict with highway traffic, and will not make use of local roads infrastructure during the

mine’s operation



9.3.1



TS1: Increase in Project-related traffic on local and national roads causing

increased wear and tear and risk of road accidents

Construction



Operation



Decommissioning



Post-Closure



Traffic volumes on local and national roads, such as the Makeni Highway (which connects

Lunsar to Freetown and therefore will be used by vehicles transporting goods and materials

from the port or capital to the mine site) will increase during construction, decommissioning

and operation of the mine. This could affect road safety for other road users through

increased wear and tear on the roads (as well as increasing vehicle maintenance costs) and

risk of road accidents. The impact of traffic associated with a mining site on local road safety

U3823_Marampa_ESIS_Final.docx



September 2012

Page 204 of 298



SRK Consulting



Marampa Iron Ore Project ESIS – Main Report



is generally a function of the following three factors:





The nature of the traffic generated by the mine (HGV’s, dump trucks, oversize loads,

freight vehicles, cars, light vans, etc.) and the frequency of movements of these;







The nature and density of the existing traffic and other road users on the roads affected

by the mine traffic; and







The condition and suitability of the roads to cope with the nature of the mine traffic.



In the case of this Project, the majority of the mine-related traffic will be limited to the mine’s

daily operation and servicing by various freight and light vehicles and its construction and

decommissioning (i.e. construction related traffic) as mentioned above. The operation of the

mine in terms of on-site transportation of crushed rock, ore, waste rock, processed ore and

soil movements will be on dedicated haul and mine site roads and will not generally affect the

local road network. Traffic safety impacts relating to use of haul roads by communities during

operation of the Project are discussed separately in Section 9.3.2 (impact TS2).

The Makeni Highway is an engineered tarmac highway, and the current level of usage of the

road includes usage relating to other mining activities in the area. The additional traffic which

the mine will generate will therefore be broadly of a nature which is in-keeping with the type of

traffic currently utilising the highway, being mainly light vehicles (cars, vans and light

transporter vehicles) with some heavy goods vehicles (HGVs). During the construction and

decommissioning phases of the mine, over-size loads could be expected to be travelling to

and from the site. However, the relatively good standard of the Makeni Highway’s construction

and the relatively low level of existing traffic upon it mean that such occasional loads can be

accommodated by the existing traffic-highway system. The appropriate marking of over-size

loads and ensuring that they are accompanied by ‘pilot’ vehicles is a management measure

which can also be readily implemented to minimise road safety hazards from the movements

of such loads on the public highway.

The risk of materials or items falling from construction vehicles, light freight and HGV’s and

causing a safety hazard is always present during construction of large developments. It can

however be readily managed by ensuring vehicles conveying construction and fabrication

materials are appropriately sheeted and that loads are securely placed and attached, as is

generally standard practice. Freight and goods vehicles delivering essential supplies and

maintenance equipment to the site will, similarly, be either of tanker design (on the case of

liquids, (fuels, beneficiation plant chemicals, etc.,) or rigid body design (in the case of freight

and service vehicles) thereby minimising the risk of objects falling from them and causing a

safety hazard.

Impacts on road surface condition and maintenance through wear and tear resulting from

increased road use by heavy vehicles may include potholes and erosion of the road edge.

Both of these can become progressively worse with time and are exacerbated by rainy

conditions, which contribute to erosion of the road’s subsurface layers by washing away the

fine soil particles responsible for cohesion of the larger particles. Road wear and tear

increases maintenance costs (both for vehicle owners and the authority responsible for

maintenance of the road) and, if not timeously repaired, increases safety risks for vehicles

using the road. As the nature of the traffic to be generated for the mine is generally similar to

that already using the highway, the additional impact on safety and road maintenance is

considered to be low. Impacts on public roads more local to the site (which are presumably

designed to accommodate predominantly lighter vehicles) are expected to be higher, and

redesign of these roads to accommodate the additional mine-related traffic may be required.

U3823_Marampa_ESIS_Final.docx



September 2012

Page 205 of 298



SRK Consulting



Marampa Iron Ore Project ESIS – Main Report



The impact on roads and traffic will last from the inception of site construction activities

through to the end of the decommissioning phase. Although the impact could potentially be

experienced over the length of the highway over which mine-generated traffic travels, this

would be substantially ‘diluted’ by the mine-generated traffic’s inclusion in the general traffic

flow. Therefore the area in which the greater part of the risk occurs is more local to the site, in

particular district or local roads used to access the site after exiting the Makeni highway.

Careful timing of delivery of oversize loads, for example, and ensuring that delivery vehicles

are appropriately sheeted and that loads are correctly distributed and fastened in accordance

with standard health and safety procedures, as well as contribution to road maintenance in

the area, could reduce the safety risk and therefore the significance of the impact. As

numerous uncertainties remain, especially when rating the significance of safety risks, the

confidence in the rating is medium. Although impacts on road conditions are reversible, safety

impacts on other road users are not.

Impact TS1: Increase in Project-related traffic on local and national roads causing increased

wear and tear and risk of road accidents

Impact characteristics



Initial impact



Residual or optimised impact

(taking cognisance of management

measures)



Type (+ / - /neutral)



Negative



Negative



Sensitivity



Medium



Medium



Receptor

importance or

value



Medium



Low



Extent of change /

threshold

compliance



Medium



Low



Magnitude rating



MODERATE



MINOR



Magnitude

description



Timeframe

description



Duration



Medium term



Medium term



Frequency



Low



Low



Timeframe rating



MEDIUM TERM



MEDIUM TERM



INTERMEDIATE



INTERMEDIATE



Spatial Scale

CONSEQUENCE RATING



MEDIUM



LOW



PROBABILITY RATING



DEFINITE



POSSIBLE



SIGNIFICANCE RATING



MEDIUM (-ve)



LOW (-ve)



Reversibility / sustainability



Irreversible



Confidence



Medium



Management measures





Appropriately sign-post the site entrance and access to the Makeni highway.







Design site roads to a standard suitable for mine and construction traffic, and maintain the

roads to this standard.







Assess the condition of local roads and their capacity to accommodate the mine-specific traffic

and if necessary upgrade the roads prior to mine construction.







In conjunction with the Government of Sierra Leone, devise and implement a road

maintenance programme for roads affected by the Project.



Good practice measures:





Design and implement sheeting and correct positioning and securing of loads on vehicles



U3823_Marampa_ESIS_Final.docx



September 2012

Page 206 of 298



SRK Consulting



Marampa Iron Ore Project ESIS – Main Report



in line with international health and safety procedures.



9.3.2







Control delivery of oversize loads to site during times of minimal highway traffic as far as

possible, and minimise travel outside daylight hours.







Minimise travel by heavy vehicles during heavy rains.



TS2: Use of mine site roads by local communities and their livestock causing

increased safety risks due to road accidents

Construction



Operation



Decommissioning



Post-Closure



A potential source of safety impact to local communities and their livestock is the use of mine

site roads (such as haul roads, which will not be fenced) as access routes, either for crossing

or travelling along as an easier alternative to the informal access routes currently used (see

discussion in Section 7.1.2 – Impact LT2). This creates a risk of injury or fatality resulting from

collision with pedestrians or livestock, or objects falling from trucks onto pedestrians. As it is

expected that the haul roads and other on-site roads will intersect current access paths used

by communities, crossing points are likely to be created, both for use by communities, for

example when accessing other villages, and possibly also their livestock. This uncontrolled

crossing over working mine site roads will pose an obvious safety risk if safe alternative

crossing points are not provided, and crossing at other points is prevented.

An additional aspect of the risk is the use of haul roads (or other mine site roads) themselves,

as an alternative to the current access tracks, many of which are in bad condition and are only

passable on foot. Despite being limited to areas accessible from the mine site roads, this

would be an attractive option particularly for transportation of goods to markets or other

villages, as it would make mechanical transportation of the load a more viable option. The

possibility of objects falling from mine site vehicles and causing a safety hazard for

pedestrians is another potential risk, particularly so where ore, rock or mining equipment are

transported.

Based on the estimation of 300 mining days per year, it is estimated that up to about 85 kt ore

would need to be transported per day along haul roads from the pit to the beneficiation plant,

requiring approximately 350 movements in a 240 tonne truck, and 120 kt rock waste per day

requiring approximately 500 truck movements between the pits and the waste rock dumps.

Total truck movements would effectively be doubled to account for the return empty truck

journey, resulting in approximately 700 movements per day (or one truck every two minutes)

on the haul roads, and 1000 movements per day (or one truck every 1.5 minutes) between

the pits and the WRD. These numbers do not however account for other mine traffic on the

site roads so the numbers are likely to be higher. Vehicle entrainment of dust would decrease

visibility, thereby increasing the safety risk. The impact would peak during operation, but

continue until the end of decommissioning, when mine-related traffic would no longer use the

site. The implementation of the management measures listed below could decrease the

probability of accidents occurring, thereby reducing the significance rating of this impact. As

the extent to which local communities will use or cross the mine site roads has not been

established, the impact cannot be rated with a high level of confidence.



U3823_Marampa_ESIS_Final.docx



September 2012

Page 207 of 298



SRK Consulting



Marampa Iron Ore Project ESIS – Main Report



Impact TS2: Use of mine site roads by local communities causing increased safety risks due

to road accidents

Impact characteristics



Initial impact



Residual or optimised impact

(taking cognisance of management

measures)



Type (+ / - /neutral)



Magnitude

description



Timeframe

description



Negative



Negative



Sensitivity



Medium



Medium



Receptor

importance or

value



Medium



Medium



Extent of change /

threshold

compliance



Medium



Medium



Magnitude rating



MODERATE



MODERATE



Duration



Medium term



Medium term



Frequency



High



High



Timeframe rating



MEDIUM TERM



MEDIUM TERM



Spatial Scale



SMALL



SMALL



CONSEQUENCE RATING



MEDIUM



LOW



PROBABILITY RATING



DEFINITE



UNLIKELY



SIGNIFICANCE RATING



MEDIUM (-ve)



LOW (-ve)



Reversibility / sustainability



Irreversible



Confidence



Medium



Management measures





In agreement with local communities, establish safe road crossing points at selected localities.







Enforce speed limits and safe diving practice.







Educate local communities on traffic safety.







Implement dust control measures on unpaved roads and manage sources of dust close to

roads to maintain visibility and traffic safety.







Consider providing and maintaining access paths alongside roads for key access area.



9.4



Security and Social risks

Protection of human rights and ensuring health and safety of both the community and the

workers is a responsibility of the Project developers. Potential impacts and risks to human

rights, security and community health and safety are discussed below.



9.4.1



SR1: Risk of human rights abuses due to conflict with the communities

Construction



Operation



Decommissioning



Post-Closure



Conflicts which are dealt with through force (including armed force) either by local police (on

request of the Project proponent) or private security guards employed by the Project can lead

to violation of human rights, particularly the right to freedom, freedom of expression and

health (and safety). There have been recent incidents, on other Sierra Leone mining Projects,

of police using force (lock ups and open firing leading to death or injury of members of the

public) hence there is a need to manage this risk/potential impact.

Potential tension between the community and the Project as well as potential for intra and

U3823_Marampa_ESIS_Final.docx



September 2012

Page 208 of 298



SRK Consulting



Marampa Iron Ore Project ESIS – Main Report



inter village conflict due to perceived or real unequal access to Project related benefits (as

discussed in Impact SO3, Section 8.3.3) can lead to human rights abuse if not prevented or

managed appropriately.

The prevention and management measures will be guided by the Voluntary Principles on

Security and Human Rights (VPSHR) that provide guidance on the roles and responsibilities

of companies (in the extractive sector) and civil society. A culturally appropriate programme

for stakeholder consultation with regular dissemination of information and an active

mechanism for recording and resolving community grievances in a timely manner will be

necessary for managing this impact. The Project community relations team will monitor the

human rights situation to assess if the possibility of this impact occurring is decreasing or

increasing and plan accordingly (as needed).

The impact has the highest probability of manifesting during construction and operations, with

reduced probability during decommissioning. The mitigation measures largely focus on

eliminating the possibility of human rights violation and on reducing the severity of the impact

if anything does go wrong. Any deterioration in the human rights situation is difficult to

manage but reversible. A strong policy and programme by MIOL for protection of human

rights can effectively prevent this impact hence the higher confidence rating.

Impact SR1: Risk of human rights abuses due to conflict with communities

Impact characteristics



Initial impact



Residual or optimised impact

(taking cognisance of management

measures)



Type (+ / - /neutral)



Magnitude

description



Timeframe

description



Negative



Negative



Sensitivity



High



High



Receptor

importance or

value



High



High



Extent of change /

threshold

compliance



Major



Minor



Magnitude rating



MAJOR



MODERATE



Duration



Long term



Long term



Frequency



-



-



Timeframe rating



LONG TERM



LONG TERM



Scale



SMALL



SMALL



CONSEQUENCE RATING



HIGH



MEDIUM



PROBABILITY RATING



POSSIBLE



UNLIKELY



SIGNIFICANCE RATING



HIGH (-ve)



LOW (-ve)



Reversibility



Reversible



Confidence



High



Mitigation measures





Provide training to MIOL security staff and local police on the Voluntary Principles on Security

and Human Rights.







Maintain the grievance procedure, and encourage and facilitate stakeholders to use the

mechanism to express concerns.



U3823_Marampa_ESIS_Final.docx



September 2012

Page 209 of 298



SRK Consulting



9.4.2



Marampa Iron Ore Project ESIS – Main Report



SR2: Increased exposure to communicable diseases due to an influx of

workers, potentially resulting in a deterioration in public health

Construction



Operation



Decommissioning



Post-Closure



As per the Lunsar Peripheral Health Unit (PHU) records since 2005 communicable diseases,

particularly Sexually Transmitted Infections (STIs) and HIV/AIDS are on the increase in the

Chiefdom. Factors such as the arrival of a predominantly male workforce (Project related as

well as speculative job seekers) and increase in disposable incomes can lead to further

increase in local prostitution and arrival of commercial sex workers in the Lunsar area. The

incidence of HIV/AIDS amongst commercial sex workers is estimated at 10% against the

incidence among the general population at 1.6%. Mixing between outsiders and locals can

also cause an increase in the incidence of other communicable diseases such as

tuberculosis, malaria, respiratory infections and diarrhoea.

Management measures, implemented by the Project clinic for the mine employees and by the

PHU’s for the community, will focus on prevention and control to minimise the extent and

probability and on early diagnosis and treatment to minimise the duration. This impact would

manifest mainly during the construction phase, when the influx in population would be at its

peak, however it can continue into the operation phase as well with slightly less intensity. The

confidence is medium as other factors, unrelated to the Project, may influence the overall

impact experienced in the area.

Impact SR2: Increased exposure to communicable diseases due to an influx of workers,

potentially resulting in a deterioration in public health

Impact characteristics



Initial impact



Residual or optimised impact

(taking cognisance of management

measures)



Type (+ / - /neutral)



Magnitude

description



Timeframe

description



Negative



Negative



Sensitivity



High



High



Receptor

importance or

value



High



High



Extent of change /

threshold

compliance



Moderate



Minor



Magnitude rating



MODERATE



MINOR



Duration



Long term



Medium term



Frequency



-



-



Timeframe rating



LONG TERM



MEDIUM TERM



Scale



SMALL



SMALL



CONSEQUENCE RATING



MEDIUM



LOW



PROBABILITY RATING



DEFINITE



POSSIBLE



SIGNIFICANCE RATING



MEDIUM (-ve)



LOW (-ve)



Reversibility



Partially Reversible



Confidence



Medium



U3823_Marampa_ESIS_Final.docx



September 2012

Page 210 of 298



SRK Consulting



Marampa Iron Ore Project ESIS – Main Report



Impact SR2: Increased exposure to communicable diseases due to an influx of workers,

potentially resulting in a deterioration in public health

Mitigation measures





Develop and implement management policies for HIV/AIDS, tuberculosis and other potential

communicable diseases focusing on prevention, control, diagnosis and treatment in

coordination with NGOs and local government.







Provide health awareness programmes and counselling services to employees.







Promote use and availability of condoms at the workers camp.







Undertake routine health screening of employees to detect and treat diseases early.



9.5



Other hazards potentially resulting in injury

The additional hazards discussed below were identified as those most pertinent to the Project.

In this section ‘hazard’ is defined as the potential to cause harm; risk is the probability of harm

arising from that hazard. The risk may only materialise under a certain set of circumstances.

Therefore although risk is characterised in a similar way to impacts (consequence and

probability), generally the probability of such risks occurring is much lower than the impacts

discussed in the previous sections due to standard controls implemented to minimise the

identified risks.

Mines, roads and associated infrastructure are inherently dangerous facilities, with physical,

chemical and electrical hazards with potential to harm people or wildlife. The risk of injury or

harm and the significance of resulting impacts relate to a number of factors including:





type of hazard;







when, where and how the event materialises;







number of people injured or the extent of ecological damage;







duration of the harmful exposure;







frequency with which the hazard causes injury or harm; and







extent to which injury or harm could have been prevented (for example with suitable

management plans in place).



The most significant Project hazards are discussed in more detail below. Because of the

number of variables affecting the consequence and probability of such events, accurate

significance rating of possible impacts should the risk materialise is not possible. Each event

must be evaluated on an individual basis, in accordance with the incident reporting system

outlined in Section 11.3.2.



9.5.1



OH1: Blasting resulting in fly rock potentially harming people or their

possessions

Fly rock refers to uncontrolled rock flung into the air as a result of blasting. It may result in

death or serious injury on impact with humans or animals within the area around the pits and

is one of the most common causes of injury related to blasting. To reduce the risk of injury the

Project will conduct blasting in accordance with international safety standards. Open pit

blasting will be conducted using standard mining industry practices and procedures for

securing personnel and equipment. This includes the development and implementation of

standard operating procedures, blasting rules and a safety management plan that:





Delineates the danger zone associated with each blast of at least 400m and clear



U3823_Marampa_ESIS_Final.docx



September 2012

Page 211 of 298



SRK Consulting



Marampa Iron Ore Project ESIS – Main Report



workers from this zone before, during and after each blast; and





9.5.2



Provides an audible warning at least three minutes before a blast is fired.



OH2: Community exposure to toxic or hazardous substances

Community exposure to toxic or hazardous substances is most likely to occur as a result of

two factors. The first is accidental spills of these substances to the environment during

handling, storage, disposal or transportation. The second is via landfill disposal of substances

in proximity to communities. Spills may occur during construction and operation, or

decommissioning (when any hazardous substances stored on site would be removed and

either disposed of or used elsewhere). Hazardous substances that will be stored and used on

the mine site include fuels (both HFO and diesel), oil, coolant and hydraulic fluid for mining

equipment (stored in 200 l drums). Impacts resulting from spills of product or tailings material

to water resources are discussed and rated under Impact WR6.

The potential impact associated with each release will depend on the source of material

released, its inherent hazard potential (toxic, acidic, flammable etc.), the volume released, the

extent of release and sensitivity of any human or ecological receptors. Particularly spills close

to water courses (or other water resources) could result in significant ecological and health

impacts due to the rapid spread of contaminants in water, affecting downstream users. .

In terms of exposure to potentially hazardous substances in the landfill associated with the

mine, it is important to note that the landfill at the site will be solely for domestic (non-mining)

type wastes generated by activities associated with the mining operations. Wastes strictly

defined as ‘toxic’ or ‘hazardous’ in accordance with international definitions will be removed

from the mine site to an appropriately licensed waste facility. However, the risk of exposure of

communities to decaying (and potentially toxic) organic matter in the landfill remains, but can

be effectively mitigated by implementation of the management measures listed under Impact

EB4 (Section 7.3.4), with particular attention to the following:





Implementation of standard management practices such as ensuring appropriate site

security and fencing, to prevent unauthorised access to the waste landfill site.







Thorough and regular compaction and covering of wastes with inert materials (at least

weekly). This would also greatly reduce the likelihood of pests being attracted to the

landfill, and the associated health hazards.



The potential impacts associated with spills of toxic or hazardous materials can be reduced

through the implementation of standard management measures, which aim to minimise the

risk of spills occurring and the extent of any damage should a spill occur. Recommended

general good practice measures include the following:





Design hazardous material containment structures taking into consideration natural

hazards and the implications of these on structural integrity of the containment facilities.







Size containment areas to contain 110% of the contents of the largest tank within the

facility or provide facilities to direct excess volume to an alternative spill containment

facility.







Pave (with an impermeable surface such as concrete) mine site fuel delivery and

dispensing pump areas and designed these areas to drain into the adjacent storage tank

containment areas.







Prohibit construction of hazardous material facilities (including temporary and permanent

refuelling areas) within drainage lines or the 1 on 100 year flood lines of watercourses.







Treat (for example with an oil separator), evaporate or dispose of as a hazardous



U3823_Marampa_ESIS_Final.docx



September 2012

Page 212 of 298



SRK Consulting



Marampa Iron Ore Project ESIS – Main Report



material any polluted water collected in hazardous material containment facilities.



9.5.3







Require vehicle maintenance to be undertaken in the designated workshops where

appropriate pollution control measures are provided to prevent leaks or spills of fuel or

lubricants reaching the environment.







Develop and implement a spill prevention and control system as part of the Emergency

Preparedness and Response Plan for the mine site (Section 11.6).



OH3: Fire or explosions due to storage of explosives and use of combustible

materials

The storage and use of both fuels (and other combustible materials) and explosives poses an

inherent fire, and therefore safety, risk to workers on site and surrounding communities. To

minimise the risk, standard international good practice will be followed with regard to storage

and handling of these materials, and occupational health and safety guidelines with regard to

safe working conditions and the use of PPE will be adhered to. As detailed in Section 4.8.7,

fire extinguishers will be available at storage areas for flammable substances, and a fire water

system will be installed, servicing the beneficiation plant and accommodation areas.



9.5.4



OH4: Failure of the TSF resulting in pollution or harm to individuals

The most significant potential safety and environmental hazard resulting from failure of mine

workings is structural failure of the TSF (such as foundation failures, containment wall

collapse, or failure of the tailings pipeline). This could typically be caused by seismic activity,

and may result in contamination of surface water, groundwater or soils in the surrounding

areas, with tailings material. However, as described in Section 5.3, the Project site is located

in one of the least seismically active zones in Africa, and is therefore considered to be in a low

seismic hazard area. The TSF is designed to withstand an operating basis earthquake loading of

²



0.06g (0.6 m/s ) and a post-closure maximum credible earthquake loading of 0.1g (0.1 m/s²).



The design of the TSF is in accordance with the internationally accepted Australian National

Committee on Large Dams Incorporated (ANCOLD) Guidelines on Tailings Dam Design,

Construction and Operation, published in 1999. It is based on a tailings concentration of 60%

(solids by mass), a deposited dry density of1.5 t/m³ and is designed to contain a 1 in 1000

average recurrence interval three-day rainfall event, whilst maintaining a freeboard of at least

0.3 m. Thickening of tailings, as proposed by the design engineers, has the advantage of

reduced water content over conventional methods of tailings disposal, as it decreases the

likelihood of tailings and process fluid leaks, and the widespread release and downstream

spread thereof in the event of leaks. Following closure the TSF will be rehabilitated and

excess water will drain, as the tailings material becomes increasingly solid and stable. A pond

will remain on the TSF, and beach areas above the pond surface will be capped by covering

with soil and rock. Further detail regarding rehabilitation and capping of the TSF will be

confirmed after geochemical characterisation of the tailings material has taken place. Further

detail on the design of the TSF is available in the Tailings Storage Facility Design Interim

Scoping Level Report (August 2011) by Coffey, which is included in Appendix E.

Due to the low seismicity of the area and inherent design precautions in the TSF design, the

likelihood of its failure is considered to be low. The relatively inert nature of the predicted

tailings material implies that, should TSF failure occur, the impacts on human health resulting

from exposure to tailings, contaminated surface water, groundwater or soil are not expected

to be significant. However this would of course depend on the amount of tailings material

released. No additional good practice measures are recommended.

U3823_Marampa_ESIS_Final.docx



September 2012

Page 213 of 298



SRK Consulting



10



Marampa Iron Ore Project ESIS – Main Report



CUMULATIVE IMPACTS

For the purposes of this assessment, the definition of cumulative impacts provided in the

IFC’s Glossary of Terms (IFC, 2006) has been used: ‘the combination of multiple impacts

from existing Projects, the proposed Project and/or anticipated future Projects that may result

in significant adverse and/or beneficial impacts that would not be expected in case of a standalone Project.’ The aim of this preliminary assessment is therefore to identify, and if

necessary lay the groundwork for possible issues requiring co-ordinated actions by a number

of agencies or groups.

The assessment considers the most significant impacts and risks identified for the Project

(those rated high in Chapters 7, 8 and 9) and overlays them in time and space with known or

possible impacts or risks from other current, planned or reasonably foreseeable activities. In

the case of the Project, there has been prior development in the area, mainly linked to mining,

and at the time of writing this ESIA SRK there are two other iron ore mining Projects in the

country (one by London Mining and the other by AML), with the London Mining (LM) Project

being immediately adjacent to MIOL and AML sharing infrastructure with MIOL. The

cumulative impact assessment is therefore predominantly based on the likely impacts of the

London Mining and MIOL, as well as the AML mining Project and Bumbuna Dam

hydroelectric Project on the Rokel River upstream of the MIOL Project. Emphasis is on

significant impacts that are additive or synergistic in nature.

The cumulative assessment consists of the following steps:





Using knowledge gained from the baseline studies and from stakeholder consultation,

the past, present and reasonably foreseeable future activities from sources external to

the Project but occurring in the Project’s area of influence are identified (Table 10-1).

This includes the possible future expansion of the MIOL Project, including product export

infrastructure, which is not otherwise covered by this impact assessment (Section 3.2).







Based on the results of the impact assessment (Chapters 7, 8 and 9), a preliminary

judgement is made on whether cumulative impacts on specific environmental or social

components are possible or likely – the results are given in Table 10-1.







Where potential cumulative impacts are identified in Table 10-1, significant Project

impacts (rated high in Chapters 7, 8 and 9) are evaluated for their potential additive or

synergistic interaction with potential future developments in the following sub-sections.



The process outlined above yielded a number of types of potentially significant cumulative

impacts, as described below.



U3823_Marampa_ESIS_Final.docx



September 2012

Page 214 of 298



SRK Consulting



Marampa Iron Ore Project ESIS – Main Report



Table 10-1: Past, present and reasonably foreseeable activities in Project affected area potentially resulting in cumulative impacts

Project

component

(and area

affected)

Mine site and

water supply



Past and present

activities causing

significant impacts







Concentrate

export (Stage

2) from mine

site



LM mine

(construction and

development)

AML railway line

(along which MIOL

pipeline will run)

and port facilities at

Pepel (then

possibly Tagrin)



Potentially significant cumulative impacts

Reasonably foreseeable

future activities

















National and

Local Road

usage







Traffic associated

with construction

and operation of

AML and LM mines

Traffic associated

with other

development in the

Lunsar area











Relocation of

local

communities







Development of

LM mines



Bumbuna dam

hydroelectric Project

MIOL/LM future

expansions

Construction and

operation of MIOL

product export pipeline

for Stage 2 expansion

Product dewatering at

port

Traffic increases in

Lunsar as a result of

growth in local

population (due to

development in the

area)

MIOL/LM future

expansions

Construction of

Bumbuna dam

hydroelectric Project

Additional relocations

and land acquisition

required (due to MIOL

Project expansion and

other Projects)



Land

transformation



Water

resources



Air quality



Ecological

systems



Distur(a)

bance



Economic

growth



Social

(b)

change



Possible



Likely



Possible



Possible



Possible



Likely



Likely



Possible



Possible



None



Possible



Possible



Possible



Possible



None



None



Possible



None



Possible



Possible



Possible



Possible



Possible



None



Possible



Possible



Possible



Likely



(a)



Includes: noise, visual, vibrations and traffic



(b)



Includes: equity issues, access to services, deterioration in health, social ills, food and water security, pressure on infrastructure and services, etc.



U3823_Marampa_ESIS_Final.docx



September 2012

Page 215 of 298



SRK Consulting



Marampa Iron Ore Project ESIS – Main Report



Based on the evaluation above the most significant cumulative impacts are likely to be those

on water resources, economic growth and social change, and are discussed in Sections 10.1

to 10.3 below. The following cumulative impacts could also occur, but MIOL’s contribution is

unlikely to significantly change the overall impact to the area:





Land transformation: the cumulative effect of other developments in the area may

increase the extent of disturbed areas from those in and around the Project footprint to

the general surroundings. This would place added pressure on non-disturbed areas for

agricultural land and natural resources; cause more widespread disruption of community

access routes and changes in the visual character of the general area and more

widespread erosion of topsoil, affecting land capability.







Air quality: MIOL’s proposed current and future developments, along with London

Mining’s operations, AML’s railway and the general development of the central part of

Sierra Leone will result in increased contributions of gaseous and particulate matter to

the local air quality catchment. MIOL’s contribution to this is moderate at most and this

regional issue can only be managed with co-ordination from government bodies to

ensure ambient air quality is monitored on an ongoing basis and controls put in place to

minimise long term health risks to communities in the area.







Ecological systems: Cumulative impacts on ecological systems would result primarily

from the other cumulative impacts discussed here. These include land transformation,

which would place undisturbed areas under increased pressure; disturbance of wildlife;

and impacts on water resources, reducing the amount of wetland habitat available (e.g.

through groundwater drawdown), and reducing instream habitats through altered stream

flow.







Disturbance: MIOL will slightly contribute to the already increasing noise, visual and

vibration disturbance in the Lunsar area. Other forms of disturbance potentially resulting

in cumulative effects include lighting (of other mines or developments in the area), and

traffic, affecting road safety and condition in the general Project area.



10.1 Water resources

Cumulative impacts on water resources are expected to affect both surface and groundwater

resources, which are used by local communities for domestic purposes, agriculture and

industry and are important for the riverine ecological systems. It is understood the first phase

of the nearby London Mining operation involves re-processing of tailings material from

previous mining rather than mining of fresh ore, and it is therefore assumed pit dewatering

would initially not be required. However, an expansion of the operation to mine fresh ore is

proposed, and may require pit dewatering. The MIOL impacts of groundwater drawdown on

water supply to local communities is currently only of medium to low significance however

given community reliance on groundwater and the proposed future expansions of both MIOL

and LM pit dewatering could further increase risks to domestic groundwater supply and

agricultural/ecological systems reliant on groundwater fed wetlands in the area.

The use or impoundment of surface water from local resources by MIOL, LM and developing

area of Lunsar could have significant cumulative impacts on river flow patterns and surface

water availability in the area. These local impacts may cumulatively impact the Rokel River

which although not currently significantly impacted, may in future be influenced by the

proposed expansion of the Bumbuna dam hydroelectric Project, located upstream on the

Rokel River.



U3823_Marampa_ESIS_Final.docx



September 2012

Page 216 of 298



SRK Consulting



Marampa Iron Ore Project ESIS – Main Report



10.2 Economic growth

The significant Project impacts associated with economic growth and development are

assessed in Chapter 8 (Impacts ED1 to ED4). Development of other Projects in the area

could potentially result in significant positive synergistic effects in the local economy,

benefiting local communities and Lunsar town, if not Sierra Leone as a whole. This growth

would result from:





direct employment and skills development from the Project and other developments

during both construction and operation;







outsourcing opportunities for local suppliers; and







increase in government revenue potentially resulting in investment in social

development.



Initial Project related economic growth and development would result from MIOL capacitybuilding programmes as employees are trained and gain experience. Parallel employment

and training would occur for the Project’s support services in the area. Other mining and

industrial developments within the Marampa area could significantly add to the critical mass

and make this growth self-sustaining, fuelling further economic growth, for example:





experienced employees would have the opportunity to increase their earning potential by

seeking employment at other developments;







other businesses would develop to provide services to the local population leading to the

creation of alternative livelihoods;







increased development and employment would increase the tax base, which could lead

to other educational and training opportunities;







increased social services from the local governments;







capacitated communities may be more able to express their wishes or concerns; and







vulnerable groups, such as women and the elderly, may become more empowered if

they can be involved in both Project and other economic activities.



Cumulative impacts between the Project and other developments have the potential to

contribute to significant synergistic effects on the macro-economy of the area. The Project

may therefore be a contributor to growth in the area, encouraging other unrelated industry to

develop. Successful regional development will mitigate negative impacts associated with the

cessation of a single activity (such as when the Project closes). Other developments in the

area will then be able to absorb trained workers, potentially use Project infrastructure (such as

the power station, accommodation camp and associated facilities, and rail spur line) and

make use of the support services, so that the closure of any one development will not

necessarily translate into a regional economic downswing but instead provide added local

resources to support further sustainable development.



10.3 Social change associated with population increase due to in-migration

The significant Project-related impacts associated with population increase due to in-migration

are discussed in Chapter 8 (Impact SO1), and include competition for jobs and resources.

Additional development in the Lunsar area, such as other mines and secondary development,

is likely to trigger further in-migration of job seekers (some has already been observed as

result of London Mining’s operations). If not effectively mitigated, this could lead to

proliferation of informal settlements and social issues relating to unemployment in the area.

U3823_Marampa_ESIS_Final.docx



September 2012

Page 217 of 298



SRK Consulting



Marampa Iron Ore Project ESIS – Main Report



This will also put increased pressure on existing infrastructure and services, food security and

water supply, all of which are already under strain at times to meet the needs of the current

population. Mitigation measures for this potential cumulative impact, beyond those defined for

the Project, will require coordinated management by a number of private and public sector

parties and therefore cannot be defined at this time and as such are not included in the EMP

(Appendix F). However, it is important these issues are addressed in a timely manner as

population increase through in-migration could indirectly increase the magnitude of other

Project related impacts on local communities.



U3823_Marampa_ESIS_Final.docx



September 2012

Page 218 of 298



SRK Consulting



11



Marampa Iron Ore Project ESIS – Main Report



ENVIRONMENTAL AND SOCIAL MANAGEMENT SYSTEM

This document describes the framework for the Environmental and Social Management

System (ESMS) for the Project. The framework has been developed with consideration of the

requirements of Sierra Leone’s legislation and guidelines, the IFC’s Performance Standard 1

and the main principles in the International Standards Organisation (ISO) 14001 Standard

(ISO 14001:2004, 2004). Some organisations use different terms for an ESMS, for example

the International Standards Organisation (ISO) uses “environmental management system” or

“EMS”. For the purposes of this document, the terms are synonymous.

The IFC Performance Standards state the objectives of an ESMS are to:





identify and assess social and environmental impacts, both adverse and beneficial;







avoid, or where avoidance is not possible, minimize, mitigate or compensate for adverse

impacts on workers, affected communities, and the environment;







ensure that affected communities are engaged on issues that could potentially affect

them; and







promote improved social and environmental performance of companies through the

effective use of management systems.



IFC Performance Standard 1 goes on to explain an ESMS has the features listed below.





it is a dynamic, continuous process initiated by management and involving

communication between the Project owner, its workers, and the local communities

directly affected by the Project;







it is based on the business management process of “plan-do-check-act” (this is the same

basic process used in ISO14001);







it entails the thorough assessment of potential environmental and social impacts and

risks from the early stages of Project development; and







it provides order and consistency for mitigating and managing these on an ongoing basis

throughout the life of the Project.



The basic elements of the ESMS for the Project are outlined in Table 11-1 with more detail on

each element, and how it applies, given in the following sub-sections. The elements of the

ESMS are discussed under the headings of the “plan-do-check-act” business performance

improvement cycle. Stakeholder engagement is an element of the ESMS that applies to all

steps of the “plan-do-check-act” cycle as shown in Table 11-1.

An important component of the ESMS is the Environmental and Social Management

Programme (ESMP). As with the ESMS, the ESMP may be known by different names, but in

this instance is considered synonymous with the term “Environmental Management

Programme” (EMP) used in certain jurisdictions, including Sierra Leone and which has

therefore been used in this report. The EMP presents MIOL’s commitments to manage the

impacts identified by the impact assessment process (Section 3.3.3). The EMP falls under the

element of the ESMS entitled “objectives, targets and plans for management”.



U3823_Marampa_ESIS_Final.docx



September 2012

Page 219 of 298



SRK Consulting



Marampa Iron Ore Project ESIS – Main Report



Table 11-1: Elements of the ESMS

Elements of the ESMS for the Project

Primary function



Leadership and

accountability



Plan

(Section

11.1)







Legal and other

requirements







Aspect

identification

and impact

assessment







Objectives,

targets and

plans









Roles and

responsibility



Do

(Section

11.2)



Contractors,

suppliers and

vendors







Competence,

training and

awareness







Communication

Operational

controls and

maintenance



Check

(Section

11.3)













Provide sufficient management sponsorship of

human and financial resources

Establish roles and responsibilities for

implementation

Consider environmental and social impact

management and performance in the selection

and management of third party services

Make personnel aware of their responsibilities

and enable them to be capable and competent

in meeting their responsibilities

Maintain internal and external communications

to enable effective environmental management

Implement operational controls and maintain

equipment to uphold environmental

performance and compliance and to manage

impacts and risks

Control and maintain documents and records

associated with environmental and social

management



Documentation

and record

keeping







Assessing,

correcting and

improving

performance







Monitor environmental and social management

and performance and take measures to

continually improve performance



Nonconformance

and incident

reporting







Promptly report non-conformances and

incidents are promptly reported and take

corrective and preventative actions to reduce

the likelihood of recurrence

Report on compliance with the EMP and ESMS

performance to senior management, regulatory

authorities and affected communities

Require site, regional and senior management

to review the suitability, adequacy and

effectiveness of the ESMS and identify

improvement actions to facilitate continuous

improvement

Modify the ESMS in response to changes in the

Project and to changes in the organisation,

personnel, operations and processes



EMP and ESMS

reporting









Act

(Section

11.4)



Produce and communicate a statement of

corporate commitment to environmental and

social management (e.g. policy statement)

Establish, document, implement, maintain and

improve the Project ESMS

Identify and provide access to legal

requirements and other obligations

Identify aspects (“mechanisms” by which Project

activities impact on the environment) and

assess associated impacts throughout the

Project life (the ESIA falls under this element of

the ESMS)

Define objectives, targets, criteria and actions

for the management of potential impacts (the

EMP falls under this element of the ESMS)



Governance/

management

review

Management of

change







Elements applying

to all steps of the

cycle

Emergency planning, response and recovery (Section 9.6)

Maintain emergency response preparedness through the identification of potential environmental emergencies, development of response plans

and allocation of response and recovery resources.



Elements



Stakeholder engagement (Section 9.5)

An ongoing process, throughout the life of the Project.

Serves to build and maintain a constructive relationship with communities affected by the Project



Steps of

the “plando-checkact” cycle



The arrows show where there is integral relationship between stakeholder engagement and

other elements of the ESMS.



U3823_Marampa_ESIS_Final.docx



September 2012

Page 220 of 298



SRK Consulting



Marampa Iron Ore Project ESIS – Main Report



11.1 Planning elements

11.1.1 Leadership and accountability

Policy

The Project will be undertaken in accordance with MIOL’s corporate policies, which are

attached as Appendix H. This will include as a minimum the following policies: Environment

Policy, Health and Safety Policy, Human Resources Policy and Community Policy. MIOL will

periodically review the scope and effectiveness of its policies (Section 11.4.1). The policies

will be documented, maintained, implemented and communicated to MIOL employees,

contractors, suppliers and the public.

As a subsidiary of Cape Lambert Resources Limited, MIOL is committed to operating in

accordance with the policies of its parent company, which operates according to stated

principles of Environment, Health and Safety (EHS) and Corporate Social Responsibility

(CSR).

ESMS

MIOL will establish, document, implement, maintain and continually improve an ESMS for the

Project. The ESMS will be in place prior to construction.



11.1.2 Legal requirements and other obligations

The Project’s ESMS takes account of both legal and other obligations imposed on the Project.

The various types of obligations considered are shown conceptually in Figure 11.1.



Figure 11.1: Types of obligations relevant to the ESMS

U3823_Marampa_ESIS_Final.docx



September 2012

Page 221 of 298



SRK Consulting



Marampa Iron Ore Project ESIS – Main Report



MIOL will identify, document and maintain a register of legal requirements and other

obligations applicable to the Project. It will also:





track developing legislation and regulations that may apply to operations and activities to

anticipate and prepare for compliance;







inform employees and others working on behalf of the company of existing and emerging

obligations that apply to their job responsibilities; and







consider the register in the setting and review of objectives, targets and plans for

management of impacts.



11.1.3 Aspect identification and impact assessment throughout the Project life

A key element of the ESMS is identification of aspects and assessment impacts. The impact

assessment documented in this report is the initial stage of this element of the ESMS.

Procedures will be set up, implemented and maintained for the ongoing identification of any

new environmental (or social) aspects. These will be evaluated using impact and risk

assessments on an ongoing basis through the Project life, probably in the form of regular

workshops attended by the environment and community teams, as well as the various

engineering and operating teams. The reviews will address:





significant aspects not covered by this ESIA;







any impact arising that was not predicted by the ESIA or did not develop as predicted by

the ESIA;







any changes in the Project or new developments arising subsequent to the completion of

this ESIA (Section 11.4.1).



11.1.4 Objectives, targets and plans for management throughout the life of the Project

This element of the ESMS pertains to the setting of objectives and targets for environmental

and social management, and plans for the achievement of these objectives and targets at

20

corporate and Project/ site levels. The EMP described below embodies this element of the

ESMS at the Project level.

The primary purpose of the EMP is to guide environmental and social management

throughout the life of the Project. The core of the EMP is a statement of environmental and

social management objectives and associated management measures. The EMP will be

supported by other documentation, such as the original Project design (described in Section

4) and specific management plans and operating procedures.

The preliminary EMP commitments presented in tabular formal in Appendix F are derived

from the following sources within the ESIS:





inherent design or management measures described in the Project Description in

Chapter 4;







mitigation and enhancement measures identified in Chapters 7, 8 and 9, which are

required to manage identified impacts; and







good practice management measures presented in Chapters 7, 8 and 9, which may not

significantly alter the impact rating but are considered standard industry practice for the

management of such impacts and have been voluntarily adopted by MIOL.



20



For the purposes of this report EMP includes measures related to social management and could equally be known as the

environmental and social management plan or ESMP.



U3823_Marampa_ESIS_Final.docx



September 2012

Page 222 of 298



SRK Consulting



Marampa Iron Ore Project ESIS – Main Report



During the Project life, the EMP may need to be amended to address a specific requirement,

such as those included in the obligations register (Section 11.1.2). Therefore, in subsequent

updates of the EMP, a column entitled ‘Source’ may be needed to indicate additional sources

of commitments, for example conditions of approval included in permits, or commitments

made to stakeholders.

Management plans and other forms of supporting documentation will be developed by MIOL

or its contractors, where needed, to provide further detail on how key actions identified in the

EMP will be executed. The need for supporting management plans or other supporting

documents has been determined initially during the ESIA, based on the risk posed by or

complexity of the impact/s or area requiring management. Consideration is also given to the

regulatory requirements of Sierra Leone.

Recognising the EMP could become legally binding, by means of the conditions of approval

attached to authorisations (licences/ permits), it is considered desirable that the supporting

documentation is separated from the EMP. This allows for flexibility in meeting the objectives

and commitments in the EMP; the EMP supporting documents can be dynamic documents,

adaptable to changing circumstances, and can be modified (without necessarily requiring

regulatory approval of each modification) providing the changes are in compliance with the

stated objectives in the EMP.

Supporting documents identified as a result of the ESIA or Sierra Leone regulations include

the following plans:





Environmental Management Programme and Social Management Programme (Appendix

F);







Stakeholder Engagement Plan (Appendix C); and







Resettlement Framework (Appendix D).







Additional plans to be prepared during Stage 1 detailed design for construction include

(note these may be individual or combined plans):







-



construction management plan (addressing land clearance, water/waste

management, air quality, noise, vibrations and other environmental impacts

associated with construction);



-



community development plan;



-



recruitment plan



-



training and skills development plan;



-



grievance management plan;



-



occupational health and safety plan;



-



security management plan;



-



closure and rehabilitation plan.



Additional plans to be prepared and/or reviewed during the construction phase ready for

operation include (note these may be individual or combined plans):

-



community health and safety plan;



-



water management plan;



-



waste management plan;



U3823_Marampa_ESIS_Final.docx



September 2012

Page 223 of 298



SRK Consulting



Marampa Iron Ore Project ESIS – Main Report



-



soil management plan;



-



air quality management plan;



-



wildlife and habitat management plan



-



emergency preparedness and response plan;



-



spill prevention control and countermeasure plan;



-



hazardous materials management plan; and



-



closure and rehabilitation plan.



The supporting documentation may need to be presented differently, depending on the target

audience and Project requirements, for example:





an issues-driven format is often required to facilitate communication with regulatory

authorities and stakeholders (for example community development plan); and







an area/activity-driven format is needed for ease of application by the parties responsible

for Project execution (for example construction management plan, waste rock dump

management plan, spill prevention plans etc.).



11.2 Implementation (Do) elements

Effective implementation and functioning of the EMP depends on adequate human and

financial resources, clearly defined responsibilities for environmental and social management,

appropriate training and good communication. An outline of how these features will be

managed for the Project is presented below.



11.2.1 Roles and responsibility

MIOL will define, document and communicate the environmental and social management

roles and responsibilities of Project personnel, including contractors and others working on

behalf of the company, in all phases of Project implementation from detailed design through to

closure. Personnel with specific roles and responsibilities will have the authority, and be held

accountable for, carrying out these.

The basic roles required to implement the EMP, and establish and maintain the ESMS, are

shown in Table 11-2. These roles need to be reviewed and incorporated into the

organisational structures for the various phases of the Project from detailed design through to

closure. A key requirement is for the senior environmental management professional to

report directly to the on-site senior manager (the General Manager).



11.2.2 Contractors, suppliers and vendors

Environmental and social performance, programmes and risk management will be considered

in the selection and management of contractors, suppliers and vendors. Contracts will

address potential environmental and social liabilities and responsibilities including the

following:





use of competent, trained staff, including subcontractors;







consequences for failing to meet obligations;







monitoring of performance;







required job-specific, site-specific training;







compliance with MIOL policies and site standards and applicable legal requirements;



U3823_Marampa_ESIS_Final.docx



September 2012

Page 224 of 298



SRK Consulting



Marampa Iron Ore Project ESIS – Main Report







responsibility for chemicals and hazardous materials brought on-site and wastes

generated on-site, including closure activities where appropriate; and







identification of a lead responsible person for both MIOL and the contractor.



Contractors, including their employees and associated subcontractors, will be made aware of

the environmental risks, associated controls, procedures and standards relevant to their work

on-site (Section 11.2.3), probably through the imposing of contracting clauses. The activities

and performance of contractors will be monitored by MIOL against the terms of the contracts.

Table 11-2: Key Roles for Environmental and Social Management

Roles



Relevant Responsibilities



Chief executive

officer (CEO)







Top management



Endorse the environmental and social management policy and require it to be

communicated to the public.

• Allocate adequate human and financial resources to enable effective functioning

and continual improvement of the ESMS.

• Establish and maintain a governance system.

Policy

• Develop, review and update MIOL’s policy/s on environmental and social

management.

• Incorporate principles of MIOL’s policy/s in business decisions.

Compliance

• Confirm necessary authorisations (licences/ permits) have been obtained for the

Project.

• Confirm compliance with legal requirements and other obligations pertaining to

environmental and social management.

• Commit contractors and suppliers to meeting relevant environmental and social

obligations by means of specific conditions in the contracts of appointment.

Roles and responsibility

• Define, document and communicate environmental and social management roles,

responsibilities and authorities.

• Provide sufficient appropriately trained human resources and adequate financial

resources to enable effective functioning and continual improvement of the ESMS.

• Hold personnel responsible for meeting their assigned responsibilities.

Communication and reporting

• Confirm there is adequate ongoing stakeholder engagement.

• Confirm obligations for reporting to regulatory authorities, development financiers

and affected communities are met.

Management review

• Provide leadership in the pursuit of environmental and social management.

• Examine and review the ESMS periodically to determine its suitability, adequacy

and effectiveness.

• Support action to enhance the ESMS and make improvements in environmental

and social management performance.



U3823_Marampa_ESIS_Final.docx



September 2012

Page 225 of 298



SRK Consulting



Marampa Iron Ore Project ESIS – Main Report



Roles



Relevant Responsibilities



Environmental

management team



ESMS

• Establish the ESMS, with assistance from the senior management, division

managers and community relations managers.

• Liaise with division managers regarding environmental management roles,

responsibilities and authorities throughout operational divisions.

• Coordinate monitoring and evaluation activities and confirm corrective actions (an

action taken to address a non-conformance) are taken to address incidents and

non-conformances (a failure to comply with the Project’s ESMS).

• Report progress in implementation and functioning of the ESMS to senior

management, development financiers, regulatory authorities and stakeholders.

EMP and obligations register

• Keep the EMP and obligations register up to date and confirm they address all

relevant environmental and social obligations.

• Present the EMP in an appropriate format for communication with regulatory

authorities and other stakeholders.

• Present the EMP in an appropriate format for communication with parties

responsible for Project execution.

• Compile EMP compliance reports.

• “Sign-off” actions in the EMP and non-conformances once they have been

completed.

• Assist the Environmental Management team with ongoing reporting to stakeholders

on EMP and supporting management plans, and progress with implementation of

management measures.

• Assist Environmental Manager and division managers with stakeholder

communication where awareness and/ or co-operation of stakeholders are required

to implement management measures

• Manage the grievance mechanism

• Confirm the ESMS and EMP are established, communicated, implemented and

maintained in their respective areas

• Provide leadership in the pursuit of environmental and social management

• Identify ways to improve environmental and social performance through daily

monitoring of their activities and evaluating implementation

• Review monitoring results, incidents and corrective actions taken

• Evaluate adequacy and effectiveness of awareness and skills training programmes

pertinent to environmental and social management

• Maintain internal communication of environmental and social matters between the

Environmental Manager, Community Relations Manager and other personnel, and

promote environmental and social awareness.

• Comply with MIOL policies, site standards and applicable legal requirements.

• Work in accordance with the EMP and supporting documents.

• Report problems or deviations from the ESMS or EMP to division managers and/or

environmental managers, as instructed.



Government and

community relations

team



Operations

management team



All personnel and

contractors



11.2.3 Training

Personnel, including contractors’ personnel, working for or on behalf of the Project will receive

training to maintain awareness of relevant environmental and social aspects, impacts and

risks associated with the Project and corresponding controls. The training will also maintain

awareness of the environmental benefits of improved personal performance and the potential

consequences of departure from specified procedures. Visitors to Project sites will receive

relevant environmental and social awareness training as part of site induction training.

Personnel, including contractors’ personnel, will be made aware of the particular

environmental and social management responsibilities that apply specifically to their jobs.

Training needs analyses will be undertaken and personnel will be given adequate training to

meet these responsibilities.

The training programme should comprise the following elements:





identification of training needs for employees specific to their varying responsibilities;



U3823_Marampa_ESIS_Final.docx



September 2012

Page 226 of 298



SRK Consulting



Marampa Iron Ore Project ESIS – Main Report







development of a training plan and schedule to address defined needs;







verification of training programs to confirm consistency with organisational requirements;







training of target employees and documentation of training received;







evaluation of training effectiveness; and







review and modification of training programmes, as required.



Personnel with direct responsibility for implementation of the EMP and functioning of the

ESMS should receive additional training to:





provide them with the knowledge and skills necessary to perform their work;







maintain their knowledge of relevant environmental and social obligations; and







enable them to implement specific measures required under the EMP in a competent

and efficient manner.



Training requirements and completed training will be documented. Procedures to evaluate the

effectiveness of such training will be implemented.



11.2.4 Communication

To effectively implement environmental and social management, the relevant managers will

maintain lines of internal communication and provide information regarding the EMP, ESMS

and environmental and social management performance, incidents, good practices, lessons

learned and concerns to personnel electronically, on notice boards and/or in newsletters.

Such communication will be used to inform the personnel of their individual responsibilities

with respect to the ESMS and to raise awareness on specific matters. External stakeholder

engagement is discussed in Section 11.4.

A grievance mechanism will be established (Section 11.4) and will provide a means for

Project personnel, including contractors’ personnel, to anonymously raise environmental and

social concerns (this grievance mechanism will be separate from the system dealing with

employee grievances that need to be handled by the human resources department).



11.2.5 Operational controls

Operational controls will be implemented to maintain performance and compliance, and to

manage impacts and risks. Operational controls may include:





administrative controls such as performance standards;







standard operating procedures and work instructions; and







engineered controls such as pollution control equipment.



Written operational controls are required where their absence could lead to deviation from

environmental obligations or objectives and targets. Written operational controls will be part

of the EMP supporting documentation (Section 11.1.4).

The adequacy, suitability, and effectiveness of operational controls will be reviewed regularly.

Documentation on the design basis and operating criteria/limits for equipment having the

potential to impact environmental performance will be maintained.

Operating equipment, as well as environmental monitoring and measurement devices, will be

maintained consistent with manufacturers’ specifications and good management practice to

reduce the potential for environmental incidents and adverse environmental impacts.



U3823_Marampa_ESIS_Final.docx



September 2012

Page 227 of 298



SRK Consulting



Marampa Iron Ore Project ESIS – Main Report



11.2.6 Documentation and record keeping

Elements of the ESMS will be documented and controlled in accordance with a document

control system. Records demonstrating compliance with legal requirements and conformance

with the ESMS will also be maintained. MIOL will establish, implement and maintain

procedures for:





ESMS document control detailing how the creation, review and updating of various types

of documents will be managed and who will be responsible; and







record identification, storage, protection, retrieval, retention and disposal.



Documentation and record keeping controls will include:





measures to enable relevant documents (including those of external origin deemed

necessary for planning and operation of the ESMS) and records to be readily available

and identifiable (labelled, dated and properly filed), legible and protected from damage;







periodic review, revision and approval of documents for adequacy by authorised

personnel;







making current versions of relevant documents available at locations where operations

essential to the effective functioning of the ESMS are performed;







suitably identifying obsolete documents retained for legal and knowledge preservation

purposes; and







identification and segregation of confidential and privileged information.



11.3 Monitoring and reporting (Check) elements

To confirm effective implementation of the ESMS and conformance with the EMP, monitoring

of performance is required. Checks include monitoring, site inspections and formal audits.

Linked to this, measures need to be taken to remedy non-conformances and to continually

improve environmental performance. These activities fall under the heading “assessing,

correcting and improving performance” (11.3.1). Incident reporting (Section 11.3.2) and

reporting on the effectiveness of the ESMS and compliance with the EMP (Section 11.3.3) are

also classified as “check” elements of the ESMS.



11.3.1 Assessing, correcting and improving performance

Monitoring programmes

The aim of monitoring programmes is to:





provide measurements of environmental and social impacts of the Project;







ascertain and demonstrate compliance with conditions of approval and other legislation;







provide sufficient evidence to address any claims made against the Project in respect of

environmental and social matters;







track performance of the ESMS and progress in the implementation of the EMP;







track and measure key indicators and other performance measures over time to improve

the Project’s performance and reduce the likelihood of environmental incidents; and







inform decision processes for determining management actions.



The monitoring programmes cover the physical, biological and social components of the

operation and are integrally linked with the assessment criteria stated in the EMP.

Preliminary monitoring programmes have been prepared and are included in Appendix G.

Where appropriate and possible, the sampling parameters and locations used in the ESIA

U3823_Marampa_ESIS_Final.docx



September 2012

Page 228 of 298



SRK Consulting



Marampa Iron Ore Project ESIS – Main Report



baseline studies have been retained to provide data continuity.

The monitoring programme identifies monitoring parameters, sampling locations, sampling

frequency and duration and detection limits (where appropriate). It includes control sites,

where relevant. The focus and extent of monitoring is commensurate with the risk of impacts

occurring, the sensitivity of the surrounding areas and the affected communities’ perceptions

of risks to their health and environment. For some types of monitoring, thresholds or targets

are available (and included in the environmental or social management programmes

described above). In other cases, the monitoring results will be compared to the baseline

data set gathered as part of this ESIA. Lastly, where neither thresholds nor baseline data are

available, the initial data collection may form the baseline for future data collection.

Data will be documented and interpreted. Temporal and spatial trends in the data will be

discerned and compliance with relevant thresholds will be evaluated. Monitoring reports will

be produced to meet internal and external reporting requirements (Section 11.3.2). If

monitoring results indicate non-conformance with stipulated thresholds or if a significant

deteriorating trend is observed, it will be recorded as a non-conformance and handled by the

non-conformance and incident procedure (Section 11.3.2).

The preliminary monitoring programmes in Appendix G provide a framework of monitoring to

evaluate performance and assist in predicting and managing impacts. In conjunction with the

development of supporting documentation for the EMP (Section 11.1.4), detailed monitoring

plans, with appropriate sampling protocols where relevant, may need to be developed. These

more detailed supporting documents would include the criteria against which the monitoring

results will be compared and the actions required if the criteria or thresholds are exceeded.

The supporting documents may also cover:





sample or data collection methods;







sample handling, storage and preservation;







sample or data documentation;







quality control;







data reliability (calibration of instruments, test equipment, and software and hardware

sampling);







data storage and backup, and data protection;







interpretation and reporting of results; and







verification of monitoring information by qualified and experienced external experts.



The frequencies and locations of monitoring may need to be adjusted depending on final

Project design and ongoing review of results obtained by the monitoring programmes.

Therefore the programmes will be reviewed on a regular basis (at least annually) and

adjusted, where necessary (Section 11.4.1). Changes to the EMP or obligations register may

also result in changes to the monitoring programme.

Site inspections

Site inspections will be undertaken regularly in relevant areas of the Project. The inspections

will focus on compliance with the EMP and conformance with the ESMS. The inspections will

play an important role in increasing awareness of EMP and ESMS requirements.

Minor non-conformances will be discussed during the inspection and recorded as a finding in

the inspection report. Serious non-conformances will be reported as incidents (Section

11.3.2). Inspection results will be disclosed at management meetings.

U3823_Marampa_ESIS_Final.docx



September 2012

Page 229 of 298



SRK Consulting



Marampa Iron Ore Project ESIS – Main Report



Formal audits

Formal audits of both the EMP and the functioning of the ESMS will be undertaken at planned

intervals in accordance with the requirements of MIOL and regulatory authorities. Procedures

for audits will be established, implemented and maintained. These will cover the audit criteria,

scope, frequency and methods, and will address the responsibilities and requirements for

planning and conducting audits, reporting results and retaining associated records.

Audits will include both internal and external audits, as well as regulatory audits required by

SLEPA. Internal audits will be undertaken frequently and may include review of contractors,

evaluation of implementation of a specific supporting document or evaluation of one area of

site against the relevant EMP conditions. External audits occur less frequently (for example

every one or two years) and are likely to focus on the EMP, though more detailed audits could

be commissioned if considered necessary.

Negative findings arising from an audit will be dealt with in accordance with the nonconformance and incident procedure (11.3.2). Results from audits and evaluations of

compliance with legal requirements will be reported to site and senior management and

subject to management reviews (Section 11.4.1).



11.3.2 Non-conformances and incident reporting

Non-conformances include the following:





exceedances of relevant thresholds as identified during routine monitoring;







non-conformances with the requirements of the EMP or supporting documentation

identified during an internal inspection;







non-conformances identified during an audit or by regulatory authorities, including legal

non-conformances;







events, such as spills, resulting in environmental harm;







events that did or could result in risks to community health and safety; and







significant complaints or grievances received from any source.



A process will be established for the identification, investigation and tracking of nonconformances, including:





prioritising and classifying non-conformances based on the type and severity of the nonconformance;







recording of non-conformances and the results of corrective and/or preventive actions,

including the actions necessary to mitigate or remedy any associated impacts;







defining results expected from the corrective and/or preventative actions;







confirming the corrective and/or preventive actions taken to eliminate the causes of the

non-conformance are appropriate to the magnitude of problem and commensurate with

the impacts encountered;







reviewing the effectiveness of the corrective and/or preventive actions taken; and







implementing and recording required changes in the EMP or monitoring programme

resulting from corrective and preventive action.



Serious non-conformances will be classified as incidents. Incidents will be promptly reported

to appropriate management. MIOL will prepare a guideline on:





the types of incidents reportable to internal management at the site, Project and

corporate levels, as well as to regulatory authorities and other external stakeholders; and



U3823_Marampa_ESIS_Final.docx



September 2012

Page 230 of 298



SRK Consulting







Marampa Iron Ore Project ESIS – Main Report



standards to be observed when reporting incidents.



The investigation of incidents and evaluation of effectiveness of existing controls and

response actions will be undertaken at a level commensurate with the severity of the incident.



11.3.3 EMP and ESMS Reporting

Progress on compliance with the EMP will be reported to:





Project site and MIOL senior management;







regulatory authorities, as required; and







affected communities and other stakeholders who have an interest in the Project

(Section 11.5).



In addition, the formal audit reports on compliance with the EMP and the functioning of the

ESMS will be made available to site and corporate management.



11.4 Act elements

11.4.1 Governance/ Management review

Project site management and MIOL senior management will review the EMP and ESMS on a

periodic basis to determine its suitability, adequacy and effectiveness. Each management

review will initiate a new plan-do-check-act cycle with enhancement of the ESMS and

continuous improvements in environmental and social management performance. The

management review will cover:





progress and closure of actions from previous management reviews;







monitoring programmes findings/ the extent to which objectives and targets have been

met;







findings of audits (Section 11.3.1);







incidents and the status of corrective and/or preventative actions (Section 11.3.2);







impact and risks assessments (Sections 11.1.3 and 11.4.2);







changing circumstances, including changes to operations, Sierra Leone legislation or

guidelines, ownership, socio-political circumstances (Section 11.1.2);







legal compliance and compliance with other obligations (Section 11.1.2);







stakeholder concerns, requests or complaints (Section 11.5);







adequacy of policies, EMP, monitoring plans, support documents and overall functioning

of the ESMS to meet operational and corporate requirements; and







recommendations for improvement.



11.4.2 Management of change

Changes to the Project can be expected throughout the life of the Project. These can range

from changes to operations and infrastructure, new developments (such as an expansion),

changes to personnel and the Company, changes in legislation and changes to the

environment of the Project (such as a new settlement established near Project infrastructure).

These changes could result in changes to the significance of environmental and social

impacts and risks, or identification of new aspects or impacts (Section 11.1.3). This may

necessitate updates to existing authorisations/ permits, changes to the EMP (which may have

to be approved by regulatory authorities), changes to supporting documentation including

monitoring programmes and general changes to the ESMS framework.



U3823_Marampa_ESIS_Final.docx



September 2012

Page 231 of 298



SRK Consulting



Marampa Iron Ore Project ESIS – Main Report



A procedure for the management of change will be established and maintained by MIOL. This

will:





observe the corporate owners’ requirements for the management of change;







identify proposed changes that could alter environmental or social impacts and risks and/

or require new authorisations/ permits or changes to existing authorisations/ permits; and







define the impact and risk assessments appropriate to different types of changes, which

need to be undertaken by competent personnel.



Changes will not be made without the required authorisations/ permits in place. The measures

identified as necessary to mitigate impacts and risks will be implemented. The various

elements of the ESMS will be modified as required in response to the change,

A procedure specifically for changes to the policy/s, EMP, monitoring programmes and

supporting documentation will be established. This will detail:





how the changes are to be recorded;







who has responsibility for overseeing changes and checking they do not conflict with any

planning conditions or other obligations;







the process of review and sign off in response to changes; and







how changes to the EMP should be communicated internally and externally.



11.5 Stakeholder engagement

Stakeholder engagement provides stakeholders with opportunities to express their views on

Project risks, impacts and impact mitigation measures and involves appropriate consideration

of the views and responses by Project management (IFC 2012). Table 11-1 shows

stakeholder engagement applies to each of the steps of ESMS “plan-do-check-act” cycle and

is an integral part of several ESMS elements. The relationship between stakeholder

engagement and these elements is explained further in Table 11-3.

MIOL will establish a programme of stakeholder engagement for the Project that builds on the

consultation undertaken for the ESIA. This will continue throughout the life of the Project.

When the Project enters the construction phase, and throughout the remaining life of the

Project, stakeholder engagement will include:





reporting on the implementation of the EMP and relevant supporting management plans;







opportunities for stakeholders to respond to the information received; and







constructive dialogue on environmental and social issues and performance.



The stakeholder engagement process will be documented, including:





maintenance of a stakeholder database with stakeholder details;







records of information disclosed to stakeholders;







records of stakeholder engagements; and







records of inputs from stakeholders and responses to these.



U3823_Marampa_ESIS_Final.docx



September 2012

Page 232 of 298



SRK Consulting



Marampa Iron Ore Project ESIS – Main Report



Table 11-3: Relationship between stakeholder engagement and the ESMS elements

Steps of

the “plando-checkact” cycle



ESMS elements that stakeholder engagement is integral to

ESMS elements



Role of stakeholder engagement



ESIA



During the ESIA, the focus of stakeholder engagement has been the

involvement of stakeholders in Project-planning and Project-approval decisionmaking processes. It facilitated identification of stakeholder’s concerns so they

could be addressed in the Project design and/or EMP. It forms the basis for

stakeholder engagement throughout the life of the Project.



EMP



Stakeholders will be involved in the review and approval of the preliminary

EMP. Throughout the life of the Project, there should be ongoing reporting to

stakeholders on progress in the implementation of the EMP and supporting

management plans that are of interest to them. The EMP and supporting

management plans may need to be revised in response to stakeholders’

concerns.



Communication



Communication with stakeholders will be required to implement some

management actions. The communication will be required to raise awareness

and/or co-operation of potentially affected communities and other stakeholders.

MIOL will determine effective communication methods for making affected

communities aware of actions they may need to take to avoid exposure to

operation-related hazards and how they can maximise on opportunities

resulting from the operation.



Plan



Do



Assessing,

correcting and

improving

performance



Check



Reporting



Participatory monitoring is desirable. This entails involvement of stakeholders,

particularly affected communities, in monitoring and verifying information to

check that impact mitigation measures are appropriate.

Grievances will be handled as incidents and managed through the incident

procedure to enable the grievance to be received, documented, addressed and

results fed back to the complainants. This procedure will protect the

confidentiality of the persons raising the complaint, where necessary. The

feedback will be easily accessible and understandable to members of the

affected community and/or staff.

Stakeholders affected by the Project will be informed of progress in the

implementation of the management plans and of the effectiveness of

management measures.



11.6 Emergency preparedness and response

The Project will implement and maintain an Emergency Preparedness Response and

Recovery Plan (EPR&R). The plan will be in place prior to construction. The purpose of the

EPR&R is to provide a framework for a comprehensive system to:





establish a process to identify potential emergency situations prior to their occurrence;







take steps to prevent or minimize the impact of potential emergencies;







train personnel to appropriately identify, report and respond to emergencies;







provide and maintain emergency response resources and equipment to mitigate potential

emergencies;







define detailed procedural steps to respond and manage various types of potential

emergencies;







provide information to and consult with the surrounding community regarding

environmental risks and response measures;







co-ordinate with external emergency response organizations;







test communications, emergency procedures and equipment on a periodic basis;







contain, where practicable, any emergencies and their effects within Project site

boundaries;



U3823_Marampa_ESIS_Final.docx



September 2012

Page 233 of 298



SRK Consulting



Marampa Iron Ore Project ESIS – Main Report







safely return to normal operations following an emergency;







identify the cause(s) of an emergency event and the corrective and preventative

measure to avoid a reoccurrence; and







review and update plans and procedures based on lessons learned from tests and

responses to actual emergencies.



The EP&R will be prepared in accordance with:





IFC Performance Standards (PS) PS3 Resource Efficiency and Pollution Prevention and

PS4 Community Health, Safety and Security, which require that a plan is in place to

effectively respond to emergencies associated with Project hazards and that local

communities are involved in the planning process (IFC, 2012);







WBG General EHS Guidelines, Volume 3 Community Health and Safety, Section 3.7

Emergency Preparedness and Response and the equivalent sections of the Sectoral

EHS Guidelines relevant to the Project (WBG, 2007/8);







United Nations Environment Programme (UNEP) guidelines for Awareness and

Preparedness for Emergencies at Local Level (APELL), including the guidelines for

mining (UNEP, 2001), port areas (UNEP and the International Maritime Organisation,

1996) and dangerous goods transport (UNEP, 2000); and







the ICMM and UNEP guideline on good practice in emergency preparedness and

response (2005).



For the purposes of the EPR&R, the term “emergency” will refer to an unplanned event when

a Project operation loses control, or could lose control, of a situation that may result in risks to

human health, property or the environment. The EPR&R will not cover safe work practices for

frequent upsets or events, which will be covered by occupational health and safety plans.

The EPR&R will contain the following elements:





administration (relevant policy, purpose, distribution, definitions, scope, criteria for

triggering the EP&R, date and frequency of updates);







organisation of emergency areas (for example command centres and medical

stations);







roles and responsibilities;







communication systems (worker notification and

notification, media contacts and media relations strategy);







emergency resources (finance and emergency funds, fire services and medical

services, mutual aid agreements provide a clear basis for response by mutual aid

providers, contact list);







emergency equipment (such as location of isolation valves, helicopters and equipment

for fire fighting, toxicity testing, personal protection and pollution prevention equipment);







training and drills;







updating (to account for changes in equipment, personnel, and facilities);



communication,



community







checklists (role and action list and equipment checklist);







business continuity and contingency (including measures to allow business continuity

following an emergency, back-ups of critical information in a secure location to expedite

the return to normal operations following an emergency and alternative supplies of

resources such as water); and







clean up (options and procedures for clean-up following accidents);







emergency scenarios and risks (identified scenarios, people and environments at risk,



U3823_Marampa_ESIS_Final.docx



September 2012

Page 234 of 298



SRK Consulting



Marampa Iron Ore Project ESIS – Main Report



maps of risk areas, locations of hazardous substances and properties of hazardous

substances);





emergency response procedures for each emergency scenario (with specific

information on specific procedure triggers, response actions, equipment, relevant

notification procedures, relevant communication procedures, alarm systems, relevant

evacuation procedures, relevant media procedures, medical procedures, assessment,

monitoring and recording of the progress of the accident, procedures for operational shut

down if necessary, relevant procedures for clean-up, recording of actions taken to

respond and de-activation of the procedure); and







review (to identify missing or weak elements, consistency with any regional and national

disasters plans and compliance with relevant legislation and codes).



The emergency scenarios covered by the EPR&R will be determined by means of risk

assessments. Procedures will be developed for at least the following events:





off-site chemical, oil or fuel spills;







on-site chemical, oil or fuel spills;







slope failure at the tailings storage facilities, waste rock facilities or mine workings;







concentrate pipeline failure;







emergencies arising from natural hazards such as earthquakes, sandstorms, extreme

heat/cold, flash floods, monsoons, moving sand dunes, and extreme precipitation;







security incidents such as lost contact/ missing person, sabotage or a threat to kill/injure

employees;







vehicle or equipment accidents;







medical emergencies;







fire; and







blasting and explosives accidents.



The EPR&R will distinguish between two types of emergencies as follows:





Type 1 – emergencies contained within Project site boundaries requiring use of MIOL’s

emergency resources, but not requiring external resources;







Type 2 – emergencies not contained within the Project site boundaries and/ or requiring

involvement of external resources.



Type 2 emergencies require application of relevant APELL guidelines. The primary goals of

APELL are:





to raise awareness of local communities living close to industrial activities on how to

react if an accident happens; and







to establish adequate coordination and communication in situations where the public

might be affected by accidents and emergencies arising from natural hazards (such as

floods).



APELL is a multi-stakeholder dialogue working through a stepwise process comprising the 10

steps listed in the textbox below.



U3823_Marampa_ESIS_Final.docx



September 2012

Page 235 of 298



SRK Consulting

























Marampa Iron Ore Project ESIS – Main Report



The APELL process

Step 1 – identify emergency response participants and establish their roles, resources and concerns;

Step 2 – evaluate risks and hazards that may result in emergency situations in the community and define

options for risk reduction;

Step 3 – have participants review their own emergency plan, including communication for adequacy relative

to a coordinated response;

Step 4 – identify the required response tasks not covered by existing plans;

Step 5 – match to resources available from the identified participants;

Step 6 – make changes necessary to improve existing emergency plans, integrate them into an overall

community plan and gain agreement;

Step 7 – commit the integrated community plan to writing and obtain endorsement for it and relevant

approvals;

Step 8 – communicate final version of integrated plan to participating groups and ensure that all emergency

responders are trained;

Step 9 – establish procedures for periodic testing, review and updating of the plan; and

Step 10 – communicate the integrated plan to the general community.



U3823_Marampa_ESIS_Final.docx



September 2012

Page 236 of 298



SRK Consulting



12



Marampa Iron Ore Project ESIS – Main Report



CONCLUSIONS AND OVERALL ASSESSMENT

This report documents the ESIA process undertaken on behalf of MIOL for the Marampa Iron

Ore Project in the Marampa area of Sierra Leone. The ESIA has been prepared in

accordance with the Environment Protection Agency Act No. 11 of 2008 (EPA Act 2008). The

assessment of environmental and social impacts has been conducted in consideration of

input received through a comprehensive stakeholder consultation process.

The Project is being developed by MIOL, and involves four open pits for mining of iron ore (in

two Stages of development), the associated mining waste storage areas, haul roads,

beneficiation plant and accommodation areas. Infrastructure for export of product, over and

above that which will be transported via rail to Pepel port is excluded from this ESIA. Export of

product through Tagrin Point will require additional infrastructure, which will be handled under

an amendment to this ESIA, once the details thereof are known.

A Project of this scale has the potential to cause multiple impacts, both negative and positive.

This report was prepared to inform decision-makers regarding the ‘triple bottom line’

(economic, environment and social) of the Project, by providing an objective and

comprehensive analysis of the potential impacts and benefits. It has examined the Project

design information and drawn on both available (secondary) and specifically collected

(primary) baseline data (including local knowledge), as well as the discussions with

stakeholders, to identify and evaluate environmental and socio-economic impacts of the

proposed Project. This analysis has created a framework for the formulation of appropriate

management measures.

This ESIA report incorporates the following components:





an overview of the legal, regulatory and policy framework within which the Project has

been developed and will operate (Chapter 2);







a description of the ESIA process undertaken, including the associated stakeholder

consultation processes (Chapter 3 and Appendix C);







a description of the Project’s activities and the associated environmental control

measures that are inherent in the design, along with an overview of the alternatives

considered by the Project team (Chapter 4);







a description of the environmental and social setting of the Project (Chapters 5 and 6);







an analysis of the potential environmental and social impacts and risks arising as a result

of the Project along with the management measures necessary to prevent, minimise or

optimise the impacts, as necessary (Chapters 7, 8 and 9, and Appendix F); an analysis

of the potential cumulative impacts resulting from the Project (Chapter 10)







a proposed environmental and social management system (ESMS) framework to enable

the identified management measures to be successfully implemented and compliance

evaluated (Chapter 11, and Appendix F).



The scope and timing of the various baseline studies undertaken to provide data for the

impact assessment were developed and adapted to address the shifting focus of the Project

design with regard to spatial extent and production capacity. Due to the relatively early stage

of Project development, the Project description is based on the findings of the technical

scoping study, rather than more detailed pre-feasibility or feasibility studies. This required

certain assumptions to be made, particularly for the studies involving predictive impact

modelling. These assumptions (as well as any limitations) are clearly stated in the discussions

regarding the impact ratings concerned, and may have resulted in overly conservative impact

U3823_Marampa_ESIS_Final.docx



September 2012

Page 237 of 298



SRK Consulting



Marampa Iron Ore Project ESIS – Main Report



ratings for these impacts. The lack of specific detail regarding certain aspects of the Project

description (such as use of explosives) is therefore not considered to compromise the integrity

of the ESIA, provided any changes to the Project description (such as the inclusion of facilities

for product export during Stage 2) are assessed via an amendment to this ESIA.

Although the ESIA is currently intended to meet in-country requirements only, it has been

compiled with international standards in mind. Thus, wherever possible, data which may be

required for an internationally compliant ESIA have been included (for example, additional

seasonally dependent studies such as natural resource use and aquatic biodiversity).

Additionally, wet season rounds of natural resource use and surface water hydrology studies

are planned for Q3 of 2012.

The final phase of the ESIA process is regulatory review. As part of this process, this

document will be made available to interested stakeholders in accordance with the

Stakeholder Engagement Plan (Appendix C). Feedback received during this process will be

provided to the regulatory authorities.

The ESMS presented in Chapter 11 is an adaptable tool, able to respond to changes and

refinements in the Project description, as well as the social development plan. The robustness

of the supporting management programmes, along with implementation, assurance and

continual improvement functions, are fundamental to enabling the successful implementation

of management measures by MIOL, its contractors and sub-contractors.

By its nature, impact assessment can disaggregate the effects of a Project and, although it is

necessary to examine the significance of individual impacts, an overly intensive focus on such

impacts can detract from a more holistic assessment. As a result, the potential cumulative

impacts of the Project in its developmental environmental context have been examined in

Chapter 10.

In association with Chapter 10, this concluding section aims to provide this more holistic view

– a qualitative re-aggregation and synthesis of impacts, both negative and positive, which

recognises the Project will result in some negative impacts, but that there will be significant

social and economic benefits too.

A summary of the potential impacts is given in the Table 12-1 below, including the

consequence and probability, as well as the overall significance and confidence rating. The

significance is colour coded, with red indicating negative impacts and green positive. Where

consequential mitigation or enhancement measures are proposed, the residual impact ratings

are also given. For those impacts of potentially higher significance, mitigation measures are

defined and committed to in order to lower their significance to acceptable levels; this is

shown in the residual impact column. With the implementation of the mitigation measures

listed in the individual impact rating tables (and summarised in the EMP in Appendix F), the

significance of all negative impacts assessed is predicted to decrease to medium or low. As

committed to in the Project’s ESMS, these impacts will be reviewed periodically to determine

if they are still relevant and if so whether the impact significance has changed.

Most of the Project’s biophysical impacts are predicted to be of medium to low significance

due to a combination of inherent design and natural mitigation. The most significant

biophysical impacts are expected to relate to land transformation (affecting use of the land

and access by local communities) and changes to surface water flow. Socioeconomic impacts

of the Project are predicted to be wide ranging, and potentially significant, both positive and

negative.

U3823_Marampa_ESIS_Final.docx



September 2012

Page 238 of 298



SRK Consulting



Marampa Iron Ore Project ESIS – Main Report



The Project’s combined economic benefits to local communities as well as Sierra Leone as a

whole, including increased employment, economic growth, infrastructure development, and

direct and indirect fiscal receipts, will be significant (particularly with the recommended

enhancement measures). The economic growth expected to result from the Project may have

the potential to negatively affect some communities, particularly more vulnerable groups, but,

in the majority of cases, will benefit the host communities.

Land acquisition and relocation of a number of villages (approximately 10) due to positioning

of the Project infrastructure and impacts such as noise and dust emissions, will result in

some negative impacts on local communities, particularly in terms of their livelihoods and

access to natural resources, and, potentially, social order. Negative impacts on community

health, safety and security, are predicted to be low to medium for communities other than

those that will be relocated. However, the implementation of a resettlement action plan,

agreed to by the affected stakeholders, has the potential to result in equal or potentially better

situations for the affected people.

The overall conclusion of this ESIA is that the negative potential impacts assessed can be

reduced to acceptable levels with effective mitigation and management measures, which

MIOL is strongly committed to implementing. In addition, the positive economic development

impacts of the Project can be expected to be significant, not only at the local and regional

level, but also at the national level. For the local communities, this will be manifested in areas

such as employment and resultant wealth generation; training and skills development;

potential for enhanced government investment towards social development in the Project

areas as a result of tax and royalties derived from the mining operation; and the stimulation of

local economic growth in general as a result of Project generated opportunities for local

suppliers and contractors. Finally, MIOL is committed to supporting community development,

continuing to undertake stakeholder consultation and information disclosure, and monitoring

the effectiveness of its environmental and social management programmes throughout the

Project life cycle to international standards of implementation.



U3823_Marampa_ESIS_Final.docx



September 2012

Page 239 of 298



SRK Consulting



Marampa Iron Ore Project ESIS – Main Report



Table 12-1: Preliminary summary of environmental, socio-economic and health and safety impact ratings

Significance rating

Impact groups



Identified impacts



Initial impact



Residual/ enhanced

impact



Confidence



Biophysical Impacts



Land

transformation



Water

resources



Ecology and

biodiversity



Impact LT1: Change in land use as a result of mine and related infrastructure limiting use by local communities



Refer to Impact RL1



Impact LT2: Disruption of community access routes by mine infrastructure, resulting in social disruption



Refer to Impact RL2



Impact LT3: Mine infrastructure and activities resulting in visual intrusion and loss of ‘sense of place’ for local

communities



MEDIUM



LOW



Medium



Impact LT4: Loss of topsoil through erosion, decreasing land capability



MEDIUM



LOW



High



Impact LT5: Fugitive dust resulting in changes in soil chemistry and agricultural land capability



MEDIUM



LOW



Medium



Impact WR1: Pit dewatering potentially resulting in reduced groundwater availability to ecological systems and

local communities



MEDIUM



LOW



Low



Impact WR2: Surface water abstraction affecting downstream users



LOW



No Residual Impact



High



Impact WR3: Project infrastructure causing altered flow conditions, affecting downstream users



HIGH



MEDIUM



Medium



Impact WR4: Surface water diversions potentially causing changes to flood risk to adjacent agricultural areas

and communities



LOW



No Residual Impact



Medium



Impact WR5: Seepage from mining wastes potentially resulting in deteriorated water quality affecting

communities and ecological systems



LOW



No Residual Impact



Medium



Impact WR6: Discharge or runoff to surface water potentially resulting in deteriorated water quality affecting

communities and ecological systems



MEDIUM



LOW



High



Impact EB1: Site clearance and positioning of Project infrastructure potentially resulting in habitat loss and

fragmentation, and direct loss of fauna and flora



MEDIUM



LOW



Medium



Impact EB2: Soil disturbance facilitating the establishment and spread of invasive species, affecting indigenous

ecosystems



MEDIUM



LOW



High



Impact EB3: Project activities potentially resulting in sensory or other disturbance to wildlife



LOW



No Residual Impact



High



Impact EB4: Mine infrastructure and activities attracting nuisance species, resulting in impacts on indigenous

ecosystems



LOW



LOW



Medium



U3823_Marampa_ESIS_Final.docx



September 2012

Page 240 of 298



SRK Consulting



Marampa Iron Ore Project ESIS – Main Report



Significance rating

Impact groups



Identified impacts



Initial impact



Residual/ enhanced

impact



Confidence



Impact ED1: Employment generation by the Project resulting in increased standard of living for the local

community



MEDIUM



HIGH



High



Impact ED2: Employee training leading to skills development in the local community



MEDIUM



HIGH



Medium



LOW



MEDIUM



Low



Impact ED4: Opportunities for local suppliers and contractors leading to economic growth



LOW



MEDIUM



Medium



Impact RL1: Impoverishment through loss of shelter, land and communal natural resources



HIGH



MEDIUM



High



Impact RL2: Changes to community as a result of the Project potentially affecting livelihoods, access to

communal social services and infrastructure and community cohesion



HIGH



LOW



Medium



Socio-economic Impacts



Economic

development



Resettlement

and loss of land

and social and

natural

resources



Social order



Cultural

heritage



Decommissioning and

closure



Impact ED3: Increase in government income (from taxes and royalty on mining) potentially leading to social

development in the Project area



Impact RL4: Added pressure on limited host community resources, potentially resulting in food insecurity and

malnutrition



Impact not rated as it is dependent on the characteristics of

the host community, which has not yet been decided.



Impact SO1: Influx of job seekers causing increased pressure on government services and infrastructure,

potentially resulting in reduced standard of living



MEDIUM



Impact SO2: Increase in social ills/problems



LOW



Medium



MEDIUM



LOW



Medium



Impact SO3: Real or perceived unequal distribution of Project benefits leading to social tension



HIGH



MEDIUM



High



Impact AC1: Disturbance to sacred bushes and cemeteries leading to loss of community’s access cultural

resources



HIGH



LOW



High



Impact DC1: Closure of mine leading to economic decline



HIGH



MEDIUM



Medium



MEDIUM



LOW



Medium



Impact NV1: Blasting causing air overpressure and vibrations, resulting in disturbance of local communities



LOW



No Residual Impact



Low



Impact NV2: Operation of mining equipment and vehicles resulting in increase in background noise levels for

local communities



LOW



No Residual Impact



Medium



Impact TS1: Increase in Project-related traffic on local and national roads causing increased wear and tear and

risk of road accidents



MEDIUM



LOW



Medium



Impact TS2: Use of mine site roads by local communities causing increased safety risks due to road accidents



MEDIUM



LOW



Medium



Community health, safety and Security Impacts

Air quality



Noise and

vibrations



Traffic safety



Impact AQ1: Dust emissions causing nuisance and health impacts on local communities



U3823_Marampa_ESIS_Final.docx



September 2012

Page 241 of 298



SRK Consulting



Marampa Iron Ore Project ESIS – Main Report



Significance rating

Impact groups



Identified impacts

Impact SR1: Risk of human rights abuses due to conflict with communities



Social risks



Impact SR2: Increased exposure to communicable diseases due to an influx of workers, resulting in a

deterioration in public health



Initial impact



Residual/ enhanced

impact



Confidence



HIGH



LOW



High



MEDIUM



LOW



Medium



Other hazards potentially resulting in injury

Impact OH1: Blasting resulting in fly rock potentially harming people or their belongings

Hazards



Impact OH2: Community exposure to toxic or hazardous substances

Impact OH3: Fire or explosions due to storage of explosives and use of combustible materials

Impact OH4: Failure of the TSF resulting in pollution or harm to individuals



U3823_Marampa_ESIS_Final.docx



Because of the number of variables affecting the

consequence and probability of such events, accurate

significance rating of possible impacts should the risk

materialise is not possible. Each event must be evaluated on

an individual basis



September 2012

Page 242 of 298



SRK Consulting



13



Marampa Iron Ore Project ESIS – Main Report



REFERENCES

th



Brady, N.N. and Weil, R.R. 2002. The Nature and Properties of Soil (13 edition), Prentice

Hall, New Jersey

Taylor, JC, Harding, WR and Archibald, CGM 2007b. An illustrated guide to some

commondiatom species from South Africa. Water Research Commission Report TT282/07.

Water Research Commission. Pretoria.

Van Dam, H., Mertens A., and Sinkeldam, J. 1994. A coded checklist and ecological indicator

values of freshwater diatoms from The Netherlands. Aquatic Ecology 28(1): 117-133.

Payne, A. I, Wakeford, R. C. and Ndomahina, T. E. 2010. Fish distribution and zonation

along a tropical African river, the Rokel/Seli River, Sierra Leone, West Africa. Smithiana

Bulletin 12: 25–36.

Bousso, T. and Lalèyè, P. 2006c. Marcusenius meronai. In: IUCN 2010. IUCN Red List of

Threatened Species. Version 2010.4. . Downloaded on 03 May 2011.

Bousso, T. and Lalèyè, P. 2006e. Tilapia joka. In: IUCN 2010. IUCN Red List of Threatened

Species. Version 2010.4. . Downloaded on 01 May 2011

Brown, D. S 1994. Freshwater snails of Africa and their medical importance.

Francis. Revised second edition. London. x + 609 pp.



Taylor &



Kristensen, T.K. and Stensgaard, A-S. 2006. Sierraia leonensis. In: IUCN 2010. IUCN Red

List of Threatened Species. Version 2010.4. . Downloaded on 27

October 2010.

Lalèyè, P. 2006. Scriptaphyosemion roloffi. In: IUCN 2010. IUCN Red List of Threatened

Species. Version 2010.4. . Downloaded on 01 May 2011.

Canadian Council of Ministers of the Environment (CCME), 2007. Available online at

http://www.ccme.ca

Statistics Sierra Leone, 2008. Available online at: www.statistics.sl

EM-DAT, 2012. International Disaster Bureau. Available online at www.emdat.be

PreventionWeb, 2012,

www.preventionweb.net



Disaster



reduction



community



website.



Available



online



at



Okoni-Williams, A.D, Shokellu Thompson, H., Wood, P., Koroma, A.P. and Robertson, P.

2001. Sierra Leone. In: Fishpool, L.D.C. and Evans, M.I. (eds) Important Bird Areas in Africa

and Associated Islands: Priority Sites for Conservation. Birdlife Conservation Series 11.

BirdLife International.

Nippon Koei UK. 2005. Bumbuna Hydroelectric Project Environmental Impact Assessment.

January 2005. Nippon Koei UK International Consulting Engineers.

Bateman, 2012. Revised Scoping Study Report M6037-2700-001, April 2012

NSADP, 2009. National Sustainable Agriculture Development Plan (2010 – 2030). Sierra

Leone’s comprehensive African Agriculture Development Programme. 45pp

rd



Mason, B; 1966. Principles of Geochemistry. 3 Edition. John Wiley and Sons Inc. 329pp

IFC (International Finance Corporation) (2007). Environmental Health and Safety Guidelines



U3823_Marampa_ESIS_Final.docx



September 2012

Page 243 of 244



SRK Consulting



Marampa Iron Ore Project ESIS – Main Report



for Mining, World Bank Group. Available at: http://www.ifc.org

International Union for the Conservation of Nature (IUCN) 2001. IUCN Red List Categories

and Criteria: Version 3.1.



U3823_Marampa_ESIS_Final.docx



September 2012

Page 244 of 244



SRK Consulting

Units



Marampa Iron Ore Project ESIS – Glossary, Abbreviations,



Glossary

TERM



EXPLANATION



Aquifer



An underground layer of water-bearing permeable rock, or unconsolidated

materials (gravel, sand, silt, or clay) from which groundwater can be usefully

extracted using a water well.



Background or

baseline conditions



The level or concentration of the substance or compound being measured,

prior to additional activity.



Baseline data



Data gathered during the Social and Environmental Assessment used to

describe the relevant existing conditions of the project, such as physical,

biological, socio-economic, and labour conditions, including any changes

before the project commences.



Bioaccumulation



Means to accumulate in a biological system and is commonly taken to

measure the uptake over time of a substance, called a bioaccumulant, that

can accumulate in a biological system



Biodiversity



An integrating concept that includes the ecosystems within which the people

of the world live, as well as the multitude of species that are used by

humankind for food, fibre, medicines, clothing and shelter. Biodiversity is the

variety of life in all its forms, including genetic, species and ecosystem

diversity.

The total area from which a river or waterway collects surface water runoff.



Catchment

Consultation



Consultation involves two-way communication between the client and the

affected communities. The consultation process should be undertaken in a

manner that is inclusive and culturally appropriate and that provides the

affected communities with opportunities to express their views on projects

risks, impacts and mitigations measures, and allows the client to consider and

respond to them. The consultation process will ensure free, prior and

informed consultation.



Cultural heritage



A unique and non-renewable resource that possesses cultural, scientific,

spiritual or religious value and includes moveable or immoveable objects,

sites structures, groups of structures, natural features, or landscapes that

have archaeological (prehistoric), paleontological, historical, cultural, artistic,

and religious values, as well as unique natural environmental features that

embody cultural values, such as sacred groves.



Cumulative impacts



Impacts associated with the proposed project in combination with the impacts

of other past, existing and proposed developments in the area.



Deposit



An anomalous occurrence of a specific mineral or minerals within the earth’s

crust



Downstream



The direction toward which groundwater is moving under natural conditions:

from higher to lower piezometric heads



Effluent



Wastewater (treated or untreated) that flows out of a treatment plant, sewer,

or industrial outfall; generally refers to wastes discharged into surface waters.



Endangered species



Species that are under threat of extinction.



Environmental

impacts



Are the consequences of project activities or aspects on environmental

resources or receptors of particular value or sensitivity.



Fault



A planar rock fracture which show evidence of relative movement



Feasibility study



A definitive engineering study addressing the economic viability of bringing a

deposit to the production stage; taking into consideration all associated costs,

revenues and risks



Geomorphology



The scientific study of landforms and the processes that shape them.



Greenhouse gases

(GHGs)



The six greenhouse gases that form the Kyoto Protocol to the United Nations

Framework Convention on Climate Change i.e. Carbon Dioxide (CO2),

Methane (CH4), Nitrous oxide (N20), Hydro fluorocarbons (HFCs),



U3823_Marampa_ESIS_Final.docx



September 2012

Page i of iv



SRK Consulting

Units



TERM



Marampa Iron Ore Project ESIS – Glossary, Abbreviations,



EXPLANATION

Perfluorocarbons (PFCs), Sulphur hexafluoride (SF6). Some greenhouse

gases occur naturally in the atmosphere, while others result from human

activities.



Groundwater



The part of the subsurface water that is the zone of saturation, including

underground streams



Groundwater table



The level below the earth's surface at which the ground becomes saturated

with water. The water table is set where hydrostatic pressure equals

atmospheric pressure



Hazardous waste



Substances classified as hazardous wastes possess at least one of four

characteristics- ignitability, corrosivity, reactivity, or toxicity - or appear on

special lists.



Information disclosure

(also Public

Disclosure)



The process of providing information to the affected communities and other

stakeholders that is timely, accessible, understandable, and in the

appropriate language(s). For projects with potential adverse impacts,

information on the purpose, nature and scale of the project, the duration of

proposed project activities, and any potential risks to and potential impacts on

such communities should be included.



Infrastructure



The supporting installations and services that supply the needs of the project.



Land capability



The ability of the land to support a particular land use. Classification is based

on an assessment of the land's biophysical characteristics, the extent of

which these will limit particular land uses, the current management

technology available and soil erosion hazard.



Leachate



The liquid that can appear from beneath waste rock or ore/tailings deposits.

Leachate can sometimes contain dissolved minerals, metals or chemicals

leached out of ore, rock or soils.



Local community



Community within a project’s area of influence.



Mitigation measures



The measures attempting to prevent hazards from developing into disasters

altogether, or to reduce the effects of disasters when they occur



Open pit



Mine excavation produced by quarrying or other surface earthmoving

equipment.



Ore



Accumulation of minerals containing a substance which can be economically

recovered.



Ore body



The column of rock contained the mineral resource



Permeability



Degree to which fluids can move through rock or soil.



Pollution



Refers to both hazardous and non-hazardous pollutants in the solid, liquid, or

gaseous forms, and is intended to include other forms such as nuisance

odours, noise, vibration, radiation, electromagnetic energy, and the creation

of potential visual impacts including light.



Pre-feasibility Study



The initial stage of the feasibility study in which the accuracy of the factors

involved such as costs and revenues is ± 25%.



Receptors



Comprise people or human-made systems, such as local residents,

communities and social infrastructure.



Resources



Components of the biophysical, socio-cultural and economic environment that

can be used for some purpose.



Run-off



That part of precipitation, snow melt, or irrigation water that drains or flows off

the land into streams or other surface waters



Seepage



The escape of liquids downward through the soil



Significance of impact



The significance of the unmanaged and managed impacts taking into

consideration the probability of the impact occurring, the extent over which

the impact will be experienced, and the intensity/severity of the impact.



Stakeholder



A person or group that has an investment, share, or interest in something, as

a business or industry.



U3823_Marampa_ESIS_Final.docx



September 2012

Page ii of iv



SRK Consulting

Units



Marampa Iron Ore Project ESIS – Glossary, Abbreviations,



TERM



EXPLANATION



Stakeholder

engagement



Engagement is an on-going process involving disclosure of information,

consultation with affected communities, and the establishment of a grievance

mechanism.



Tailings



Material rejected from treatment plant after the recoverable valuable minerals

have been extracted.



Waste rock



Rock excavated from pit, no longer required and placed in a waste pile



Working conditions



Conditions in the workplace and treatment of workers. Conditions in the

workplace include the physical environmental, health and safety precautions

and access to sanitary facilities. Treatment of workers includes disciplinary

practices, reasons and process for termination of workers and respect for the

worker's personal dignity.



Abbreviations

AML

ANFO

ANZECC

ARPS

ARDML

Bateman

BID

Cape Lambert

CBO

DELCO

DoE

EHS

EMP

EPA

EPCM

EPR&R

ESIA

ESMS

ESS

FEL

GDP

GIIP

GoS

HDPE

HEC-RAS

HFO

IFC

IFC PS

London Mining

MCC

MIOL

MLCPE

MMR



African Minerals Limited

Ammonium nitrate-fuel oil

Australian and New Zealand Environmental Conservation Council

African Railways and Port Services Ltd

Acid Rock Drainage Mineral Leaching

Bateman Engineering Pty Ltd – authors of the Mining Scoping Study

Background Information Document

Cape Lambert Resources Limited

Community Based Organisation

Sierra Leone Development Company Ltd

Department of Environment

Environmental, Health and Safety

Environmental Management Programme

Environmental Protection Agency (also known as SLEPA)

Engineering, Procurement and Construction Management

Emergency Preparedness, Response and Recovery Plan

Environmental and Social Impact Assessment

Environmental and Social Management System

Environmental Scoping Study

Frontend Loader

Gross Domestic Product

Good International Industry Practice

Government of Sierra Leone

High Density Polyethylene

Hydrologic Engineering Centre’s River Analysis System

Heavy Fuel Oil

International Finance Commission

International Finance Corporation Performance Standards on Social and

Environmental Sustainability

London Mining plc

Motor Control Centre

Marampa Iron Ore Limited

Ministry of Lands, Country Planning and the Environment

Ministry of Mineral Resources



U3823_Marampa_ESIS_Final.docx



September 2012

Page iii of iv



SRK Consulting

Units



NACEF

NAF

NAG

NGO

PAP

QA/QC

ROM

RWG

SD

SEP

SLEPA

SRK

ToR

TSF

UNEP

WHIMS

WHO

WRD



Marampa Iron Ore Project ESIS – Glossary, Abbreviations,



National Environmental and Forestry Commission

Non Acid Forming

Net Acid Generation

Non-government Organisation

Project Affected People

Quality Assurance / Quality Control

Run of Mine

Resettlement Working Group

Supporting Document

Stakeholder Engagement Plan

Sierra Leone Environmental Protection Agency (also known as EPA)

SRK Consulting (UK) Ltd

Terms of Reference

Tailings Storage Facility

United Nations Environment Programme

Wet High Intensity Magnetic Separation

World Health Organisation

Waste Rock Dump



Units

Mt

Masl

Mtpa

Mbgl

Ha

bcm

kt

µm

kV

MW

°C



Million metric tonnes

Metres above sea level

Million metric tonnes per anum

Metres below ground level

Hectares

Bank cubic metre

Kilo tonne

Micrometres

Kilovolts

Megawatt

Degrees Celcius



U3823_Marampa_ESIS_Final.docx



September 2012

Page iv of iv



SRK Consulting



Marampa Iron Ore Project ESIS – Technical Appendix A



APPENDIX A

A



SUMMARY OF APPLICABLE LEGISLATION AND

INTERNATIONAL GUIDELINES



U3823_Marampa_ESIS_Final.docx



September 2012

Page A1 of A1



1

Appendix A



Appendix A: Relevant Legislation and International Standards

1 INTRODUCTION



1



2 NATIONAL LAW



2



2.1 Introduction and overview

2

2.2 Legislative and regulatory framework for environmental management

3

2.2.1 National Environmental Policy

3

2.2.2 Government agencies responsible for the environment

4

2.2.3 The Environment Protection Agency Act (No. 11 of 2008)

5

2.2.4 EIA procedure specified in the EPA Act 2008

5

2.2.5 Guidelines on EIA procedures

6

2.3 Environmental management provisions in mining legislation

9

2.3.1 The Mines and Minerals Act 2009

Error! Bookmark not defined.

2.4 Legislation pertaining to disturbance of forests

13

2.4.1 Forestry Act, 1988

13

2.4.2 The Forestry Regulations, 1989

14

2.5 Water law

15

2.5.1 Current legislation

15

2.5.2 National Water and Sanitation Policy

15

2.5.3 Water permits needing to be obtained

17

2.6 Legislation pertaining to land tenure

17

2.7 The Factories Act – 1974

18



3 INTERNATIONAL LAW, STANDARDS AND CODES OF CONDUCT



19



3.1 International law

3.1.1 Declarations and customary law

3.1.2 Multilateral treaties

3.1.3 Regional treaties influencing international practice

3.2 Conditioning of project finance: Equator Principles and the IFC Performance

Standards and World Bank EHS Guidelines

3.2.1 Introduction to the Equator Principles

3.2.2 Introduction to the IFC Performance Standards

3.3 Self regulation in the mining sector

3.3.1 United Nations Global Compact and the Global Reporting Initiative

3.3.2 International Council on Mining and Metals Sustainable Development

Framework

3.3.3 Voluntary Principles on Security and Human Rights

3.3.4 The Extractive Industry Transparency Initiative

3.3.5 Mining and Metals Sector Good Practice website



4 REFERENCES



1



19

21

22

26

26

26

27

32

32

32

33

34

34



35



INTRODUCTION

This appendix outlines legislation, standards and codes of practice influencing the approach

to the ESIA for the Marampa Project and will continue to influence management practices

throughout the life of the project. The focus is on legal instruments and guidelines applicable

to biological, physical and social dimensions of the environment and sustainable

development. Relevant legislation in Sierra Leone is outlined in Section 2. The influences

and obligations arising from international law, standards and codes of practice are

considered in Section 3.



U3823



August 2012



2

Appendix A



2



NATIONAL LAW

This section identifies legislation relevant to the environment (Section 2.1) and then focuses

on the regulatory framework for environmental management in Sierra Leone, including

relevant environmental impact assessment (EIA) legislation and guidelines (Section 2.2) and

environmental provisions in mining legislation (Section 2.3).

It also provides brief

background on the status of legislation pertaining to use of forest resources, water

resources, and land resources (Sections 2.4, 2.5 and2.6, respectively).



2.1



Introduction and overview

Since Sierra Leone’s emergence from the civil war in 2002, much effort is being directed into

the reform of law to improve governance and promote security, peace and development. All

legislation pertinent to resources such as minerals, water and land is under review. The

revisions are generally being made to promote good governance and address the lack of

institutional capacity and monitoring mechanisms. The revisions are also geared to

encourage foreign and local investment and development that will be socially and

economically beneficial for the country. Furthermore, the revisions are being undertaken to

meet the requirements of the many international treaties that Sierra Leone has signed in the

last decade.

A summary of current legislation pertinent to the environment and to sustainable

development needing to be taken into account in the planning and implementation of the

Marampa Project is listed in Table 2-1.



Table 2-1: Sierra Leone legislation pertinent to the environment and

sustainable development of the Marampa Project

Primary

subject



Policy



Legislation



Environment

and

sustainable

development



National

Environmental Policy

(1994)







The Environment Protection Agency Act, 2008 (No. 11 of

2008)



Mineral

resources and

mining



Core Mineral Policy of

the Government of

Sierra Leone (2008)









National Reconstruction and Development Act, 1999

(No. 5 of 1999)

Mines and Minerals Act,1994



Water



National Water and

Sanitation Policy

(August 2008)









The Water (Control and Supply) Act, 1963

Sierra Leone Water Company Act, 2001 (No. 6 of 2001)



Biodiversity

and biological

resources



National Biodiversity

Strategy and Action

Plan (developed in

accordance with the

requirements of the

convention on







Wildlife Conservation Act, 1972 (No. 27 of 1972)









Forestry Regulations, 1989 (P.N. No. 17 of 1990)

Forestry Act, 1988



Forestry



U3823



August 2012



3

Appendix A



Primary

subject



Policy



Legislation















Sierra Leone Fisheries (Management and Development)

(Amendment) Act, 2007 (No. 10 of 2007)

Fisheries Regulations, 1995

Fisheries (Management and Development) Decree, 1994

Fisheries (Amendment) Regulations, 1994 (P. N. No. 4 of

1994)

Fisheries Management and Development (Amendment)

Act, 1992 (No. 7 of 1992)

Fisheries Regulations, 1990 (Public Notice No. 15 of

1990)

Fisheries Management and Development (Amendment)

Act, 1990 (Act No. 9 of 1990)

Fisheries Management and Development Act, 1988 (Act

No. 4)

Fisheries (Operation of Foreign Motor Fishing Vessels)

Regulations, 1985 (P.N. No. 1 of 1986)

Devolution of Estates Act, 2007 (No. 21 of 2007)

Land Commission Act (not promulgated yet)

Commercial Lands Act (not promulgated yet)

Protection from Radiation Act, 2001 (No. 14 of 2001)



Occupational

environment







The Factories Act, 1974 (1974)



Local

government







Local Government Act, 2004 (2004): An Act which

provides for decentralisation and devolution of functions,

powers and services to local councils.



Fishing and

marine

resources





















Land



National Lands Policy

(2005)



Radiation



2.2



Legislative and regulatory framework for environmental management



2.2.1



National Environmental Policy

A National Environmental Policy was developed for Sierra Leone in 1994.

objectives and strategies of the policy are outlined in Table 2-2.



The goals,



Table 2-2: Outline of the National Environmental Policy

Aspect

Goal



Commitments











Objectives









Strategies







U3823



To achieve sustainable development in Sierra Leone through sound environmental

management.

To secure for all Sierra Leoneans a quality of environment adequate for their health

and well being;

To conserve and use the environmental and natural resources for the benefit of

present a future generations;

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; and

To raise public awareness and promote understanding of the essential linkages

between environment development and to encourage individual and community

participation in environmental improvement efforts.

To establish and/or strengthen environmental protection standards, monitor

changes in, and publish relevant data on, environmental quality and resource use;

To promote prior EIA of 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; and

To promote environmental management through the creation of administrative and

infrastructural support with appropriate financial backing;

To cooperate in good faith with other countries and agencies to achieve optimal use

of transboundary natural resources and effective prevention or abatement of

transboundary environmental protection.



August 2012



4

Appendix A



2.2.2



Government agencies responsible for the environment

The Environment Protection Agency Act (No. 11 of 2008), promulgated in September 2008,

provides for the establishment of an Environment Protection Agency (EPA). The EPA will

take over responsibility for environmental matters from other institutions that have held these

responsibilities in the last decade. These institutions are:





the Department of Environment (DOE), within the Ministry of Lands, Country Planning

and the Environment (MLCPE);







the National Environment Protection Board; and







the National Environmental and Forestry Commission (NACEF), which was

established in 2005 by the President (President Ahmad Tejan Kabbah), and which

was later referred to as the Environment Commission (according to the National Water

and Sanitation Policy, published by the Ministry of Energy and Power, August 2008).



The responsibilities of the DOE and National Environmental Protection Board were defined

in the Environment Protection Act (No. 2 of 2000), which was repealed with the promulgation

of the EPA Act 2008. It is understood NACEF/ the Environment Commission was a

precursor to the EPA. The administrative staff and structures of the DOE were reported to

function within the NACEF/ Environment Commission framework in 2008 (University of

Sierra Leone, 2008).

In terms of the new EPA Act 2008 (Sections 3 to 5 and 13), the governing body of the EPA is

a Board of Directors, which comprises a chairman and senior representatives of several

ministries with an interest in environmental matters, three people knowledgeable in

commence, finance and law, and the Executive Director of the EPA. The Board has control

and supervision of the EPA and is responsible for ensuring efficient implementation of the

functions of the EPA. The EPA is not subject to the direction or control of any person or

authority other than the EPA Board.

1



The Act names the ministries to be represented on the EPA Board as follows: Ministry of

the Environment; Ministry of Local Government; Ministry of Mineral Resources; Ministry of

Marine Resources; Ministry of Agriculture and Forestry; Ministry of Tourism; Ministry of

Trade and Industry; Ministry of Transport; Ministry of Health; and Petroleum Unit.

The EPA is required to advise “the Minister” on the formulation of policies on all aspects of

the environment, co-ordinate the activities of bodies concerned with the environment and

serve as a channel of communication between such bodies and the Minister. The Act

defines “the Minister” as “the Minister charged with responsibility for the environment”. It

also states “the Ministry shall be construed accordingly”.

Additional functions of the EPA are to:





ensure compliance EIA procedures;







issue environmental permits, pollution abatement notices, directives, procedures and

warnings;







prescribe environmental standards and guidelines;



1



The titles of the named Ministries are not the same as the official names of the equivalent ministries. For example, at present

there is no “Ministry of Environment” and no “Ministry of Agriculture and Forestry”. In addition, there is no reference to a water

authority.



U3823



August 2012



5

Appendix A



2.2.3







co-ordinate the activities of such bodies as it considers appropriate for the purposes of

controlling waste handling and disposal;







collaborate and coordinate with such foreign and international bodies;







coordinate with Government Ministries, local councils and other agencies on matters

relating to environmental protection and management;







promote studies, research for protection of the environment;







develop a comprehensive database on the environment; and







promote public awareness of the environment and its importance.



The Environment Protection Agency Act (No. 11 of 2008)

The EPA Act 2008 forms the legal basis for environmental management and protection in

Sierra Leone. The Act states the term “environment” applies to the biophysical and social

2

components of the environment . As outlined in the above section, the EPA Act provides for

the establishment of an EPA, which 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 Act also requires that licences are obtained for projects with potential to have significant

impacts. No project of the type listed in the First Schedule of the Act may be undertaken

without an environmental impact assessment (EIA) licence. The Act charts the procedure to

obtain an EIA licence briefly, with emphasis on the responsibilities of the EPA and the EPA

Board, as outlined in Section 2.2.4.

Transfer of EIA licences is not automatic according to Section 35 of the Act. If there is a

change in ownership of the project, both the previous owner and the new must notify the

EPA of the change. The EPA will transfer the licence to the new owner subject to

endorsement of the licence conditions by the new owner.

The EPA is required to monitor projects for which licences have been issued, in terms of

Section 37 of the Act, in order to determine their effect on the environment and ascertain

compliance with the Act.

The Board can make regulations, in terms of Section 62 of the Act, to facilitate

implementation of the Act. These regulations can cover subjects such as financial security

to be maintained in respect of specified activities and standards, guidelines or methods for

preventing or minimising pollution.

A significant portion of the Act (Sections 40 to 52) deals with the control of ozone-depleting

substances.



2.2.4



EIA procedure specified in the EPA Act 2008

SRK understands the main steps in the procedure are as follows:





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 EIA is required;







If required, the applicant should then prepare an EIA;



2



The EPA Act 2008 explains that the term “environment” includes “land, air, water and all plants, animals and

human beings living therein and the inter-relationship which exists among these.”



U3823



August 2012



6

Appendix A







On receipt of the EIA report, the EPA will circulate it to professional bodies or

associations, Government Ministries and non-governmental organisations (NGOs) for

review;







The EPA will also open the EIA report 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

publications);







The EPA will submit the comments on the EIA, together with the EIA report, to the

Board;







If the Board approves the EIA, it will instruct the Executive Director of the EPA to issue

an EIA licence;







The EPA will issue a licence to undertake the activity/ project. The licence will have a

period of validity and contain conditions for the protection of the environment.



The EIA licence procedure presented in the EPA Act 2008 is the same as that presented in

the now repealed Environment Protection Act 2000, except the agencies responsible for

implementation of the EIA provisions have changed.



2.2.5



Guidelines on EIA procedures

Guidelines on EIA procedures were published by the Ministry of Lands, Country Planning

and the Environment (MLCPE) in July 1999. The same guidelines were re-issued by the

MLCPE in July 2002. The guidelines were originally intended to facilitate implementation of

the EIA provisions in the old Environment Protection Act 2000 and are considered by the

MCLPE to be valid for the EIA provisions in the new EPA Act, 2008. The guidelines are

summarised in Table 2-3, with emphasis on the relative responsibilities of the developer and

the EPA.

3



The guidelines assign considerable responsibility to the EPA for the EIA process including

responsibility for formulation of the EIA terms of reference (TOR) and for key public

consultation activities. Usually (in most countries) responsibility for such tasks are assigned

to the developer.

References to public consultation during the EIA process are sparse in the EIA guidelines.

The various references are listed below:





The EIA process is consultative at all stages as it requires welcomed input from all

segments of society (Section 2 of the ESIA Procedures);







In line with the transparent and consultative principles of the EIA process, the

developer is required, after the EPA has decided the project requires an EIA, to inform

the public about and make representations to the EPA on the project. The EPA

determines the most appropriate means of public notification in each case (Section 3.1

of the ESIA Procedures).







At the time of submission of the Draft environmental impact statement (EIS) for

review, the developer should make the Draft EIS available for public review and make

the necessary advertisements and arrangements for this (Section 3.4 of the ESIA

Procedures).



3



The guideline actually refers to the DOE (and the Environment Protection Department/ Director of this department) rather than

the EPA.



U3823



August 2012



7

Appendix A







The EPA must prepare a Review Report that collates comments on the Draft EIS,

(Section 3.4 of the ESIA Procedures).







The EPA must keep a register of the EIS, all related comments and decisions for

public reference and scrutiny (Section 3.7 of the ESIA Procedures).







The public have a role in environmental auditing – members of the public are

encouraged to step forward to inform the EPA of environmental offences and the EPA

must investigate these and take action (Section 3.8.3 of the ESIA Procedures).







The Technical/Working Group is composed of representatives from the private sector,

non-governmental organisations (NGOs), community groups, as well as a wide range

of government entities. The Technical/ Working group ensures different views are

heard and collaboration is encouraged (Section 2 of the ESIA Procedures).



Table 2-3: Sierra Leone EIA Procedures (MCLPE, 1999 and 2002)

EIA steps and

purpose



Developer and EIA team



EPA



4



Task



Deliverable



Task



Deliverable



Screening

To determine

whether the

project will

have significant

impacts and if

a full EIA

process is

required



Complete a standardised

project brief using the

Screening Form (Annex 2,

EIA Procedures) and submit

to the EPA (note that the

5

MMR must be involved).



Completed

screening

form



Based on the information in the

screening form, a systematic

review is undertaken by the

EPA to determine whether an

EIA is required.



The Executive

Director of the

EPA informs

the developer

of the decision

taken.



The EPA takes a decision on

required level of public

notification.



Unspecified



Tasks under

the heading of

“screening” in

the EIA

Procedures,

but could be

classified as

“EIA scoping”

tasks.



Developer is required to

inform the public about and

make representations to the

EPA on the project



Unspecified



A preliminary study or series

of investigations may be

undertaken to identify issues

that need to be addressed in

the full EIA.



Unspecified



A scoping meeting is convened

to identify issues of importance

to decision makers. Members

of affected community may be

invited to the meeting. The

developer and its consultant

shall be invited to meeting.

The Terms of Reference (TOR)

for the EIA are prepared by a

Working Group constituted by

the EPA – comprising

government administrators and

the developer.



Approved

TOR for the

EIA



EIA Scoping

To determine

the scope of

the EIA



EIA



Conduct studies of issues in

accordance with the

approved TOR. Produce an

draft environmental impact

statement (EIS)



Draft EIS



6



Initial check of the Draft EIS by

the Executive Director of the

EPA to ensure it is ready for

review.



4



The guideline actually refers to the DOE (and the Environment Protection Department/ Director of this department) rather than

the EPA

The MMR is the “Lead Sectoral Ministry (LSM)” in terms of the EIA Procedures (MLCPE, 1999 and 2002). When the

developer initiates discussions with the MMR, the MMR must inform the developer of the prescribed EIA procedures. The MMR

is obliged to forward the developer’s completed Screening Form to the EPA.

6

According to the EIA Procedure (MLCPE, 1999 and 2002), the EIS is referred to a Draft EIS initially because it represents

findings and views of the developer. When the EIS has been approved, it is referred to as a Final EIS

5



U3823



August 2012



8

Appendix A



EIA steps and

purpose



Developer and EIA team

Task



Task



Deliverable



Up to 15

copies of

the Draft

EIS



Review of the Draft EIS by the

7

EPA and Working Group .

Review process may not

exceed 90 days.



Reviewers

may request

additional

information



Developer makes the Draft

EIS available for public

review and advertises this to

the public



The EPA opens the Draft EIS

for public inspection and

8

comment and gives notice in

two consecutive issues of the

Gazette and two issues of a

newspaper (with an interval of

at least seven days between

the publications).

The Working Group and

members of the public

consulted should forward

written comments to the EPA.

EPA compiles a Review Report

9

for the Working Group/ Board .

This report collates the

comments of all recipients of

the Draft EIS and also

comments from members of

the public.



Review

Report

containing

comments on

the EIS



The EPA and/or the

developer may decide to

convene a public hearing if

there is sufficient opposition

to the project.



The EPA will co-ordinate the

public hearing and the Board

will appoint a mediator.



Record of the

public hearing



EPA issues environmental

approval when satisfied that

the proposed mitigating

measures will effectively

reduce the environmental risk.



Environmental

approval, with

or without

conditions



Environmental

approval



Incorporate the

Environmental Approval into

the EIS



Environmental

auditing



4



Deliverable



Review of the

EIS



Public hearing



EPA



Final EIS (3

copies to

the EPA)



Notify the general public of

the final decision through

public notice such as

newspapers



Keep a register of the EIS, all

related comments and

decisions for public reference

and scrutiny.



Submit monitoring reports to

the EPA in accordance with

commitments in the

monitoring and evaluation

section of the EIS.

If the project is out of

compliance with

environmental regulations,

implement remedial

measures.

Submit environmental

management records to the

EPA.



Carry out periodic audits of

each project to ensure that all

agreements that were made

and conditions of approval are

being implemented.



7



The new EPA Act 2008 refers to professional bodies, Government Ministries and NGOs rather than a “Working Group”.

The guidelines on EIA procedure suggest that the developer makes the EIA available for public review and the Act states that

EPA is responsible for this.

9

The new Act 2008 requires that comments go to the EPA Board.

8



U3823



August 2012



9

Appendix A



2.3



Environmental management provisions in mining legislation

The Ministry of Mineral Resources (MMR) controls mining and mining-related matters by

means of the Mines and Minerals Act 2009. Provisions in this Act that are pertinent to

environmental and social management in general and to the ESIA for the Marampa Project

are identified Table 2-4. The Act repeals the Mines and Minerals Act 1994. A key feature of

the new Act is that it directly addresses environmental protection, community development

and health and safety and it makes performance in all of these areas a condition for

obtaining and keeping a mineral rights licence



Table 2-4: Provisions in the Mines and Minerals Act 2009 pertinent to environmental

and social impact assessment and management

Subjects



Key provisions



Relevant

sections



General

Types of

mineral rights



Surrender,

suspension

and

cancellation of

mineral rights



Written

consents

required from

authorities

Written

consents from

landowners/

occupiers



Rights to

graze stock

and cultivate

land

Surface lease

agreements



Compensation



U3823



The Act distinguishes the following mineral rights:

• a reconnaissance licence;

• an exploration licence;

• an artisanal mining licence;

• a small-scale mining licence; and

• a large-scale mining licence.

The Act specifies the processes and conditions under which a mineral right can be

suspended and/or cancelled. The Minister may suspend or cancel a mineral right if

the mineral right holder:

• grossly violates health and safety regulations or causes environmental harm;

• employs child labour;

• fails to submit required reports;

• violates any provision of the Act;

• fails to substantially comply with the terms of the community development

agreement.

Relationship between mineral rights and surface rights

(Part V, Articles 32 to 38)

The Act restricts the mineral right holder to exercise their rights on the following

without a consent from the responsible authority:

• land dedicated for public purposes (such as cemeteries, parks and roads);

• land reserved for a railway, highway or waterway;

• land within 200 m metres of any township.

To exercise mineral rights, the holder of a mineral right must obtain written consent

from the landowners/ occupiers for:

• land dedicated as a place of burial or which is a place of religious or cultural

significance;

• land on or within 200 metres of any inhabited, occupied or temporarily

unoccupied dwelling;

• land within 50 metres of land which has been cleared or ploughed for

agriculture including the growing of crops;

• land within 100 metres of any cattle dip, tank, dam, or other body of water.

The Minister may judge consent is being unreasonably withheld and allow the

holder of a mineral right to exercise those rights.

The Act makes provisions for rights to graze stock and cultivate land as long as

this activity does not interfere with the use of the area for mining operations.

No holder of a mineral right shall create unprotected pits, hazardous waste dumps

or other hazards that may endanger the stock, crops or other activity of the land

owner or occupier.

The Act requires mining companies to enter into surface lease arrangements with

the Government or landowners. If agreement cannot be reached between the

parties, the Minister may determine the agreement upon the advice of the Minerals

Advisory Board.

The Act provides for payment of fair and reasonable compensation for

disturbances foreseen by operations and damage done to the surface of the land.

If the holder of a mineral right fails to pay compensation when demanded, or if the

owner/occupier of the land is dissatisfied with any compensation offered, such

compensation may be determined by the Minister on the advice of the Minerals



Article 22



Articles 50

to 55



Article 32



Article 32



Article 33

Article 33



Article 34



Articles 35

to 37



August 2012



10

Appendix A



Subjects



Resettlement



An application

for a largescale mining

must include

environmental

and social

information



Terms and

conditions of

the licence



Obligations

Amendments

to licences



Rights to

other

resources



Environmental

impact

assessment

licence

Environmental

impact

assessment



U3823



Key provisions

Advisory Board.

The Act introduces an explicit sub-section on the right to resettlement for affected

parties by clarifying the rights and responsibilities of communities and mining

companies.

Large-scale mining licences (Part XII, Articles 105 to 119)



Relevant

sections

Article 38



An application for a large-scale mining licence must include the following

environmental and social information:

• proposals for the progressive reclamation and rehabilitation of land disturbed by

mining;

• effects of the mining operations on the environment and on the local population

and the proposals for mitigation, compensation and resettlement measures;

• a list of interested and affected parties including land owners and occupiers of

the area;

• details of consultation with interested and affected parties;

• a report on the goods and services required for the mining operations which

can be obtained within Sierra Leone;

• proposals for the employment and training of citizens of Sierra Leone;

• proposals for insurance cover including health and life insurance cover for

employees; and

• an environmental impact assessment licence for the project and an

environmental management programme (EMP).

The following will be appended to the large-scale mining licence as binding

obligations on the licence holder:

• the programme of mining operations approved by the Director;

• a certified copy of the agreement between the applicant and the owners of the

land over which the large-scale mining licence is granted;

• particulars of the programme for the employment and training of citizens of

Sierra Leone;

• a certified copy of the approved EMP; and

• particulars of the applicant’s proposals with respect to the procurement of

goods and services obtainable within Sierra Leone.

The holder of the mining licence is also obliged to substantially comply with the

community development agreement.

Subject to Minister approval, the holder of a large-scale mining licence may make

amendments to:

• the programme of mining operations;

• the environment management programme; and

• the programme of employment and training of Sierra Leone citizens.

Subject to the provisions of this Act and any other law holders of a large-scale

mining licence shall have the exclusive right to carry on operations and establish

infrastructure, including mine residue disposal facilities, in the licence area and

may utilize the water and timber as necessary for mining operations.

Protection of the Environment (Part XV, Sections 131 to 137)



Article 106



All small and large-scale mining licence holders must acquire environmental impact

assessment licences, in accordance with the Environmental Protection Act 2000 (it

is necessary to undertake an environmental impact assessment and produce an

EMP to obtain this licence).

The environmental impact assessment must be based on environmental baseline

work and include the following:

• detailed description of the environment supported by relevant measurements;

• detailed description of the project including all phases of development,

operations, reclamation and closure, and including

o

detailed resource requirements and emissions;

o

identification of the likely major environmental impacts;

o

review of residual and immitigable environmental impacts;

o

broad and detailed objectives regarding each environmental impact and

means for achieving them;

o

predicted effect of each environmental mitigation activity;

o

budget and timetables for implementation;

o

identification of likely major social impacts and mitigation measures;

o

methodologies to be used for monitoring potential negative impacts and

the source of funding for monitoring;

o

identification of people/ agencies responsible for implementation of



Article 131



Article 110



Article 115

Article 113



Article 114



Article 133



August 2012



11

Appendix A



Subjects



Public

consultation



Updating of

the EMP

Annual

progress/

status report

Rehabilitation

Financial

assurance



Key provisions

environmental management and monitoring; and

o

an EMP

An applicant for a mining licence that is required to submit an environmental impact

assessment must consult the public to introduce the project and verify possible

impacts.

The environmental impact assessment, EMP and annual status reports are

considered to public documents and will be made available for public review

The EMP must be updated and submitted for approval whenever there is a change

in mining operations

An annual report on progress in the implementation of the EMP is required.

The Director of Mines may suspend the licence if it is decided that the

programme is not succeeding.

Conditions relating to rehabilitation may be included in a mineral right granted

under the Act.

All small-scale and large-scale licence holders must provide financial assurance for

the performance against any obligations originating from an environmental impact

assessment and management plan.



Relevant

sections



Article 133



Articles

133 and

134

Article 133

Article 134



Article 136

Article 136



To strengthen the Government’s ability to manage environmental issues

associated with mining, the Act empowers the Minister to make specific

rehabilitation activities a condition of a mineral right.

If the company does not comply and the Government has to undertake work to

remedy, the amount expended will be considered a debt to the Government and

recoverable in court.

Eligible forms of financial assurance include one or a combination of the following:

• surety bond;

• trust fund with pay-in period;

• insurance policy;

• cash deposit; and

• annuities.

Community development (Part XVI, Articles 138 to 141)

Obligation to

promote

community

development

Community

development

agreement



The holder of a small-scale or large-scale mining licence must assist in the

development of mining communities affected by its operations to promote

sustainable development, enhance the general welfare and the quality of life of the

inhabitants, and shall recognize and respect the rights, customs, traditions and

religion of local communities.

A community development agreement must be prepared where:

• underground mines moving more than 100,000 tonnes/ year and open pit

mines moving more than 250,000 tonnes/ year.

• mines employing/ contracting more than 100 workers on a typical day.



Article 138



Article 139



The primary host community is the single community of persons mutually agreed

by the holder of the small-scale or large-scale mining licence and the local council.

If there is no community of persons residing within 30 km of any boundary defining

the mining licence area, the primary host community shall be the local council.

While a community development agreement is formed between the mining

company and community, the Minister is required to approve the plan.

The minimum expenditure for the implementation of the agreement by the holder of

the mineral right of 0.1% of gross annual revenue for the implementation of the

agreement.



U3823



August 2012



12

Appendix A



Subjects



Key provisions



Contents of

the agreement



The community development agreement must identify the primary host community

and include:

• objectives of the agreement;

• obligations of the licence-holder to the community;

• obligations of the primary host community;

• means for review of the agreement;

• consultative and monitoring frameworks and means by which the community

can participate in planning, implementation, management and monitoring of

activities carried out under the agreement; and

• a statement defining the process through which disputes will be resolved

(including the involvement of the local authority and the Minister).

Types of projects that should be considered in the agreement are:

• educational scholarship, apprenticeship, technical training and employment

opportunities for the community;

• financial and other forms of contributions towards infrastructural development

and maintenance involving education, health, roads, water, power and other

community services;

• assistance towards the creation and development of small and micro sized

enterprises;

• agricultural product marketing; and

• methods and procedures of environment and socio-economic management and

local governance enhancement.

The agreements may not address:

• imposition of additional taxes/ fees/ rent for the benefit of the primary host

community;

• provision of vehicles to the community unless it is for a specialised purpose

(such as an ambulance or bus); or

• provision of money, goods or facilities for the sole benefit of an individual or

single family unit.

All agreements entered into by large-scale mining licence holders and communities

must be approved by the Minister and the Act empowers the Minister to make

determinations where parties cannot come to agreement.

Health and safety (Part XVII, Articles 142 to 147)



Types of

projects to be

considered in

the agreement



Approval of

the agreement



Duties of

mineral rights

holders



Duties of

workers



Health and

safety

regulations



U3823







Provide and promote conditions for safe operation and a healthy working

environment.

• Initiate measures necessary to secure, maintain and enhance health and

safety.

• Ensure the mine is operated and maintained in such a way that workers can

perform their work without endangering the health and safety of themselves or

others.

• Ensure that persons who are not employees but who may be directly affected

by activities at the mine are not exposed to any health and safety hazards.

• Ensure that all persons working at the mine have the necessary skills and

resources to undertake their work safely.

• Take all reasonable steps to continuously prevent injury or loss of life when the

mine is not being worked.

• Establish a policy for the compensation of injured workers.

• Comply with all measures and procedures established by the mineral right

holder to ensure health and safety at the mine.

• Take reasonable care to protect their own health and safety and that of other

persons.

• Take proper care of all health and safety facilities and equipment.

• Report promptly any situation which he believes could present a risk to health

and safety.

• Any worker shall have the right to leave the mine if he believes that

circumstances pose a serious danger to their own health and safety.

The Act obligates the Minister to make regulations for securing, as far as possible,

the health and safety of employees involved in any operation associated with a

mineral right.



Relevant

sections

Article 140



Article 140



Article 140



Article 141



Article 142



Article 143



Article 147



August 2012



13

Appendix A



Subjects



Key provisions



Relevant

sections



Financial (Part XVIII, Articles 148 to 162)

Transparency

in the

extractive

industry:

disclosure of

revenues and

payments



The Minister must:

• develop a framework for transparency in the reporting and disclosure of

revenue due to or paid to Government;

• request, from any person engaged in the extractive industry, an accurate record

of the cost of production and volume of sale of minerals extracted;

• request, from any person engaged in the extractive industry, an accurate

account of money paid by and received from such person at any period;

• ensure that all payments due to the Government from a person engaged in the

extractive industry, including taxes, royalties, dividends, bonuses, penalties,

and levies, are made; and

• disseminate information concerning the revenue of the Government from the

extractive industry at least annually.

Miscellaneous (Part XIX, Articles 163 to 175)



Article 159



Preferential

procurement

of Sierra

Leonean

goods and

services

Preferential

employment

of Sierra

Leoneans

Reporting on

employment

and training



Companies must preferentially procure goods made in Sierra Leone and services

from agencies in Sierra Leone and owned by Sierra Leoneans or companies

registered in Sierra Leone or Public Corporations.



Article 163



Companies must give employment preference to Sierra Leonean citizens; holders

of small and large scale mining licences must undertake a scheme of training to

ensure the advancement of Sierra Leoneans in skilled, technical, supervisory,

administrative and managerial positions.

Small- and large-scale mining licence holders are also required to submit annual

reports on employment and training, failure to do so shall be considered material

breach of licence.



Article 164



Article 164



Core Mineral Policy of the Government of Sierra Leone 2008

The Core Mineral Policy (CMP) of the Government of Sierra Leone has been designed to

create an investor-friendly business environment in order to attract much needed foreign and

local investments into the minerals sector. It is designed to enhance the social and

economic benefits for the country and the communities affected by mining activities. The

sector is expected to make important contributions towards industrial, social, economic and

infrastructure development. It is also expected to provide new employment opportunities,

generate foreign exchange earnings and contribute significantly to government revenue.

The CMP aims to ensure tht the development of the minerals sector is achieved in ways that

will protect the environment and that are socially responsible and economically viable.



National Reconstruction and Development Act, 1999 (No. 5 of 1999)

This Act establishes a Commission to secure and monitor the legitimate exploitation of Sierra

Leone's' gold and diamonds, and other resources that are determined to be of strategic

importance for national security and welfare as well as to cater for post-war rehabilitation and

reconstruction. It states the commission will supervise and develop the exploration and

exploitation of precious metals and diamonds and other natural resources of Sierra Leone.



2.4



Legislation pertaining to disturbance of forests



2.4.1



Forestry Act, 1988

This Act focuses on forests, but includes provisions for the declaration of protected areas for

soil, water, flora or fauna conservation and protected trees anywhere in Sierra Leone. Most

of provisions of the Act apply only to classified forests, which may be either national or

community forest. A classified forest may have protection or production as its primary



U3823



August 2012



14

Appendix A



purpose, but in both cases it is to be managed for the maximum combination of benefits

compatible with the primary purpose. The clauses of relevance to the environmental and

social assessment and management are listed below.



2.4.2







There is a general prohibition against logging and other activities in classified forests,

except as authorized under the Act.







The Chief Conservator of Forest, with the directives of the minister, is responsible for

the management of the forest resources of the country. The Chief Conservator is

required to compile a national inventory of forest resources and a national forest

management plan.







A national forest is required to be on state-owned or -leased land. Community forests

on chiefdom lands are created by agreement between chiefdom authorities and the

Chief Conservator (Part V, Section 18). The agreement must delineate the area and

describe the the forest resources and potential of the area.







Management of community forests may be provided by the Forestry Division, by the

chiefdom or local authority, or by non-governmental organizations. Utilization may be

permitted to community members or others, and may be subject to fees and other

conditions







Detailed inventories of classified forests may be required by regulation.







Detailed management plans are encouraged for all classified forests, although they

are only required in the case of a concession for a national forest.







Utilization of national forests may be authorized by licence or concession, which is

subject to the payment of prescribed fees and to management, reforestation and

working plans prepared or approved by the Chief Conservator.







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). Failure to observe this is an offence punishable with a fine.







Any one permitted to fell timber is liable to paying a reforestation fee (Section 17),

which is to be paid to the Chief Conservator and will be paid into a reforestation fund

established under the Act. Mining companies can have this fee refunded where it

undertakes reforestation in the rehabilitation of disturbed land.



The Forestry Regulations, 1989

No classified/ protected forest can be used or disturbed without written permission from the

Chief Conservator of the forest. A licence may be issued by an inspector of the Forestry

Division authorising the holder of the mining lease, to clear land in a classified forest for the

purpose of mining (Section 15, Subsection 1).

A holder of a licence for deforestation of, or vegetation removal from the environment, must

observe conditions in Section 15, Subsection 3, which include the following conditions:



U3823







removal of vegetation, can be done for mining operations only within an area licenced

for this purpose;







specified land area, shall be cleared within a stated time, but trees requested not to be

felled, removed or damaged, are to be left standing;







trees to be felled shall be identified, except where total felling is authorised;







a forest severance fee and a minor forest produce fee, shall be paid in respect of all

forest produce that is merchantable, which may be removed by clearance of

vegetation;



August 2012



15

Appendix A







at the completion of mining, the area shall be replanted with approved crops or trees

by the mining company, or provision made for this to be done by payment of the

estimated reforestation cost; and







required method of cultivation and silviculture, specified by the Chief Conservator,

must be employed.



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 bushes are protected by the stipulated regulations of Section 40, whereby clearance

of vegetation from land designated as sacred bush, is prohibited except by clearance

authority from the Chief Conservator.



2.5



Water law



2.5.1



Current legislation

With the exception of legislation pertaining to water supply and sanitation, there is no water

management legislation in Sierra Leone. Existing legislation pertaining to water supply and

sanitation includes:





The Guma Valley Water Act (1961), which deals with water supply services to the city

of Freetown.







The Water (Control and Supply) Act (1963), which deals with water supply services in

urban centres except for Freetown as well as rural areas in the country. The

responsible authority is the Water Supply Division (WSD) of the Ministry of Energy and

Power.







The Sierra Leone Water Company Act (2001) which establishes the Sierra Leone

Water Company (SALWACO) to provide water supply services in the district towns of

Bo, Kenema, Koidu, Makeni, Kabala and the International Airport at Lungi (thus some

of the responsibilities of WSD are transferred to SALWACO).

It has reportedly been recognised that the existing legislation is inadequate and high priority

has been given to the development of a National Water and Sanitation Policy.



2.5.2



National Water and Sanitation Policy

The latest version of the policy was published by the Ministry of Energy and Power in August

2008. The policy covers the following subjects:





water resources management







urban water supply and sewerage







rural water supply







hygiene and sanitation; and







legal, regulatory and institutional framework.



Water resources management

Specific policy objectives relevant to water resources management include:





U3823



to vest in the State all water in the country and provide every citizen equal right to

access and use the nation’s natural water resources;



August 2012



16

Appendix A







to ensure effectiveness and efficiency of water resources utilization;







to promote management of water conservation and quality standards of water

resources;







to develop a water management system that protects the environment, ecological

system and biodiversity;







to develop appropriate and sustainable procedures for water resources assessment;







to develop sustainable integrated plans for water resources development;







to develop a database and information for development of water projects;







to carry out research and technological development;







to undertake training and human resources development;







to develop disaster prevention and management plans;







to promote regional and international cooperation on utilization of trans-boundary

water resources;







to increase utilisation of groundwater resources; and







to develop sustainable financing of water resources management activities.



The NWSP states future water management approaches will focus on how water is best

used beneficially and efficiently. Accordingly, water should be prioritised as follows:





Adequate quantity and acceptable quality water for basic human needs will receive

first priority.







Water for the environment to protect the ecosystems that underpin the country’s water

resources, now and in the future will attain second priority and will be reserved.







Other uses such as agriculture, industrial production, hydropower production, mining,

livestock keeping, fish production and processing, fish farming etc will be subject to

social and economic criteria which will be reviewed from time to time.







Utilisation of trans-boundary water resources will be based on the principle of equity,

right and rationality in accordance with agreements among the riparian states, and by

respecting the principles of international obligations on trans-boundary water

resources.



The Ministry of Lands, in collaboration with the National Water Resources Board (NWRB),

will carry out resource mapping to support better allocation and use, and the need to protect

sources and resources. And the following issues are addressed:





Water use permits will only be issued for a determined beneficial water use.

Procedures, criteria and guidelines for issuing the permits will be prepared and made

operational by the NWRB.







Trading of water rights, application of economic incentives and pricing for water use

shall be gradually built into the management system as a means for managing

demand requirements.







The “polluter pays” principle shall apply in conjunction with other legal and

administrative actions.

Environmental standards for in-stream flows, industrial

effluents and other waste discharges for meeting environmental objectives will be

developed and enforced.



Future regulatory bodies/ institutions

With respect to the legal, regulatory and institutional framework, key objectives are listed

below.



U3823



August 2012



17

Appendix A







Enact new unified water legislation (Water Law) which creates a level playing field for

all those involved in the sector, public and private, present and future.







Create a transparent and independent regulatory regime including the establishment

of an independent regulatory authority with appropriately qualified personnel for

regulating the water supply and waste disposal activities.







Ensure the roles and responsibilities of stakeholders involved in the water and

sanitation sector are clearly defined and allow for coordination and collaboration

between stakeholders for the benefit of the national economy and the population of

Sierra Leone.



A NWRB will be established and become the overall responsible institution for the water

resources management continuum from upstream freshwater sources to freshwaterseawater interface. It will be responsible for implementing the water resources management

strategies. Core functions will include: water resources exploration, water resources

assessment both in quantity and quality, monitoring and evaluation, water allocation,

pollution control, and other cross-sector activities such as catchments management,

planning and development.

The Ministry of Marine Resources, in collaboration with the NWRB, will continue to be

responsible for planning, developing, managing and conservation of all living and non-living

aquatic resources including fisheries and fish culture and regulates activities for both in-land

water and marine fishing.

Local Councils will be responsible for implementing water resources plans, protection and

conservation of natural resources at district level, establishment of bye-laws on the

management of water resources, and conflict resolution in accordance with established laws

and regulations. District Water and Sanitation (WATSAN) Committees will be statutorily

established, comprising water and sanitation sector stakeholders to carry out the abovementioned tasks

Participation of communities in decision-making, planning, management and implementation

of water resources management and development will be enhanced through statutory

establishing village/community water and sanitation committees.



2.5.3



Water permits needing to be obtained

Currently, there are no water permits to be obtained for the Project because there is no

legislation controlling:





2.6



abstraction of water from water resources;







water use for industrial purposes;







effluent discharges or other discharges to watercourses;







impounding of water; and







diversion of watercourses.



Legislation pertaining to land tenure

Rural land in Sierra Leone is held by landowning families (extended families or lineages) with

chieftaincy structure playing a significant administrative and custodian role. Extended

families are attached to particular areas within chiefdom. While there are section chiefs at

different administrative levels, the paramount chief is particularly important in land matters.

At present, the sale of land is virtually impossible and leasing of land is tricky. Property



U3823



August 2012



18

Appendix A



boundaries have not been surveyed, written deeds do not exist and both chiefs and

recognised representatives of land owning families have to be involved decisions on leasing

of land. Furthermore, both national legislation and customary law apply, and the relevant

national legislation is under revision and the relevant customary law is unwritten. A detailed

review of this predicament is presented in a paper by the Food and Agriculture Organization

(FAO) of the United Nations (2006).

According to the FAO (2006), the formal legal environment regarding land in Sierra Leone is

currently undergoing significant change and the primary pieces of legislation regarding land

are:





The Land Policy. The new National Lands Policy (2005) articulates sufficiently the urgent

need for a more coherent approach to land administration since the war. Statement of

the policy appears to support the inalienability of land with regard to the landowning

families and the role of descendants in claiming rights to land. In addition policy does

acknowledge that land is sold in urban areas in the provinces.







The Land Commission Act. The overall purpose of this Act is to establish a Lands

Commission with offices at the federal, provincial and district levels in order to grant

rights to lands, impose restrictions, implement policies on land and rural development,

advise government local councils and traditional authorities on the policy framework for

the development of particular areas, recognize and establish the content of land tenure

rights as well as transform ownership rights of such lands; advice and assist in the

execution of a registration programme and perform other functions as necessary.







The Commercial Lands Act. The law project to formulate legislation on the commercial

use of land was the first major activity of the Law Reform Commission. The purpose of

the project was to find approaches to modernizing the laws dealing with commercial use

of land, particularly in the provinces where customary law predominates, with the

purpose to attract foreign and local investment to set up large scale commercial activities

involving land.



Neither the Land Commission Act nor the Commercial Lands Act have been promulgated

yet. The recent Devolution of Estates Act, 2007 (No. 21 of 2007) deals with land ownership

and inheritance. This Act makes provision with respect to intestate succession and

succession by will of estates including land and land-related rights. The Act sets out rules

relative to inheritance and related distribution of estates in the case a person dies without

having made a will. The Act also defines offences against persons entitled to inheritance or

related to the deceased person.



2.7



The Factories Act – 1974

This Act deals with the safety, security and welfare of factory employees. It requires every

factory to be kept in a clean state and free from effluent arising from any drain, sanitary

convenience or nuisance. This part of the Act also states that for overall safety of all

employees, the factory must not be overcrowded, must be effectively ventilated, and

provided with suitable lighting systems. Every care must be taken by the factory holder, to

secure the health, safety and welfare of all employees. The Act also covers reporting of all

injuries, accidents, diseases and death and the powers of inspectors.



U3823



August 2012



19

Appendix A



3



INTERNATIONAL LAW, STANDARDS AND CODES OF

CONDUCT

An overview of the main international initiatives having influenced approaches to ESIA in the

last two decades are outlined in Figure 3-1. They include the 1992 Rio Declaration; 2000

United Nations Millennium Declaration; the 2000 United Nations Global Compact; and the

2002 Millennium Development Goals. For the mining industry, further impetus has been

added by the findings of research projects from 2000 to 2005 – including the Global Mining

Initiative; the Mining, Minerals and Sustainable Development Project, and the World Bank

Extractive Industries Review. The International Finance Corporation’s (IFC) Performance

Standards, which were published in April 2006, reflect these developments.

The

International Council on Mining and Metals’ (ICMM) Sustainable Development Framework

also reflects and reinforces these developments.

International law, standards and codes of conduct concerning environmental management

and sustainable development that are of relevance to the Marampa Project are discussed in

this section under the following headings:



3.1







international law (Section 3.2);







conditioning of project finance – Equator Principles and IFC Performance Standards

(Section 3.3); and







self-regulation in the mining sector (Section 3.4).



International law

International law pertinent to the environment and sustainable development comprises:





customary international law, which is applicable to all states and it results from general

and consistent practice followed by states out of a sense of legal obligation, so much

so that it becomes custom;







treaties (the term “treaty” encompasses “agreements, covenants, conventions, pacts,

protocols, and statutes”), which are generally intended to be implemented through

enactment and enforcement of laws at national levels; and







judicial decisions of international courts and tribunals.



International practices pertaining to environmental management and sustainable

development are strongly influenced by declarations and treaties as outlined below.

Declarations are generally not immediately legally binding but can acquire the force of

international customary law if they continue to express an international consensus which

states adhere to over time.



U3823



August 2012



20

Appendix A



Figure 3-1: International initiatives influencing the scope of and approaches to ESIA



U3823



August 2012



21

Appendix A



3.1.1



Declarations and customary law

Declarations influencing international practice in the fields of environmental management

and sustainable development are listed below in order of their relative importance to these

fields:





The 1992 Declaration on Environment and Development (referred to as the “Rio

Declaration);







The 1972 Declaration on the Human Environment (referred to as the “Stockholm

Declaration”);







The 1948 Universal Declaration of Human Rights;







The 2000 United Nations Millennium Declaration;







The 2007 Declaration on the Rights of Indigenous Peoples; and







The 1998 Declaration on Fundamental Principles and Rights at Work.



The Rio Declaration is of major importance because it reinforced the notion of sustainable

development. Many of the principles in the Rio Declaration are acquiring the force of

international customary law according to UNEP (2005).

In the last decade, the set of concerns addressed under the heading “sustainable

development” has been extended to include:





human rights – up-holding and supporting universal human rights;







labour standards – up-holding labour standards, particularly those that pertain to

human rights.







working against corruption of all forms, including extortion and bribery.



Key initiatives influencing this are the 2000 United Nations Millennium Declaration and 2002

Millennium Development Goals. The Millennium Declaration Goals recognise explicitly the

interdependence between sustainable development, growth and poverty reduction. They

comprise eight international development goals that 189 United Nations member states have

agreed to achieve by the year 2015. They were developed out of the United Nations

Millennium Declaration and synthesise, in a single package, many of the most important

commitments made separately at the international conferences and summits of the 1990s.

They also acknowledge that development rests on the foundations of democratic

governance, the rule of law, respect for human rights and peace and security.

All principles contained in the Universal Declaration of Human Rights are considered to be

international customary law and do not require signature or ratification by the state to be

recognised as a legal standard (UNEP, 2005).

The Declaration on the Rights of Indigenous Peoples, which was adopted by the United

Nations General Assembly in September 2007 (United Nations website, March 2009), has

high profile in the realm of sustainable development. The Declaration sets out the rights of

indigenous peoples, prohibits discrimination against indigenous peoples and promotes their

full and effective participation in all matters that concern them.

The 1998 Declaration on Fundamental Principles and Rights at Work requires both states

and businesses to observe International Labour Organisation (ILO) Conventions that are of

fundamental importance from a human rights perspective. These conventions pertain to:



U3823



Freedom of association, collective bargaining, and industrial relations;

August 2012



22

Appendix A



3.1.2







Forced labour;







Elimination of child labour and protection of children and young persons; and







Equality of opportunity and treatment/ elimination of discrimination in respect of

employment and occupation.



Multilateral treaties

Multilateral treaties pertinent to the environment and sustainable development include

numerous environmental treaties, some human rights treaties and some workplace treaties.

The treaties are officially recorded as follows:





Environment and human rights treaties are recorded in the United Nations Treaty

Series (March 2009) under the headings “Environment (Chapter 27)” and “Human

Rights (Chapter 4)”.







Workplace treaties are better known as ILO conventions because they are

promulgated by ILO, an agency of the United Nations. They are recorded on the ILO’s

ILOLEX website (ILOLEX, March 2009).



Environmental treaties

Most international environmental treaties that are considered to be important by the United

Nations Environmental Programme (UNEP, 2005) are in force in Sierra Leone. These

treaties are listed in Table 3-1. The Government of Sierra Leone has secured funding from

the Global Environment Facility (GEF) to facilitate the fulfilment of the treaty mandates and

to develop strategic action plans that link country action to the broader global environmental

management and sustainable development. The United Nations Development Programme

is providing provides supervisory and management support with this (Sierra Leone

Information System, 2009).



Table 3-1: International environmental treaties endorsed by Sierra Leone

Topic



Climate

change and

the ozone

layer



Hazardous

chemicals,

waste and

pollution



U3823



Convention



In force in

Sierra

Leone



Title



Date



United Nations Framework Convention on Climate

Change



1992



1995



Kyoto Protocol to the United Nations Framework

Convention on Climate Change



1997



2007



Convention for the Protection of the Ozone Layer



1985



2001



Montreal Protocol on Substances that Deplete the Ozone

Layer



1987



2001



Amendment to the Montreal Protocol on Substances that

Deplete the Ozone Layer



1990



2001



Amendment to the Montreal Protocol on Substances that

Deplete the Ozone Layer



1992



2001



Amendment to the Montreal Protocol on Substances that

Deplete the Ozone Layer



1997



2001



Amendment to the Montreal Protocol on Substances that

Deplete the Ozone Layer

Basel Convention on the Control of Transboundary

Movements of Hazardous Wastes and their Disposal

Bamako Convention on the Ban of the Import into Africa

and the Control of Transboundary Movement and

Management of Hazardous Wastes within Africa

Stockholm Convention on Persistent Organic Pollutants



1999



2002



1989

1991



2001



Signed in

2003, not in

force

2004

August 2012



23

Appendix A



Topic



Desertification



Biodiversity

and the

protection of

plants and

animals



Cultural

heritage



Convention

Title



Date



Rotterdam Convention on the Prior Informed Consent

Procedure for Certain Hazardous Chemicals and

Pesticides in International Trade

International Convention to Combat Desertification in

those Countries Experiencing Serious Drought and/or

Desertification, particularly in Africa

African Convention on the Conservation of Nature and

Natural Resources (Revised Version)



1998



African Convention on the Conservation of Nature and

Natural Resources



1968



Convention on Biological Diversity

Cartagena Protocol on Biosafety to the Convention on

Biological Diversity

Convention on the Conservation of Migratory Species of

Wild Animals

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 International Trade in Endangered Species

of Wild Fauna and Flora

Amendment to the Convention on International Trade in

Endangered Species of Wild Fauna and Flora (Art.XI)



1992

2000



In force in

Sierra

Leone



1994



1997



2003



Signed in

2003, not in

force

Signed in

1968, not in

force

1995



1979

1999



2002



2005



1973



Signed in

2005, not in

force

1995



1979



1995



Convention on Wetlands of International Importance

especially as Waterfowl Habitat



1971



2000



Protocol to amend the Convention on Wetlands of

International Importance especially as Waterfowl Habitat



1982



2000



Amendments to Articles 6 and 7 of the Convention on

Wetlands of International Importance especially as

Waterfowl Habitat



1987



2000



Convention concerning the Protection of the World

Cultural and Natural Heritage



1972



1994



Human rights treaties

Of the 25 United Nations treaties on human rights that are listed in the United Nations Treaty

Series (March 2009), 14 have been signed by Sierra Leone (Table 3-3).



Table 3-2: United Nations treaties on human rights and endorsement of these

by Sierra Leone



U3823



United Nations Treaties

(List from from the United Nations Treaty Series

(http://untreaty.un.org/ )



Date



In

force



1. Convention on the Prevention and Punishment of the

Crime of Genocide



1948



1951



2. International Convention on the Elimination of All Forms of

Racial Discrimination



1966



1969



2.a. Amendment to article 8 of the International Convention

on the Elimination of All Forms of Racial Discrimination



1992



Not yet



3. International Covenant on Economic, Social and Cultural

Rights



1966



1976



Endorsement by

Sierra Leone

Ratification,

Accession (a),

Signature (s)



1967



1996(a)



August 2012



24

Appendix A



United Nations Treaties

(List from from the United Nations Treaty Series

(http://untreaty.un.org/ )



Date



In

force



Endorsement by

Sierra Leone



4. International Covenant on Civil and Political Rights



1966



1976



1996(a)



5. Optional Protocol to the International Covenant on Civil

and Political Right



1966



1976



1996(a)



6. Convention on the non-applicability of statutory limitations

to war crimes and crimes against humanity



1968



1970



7. International Convention on the Suppression and

Punishment of the Crime of Apartheid



1973



1976



8. Convention on the Elimination of All Forms of

Discrimination against Women



1979



1981



8.a. Amendment to article 20, paragraph 1 of the Convention

on the Elimination of All Forms of Discrimination against

Women



1995



Not yet



8.b. Optional Protocol to the Convention on the Elimination of

All Forms of Discrimination against Women



1999



Not yet



2000 (s)



9. Convention against Torture and Other Cruel, Inhuman or

Degrading Treatment or Punishment



1984



1987



2001



9.a. Amendments to articles 17 (7) and 18 (5) of the

Convention against Torture and Other Cruel, Inhuman or

Degrading Treatment or Punishment



1992



1987



9.b. Optional Protocol to the Convention against Torture and

Other Cruel, Inhuman or Degrading Treatment or

Punishment



2002



Not yet



2003 (s)



10. International Convention against Apartheid in Sports



1985



1988



1986 (s)



11. Convention on the Rights of the Child



1989



1990



1990



11.a. Amendment to article 43 (2) of the Convention on the

Rights of the Child



1995



2002



2001 (a)



11.b. Optional Protocol to the Convention on the Rights of

the Child on the involvement of children in armed conflict



2000



2002



2002



11.c. Optional Protocol to the Convention on the Rights of

the Child on the sale of children, child prostitution and child

pornography



2000



2002



2001



12. Second Optional Protocol to the International Covenant

on Civil and Political Rights, aiming at the abolition of the

death penalty



1989



1991



2001



13. International Convention on the Protection of the Rights

of All Migrant Workers and Members of their Families



1990



14. Agreement establishing the Fund for the Development of

the Indigenous Peoples of Latin America and the Caribbean



1992



1993



15. Convention on the Rights of Persons with Disabilities



2006



Not yet



2007 (s)



15.a. Optional Protocol to the Convention on the Rights of

Persons with Disabilities



2006



Not yet



2007 (s)



16. International Convention for the Protection of All Persons

from Enforced Disappearance



2006



Not yet



2007 (s)



Ratification,

Accession (a),

Signature (s)



1998



Workplace treaties/ ILO Conventions

ILO Conventions are treaties and they are subject to ratification by member states.

According to the ILO ILOLEX website (ILOLEX, March 2009), Sierra Leone has ratified 17

ILO conventions (ILO, August 2008).

The ILO Conventions of relevance to the ESIA for the Marampa Project are listed in Table

3-1 . Sierra Leone ratified many of the ILO Conventions that are considered to be important



U3823



August 2012



25

Appendix A



in terms of the 1998 Declaration on Fundamental Principles and Rights at Work

(Section 3.2.1) in the 1960s. It has not yet ratified those pertaining to forced labour.



Table 3-3: ILO Conventions of relevance to the ESIA for the Marampa Project

ILO Conventions



Importance



Ratified

by Sierra

Leone

11



Grouping



Conventions



Human

10

rights



Mining



Freedom of

association,

collective

bargaining, and

industrial

relations



Freedom of Association and Protection of

the Right to Organise Convention, 1948

(No. 87)



X



X



1961



Right to Organise and Collective Bargaining

Convention, 1949 (No. 98)



X



X



1961



Forced labour



Forced Labour Convention, 1930 (No. 29)



X



X



Abolition of Forced Labour Convention,

1957 (No. 105)



1961

1961



Elimination of

child labour and

protection of

children



Minimum Age Convention, 1973 (No. 138)



X



X



Worst Forms of Child Labour Convention,

1999 (No. 182)



X



X



Equality of

opportunity and

treatment



Equal Remuneration Convention, 1951 (No

100)



X



X



1968



Discrimination (Employment and

Occupation) Convention, 1958 (No 111)



X



X



1966



Occupational

safety and

health



Occupational Safety and Health

Convention, 1981 (No. 155)

Protection

against

specific

risks



X



Working Environment (Air

Pollution, Noise and

Vibration) Convention, 1977

(No. 148)

Chemicals Convention, 1990

(No. 170)

Prevention of Major Industrial

Accidents Convention, 1993

(No. 174)



Protection

in specific

branches

of activity

Indigenous and

tribal peoples



Safety and Health in

Construction Convention,

1988 (No. 167)

Safety and Health in Mines

Convention, 1995 (No. 176)



X



Indigenous and Tribal

Peoples Convention, 1989

(No. 169)



X



The ILO Indigenous and Tribal Peoples Convention, 1989 (No 169), is considered important

from the environmental and social perspectives (UNEP, 2005). It requires the adoption of

special measures to protect and preserve the environment of indigenous and tribal people. It

contains numerous references to lands, resources and the environment of indigenous

people.



10



ILO Conventions recognised as being of fundamental importance from a human rights perspective in terms of the 1998

Declaration on Fundamental Principles and Rights at Work (Section 3.2.1).

Conventions considered to be important by the International Council on Mining and Metals (ICMM, March 2009).



11



U3823



August 2012



26

Appendix A



3.1.3



Regional treaties influencing international practice

Some conventions of the United Nations Economic Commission for Europe (UNECE) are

considered to have global significance, even though their field of application is regional.

These are listed in Table 3-5.



Table 3-4: UNECE conventions that are considered to have global importance



3.2



UNECE Conventions



Global importance



Convention on Long-range Transboundary Air

Pollution (CLTRAP, 1989)



Addresses long-range transboundary air

pollution.



Convention on Environmental Impact Assessment in

a Trans-boundary Context (Espoo, 1991)



Set an international precedent on

transboundary EIA and public involvement.



Convention on the Protection and Use of

Transboundary Watercourses and International

Lakes (Water Convention, 1992)



Laid down the principles of transboundary

cooperation within river basins for the first

time under international law.



Convention on Access to Information, Public

Participation in Decision Making and Access to

Justice in International Environmental Matters

(Aarhus, 1998)



Considered to be of global importance as an

elaboration of Principle 10 of the Rio

Declaration.



Conditioning of project finance: Equator Principles and the IFC

Performance Standards and World Bank EHS Guidelines

Development financiers play a major role in the development and enforcement of

international sustainable development standards through the conditioning their loans. This

conditionality comes in two forms: (1) the use of ESIA to screen projects in advance of loan

approval and (2) actual loan conditions imposed on projects.



3.2.1



Introduction to the Equator Principles

The Equator Principles require that financial institutions to condition their loans. They were

published in June 2003, by several private banks and the International Finance Corporation

(IFC), and were updated in July 2006. By February 2009, 65 financial institutions had

adopted the Equator Principles (Equator Principles website, March 2009).

The founding banks chose to model the Equator Principles on the environmental and social

standards of the World Bank Group. When the Equator Principles were first published, the

IFC invested in rigorous updating of the standards. The products of this exercise are the IFC

Performance Standards on Social and Environmental Sustainability (IFC Performance

Standards), which were published in April 2006 and are recognised as being the best and

most comprehensive standards available to international finance institutions working with the

private sector. The revised Equator Principles were published largely in response to the

publication of the IFC Performance Standards.

The 2006 Equator Principles require observance of the new International Finance

Corporation (IFC) Performance Standards and the World Bank Group Environmental, Health

and Safety (EHS) Guidelines (Equator Principles, March 2009).

A summary of the Equator Principles is presented in Table 3-6.



Table 3-5: Overview of the Equator Principles

Title

Principle 1:

Review and



U3823



Outline

Determine the screening category the project belongs to.

Most mines fall in Category A (Projects with potential significant adverse social or



August 2012



27

Appendix A



Title

Categorisation

Principle 2:

Social and

Environmental

Assessment

Principle 3:

Applicable

Social and

Environmental

Standards

Principle 4:

Action Plan

and

Management

System

Principle 5:

Consultation

and

Disclosure

Principle 6:

Grievance

Mechanism

Principle 7:

Independent

Review

Principle 8:

Covenants



Principle 9:

Independent

Monitoring

and Reporting

Principle 10:

Equator

Principle

Financial

Institutions

(EPFI)

Reporting



3.2.2



Outline

environmental impacts that are diverse, irreversible or unprecedented)

An ESIA must be completed for each project assessed as being either Category A

or Category B.



The ESIA must establish the project's overall compliance with, or justified deviation

from, applicable IFC Performance Standards and World Bank Group

Environmental, Health and Safety (EHS) Guidelines. The ESIA must address

compliance with relevant host country laws, regulations and permits that pertain to

social and environmental matters.

An Action Plan that addresses the relevant findings, and draws on the conclusions

of the ESIA must be prepared. This must describe and prioritise the actions needed

to implement mitigation measures, corrective actions and monitoring measures

necessary to manage the impacts and risks identified in the ESIA. Establish an

Environmental and Social Management System (ESMS) that addresses the

management of identified impacts.

There must be consultation with project affected communities in a structured and

culturally appropriate manner. The process, results of the consultation and any

actions agreed resulting from the consultation must be documented.

Establish a grievance mechanism to ensure that consultation, disclosure and

community engagement continues throughout construction and operation of the

project. Inform the affected communities about the mechanism.

For all Category A projects and, as appropriate, for Category B projects, an

independent social or environmental expert should review the assessment, action

plan and consultation process documentation to assess Equator Principles

compliance.

The borrower will covenant in financing

documentation:

a) to comply with all relevant host country social and environmental laws and

permits;

b) to comply with the action plan;

c) to provide periodic reports (not less than annually) by in-house staff or third party

experts that document compliance;

d) to decommission the facilities, where applicable and appropriate, in accordance

with an agreed decommissioning plan.

If the borrower fails to comply, development financiers reserve the right to exercise

remedies, as they consider appropriate.

Monitoring information to be shared with development financiers must be verified

by an independent expert or qualified and experienced external experts retained by

the borrower.

Each EPFI adopting the Equator Principles commits to report publicly at least

annually about its Equator Principles implementation processes and experience,

taking into account

appropriate confidentiality considerations.



Introduction to the IFC Performance Standards

The IFC Performance Standards are matched with corresponding Guidance Notes that

provide guidance on the requirements contained in the standards and on good sustainability

practices to help clients improve project performance. These Guidance Notes are updated

on a regular basis. The most recent versions were published in July 2007 with a new set

expected early in 2011.



U3823



August 2012



28

Appendix A



The IFC Performance Standards (April 2006) are entitled:





1: Social and Environmental Assessment and Management System;







2: Labour and Working Conditions;







3: Pollution Prevention and Abatement;







4: Community Health, Safety and Security;







5: Land Acquisition and Involuntary Resettlement;







6: Biodiversity Conservation and Sustainable Natural Resource Management;







7: Indigenous Peoples; and







8: Cultural Heritage.



IFC Performance Standard 1 establishes the importance of:





integrated assessment to identify the social and environmental impacts, risks, and

opportunities of projects;







effective community engagement through disclosure of project-related information and

consultation with local communities on matters that directly affect them ; and







the client’s management of social and environmental performance throughout the life

of the project.



IFC Performance Standards 2 through 8 establish requirements to avoid, reduce, mitigate or

compensate for impacts on people and the environment, and to improve conditions where

appropriate. Where social or environmental impacts are anticipated, the client is required to

manage them through its Social and Environmental Management System consistent with

Performance Standard 1 (IFC website, March 2009). Figure 3-2. illustrates an ESIA

procedure in terms of IFC Performance Standard 1. More background on this procedure is

provided in Table 3-7.

The IFC recommends that assessment should begin as early as possible, as collection of

baseline data required for definition of impacts may require months or even years and

potential impacts can be identified and avoided or mitigated in the earliest stages of

planning.



U3823



August 2012



29

Appendix A



Figure 3-2: ESIA12 procedure in terms of the IFC Performance Standard 1



12



The IFC Performance Standards use the term “social and environmental assessment (SEA)” instead of ESIA –ESIA has been

used here for the purposes of consistency with the rest of the document.



U3823



August 2012



30

Appendix A



Table 3-6: ESIA13 procedure in terms of the IFC Performance Standard 1 14

Steps

Screening



Scoping



Description of activities

Screening is a quick, high-level analysis to determine whether a full ESIA is

necessary.

Scoping produces a plan for the assessment. It determines

 which impacts are likely to be significant and should become the main focus

of the assessments;

 data availability and gaps;

 the appropriate spatial and temporal scopes for the assessment; and

suitable survey and research methodologies.

Stakeholders – including government officials and local communities – are

consulted to help identify key impacts and input to the assessment plan.

Baseline studies provide a reference point against which any future changes

associated with a project can be assessed and offer information for subsequent

monitoring of performance.



Baseline studies



It may be necessary to commission lengthy field-based studies to fully capture

seasonal trends.

The first step in conducting a baseline study is creating a map of the potentially

affected area. Additional survey work and consultation with local experts is

usually required to get a full picture of an area. It is important to remember that

baseline information is often not sufficient to determine impacts; the information

forms the basis of subsequent impact assessment activities.

Impact prediction and evaluation is the heart of the ESIA. Impact prediction

requires professional judgment, and will require input from relevant experts.



Impact prediction

and evaluation



Once the potential impacts are more fully understood, it is necessary to judge

the significance of each impact, to determine whether it is acceptable, requires

mitigation or is unacceptable.

Determining the significance of impacts is a complex and subjective process.



Mitigation



Consideration of

alternatives



Consultation with local stakeholders is vital at this stage, and particular

attention should be given to vulnerable or disadvantaged communities.

Mitigation aims to eliminate or reduce negative impacts. Mitigation options

should generally be considered in the following order of preference:

1. Avoidance of impacts altogether

2. Reduction of impacts where unavoidable

3. Restoration of disturbed areas to their original state

4. Relocation of affected communities

5. Compensation for any residual, unavoidable damage

When all mitigation measures have been identified, a comparison of

alternatives will allow identification of the least damaging option.

This is an iterative process of comparing potential impacts and mitigation

options of a series of alternative designs, locations, technologies and

operations to identify the optimal configuration that meets or exceeds the

requirements of national legislation and any funding agencies.



13



The IFC Performance Standards use the term “social and environmental assessment (SEA)” instead of ESIA –ESIA has been

used here for the purposes of consistency with the rest of the document.

14

Source: IFC, March 2006. A Guide to Biodiversity for the Private Sector: The Social and Environmental Impact Assessment

Process. (http://www.ifc.org/ifcext/sustainability.nsf/AttachmentsByTitle/BiodivGuide_ESIA/$FILE/ESIA.pdf)



U3823



August 2012



31

Appendix A



Steps



Description of activities

Also called an Action Plan, an ESMP defines resources, roles and

responsibilities required to manage impacts and implement mitigation

measures.



Environmental and

Social Management

15

Plan (ESMP)



Environmental and

Social Impact

Statement (ESIS)/

Environmental and

Social Impact

Report (ESIR)



The ESMP forms a link between the ESIA and the Environmental and Social

16

Management System (ESMS ). The central elements of a ESMP should

include a prioritized description of the activities planned to mitigate impacts, a

time line and identification of resources to ensure the ESMP can be delivered,

and a communication plan that indicates how progress in the implementation of

the ESMP will be disclosed.

The ESMP should also define monitoring requirements to determine whether

mitigation is successful. Monitoring is important for providing evidence of

compliance with ESMP and the effective implementation of management

measures.

The ESIS/ ESIR is the physical report on the ESIA process and findings. The

ESIA should provide a clear, jargon-free review of potential impacts and how

they have been and will be mitigated.

The report often forms the basis of public consultation activities and is the

document that is presented to regulatory authorities and others, including IFC,

as the basis for decision making.

Public disclosure helps affected communities understand risks, impacts and

opportunities related to potential projects.



Introduction to the World Bank Group EHS Guidelines

The World Bank Group Environmental, Health, and Safety Guidelines (known as the 'EHS

Guidelines') were published in 2007 and 2008. The EHS Guidelines are intended to be living

documents, and will be updated on a regular basis. The EHS Guidelines are technical

reference documents with general and industry-specific examples of Good International

Industry Practice (GIIP), as defined in IFC's Performance Standard 3 on Pollution Prevention

and Abatement. The World Bank Group EHS Guidelines that may apply to the Marampa

Project are listed in Table 3-8.



Table 3-7: EHS Guidelines that may be relevant to the Marampa Project

Sector



Standard or guideline name



General



EHS General Guidelines



Mining and processing



EHS Guidelines for Mining



Power plant & distribution



EHS Guidelines for Electric Power Transmission and

Distribution

Draft EHS Guideline for Thermal Power Plants



Non-mining waste



EHS Guidelines for Waste Management Facilities



Water supply and sewage



EHS Guidelines for Water and Sanitation Facilities



15



The IFC uses the term “social and environmental management plan (ESMP)”.



16



The IFC uses the term “social and environmental management system (SEMS)”.



U3823



August 2012



32

Appendix A



3.3



Self regulation in the mining sector

In addition to international and national law, there are rules and regulations created by

businesses themselves for self-regulation in the business community and for voluntary

regulation by individual companies. These exist in the form of business charters, codes of

conduct/ ethics/ practice and good-practice guidelines. Those of particular importance to

environmental management and sustainable development in the mining sector are identified

in this section. The IFC Performance Standards and EHS Guidelines do encourage

observance of the codes and guidelines.



3.3.1



United Nations Global Compact and the Global Reporting Initiative

The United Nations Global Compact is a corporate governance initiative, launched in July

2000, that aims to mainstream ten principles in business activities around the world and to

catalyse actions in support of broader United Nations goals, such as the Millennium

Development Goals. The Global Compact's ten principles are derived from:





The 1948 Universal Declaration of Human Rights;







The 1998 Declaration on Fundamental Principles and Rights at Work;







The 1992 Rio Declaration; and







The 2003 United Nations Convention against Corruption (the tenth principle was

added to the Global Compact in 2004 in response to this convention).



The United Nations Global Compact has been given impetus by the Global Reporting

Initiative (GRI). The GRI has established a sustainability reporting framework that sets out

the principles and indicators that organizations can use to measure and report their

economic, environmental, and social performance. The GRI reporting framework is strongly

influenced by the UN Global Compact and is widely used by corporations. GRI reporting by

the mining sector is discussed further in Section 3.4.2.

On the subject of human rights, the United Nations Global Compact requires that businesses

support and respect the protection of internationally proclaimed human rights and make sure

that they are not complicit in human rights abuses.



3.3.2



International Council on Mining and Metals Sustainable Development

Framework

The International Council on Mining and Metals (ICCM) was formed in 2001 to represent the

world’s leading companies in the mining and metals industry and to advance their

commitment to sustainable development. The ICCM has a Sustainable Development

Framework that comprises three elements: a set of ten principles (including a set of

supporting position statements); public reporting; and independent assurance (ICCM

website, March 2009).

The ICMM Sustainable Development Framework has been influenced by:



U3823







the 1992 Rio Declaration (Section 3.2.1);







the United Nations Global Compact (Section 3.2.1);







the Global Reporting Initiative (Section 3.2.1);







Voluntary Principles on Security and Human Rights (Section 3.4.3);







the Global Mining Initiative, which was undertaken by nine large mining companies in

order to prepare the sector for the World Summit on Sustainable Development

(WSSD) in 2002;

August 2012



33

Appendix A







the Mining, Minerals and Sustainable Development (MMSD) project and the MMSD’s

Breaking New Ground report, which was published in 2002; and







the World Bank’s Extractive Industries Review (EIR), which was undertaken in 2004

and ended with focus on sustainable development and poverty alleviation.



The ten ICCM principles are as follows:

1.



Implement and maintain ethical business practices and sound systems of corporate

governance;



2.



Integrate sustainable development considerations within the corporate decisionmaking process;



3.



Uphold fundamental human rights and respect cultures, customs and values in

dealings with employees and others who are affected by our activities;



4.



Implement risk management strategies based on valid data and sound science;



5.



Seek continual improvement of our health and safety performance;



6.



Seek continual improvement of our environmental performance;



7.



Contribute to conservation of biodiversity and integrated approaches to land use

planning;



8.



Facilitate and encourage responsible product design, use, re-use, recycling and

disposal of our products;



9.



Contribute to the social, economic and institutional development of the communities

in which we operate; and



10.



Implement effective and transparent engagement, communication and independently

verified reporting arrangements with our stakeholders.



The principles listed above were first published in May 2003 and have since been

complemented with a number of position statements that give greater clarity to the

commitments implicit in the principles. ICMM corporate members have to implement the

principles and measure their performance against the principles. They also have to

undertake public reporting in accordance with the Global Reporting Initiative’s Sustainability

Reporting Guidelines and Mining and Metals Sector Supplement (ICCM website, March

17

2009) . The ICMM Assurance Procedure, which was approved in May 2008, must be

implemented by all ICMM members in relation to their sustainability reports for the financial

year ending December 2009 or March 2010 (ICCM website, March 2009).



3.3.3



Voluntary Principles on Security and Human Rights

The Voluntary Principles on Security and Human Rights address the negative impacts that

company security could have on the human rights of local communities (Voluntary Principles

website, March 2009). The principles were launched in the year 2000 and were developed

through dialogue between multinational companies in the extractive and energy sectors,



17



The Global Reporting Initiative (GRI) is a sustainability reporting framework that sets out the principles and indicators that

organizations can use to measure and report their economic, environmental, and social performance. The GRI reporting

framework is strongly influenced by the UN Global Compact and is widely used by corporations.



U3823



August 2012



34

Appendix A



human rights non-governmental organisations (NGOs) and the United States and British

governments.

The principles guide companies in maintaining the safety and security of their operations

within an operating framework that ensures respect for human rights and fundamental

freedoms. A significant number of large multinational companies have now adopted or

adhere to the principles (Voluntary Principles website, March 2009).



3.3.4



The Extractive Industry Transparency Initiative

The Extractive Industries Transparency Initiative (EITI) aims to increase transparency over

payments by companies to governments and government-linked entities, as well as

transparency over revenues by those host country governments (EITI website, Voluntary

Principles website, March 2009). The United Kingdom’s Department for International

Development (DFID) plays an important role in the promotion and coordination on the

initiative.

To date, no countries have completed EITI validation, although preparations are well

advanced in several EITI candidate countries (EITI website, March 2009). EITI supporting

companies are those that have endorsed the EITI Principles and Criteria and contribute to

implementation in EITI implementing countries. About 40 of the world’s largest oil, gas and

mining companies support and actively participate in the EITI process.



3.3.5



Mining and Metals Sector Good Practice website

A website called “Good Practice: Sustainable Development in the Mining and Metals Sector”

(Good Practice website) has recently been developed by the ICCM, together with the United

Nations Conference of Trade and Development (UNCTAD), UNEP and the UK Department

for International Development (DFID). This website is intended to provide access to a library

of good practice guidelines, standards, case studies, legislation and other relevant material

that are leading examples of their kind globally (Good Practice website, March 2009).

The target audience for the website is people who are directly and indirectly involved in the

design, operation and regulation of mining and metals facilities. The site is intended to

support the implementation and effective achievement of the ICMM Sustainable

Development Principles. It will also encompass a host of additional issues lying outside the

scope of these principles (Good Practice website, March 2009).

The Tailings Good Practice website was launched October 2005 by the ICCM and the

International Commission on Large Dams (ICOLD). It has been is linked to the broader

Good Practice site. It was developed to provide a resource on all aspects of tailings in the

context of good practice in the mining and metals sector (Good Practice website, March

2009).

The following guidelines are of interest to the Marampa Project:



U3823







Good Practice Guidance on HIV/AIDS, TB and Malaria;







Planning for Integrated Mine Closure: Toolkit;







Metals Environmental Risk Assessment Guidance;







Good Practice Guidance for Mining and Biodiversity;







Good Practice in Emergency Preparedness and Response; and







Community Development Toolkit.



August 2012



35

Appendix A



4



REFERENCES

ECOLEX, March 2009. ECOLEX is an information service on environmental law, operated

jointly by United Nations Environmental Programme (UNEP), the Food and Agriculture

organisation of the United Nations (FAO) and the International Union for Conservation of

Nature (IUCN). Web address: www.ecolex.org/ .

Equator Principles, March 2009. Website on the Equator Principles": A financial industry

benchmark for determining, assessing and managing social & environmental risk in project

financing, which is maintained by the Equator Principles Financial Institutions. Web address:

http://www.equator-principles.com/.

Extractive Industries Transparency Initiative (EITI), March 2009. EITI Website maintained by

United Kingdom’s Department for International Development (DFID). Web address:

http://www.eitransparency.org/node.

Food and Agriculture Organization (FAO) of the United Nations. 2006. Land tenure, food

security and investment in postwar Sierra Leone.

Good Practice website, March 2009. Good Practice: Sustainable Development in the Mining

and Metals Sector website. Developed by the International Council on Mining and Metals

(ICMM), together with the United Nations Conference of Trade and Development (UNCTAD),

the United Nations Environment Programme (UNEP), and the UK Department for

International

Development

(DfID).

Web

address:

http://www.goodpracticemining.org/index.php.

IFC, March 2009.

Websites on the IFC Performance Standards on Social and

Environmental Sustainability and the World Bank Group Environmental, Health and Safety

Standards.

Web

addresses:

and

;

http://www.ifc.org/ifcext/sustainability.nsf/Content/PerformanceStandards

http://www.ifc.org/ifcext/sustainability.nsf/Content/EnvironmentalGuidelines.

ILOLEX, March 2009.

ILOLEX is a database containing ILO Conventions and

Recommendations

and

numerous

related

documents.

Web

address:

http://www.ilo.org/ilolex/english/docs/.

International Council on Mining and Metals (ICCM), March 2009.

address: http://www.icmm.com/.



ICCM website. Web



International Finance Corporation (IFC), March 2006. A Guide to Biodiversity for the Private

Sector: The Social and Environmental Impact Assessment Process. Web address:

http://www.ifc.org/ifcext/sustainability.nsf/AttachmentsByTitle/BiodivGuide_ESIA/$FILE/ESIA.

pdf

International Labour Organisation (ILO). August 2008. ILO website. Web addresses:

http://www.ilo.org/ilolex/; http://www.ilo.org/dyn/declaris/DECLARATIONWEB.INDEXPAGE;

http://www.ilo.org/global/About_the_ILO/Mission_and_objectives/lang--en/index.htm;

http://www.ilo.org/global/About_the_ILO/Mainpillars/Therightsatwork/lang--en/index.htm; and

http://www.ilo.org/dyn/declaris/DECLARATIONWEB.ABOUTDECLARATIONHOME?var_lan

guage=EN.



U3823



August 2012



36

Appendix A



Ministry of Energy and Power (MEP). 2008. The Republic of Sierra Leone National Water

and Sanitation Policy, August 2008).

Ministry of Lands, Country Planning and the Environment (MLCPE). 1999 and 2002. The

Republic of Sierra Leone EIA Procedures. Freetown.

Ministry of Mineral Resources (MMR). 2005. Details of Policy Measures Relating to SmallScale and Artisanal Mining and Marketing of Precious Minerals.

Sierra Leone Information System (SLIS). 2009. Sierra Leone Encylopedia 2008. The Sierra

Leone Encyclopedia is a core project of the SLIS positioned under Development Assistance

Coordination Office (DACO). The Encyclopedia 2008 of Sierra Leone is a joint United

Nations and Government of Sierra Leone effort.

Web address: http://www.dacosl.org/encyclopedia/

United Nations Environmental Programme (UNEP), 2005. Training Manual on International

Environmental Law. Edited by L Kurukulasuriya of UNEP and N A Robinson of Pace

University School of Law on behalf of the International Union for Conservation of Nature

(IUCN)

Academy

of

Environmental

Law.

http://www.unep.org/law/PDF/law_training_Manual.pdf.

United Nations Global Compact, March 2009. Website of the United Nations Global

Compact. Web address: http://www.unglobalcompact.org/.

United Nations Treaty Series, March 2009. Web addresses: http://untreaty.un.org/ and

http://treaties.un.org/Pages/ParticipationStatus.aspx.

United Nations, March 2009. Website of the United Nations Permanent Forum on

Indigenous Issues. Web address: http://www.un.org/esa/socdev/unpfii/.

University of Sierra Leone. 2008. Mineral Sector Technical Assistance Project (MTAP)

Environmental and Social Impact Assessment (ESIA) Study. Undertaken on behalf of the

Government of the Republic of Sierra Leone/ Ministry of Mineral Resources (MMR) and the

World Bank, by ET Ndomahina (Consultant) of the Institute of Marine Biology and

Oceanography, Fourah Bay College.

Voluntary Principles, March 2009. Website on the Voluntary Principles on Security and

Human Rights, which is maintained by the International Business Leaders Forum and

Business for Social Responsibility. Web address: http://www.voluntaryprinciples.org/



U3823



August 2012



SRK Consulting



Marampa Iron Ore Project ESIS – Technical Appendix B



APPENDIX B

B



SLEPA APPLICATION FORM AND SUPPORTING

CORRESPONDENCE



U3823_Marampa_ESIS_Final.docx



September 2012

Page B1 of B1



17 August 2010

Ref: MP.20.10.01.02 – 02

Mr Momodu A. Bah - Acting Deputy Director,

Sierra Leone Environmental Protection Agency

3rd Floor, Youyi Building, Brookfields

Freetown, Sierra Leone

Dear Mr Bah,

Ref:



Marampa Iron Ore Project

Submission of Environmental Impact Assessment Application and Screening Forms



Marampa Iron Ore (SL) Limited (Company) submits with this letter the Environmental Impact

Assessment (EIA) application and screening forms for the Marampa Iron Ore Project (Project), for

categorisation of the Project according to Sierra Leone EIA Regulations.

It should be noted that the Project is at a very early stage and many studies are still required before

the Company can determine whether development of the Project will be technically and

economically feasible. The Company acknowledges the importance of obtaining environmental and

social baseline information, however, and therefore wishes to initiate these studies at an early stage.

Due to the early stage of the Project, only limited information regarding certain aspects of the topics

covered in the screening form is available at this time. However, the Company trusts that sufficient

information has been provided for the Sierra Leone Environment Protection Agency (SLEPA) to

categorise the Project.

In accordance with the Environmental Protection Agency Act, 2008, the Company understands that

should a full EIA be required for the Project then the Government’s EIA Working Group would have

the responsibility of defining the Terms of Reference (ToR) for the Environmental and Social Impact

Study. If this was the case, then the Company offers to submit a draft ToR, based on the

requirements for similar projects, for consideration, review and use by the Working Group.

We look forward to your response to the screening form and categorisation of the Project. Should

you have any queries, or require further information, then please do not hesitate to contact the

undersigned.

Yours sincerely,

Marampa Iron Ore (SL) Limited



Chris Gbyl

Country Manager

Encl.



: Environmental Impact Assessment Application Form

: Environmental Impact Assessment Screening Form



49J Spur Road, Lumley, Freetown



Marampa Iron Ore Project – EIA Application Form



August 2010



APPLICATION FORM FOR AN ENVIRONMENTAL IMPACT ASSESSMENT (EIA)

LICENCE

1.



Name of Institution / Company:

Marampa Iron Ore (SL) Limited



2.



Type of Business

Mining Exploration



3.



Business Registration No.

CF/175/2007



4.



Contact Address

49J Spur Rd

Lumley, Freetown



5.



Nationality

Sierra Leonne



6.



Proposed Development

Marampa Iron Ore Project



7.



Proposed Location

In vicinity of Lunsar Townsite, Port Loko District, Sierra Leone.



8.



Cost of Proposal

USD 500 Million



9.



Estimated Duration for Development Activities

3 years



10.



State the Impact of Activities on the Following:

Tick the Appropriate Columns



POSITIVE



NEGATIVE





a)



Substantial Impact on

Ecosystem of the locality



b)



Social



c)



Aesthetic



d)



Scientific







e)



Historical







f)



State Other:













The Project provides a positive social impact not only on the immediate locality but also

surrounding areas due to the hiring of employees, and the use of suppliers and contractors

from other areas within Sierra Leone.

File Ref: P:\U3823 Marampa Iron Ore (Env)\Project\Final Report\Volume 2 ESIS Inc Tech Appendices\Appendix B - SLEPA

Corresp\SLEPA EIA Application Form_v1.docx



SRK Consulting

Marampa Iron Ore Project – EIA Screening Form



August 2010



ENVIRONMENTAL IMPACT ASSESSMENT SCREENING FORM

SECTION 1: INFORMATION ON THE CONTACT PERSON

Name:



Chris Gbyl



Institutional Affiliation:



Marampa Iron Ore (SL) Limited



Business Title / Position:



Country Manager



Telephone:



+ 232 (0) 33 294188



Email:



Chris.Gbyl@miolb.com



SECTION 2: DESCRIPTION OF THE INDUSTRY/FACTORY/COMPANY/PROJECT AND

OR PROPOSED PROJECT

Due to the early stage of Project development, the information provided by Marampa Iron Ore (SL) Ltd

in this form is preliminary and is subject to change throughout Project development.

Name:



Marampa Iron Ore Project (the Project)



Date operations started:



Construction of the Project is subject to technical and economic studies

and is not expected to commence before 2012.



Location of establishment

and/or Project:



The Project is located 90 km northeast of Freetown near the town of

Lunsar in the Port Loko District (Figure 1)



Location of proposed

project:



See above



Land area:



The total land area to be disturbed by the Project has not yet been

determined due to the early stage of Project development. The current

2

exploration licence area EXPL09/06 covers 305 km however the

Project will not cover this entire area. At present, Marampa Iron Ore

(SL) Ltd (the Company) has identified three areas that may be affected

by the Project (Figure 2). Area 1 has been identified as a potential

infrastructure location and Areas 2 and 3 have been identified as

potential mining areas. These three areas represent the environmental

and social “area of interest” at this stage of the Project and cover a

2

total of 30.4 km .



Attach a map or maps covering the proposed site and surrounding 5 km radius

Figure 1 shows the general location of the Project and Figure 2 shows the three environmental and

social areas of interest.



CURRENT LAND USE

Describe how the land is being used at present

The area of interest is a mosaic of cleared areas or secondary growth, interspersed with floodplain

subsistence cultivation along river courses, isolated settlements and small areas of palm plantations.

The crops grown within the floodplains include cassava, ground nut, rice and potato, and are largely

for subsistence use. Small villages and minor roads and tracks occur within the area of interest but

there are no other major commercial or industrial operations within the boundaries of the area of

interest.

Describe any possible alternative site(s)

The location of the mining operations is determined by underlying geology therefore no alternative

sites are possible. The infrastructure location is determined by its proximity to the existing railway line.



File Ref: P:\U3823 Marampa Iron Ore (Env)\Project\Final Report\Volume 2 ESIS Inc Tech Appendices\Appendix B - SLEPA

Corresp\SLEPA Screening Form_v4.docx



SRK Consulting

Marampa Iron Ore Project – EIA Screening Form



August 2010



Describe other types of industries or facilities (including health centers and schools), which

are located within 100 metres of the site, or are proposed to be located near the facility.

Indicate the proximity of the industrial, factory or project site and or proposed site to

residential areas, national parks or areas of ecological, historical or cultural importance.

There are no industries or facilities located within 100 m of the area of interest.

The area of interest is located near the town of Lunsar which has a population of 23,387 according to

the 2008 census. Lunsar has approximately 10 primary schools, 8 secondary schools and two

hospitals. There is no sanitation system in the town and water is either obtained from groundwater

wells or surface water sources such as the Rokel River.

2



The area of interest is located adjacent to a 10 km mining licence area (ML02/05) held by London

Mining (Figure 2). The London Mining lease is located within 100 m of the boundary of the area of

interest however the Company will not carry out activities within the London Mining lease.

The area of interest includes small villages, mostly within the Masimera and Marampa chiefdoms. The

houses in the villages are largely made out of mud with palm leaf or corrugated iron roofs. Most

villages have a hand-pump well for water supply but do not have a formal drainage system. Some

villages contain small schools which service the children of the local communities.

It is currently understood that there are no sites of ecological or cultural importance located within

100 m of the area of interest, with the exception of society bush, however this assumption will be

confirmed during the Environmental Impact Assessment (EIA). There are no protected areas located

within EXPL09/06, although there is a forest reserve 20 km to the east of the exploration licence area.

Indicate whether adequate infrastructure exists at the location and/or proposed location and

whether old or new buildings, roads, electricity and water lines or drainage systems exist at the

location and/or proposed site.

New Project-specific infrastructure will be built at the site; including a processing plant, on-site power

generator and distribution network, water storage and supply infrastructure, storm water systems,

waste management facilities, site haulage roads, auxiliary buildings and an accommodation camp.



SECTION 3: EMPLOYEES AND LABOURERS

Number of people employed: At this stage in the planning of the Project, there is no exact indication

of the number of people to be employed throughout the life of the Project. Numbers will vary between

the different Project phases; operation employment requirements are potentially to be more than 500.

Employees and labourers



During Construction



During Operation



Full Time



300+



500+



Part Time



Unknown at present



Unknown at present



Indicate whether you have or plan to construct housing / sanitation facilities for temporary or

permanent workers

An on-site accommodation camp will be provided for non local staff during work periods and a

temporary construction camp may also be required during the construction phase of the Project. The

camps will include appropriate sewerage treatment and waste management systems though details of

these are not yet available.



File Ref: P:\U3823 Marampa Iron Ore (Env)\Project\Final Report\Volume 2 ESIS Inc Tech Appendices\Appendix B - SLEPA

Corresp\SLEPA Screening Form_v4.docx



SRK Consulting

Marampa Iron Ore Project – EIA Screening Form



August 2010



SECTION 4: DESCRIPTION OF INDUSTRIAL PROCESS

Briefly describe the type and nature of industrial processes at the installation and / or

proposed installation.

The Project will include open pit mining of specular hematite (iron ore) and on-site beneficiation

including crushing, grinding, and concentrate cleaning via wet high-intensity magnetic separation.

State the type and quantity of energy used (including the origin of the energy i.e. public utility,

on site generator, wood, solar, wind etc.)

Type (s)



Quantity



Period (per day/week etc.)



On-site generator

(large)



Unknown at present but the generator will be

designed to provide all Project power

requirements



Power requirements will be

continual but Project will

aim to be self-sufficient



Estimate the quantity of water used

Use(s) of water



Quantity



Period



Source



Cooling



None



NA



NA



Steam generation



None



NA



NA



3



Production process



~10,000 m per day



Continuous



Other (e.g. potable

water, dust

suppression, vehicle

washing)



Unknown



Continuous



Unknown (possibly Rokel

River and reclaim from

tailings facility and

dewatered pits)



List the type and quantity of raw material(s) used per year in the production process (including

soil, sand, cement, aggregates, wood, animals etc). Identify the source(s) of raw material(s)

Type (s)



Quantity



Source



Large quantities of raw materials will be required for the construction and operation of the Project

although at this stage of the Project, details regarding the quantities and source of the raw materials

have not been determined. Materials will be sourced from local suppliers where feasible.



List all of the chemical(s) used in the production process or expected to be used for any aspect

of the production process (a separate list may be attached with more detailed information).

Type (s)



Description



Quantity



At this stage of the project, specific chemicals and quantities required have not been identified

however as the beneficiation process is mainly physical, so use of toxic chemicals are unlikely.

Possible chemicals that may be required include explosives, lubricants, dust control agents and water

treatment chemicals



File Ref: P:\U3823 Marampa Iron Ore (Env)\Project\Final Report\Volume 2 ESIS Inc Tech Appendices\Appendix B - SLEPA

Corresp\SLEPA Screening Form_v4.docx



SRK Consulting

Marampa Iron Ore Project – EIA Screening Form



August 2010



SECTION 5: PRODUCTS

Briefly state the nature of the product(s) or output of the facility and or proposed facility, and

the expected quantities on a quarterly or annual basis. Indicate the use and or intended use of

the product(s).

Name



Description of uses



Output



Iron concentrate

(~65% Fe)



Steel production (by third parties outside

Sierra Leone)



5 Mtpa concentrate



SECTION 6: BY PRODUCTS, WASTE MANAGEMENT AND DISPOSAL

Specify the nature of each waste or by-product and the quantity generated or to be generated.

Type (s)



Description



Quantity in 1g per weeks



Waste rock from mining process



20 Mtpa



Tailings from concentrator



10 Mtpa



Solid particulate



Dust and blasting fumes



Unknown at present



Liquid



Unknown at present (dependent on

processing activities)



Unknown at present



Gaseous



Haulage vehicle emissions

Generator emissions



Unknown at present



Solid (bulk)



State the method of disposal or management (e.g. dump site, burning, bury etc)

Details of waste management strategies have not yet been developed, however all hazardous and

non-hazardous wastes will be collected, transported, processed, recycled or disposed of in a manner

that meets national requirements and good international industry practice.

Type of waste



Method of disposal/management



Waste rock



Waste stockpiles located adjacent to pits



Tailings



Within a facility consisting of rock wall embankments



Non hazardous



Recycled, incinerated or landfill



Hazardous



Options for disposal and management of hazardous waste have not yet

been determined but measures will meet national requirements and good

international industry practice



Indicate the sources of noise pollution, the type / quality of noise (i.e. machinery / repetitive

pounding etc)

Sources of noise



Type of noise



Mining



Drilling, blasting, heavy vehicles



Processing



Crushing and grinding



On-site generators



Engine noise



File Ref: P:\U3823 Marampa Iron Ore (Env)\Project\Final Report\Volume 2 ESIS Inc Tech Appendices\Appendix B - SLEPA

Corresp\SLEPA Screening Form_v4.docx



SRK Consulting

Marampa Iron Ore Project – EIA Screening Form



August 2010



SECTION 7: ENVIRONMENTAL IMPACTS

Please indicate environmental impact (s) that may occur as a result of the factory / industrial

process and or the process of proposed project.

The potential impacts of the Marampa Project have been identified at a preliminary level in the

following table. The impacts were identified through consideration of limited information on the

Project, its environmental and social setting and taking account previous experience gained on similar

projects. The impact assessment will evaluate if these potential impacts are likely to occur and if so,

to what extent. This list of impacts may change during the period of Project development and the

ESIA will evaluate new impacts identified.

Nature of

impact



Brief description of the anticipated impacts

Modification of land by mining activities and infrastructure limiting use by local

communities



Land

transformation

and

landscape



Disturbance of transport routes by Project infrastructure affecting local communities

Mining activities and infrastructure causing visual intrusion leading to loss of sense of

place for local communities

Disturbance to sites considered to be of archaeological, historic or cultural importance

by local communities



Soil



Surface erosion by wind and water leading to degradation and/or loss of soil resulting

in reduced land capability

Uncontrolled or accidental discharges leading to deterioration of soil quality

Release of fugitive dust and particulate emissions leading to increase in background

particulate concentrations creating nuisance or health risks to local communities



Air Quality



Release of gaseous emissions (SO2, NOx and Volatile Organic Compounds) leading

to increases in background gaseous concentrations causing potential health effects to

local communities

Release of greenhouse gas emissions contributing to increasing global greenhouse

gas concentrations

Diversion of surface water drainage channels resulting in changes to water availability

for downstream users and ecosystems

Abstraction of water for the mine resulting in reduced availability of water to other

water users

Dewatering of the mine workings leading to reduced availability of water to other

water users



Surface Water



Discharges from the Project during storm events leading to contamination of local

waterways resulting in water quality impacts downstream of the mine site

Deteriorated water quality in mine water holding facilities posing risks to people and

wildlife

Mobilisation of soils due to erosion process leading to sedimentation of local

waterways potentially affecting site drainage, aquatic fauna and downstream water

users

Seepage from mine and mineral-processing residue disposal facilities or tailings

storage facility or waste rock dump failure (e.g. due to liner leakage) leading to

contamination of groundwater aquifer impacting downgradient water users



Groundwater



Mine consumption and dewatering leading to reduction in available groundwater to

downgradient users

Potential pit lake formation following closure of mine and possible impact of pit lake

water on the downstream groundwater quality



Noise and

vibrations



Project activities resulting in unacceptable increases in background noise levels for

local communities

Blasting leading to vibration disturbance to local communities



File Ref: P:\U3823 Marampa Iron Ore (Env)\Project\Final Report\Volume 2 ESIS Inc Tech Appendices\Appendix B - SLEPA

Corresp\SLEPA Screening Form_v4.docx



SRK Consulting

Marampa Iron Ore Project – EIA Screening Form



Nature of

impact



August 2010



Brief description of the anticipated impacts

Land disturbance leading to loss of habitat and individuals.



Ecology



Habitat disturbance and animal displacement due to mining activities and vehicles

resulting in changes to biodiversity.

Displacement of natural fauna due to disturbance from mining activities and vehicles

Direct and indirect employment, training and business opportunities and training,

leading to improved economy

Social investment leading to improved infrastructure and quality of life



Socioeconomic



Influx of job seekers and mine related activities increasing pressure on local

resources and services and demographic changes leading to changes in community

health

Sudden decrease in demand for workers and services, after completion of

construction phase, leading to increase in unemployment and slowing down of local

economy

Retrenchment at end of construction phase and mine closure leading to loss of

employment, income and slowing down of economy

Loss of land leading to loss of income and livelihood opportunities, relocation of

households or villages leading to long term poverty



Hazardous

incidents



Exposure to fly rock, slope failure of the tailings dam or waste rock dumps, explosion

or fire, petrochemical spills, vehicle accidents.



SECTION 8: PROPOSED MITIGATION MEASURES

Indicate the measures(s) employed to mitigate against damage likely to be caused by the

factory / industrial process and / or proposed project to humans and /or the environment.

At this stage of the Project, only a preliminary identification of potential environmental and social

impacts has been undertaken. As baseline studies and impact assessments have not been carried

out, the potential risks/impacts cannot be quantified, therefore mitigation measures have not been

proposed at this stage, however these types of impacts are typical for mining projects and considered

manageable. Following the findings of the impact assessment, specific mitigation and management

measures will be included as part of an Environmental and Social Management System (ESMS) in the

final EIA report and will be in accordance with IFC Performance Standards and World Bank

Environmental, Health and Safety Guidelines for Mining.

State any and all experience you have with implementing the above mentioned mitigation

measure(s). If you do not have prior experience, what skill (s) do you possess to implement

these mitigation measures?

The Company’s management has considerable experience in managing and operating mining

operations similar to that proposed for the Project. The EIA will be conducted by environmental

consulting firm SRK Consulting (SRK). SRK has considerable experience in conducting EIA processes

globally across all regions of the world. A list of recent environmental and social projects conducted

by SRK Consulting (UK) is attached which involved the development and implementation of mitigation

and management measures for large mining operations.

What staff training is provided or will be provided to ensure compliance with health and

environmental safety standards?

Training on health, safety and environmental issues will be provided by the Company to ensure that all

activities associated with the Project are undertaken in accordance with national requirements and

good international industry practice. Health, safety and environmental training will be compulsory for

all employees, prior to commencing any work.



File Ref: P:\U3823 Marampa Iron Ore (Env)\Project\Final Report\Volume 2 ESIS Inc Tech Appendices\Appendix B - SLEPA

Corresp\SLEPA Screening Form_v4.docx



Selected Environmental and Social Projects

Project

Name



Client



Timing



Country



Description

Environmental and Social scanning study.

Approval for Scoping phase of ESIA process,

as well as installation of meteorological

station and monitoring system with a

preliminary scoping of water resources and

surface water hydrology.

Environmental and social input compliant to

host country and international standards into

the feasibilty study for a open cast coal mine.

Environmental and Social Impact

Assessment for a copper project conforming

to EP/PS, host country requirements and

owner standards. Input to pre-feasibility.

Environmental and Social Impact

Assessment for a copper/gold project

conforming to EP/PS, host country

requirements and owner standards. Input to

pre-feasibility and feasibility studies.

Environmental and Social Impact

Assessment for a nickel/PGM project

conforming to EP/PS, host country

requirements and Barrick Standards. Input

to pre-feasibility and feasibility studies.

Development of plan of study for

environmental and social impact assessment

for an iron ore project to conform with EP/PS

and BHP Billiton/Newmont Standards as

input to project development Concept Study.



Kiaka



Volta Resources



2010 –

Ongoing



Burkina

Faso



Thar Coal



Engro Power



2009 ongoing



Pakistan



Bozshakol

ESIA



Kazakhmys



2008ongoing



Kazakhstan



Reko Diq

ESIA



Tethyan Copper

Company

(Barrick/Antofogast

JV)



2007Ongoing



Pakistan



Fedorovo



CJSC Fedorovo

(Barrick)



2007ongoing



Russia



Nimba

Mountains

Concept

Study



SMFG (Rio

Tinto/Newmont JV)



2007



Guinea



2007 2008



Suriname



Environmental and social impact assessment

process of river dredging project.



2006-2008



Suriname



Environmental and Social Impact

Assessment conforming to EP/PS and BHP

Billiton Standards.



2006-2007



Saudi Arabia



Corantijn

River

Dredging

Project ESIA

Suriname

River

Dredging

ESIA

Ghurayyah

Scoping

Study



NV BHP Billiton

Maatschappij

Suriname

(BHP Billiton)

NV BHP Billiton

Maatschappij

Suriname

(BHP Billiton)

Tertiary (Middle East)

Ltd



Environmental and social impact assessment

and input into pre-feasibility study.

Environmental and social impact assessment

and input into Feasibility Study for a

molybdenum project to meet Greenlandic

requirements.

Environmental and Social Impact

Assessment to comply with EP/PS

undertaken in parallel with feasibility study.



Malmbjerg

ESIA



International

Molybdenum plc



2005-2007



Greenland



Voskhod

ESIA



Oriel Resources Plc



2006-2007



Kazakhstan



Bulghah

ESIA

(Ma'Aden)



Bulghah ESIA

(Ma'Aden)



2005-2007



Saudi Arabia



Bakhuis

Transport

ESIA



NV BHP Billiton

Maatschappij

Suriname

(BHP Billiton)



2006Ongoing



Suriname



Environmental and Social Impact

Assessment conforming to EP/PS and BHP

Billiton Standards for the transport and

processing aspects of Bakhuis bauxite

project.



Kolwezi EIA



Adastra/Congo

Mineral

Developments

Limited (CMD)



2004-2005



DRC



Equator Principles standard environmental

and social Impact assessment for a tailing

reprocessing project.



Environmental and social impact

assessment.



SECTION 9: TESTIMONY



I confirm that the information provided herein is accurate to the best of my knowledge. I will

also endeavour to provide additional information and facilitate a site visit if required.



For Official Use Only



Reviewed by:



Classified



Date:



A



B



C



Reasons for the classification:



Endorsed by:



Date:



Approved by Director:



Date:



SRK Consulting



Marampa Iron Ore Project ESIS – Technical Appendix C



APPENDIX C

C



STAKEHOLDER ENGAGEMENT PLAN



U3823_Marampa_ESIS_Final.docx



September 2012

Page C1 of C1



MARAMPA IRON ORE PROJECT:

STAKEHOLDER ENGAGEMENT PLAN

FOR THE ENVIRONMENTAL AND

SOCIAL IMPACT ASSESSMENT



Prepared For



MARAMPA IRON ORE (S.L.) LTD



Report Prepared by



SRK Consulting (UK) Limited

UK3823



SRK Consulting



Marampa Iron Ore Project – Details



COPYRIGHT AND DISCLAIMER

Copyright (and any other applicable intellectual property rights) in this document and any

accompanying data or models which are created by SRK Consulting (UK) Limited ("SRK") is

reserved by SRK and is protected by international copyright and other laws. Copyright in any

component parts of this document such as images is owned and reserved by the copyright owner

so noted within the document.

This document may not be utilised or relied upon for any purpose other than that for which it is

stated within and SRK shall not be liable for any loss or damage caused by such use or reliance.

In the event that the recipient of this document wishes to use the content of this document in

support of any purpose beyond or outside that which it is expressly stated or for the raising of any

finance from a third party where the document is not being utilised in its full form for this purpose,

the recipient shall, prior to such use, present a draft of any report or document produced by it that

may incorporate any of the content of this document to SRK for review so that SRK may ensure

that this is presented in a manner which accurately and reasonably reflects any results or

conclusions produced by SRK.

The use of this document is strictly subject to terms licensed by SRK to its Client as the recipient

of this document and unless otherwise agreed by SRK, this does not grant rights to any third

party. This document shall only be distributed to any third party in full as provided by SRK and

may not be reproduced or circulated in the public domain (in whole or in part) or in any edited,

abridged or otherwise amended form unless expressly agreed in writing by SRK. Any other

copyright owner’s work may not be separated from this document, used or reproduced for any

other purpose other than with the document in full as licensed by SRK. In the event that this

document is disclosed or distributed to any third party, no such third party shall be entitled to place

reliance upon any information, warranties or representations which may be contained within this

document and the recipient of this document shall indemnify SRK against all and any claims,

losses and costs which may be incurred by SRK relating to such third parties.

© SRK Consulting (UK) Limited 2011



SRK Consulting (UK) Limited



SRK Legal Entity:



th



SRK Address:



5 Floor Churchill House

17 Churchill Way

City and County of Cardiff, CF10 2HH

Wales, United Kingdom.

August, 2012



Date:

Project Number:

SRK Project Director

and Project Manager:

Client Legal Entity:

Client Address:



U3823_Marampa_SEP_Final.docx



UK3823

Fiona Cessford



Corporate Consultant (Environmental)

Marampa Iron Ore Ltd

Victoria Place

31 Victoria Street

Hamilton

Bermuda

HM10



August, 2012



SRK Consulting (UK) Limited

5th Floor Churchill House

17 Churchill Way

City and County of Cardiff

CF10 2HH, Wales

United Kingdom

E-mail: enquiries@srk.co.uk

URL: www.srk.co.uk

Tel:

+ 44 (0) 2920 348 150

Fax: + 44 (0) 2920 348 199



MARAMPA IRON ORE PROJECT: STAKEHOLDER ENGAGEMENT

PLAN FOR THE ENVIRONMENTAL AND SOCIAL IMPACT

ASSESSMENT – EXECUTIVE SUMMARY

SRK Consulting (UK) Limited (SRK) has been appointed by Marampa Iron Ore (SL) Limited

(MIOL) to undertake an Environmental and Social Impact Assessment (ESIA) for the

proposed Marampa Iron Ore Project (the Project) in Sierra Leone. This document presents

the Stakeholder Engagement Plan (SEP) used to guide the process of information disclosure

and stakeholder consultations during the environmental and social assessment studies. The

SEP is a dynamic document that will be updated at different stages of the Project.

The consultation programme outlined in this SEP is based on the requirements of the Sierra

Leone national legislation and where practical, the International Finance Corporation (IFC)

performance standards.

The specific objectives of this SEP are to:





provide an identification and analysis of potential Project stakeholders;







describe relevant Sierra Leone legal requirements and international standards;







document the community engagement process to date;







describe the methodology used for consulting with relevant key stakeholders and

document their feedback; and







propose the grievance mechanism.



Based on a visit to the Project site, assessment of the potential Project footprint area and

meetings with government agencies, SRK compiled a list of potential Project stakeholders

and analysed their interest in and influence on the Project. The stakeholders are categorised

as: government authorities, residents of the villages around the mine site, community based

organisations, non government organisations and other civil society groups.

The stakeholder consultations comprised:





meetings with SLEPA and other relevant ministries to notify formal start of the ESIA

process and understand their expectations; and







formal scoping meetings with local communities and other stakeholders to record their

concerns and expectations.



The approach to the consultation and disclosure activities undertaken in support of the ESIA

process followed the commonly accepted international principles to maximise participation of

all sections of the society including any marginalised groups.

The outcomes of the meetings are summarised in the form of list of stakeholder issues and

expectations which were;





Local people/youth (born in the area) and land owners should be involved in the

employment and development process to avoid conflict.







Concerns over the decline in people working in agricultural production reducing the

availability of farm workers and increasing pressure on food resources.

Group Offices:

Registered Address: 21 Gold Tops, City and County of Newport, NP20 4PG,

Wales, United Kingdom.

SRK Consulting (UK) Limited Reg No 01575403 (England and Wales)



Africa

Asia

Australia

Europe

North America

South America



SRK Consulting



Marampa Iron Ore Project –Executive Summary







Women must be considered for employment and child labour be avoided.







Apprehensions about noise pollution, air pollution, flora and fauna biodiversity loss.

How will MIOL mitigate these issues?







Apprehension about depletion of water table, which needs to be addressed.







Concern over the inappropriate disposal of tailings.







MIOL should develop tangible structures instead of just giving out money.







Preference towards local businesses and shops for purchase of provisions and

supplies.







Resettlement is a key issue and MIOL must do this sensitively and properly where they

should buy land and build houses for them.







The authority of Paramount Chiefs is now declining MIOL and should not rely on them

too much. The Company should identify other leaders and communicate directly with

community members. Dialogue with the community should be sustained







The Community Liaison Officer (CLO) will be the key person for community outreach.







MIOL should hold monthly meetings with the community.







What will MIOL do about tailing storage facilities?







Landowners should be treated fairly whereby they receive the true money value of their

land.







The rehabilitation of mined out areas is very crucial for the sustainability in agriculture.







Concerns over the effect of air pollution and dust from vehicles will have on human

health







Concerns over heavy machines shaking nearby houses and blasting activity damaging

their houses as structures are weak.







Concerns over increases in accidents due to an increase in traffic and the safety of

people when crossing railways and roads.







Toilet facilities and clean water supply should be provided.



Future stakeholder consultations on completion of the ESIA report (in the form of an

Environmental and Social Impact Statement or ESIS) will comprise of:





feedback consultations to update the stakeholders on predicted impacts and proposed

mitigation measures; and







a public hearing meeting by SLEPA to assess public opinion on the Project.



For managing community relations MIOL will need a mechanism for effective and speedy

resolution of stakeholder complaints and problems and also to provide a satisfactory response

to their queries and issues on an ongoing basis. The mechanism will be developed in

consultation with stakeholders for transparency.



U3823_Marampa_SEP_Final.docx



August, 2012

Page ii of ii



SRK Consulting



Marampa Iron Ore Project – Table of Contents



Table of Contents

1



INTRODUCTION ................................................................................................. 1

1.1 Project background .................................................................................................................. 1

1.2 Structure of the document ....................................................................................................... 3



2



PROJECT DESCRIPTION .................................................................................. 3



3



REGULATORY REQUIREMENTS AND GUIDELINES ...................................... 6

3.1 Sierra Leone national policy guidelines ................................................................................... 6

3.1.1 Environmental Protection Agency Act, 2008 ................................................................. 6

3.1.2 Mines and Minerals Act, 2009 ....................................................................................... 6

3.2 International standards and guidelines .................................................................................... 6



4



PURPOSE OF THE SEP ..................................................................................... 8

4.1 Overview of Marampa consultation process ............................................................................ 8



5



PROJECT STAKEHOLDERS ........................................................................... 10



6



SUMMARY OF PREVIOUS CONSULTATIONS ............................................... 17

6.1 Initial community engagement by MIOL ................................................................................ 17

6.2 Scoping consultations with key government ministries ......................................................... 17

6.3 Scoping consultations with various stakeholders groups (March 2011) ............................... 18

6.3.1 Methodology used for consultation and disclosure activities ...................................... 18

6.3.2 List of stakeholders consulted ..................................................................................... 20

6.3.3 Outcomes of the consultation meetings ...................................................................... 21



7



FUTURE CONSULTATIONS............................................................................. 22

7.1.1 Consultations beyond the ESIA process ..................................................................... 23



8



GRIEVANCE MECHANISM............................................................................... 23



9



REFERENCES .................................................................................................. 23



GLOSSARY OF TERMS............................................................................................. I

ACRONYMS .............................................................................................................. II



List of Tables

Table 3-1: IFC Performance Standards: key principles for undertaking public consultations ................ 7

Table 5-1: Identification and analysis of stakeholders/ groups ............................................................. 11

Table 6-1: MIOL’s meetings with the communities in 2010 .................................................................. 17

Table 6-2: Summary of stakeholder meetings held in July 2010 .......................................................... 18

Table 6-3: Stakeholder consultation methods used .............................................................................. 19

Table 6-4: Meetings with various stakeholder groups in March 2011 .................................................. 20



List of Figures

Figure 1-1: Location of the exploration area ........................................................................................... 2

Figure 2-1: Location of proposed Project infrastructure relative to local villages ................................... 5

Figure 4-1: Marampa ESIA stakeholder engagement process ............................................................... 9



U3823_Marampa_SEP_Final.docx



August, 2012

Page i of ii



SRK Consulting



Marampa Iron Ore Project – Table of Contents



List of Technical Appendices

1. STAKEHOLDER DETAILS ................................................................................ 1I

2. MEETING MINUTES .......................................................................................... 2I

3. DISCLOSURE MATERIAL ................................................................................. 3I

4. PHOTOS ............................................................................................................. 4I

5. ISSUES AND RESPONSE RECORD................................................................. 5I



U3823_Marampa_SEP_Final.docx



August, 2012

Page ii of ii



SRK Consulting (UK) Limited

5th Floor Churchill House

17 Churchill Way

City and County of Cardiff

CF10 2HH, Wales

United Kingdom

E-mail: enquiries@srk.co.uk

URL: www.srk.co.uk

Tel:

+ 44 (0) 2920 348 150

Fax: + 44 (0) 2920 348 199



MARAMPA IRON ORE PROJECT: STAKEHOLDER

ENGAGEMENT PLAN FOR THE ENVIRONMENTAL AND

SOCIAL IMPACT ASSESSMENT

1



INTRODUCTION

SRK Consulting (UK) Limited (“SRK”) has been appointed by Marampa Iron Ore (SL) Limited

(MIOL) to undertake the Environmental and Social Impact Assessment (ESIA) for the

proposed Marampa Iron Ore Project (the Project) located in Sierra Leone. This document

presents the Stakeholder Engagement Plan (SEP), required as part of the above study, to

guide the process of information disclosure and stakeholder consultations during the ESIA

process. The SEP is a dynamic document that will be updated at different stages of the

Project. This version of the SEP presents the findings and methodology of the stakeholder

consultations undertaken during the scoping phase of the ESIA process and its outcomes. It

also provides the plan for further consultations as part of the ESIA process.



1.1



Project background

The Lunsar area was the focus of significant mining operations run by DELCO between 1933

and 1975. This mining operation, which is located within ML02/05, mined both the lateritic cap

from Masaboin and Gafal Hills, and the underlying specular hematite schists. The specular

hematite was concentrated by crushing, coarse grinding and gravity separation, with

production reaching approximately 2.5 million tonnes per annum (“Mtpa”) of concentrate in the

late 1960s (Cape Lambert, 2009). DELCO constructed a railway and port loading facility at

Pepel Port for transport of the product to worldwide markets.

During the DELCO period of operation, a large community and related infrastructure was

established, which included hospitals, schools, community halls and sports facilities for use by

employees and the local community. The health centre was a recognised training centre for

student nurses and an apprentice scheme for young men was also established. The Delco

mining operation closed in 1975, following a drop in iron ore prices, resulting in significant job

losses. Smaller-scale operations started up again in 1981, which involved dredging of the

tailings by Austrian company, Austromineral GMBH. This operation was abandoned in 1985

due to increasing production costs.

Recent exploration by MIOL, within its Exploration Licences EL46/2011-A and EL46/2011-B

(Figure 1-1), has identified six priority areas and is currently focussing on the development of

the Gafal, Rotret, Mafuri and Matukia Prospects for the current ESIA and mining licence

application.



Group Offices:

Registered Address: 21 Gold Tops, City and County of Newport, NP20 4PG,

Wales, United Kingdom.

SRK Consulting (UK) Limited Reg No 01575403 (England and Wales)



Africa

Asia

Australia

Europe

North America

South America



SRK Consulting



Marmpa Iron Ore Project – ESIA SEP



Figure 1-1: Location of the exploration area



File Ref: U3823_Marampa_SEP_Final.docx



August, 2012

Page 2 of 24



SRK Consulting



1.2



Marmpa Iron Ore Project – ESIA SEP



Structure of the document

This document consists of the following sections:



2







Section 1:



introduction and background to the Project;







Section 2:



Project description;







Section 4:



regulatory requirements and guidelines;







Section 3:



purpose and scope of the SEP;







Section 5:



potential Project stakeholders’;







Section 6:



consultations undertaken to date;







Section 7:



future consultations; and







Section 8:



grievance mechanism.



PROJECT DESCRIPTION

The Company has completed initial exploration drilling of specular hematite deposits at the

Gafal, Rotret, Mafuri and Matukia Prospects. A preliminary mining scoping study conducted

by Bateman Engineering Pty Ltd (“Bateman”) concluded that mining at a capacity of up to

15Mtpa is technically feasible, and financial estimates to date are positive. The Project Mineral

Resource is estimated at 680 million tonnes with an in-situ grade of 28.2% Fe (15% Fe cut-off

grade) and, with processing, could generate a high quality saleable iron concentrate (~65%

Fe), with low levels of deleterious elements.

1



The Project involves the construction of facilities and infrastructure to produce up to 15 Mtpa

of iron concentrate. This will be done in two stages. Stage 1 will involve the construction of

facilities to produce 2.5 Mtpa of iron concentrate through the mining of oxide ore only. Stage 2

(an extension to Stage 1) involves expanding these facilities, and the construction of additional

facilities, to enable the production of a total of up to 15 Mtpa of iron concentrate through the

mining of oxide and/or fresh ore. While the development plan of Stage 2 of the Project is

reasonably known at this time, it will be the subject of a detailed feasibility study moving

forward.

Access to existing rail and port infrastructure, which was recently upgraded and returned to

operation by African Minerals Limited (AML), offers the advantage of lower capital investment

start-up costs and Project lead time, as well as significant environmental advantages, as

opposed to construction of a new port and rail. Open pit mining is the preferred mineral

extraction method, further reducing capital development costs.

The main Project components included in this ESIA and indicated relative to the local villages

on Figure 2-1 are listed below:





Four open pits (Matukia, Gafal, Rotret and Mafuri) and four associated waste rock

dumps (“WRD”)







Run of mine (“ROM”) and low grade stockpiles







Beneficiation plant, comprising:





crushing;







stockpiling;







ore reclamation;



1



It should be noted that references to concentrate production rates refer to dry metric tonnes. The moisture content of the

product may range between 8-10%, which will increase the actual tonnage of concentrate produced, transported and

exported accordingly (wet metric tonnes).

File Ref: U3823_Marampa_SEP_Final.docx



August, 2012

Page 3 of 24



SRK Consulting



Marmpa Iron Ore Project – ESIA SEP



o



scrubbing / grinding;



o



rougher / scavenger magnetic separation;



o



rougher / scavenger concentrate regrind;



o



cleaner and recleaner magnetic separation;



o



concentrate thickening and filtration;



o



tailings thickening;



o



reagent storage and use; and



o



supporting utilities.







Tailings storage facility (“TSF”)







Power generation and distribution facilities







Water supply facilities







Stormwater management facilities







Waste water management systems







Communications systems







Accommodation







Medical and emergency services







Utilities (potable water supply, fire water system, air compressor systems)







Mobile equipment (vehicles etc)







Buildings for storage, offices, workshop, laboratory, etc







A rail spur and head, connecting to the existing Pepel railway line







Use of existing road routes for transport of supplies to the mine (including the existing

Makeni Highway, connecting Freetown to Lunsar) and some new on-site roads to

connect Project infrastructure



File Ref: U3823_Marampa_SEP_Final.docx



August, 2012

Page 4 of 24



SRK Consulting



Marmpa Iron Ore Project – ESIA SEP



Figure 2-1: Location of proposed Project infrastructure relative to local villages



File Ref: U3823_Marampa_SEP_Final.docx



August, 2012

Page 5 of 24



SRK Consulting



3



Marmpa Iron Ore Project – ESIA SEP



REGULATORY REQUIREMENTS AND GUIDELINES

This section describes both Sierra Leone requirements and international guidelines for

conducting stakeholder consultation and disclosure activities during the ESIA process and

throughout Project operation.



3.1



Sierra Leone national policy guidelines

Current Sierra Leone legislation most relevant to the ESIA process is:





the Environment Protection Agency Act No. 11 of 2008 (EPA Act 2008); and





the Mines and Minerals Act 2009.

Each of these is briefly described in the sections below.



3.1.1 Environmental Protection Agency Act, 2008

The EPA Act 2008,, Sections 27 (1) and (2) stipulate the procedure for release of the ESIA

report to the public for review and invites their comments. It includes:





circulation of the ESIA report to professional bodies or associations, Government

Ministries and non-government organisations by SLEPA;







notice by SLEPA in two consecutive issues of the Gazette to open the ESIA report for

public inspection and comments; and







notice by the Company in two issues of newspapers, with an interval of seven days

between first and second publication, inviting public inspection and comments.



Any public comments received within fourteen days of the last publication in the Gazette or

newspaper should be compiled by the company and reported to SLEPA.



3.1.2 Mines and Minerals Act, 2009

The Mines and Minerals Act (2009), Part XV (Protection of the Environment), Section 133 (2)

corroborates the provisions of the EPA Act (2008). It states that a mining licence applicant,

applying for an environmental licence, shall consult with the public to introduce the Project and

to verify possible impacts of the Project from stakeholders’ perspectives.

Subsection (3) further states that a copy of the ESIA report shall be considered nonconfidential and shall be made available to the public at the Mining Cadastre Office.



3.2



International standards and guidelines

The IFC’s Performance Standards (PS) published in January 2012 are regarded as a

benchmark for large private sector Projects. The PS are also at the core of the revised

Equator Principles, a code of practice applied by international financial organisations involved

in the financing of such Projects. The stakeholder consultation programme for the Project will

be guided by the standards and guidelines, modified to reflect the nature and scale of the

Project and other relevant factors.

The specific requirements for public consultation are contained in IFC’s Performance Standard

1: Social and Environmental Assessment and Management Systems. The requirements for

consultation are further elaborated in the corresponding Guidance Notes. The concept of free,

prior and informed consultation is explained in the same table.

For Category A Projects (such as the Marampa Project), the Project proponent is required to

consult with relevant stakeholders at least twice. First, during the scoping phase, before the

Terms of Reference (ToR) for the assessment and baseline studies are finalised, and next on

completion of the ESIA process to feedback on the potential impacts and resultant

management plans. The consultation process then continues throughout the Project



File Ref: U3823_Marampa_SEP_Final.docx



August, 2012

Page 6 of 24



SRK Consulting



Marmpa Iron Ore Project – ESIA SEP



construction, operation and closure phases, as necessary, to address relevant stakeholder

issues and concerns which are shown in table 3.1.

In addition, the Equator Principles and Performance Standards require Project proponents to

set up a system to address grievances in a prompt manner. This system should be

understandable, transparent, culturally appropriate, easily accessible and should be at no cost

to the affected people.

Table 3-1: IFC Performance Standards: key principles for undertaking public

consultations

Reference/guidance



Key Principles/concepts



PS 1: Social and

Environmental

Assessment and

Management System



Public consultation and disclosure should:



be free of external manipulation, interference, coercion or intimidation;



be inclusive of all segments of the affected communities (including

women, children, the elderly, etc.);



be informed by preliminary stakeholder analysis;



entail both open (public) community meetings and discussions with

community leaders;



clearly communicate potential Project-related risks and impacts;



start during early scoping (especially for Projects with significant

impacts);



be based on timely, relevant, understandable and accessible

information – this requires information to be provided in the languages

and methods preferred by the affected communities;



inform the terms of reference (TOR) for social and environmental

assessment;



allow time and opportunities for collective decision-making (especially

for indigenous peoples) and for contextually appropriate feedback

mechanisms;



lead to ‘broad community support’ defined as ‘a collection of

expressions by the affected communities, through individuals and their

recognised representatives, in support of the Project’.



entail a clear action plan based on the environmental and social

management plan; and



accompany all significant changes to Project planning, scope and

execution.



Free, Prior and Informed

Consultation



As per the IFC Guidance Note 1: Social and Environmental Assessment and

Management Systems, Free, Prior and Informed Consultation means that

the:

‘…consultation should be “free” (free of intimidation or coercion), “prior”

(timely disclosure of information) and “informed” (relevant, understandable

and accessible information)’ and should lead to ‘…broad community support

for the Project by the affected communities’.

Broad community support is defined as ‘a collection of expressions by the

affected communities, through individuals and their recognised

representatives, in support of the Project’.



File Ref: U3823_Marampa_SEP_Final.docx



August, 2012

Page 7 of 24



SRK Consulting



4



Marmpa Iron Ore Project – ESIA SEP



PURPOSE OF THE SEP

The purpose of the SEP is to ensure the views, interests and concerns of Project stakeholders

are taken into consideration during environmental and social impact assessment process.

The specific objectives of the SEP therefore are to:



4.1







identify potential Project stakeholders and analyse their interest/influence on the

Project;







describe relevant Sierra Leone legal requirements and international standards;







present the approach and methodology for consultation and disclosure activities;







consult with Project stakeholders and document their feedback;







document the stakeholder engagement process to date; and







propose a framework for grievance mechanism.



Overview of Marampa consultation process

An overview of the Marampa stakeholder engagement process is presented in Figure 4-1.

The overall programme is closely linked to different stages the ESIA process so as to

complement each other.



File Ref: U3823_Marampa_SEP_Final.docx



August, 2012

Page 8 of 24



SRK Consulting



Marmpa Iron Ore Project – ESIA SEP



Figure 4-1: Marampa ESIA stakeholder engagement process



File Ref: U3823_Marampa_SEP_Final.docx



August, 2012

Page 9 of 24



SRK Consulting



5



Marmpa Iron Ore Project – ESIA SEP



PROJECT STAKEHOLDERS

Project stakeholders are defined as those groups or individuals that ‘will be directly or

indirectly affected, positively or negatively, by the Project and who can contribute to or hinder

its success’ (IFC, 2012).

Identification of potential stakeholders including vulnerable groups/individuals was undertaken

as a first step while preparation of the initial SEP during July 2010. The initial list of

stakeholders was drawn based on meetings with the Project staff (at the site and in Freetown)

and assessment of the potential Project footprint area. Government representatives met

during July 2010 were asked to provide further information on names of potential

stakeholders. Each stakeholder met during the scoping process was asked to provide further

information on potential stakeholders. Hence the current list of stakeholders was developed

as a snowballing process and is presented in Appendix 1. The list of interested NGOs and

other interest groups was drawn using SRK’s prior experience of working in Sierra Leone and

in discussion with the in-country social specialist. Typically identification of stakeholders is an

on-going and iterative process and more stakeholders are expected to be identified as the

Project develops.

The analysis of stakeholders involved stakeholder categorisation in terms of their potential

interest in the Project, how they could be affected by the Project and to what degree, issues

and concerns they have with the Project and what influence they may have on the Project.

Mode and frequency of communication was suggested for each stakeholder or group. Table

5-1 presents the stakeholder analysis conducted after the scoping consultations. Updating the

stakeholder analysis is also an on-going process and should be repeated after each round of

stakeholder engagement.



File Ref: U3823_Marampa_SEP_Final.docx



August, 2012

Page 10 of 24



SRK Consulting



Marmpa Iron Ore Project – ESIA SEP



Table 5-1: Identification and analysis of stakeholders/ groups

Stakeholder

category



Stakeholder (group)/ profile



(STAKEHOLDER PROFILE)

Potential concerns and expectations from the Project



Impact/benefit

from Project



Government and

regulatory

authorities



• Port Loko District

• Paramount Chiefs (Masimera,

Marampa and Maforki)

• Lunsar Town Administration

• Sierra Leone Environment

Protection Agency (SLEPA)



• Increased revenue for development programmes

• Expect benefits to local communities and economy

• Concerned about in increase in population due to

migration of skilled and other workers

• SLEPA is responsible for issuing EIA licences which

are needed for the Project to be approved.

• Concerned about potential environmental and social

impacts

• National government ministry for mines and minerals

formulates and presents policies and legislation for the

consideration of Parliament

• The Mines Division administers the regulations made

under the mines and minerals Act and the explosive

Act. These regulations include the issue of all mineral

rights and the administration and supervision of all

activities under these rights.

• The Geological Survey Division advises Government

on all matters of geological nature. This enables the

government to grant mineral rights to interested

investors with Government’s aim in pursuing a more

creative mining development policy

• Want to know the scale of and nature of mining

operation and revenues

• Expects investment for community development



• Ministry of Land Country Planning

and Forests (Departments of

Forests and Wildlife)



• Concerned about endemic species which are also

vulnerable to hunting and illegal trade



• Ministry of Agriculture and Food

Security



• Concerned that the Project will bring many people into

the area and those who don’t get jobs will resolve to

charcoal burning and fuel wood, thus exploiting the

forest further. Expects the company to help develop the

forest.

• Already problems of low water levels and

desertification, concerned these will be exacerbated.



• Ministry of Minerals (Mining

Division)



• Ministry of Local Government



File Ref: U3823_Marampa_SEP_Final.docx



Communication

strategy



Medium



Degree of

influence

over

Project

Medium



Low



High



Two way

communication and

negotiation



Medium



High



Two way

communication



Medium



Low



Medium



High



Information

dissemination

Two way

communication



Information

dissemination



Information

dissemination



August, 2012

Page 11 of 24



SRK Consulting



Marmpa Iron Ore Project – ESIA SEP



Stakeholder

category



Stakeholder (group)/ profile



(STAKEHOLDER PROFILE)

Potential concerns and expectations from the Project



Impact/benefit

from Project



Affected

communities



• Villages falling within the potential

Project footprint area; villages

impacted by restricted access to

land other natural resources;

villages downstream of water

supply area; host resettlement

areas



• Expectation of jobs, business opportunities, training,

improvement in physical infrastructure such as –

schools, health centre, water supply, roads, electricity

and other facilities



• Land owners/farmers



• Concerned about loss of shelter and access to land and

other natural resources

• Concerned about the potential stress and trauma

related to resettlement and displacement

• Expectations of replacement houses, fair compensation

for land (and crops, trees)

• Expectations of support in livelihood restoration and

financial support during transition period

• Expect expansion in consumer base and increase in

business and growth of town

• Concerned about pressure on infrastructure as a result

of influx of job seekers

• Expectations in terms of opportunities for education and

employment for females; and upward social mobility.

Women should not be ignored in potential employment

opportunities

• Would like help to tackle pests destroying their crops

• Expects assistance for business activities and for

building up a storage facility for crops and produce.

• Concerned blasting activities will damage their houses

• Would like local people to be employed

• Creation of toilet facilities and water supplies

• Concerned about dust causing illness and increase in

accidents due to traffic

• Concerned about community development

• Concerned about wildlife protection and forest

conservation



• Lunsar residents



• Foreroad Baka women’s

association and Mabesene

women’s association



• Youth groups



File Ref: U3823_Marampa_SEP_Final.docx



Communication

strategy



High



Degree of

influence

over

Project

Medium



High



Medium



Two way

communication and

negotiation



Medium



Low



Information

dissemination



High



Low



Medium



Low



Two way

communication



Two way

communication



August, 2012

Page 12 of 24



SRK Consulting



Marmpa Iron Ore Project – ESIA SEP



Stakeholder

category



Stakeholder (group)/ profile



(STAKEHOLDER PROFILE)

Potential concerns and expectations from the Project



Impact/benefit

from Project



Non-government

Organisations

(NGOs) and special

interest groups



• Network Movement for Justice and

Development (NMJD)



NMJD is engaged in various rights based campaigns on

the issues of mining in Sierra Leone. They build the

capacity of community members and organisations on

mining law and their rights to enable them negotiate and

work with mining companies in a non-violent manner.

They summarise mining and ESIA documents into simple

language for community to understand as part of

community.

They are also working with the government to strengthen

governance and accountability

• Worried moving too fast could create problems

• Communities should know what is happening at each

stage to minimise impacts

• Concerned about rights of local people

• Green Scenery is a local NGO involved in

environmental promotion and protection; livelihood

security; human rights and governance; and peace

building and conflict resolution.

• Worried company won’t complete all stages prior to

ESIA and just do enough to gain licence

• Company should design programmes to engage with

communities, talking to people is not enough

• Chiefs are no longer in control of everything so

company should engage with all people including

youths

• Re-vegetation is important

• Concerned over change of ownership, a bond should

be left for new companies to take up

• Concerned about resettlement and land allocation

• Concerned about how company will tackle climate

change



• Green Scenery



File Ref: U3823_Marampa_SEP_Final.docx



Communication

strategy



Low



Degree of

influence

over

Project

Medium



Low



Medium



Information

dissemination



Two way

communication



August, 2012

Page 13 of 24



SRK Consulting



Stakeholder

category



Marmpa Iron Ore Project – ESIA SEP



Stakeholder (group)/ profile



(STAKEHOLDER PROFILE)

Potential concerns and expectations from the Project



Impact/benefit

from Project



Communication

strategy



Low



Degree of

influence

over

Project

Medium



• Environmental Forum for Action

(ENFORAC)



• ENFORAC are a consortium of environmental NGOs,

community groups and academic institutions who work

together to protect and advocate for Sierra Leone's

natural resources. Their main aims are:

• Natural resource management;

• Policy reforms and enforcement;

• Land use planning;

• Water catchments management;

• Waste management;

• Biodiversity management research;

• Sustainable development; and

• Mass environmental education and information

campaigns.

• ENFORAC raised concerns about visual impacts as

the landscape will be destroyed, future disaster and

digging of pits



Low



Medium



Information

dissemination



Low



Medium



Information

dissemination



Information

dissemination



Want to know what the company will do about



Noise and air pollution



Tailing storage facilities



Drilling/blasting –effects on workers and the

communities



Flora and fauna



Budget for mitigation

• Cotton Tree Foundation



• Amazonian Initiative Movement



• Focuses on business agriculture, environmental

rehabilitation (how the environment can be

rehabilitated), food security and education.

• Concerned about impacts on water and on agriculture

• Expects the company to show respect for all local

people, and to engage with different groups especially

youths

• The organisation campaigns against harmful practices

against women and girls. They specifically campaign

against Female Genital Mutilation (FGM).

• Concerned about HIV and AIDS with

foreigners/employees coming from outside not being

aware of the problem.



File Ref: U3823_Marampa_SEP_Final.docx



August, 2012

Page 14 of 24



SRK Consulting



Stakeholder

category



Other stakeholders

and stakeholder

groups



Marmpa Iron Ore Project – ESIA SEP



Stakeholder (group)/ profile



• Journalist, Universal Radio (Media)



• Marampa Community Bank



• District Medical Officer (DMO) Port

Loko



• Port Loko Teachers College

(PLTC) Administration



(STAKEHOLDER PROFILE)

Potential concerns and expectations from the Project

• Concerned about young girls being brought into

prostitution.

• Expected preference to be given to locals in terms of

employment.

• Expects company to provide proper safety gear for

employees.

• Other concerns are with women, child labour and

human resources

• Local and national newspapers, radio and T.V.

• Eager to cover issues relevant to the interests of its

audience and constituency

• Looks for negative aspects of the Projects

• The Bank was re-established after the war in 2002 by

the Government of Sierra Leone and started operating

on 7th February 2003 to provide financial services to

the Marampa community.

• Expects the company to put a percentage of their

money into the bank

• Expects the company to do local banking and pay

wages through the bank

• DMO based in the district hospital in Lunsar

• Problems with local people having to use unclean water

from upstream

• HIV/AIDS is prevalent in the area, concerned this may

get worse with influx of people

• Concerned about dust causing illness

• Concerned about biodiversity and soil depletion and

toxicity causing damage to plants

• Expects company to plant economic trees for the local

people to enhance livelihoods

• Concerned in migration may cause an increase health

and social problems such as crime

• Expects assistance for tertiary institutions as well as

primary and secondary schools

• Concerned with rail /roads and transport causing

accidents.

• Believes that if the company help the schools then

there will be a ripple effect, they can develop training



File Ref: U3823_Marampa_SEP_Final.docx



Impact/benefit

from Project



Degree of

influence

over

Project



Communication

strategy



Low



High



Information

dissemination



Low



Low



Information

dissemination



Medium



Low



Two way

communication



Medium



Low



Information

dissemination



August, 2012

Page 15 of 24



SRK Consulting



Stakeholder

category



Marmpa Iron Ore Project – ESIA SEP



Stakeholder (group)/ profile



• Murialdo Secondary School



(STAKEHOLDER PROFILE)

Potential concerns and expectations from the Project



















facilities to help people get jobs in the mine e.g.

catering

Concerned teachers may leave the school to get better

paid jobs with the Project, the company should check

employment records in interview

Concerned pupils may leave education to get work

instead of staying in school

Expects MIOL to talk with and discipline employees

who hassle the school girls.

Would like consultation to be a continuous process

Worried about demand on food, and people turning the

theft if they cannot get work.

Would like MIOL to take part in school activities

Would like MIOL to give university scholarships to

some pupils



File Ref: U3823_Marampa_SEP_Final.docx



Impact/benefit

from Project



Degree of

influence

over

Project



Communication

strategy



High



Low



Two way

communication



August, 2012

Page 16 of 24



SRK Consulting



6



Marmpa Iron Ore Project – ESIA SEP



SUMMARY OF PREVIOUS CONSULTATIONS

This section provides a summary of the stakeholder consultation activities undertaken during

this ESIA process (until March 2011).



6.1



Initial community engagement by MIOL

Prior to the start of stakeholder consultations as part of the ESIA by SRK, MIOL were involved

in meetings with the local community members and their leaders as part of the on-going

exploration activities and its on-going community support programme. The meetings

generally took the form of open public meetings in a communal venue in Lunsar. No formal

records are available of these meetings. Based on discussions with MIOL staff SRK has

noted two key meetings held during 2010. These are presented in Table 6-1.



Table 6-1: MIOL’s meetings with the communities in 2010

Place & Date



Stakeholder(s)



Meeting topics



Town Hall,

Lunsar, April

2010



General Public and community

representatives (about 800 participants)











Primary School,

Konta Village, 9

July 2010



Village residents, school children, First

Lady of Sierra Leone, local administration,

community representatives and general

pubic











6.2



The Company presented an update on the

Project progress and ongoing community

development programmes undertaken by

MIOL

The community wanted to know when the

Project would start and make employment

opportunities available

The Primary School built with assistance

from the Company was formally inaugurated

by the First Lady on behalf of the people of

Sierra Leone

Scholarships were distributed to selected

students to support them in the continuation

of their education



Scoping consultations with key government ministries

On start of the ESIA process, SRK conducted meetings with the key government agencies

(mining, environment, forestry and the local government) during July 2010.

The purpose of meetings was to:





formally initiate the ESIA process with SLEPA; and







to announce the intention to develop the proposed Project among other relevant

ministries;







to seek inputs in the stakeholder identification process to identify additional Project

stakeholders; and







to document the issues and concerns of Project stakeholders for consideration in the

ESIA process.



The meetings were held on a one-to-one basis in the ministry offices and were attended by a

representative from MIOL. Meeting minutes were recorded for each meeting. Table 6-2

presents a summary of all the meetings held. Appendix 2 presents the records taken at the

meetings.

A Background Information Document (BID) outlining the status of the Project was prepared as

a disclosure document and provided to Ministry representatives at the time of the meetings. A

copy of the BID is provided in Appendix 3.



U3823_Marampa_SEP_Final.docx



August, 2012

Page 17 of 24



SRK Consulting



Marmpa Iron Ore Project – ESIA SEP



Table 6-2: Summary of stakeholder meetings held in July 2010

Place & Date



Stakeholder(s)



Meeting topics



Follow up action by /

MIOL/SRK



Mining Cadastre

Office, 1 July

2010



Eugene Norman

(Assistant Government

Mining Engineer)

Alusine Timbo (Assistant

Government Mining

Engineer),







MIOL introduced the Project

and announced the intention to

start the ESIA.

Project Background

Information Document was

provided.

The Ministry representative

asked that the ESIA

requirements be discussed

with SLEPA.



Consultation with

SLEPA



MIOL introduced the Project

and announced the intention to

start the ESIA.

Project Background

Information Document was

provided.

Mr Bah explained the steps

leading to an ESIA licence and

asked for a letter from the

Company as formal notice to

start the ESIA process.



Send letter to SLEPA as

formal notice of intention

to undertake the ESIA

and request supply of

application form and

screening form.



MIOL introduced the Project

and announced the intention to

start the ESIA.

Project Background

Information Document was

provided.

Mr Conteh provided

information on the protected

areas and asked for a formal

letter to the Ministry for

permission to proceed with the

Project if it does not interfere

with any protected areas.



Letter to the Ministry for

permission to proceed,

once the Project

footprint area is defined.



MIOL introduced the Project

and announced the intention to

start the ESIA.

Project Background

Information Document was

provided.

The Director explained the role

of the ministry representative

on the Minerals Advisory Board

and in negotiation between

land owners and mining

companies (if required).



Formal letter to the

Ministry to seek

community cooperation

in the development of

Project.











SLEPA office, 2

July 2010



Momodu A Bah, Acting

Deputy Executive Director

(In-charge of EIA, Field

operations & Extensions),

SLEPA















Office of the

Forestry

Department, 2

July 2010



Mr Abdul-Abib F Conteh,

Deputy Director, Forestry

Division















Office of the

Ministry of the

Local

Government, 2

July 2010



Director, Ministry of the

Local Government















6.3



Scoping consultations with various stakeholders groups (March 2011)

Following meetings with the key stakeholders (Section 6.2) SRK conducted consultation

meetings with a full range of Project stakeholders in March 2011. It included meetings with

community groups, local government, NGOs and other interest groups.



6.3.1 Methodology used for consultation and disclosure activities

The methodology used for consultation meetings was based on analysis of the Project area

and stakeholders. It took into consideration specific needs of the different stakeholders/groups

(including vulnerable groups) and the following factors:

U3823_Marampa_SEP_Final.docx



August, 2012

Page 18 of 24



SRK Consulting



Marmpa Iron Ore Project – ESIA SEP







literacy level and capacity to understand technical information;







cultural background;







gender;







geographic location;







vulnerability to potential Project impacts; and







level of interest in and influence over the proposed Project;



Communication tools

Table 6-3 presents appropriate communication methods used with different stakeholder

groups.

Table 6-3: Stakeholder consultation methods used

Methods:



Stakeholders:



One-on-one meetings







































Public hearing/ meetings / open days

Focus group meetings/ workshops/

village meetings

Telephone conversations



Fax, E-mail

Media

Distribution of disclosure documents



Key Government stakeholders

NGOs

Paramount Chiefs

Affected communities

General public

Vulnerable groups in communities (eg. women, the elderly)

NGOs

Special interest groups

Government stakeholders

NGOs

Community Leaders

Government stakeholders

NGOs

All stakeholders

General public

All stakeholders

Affected communities (non-technical summaries)

(examples of disclosure materials are presented in

Appendix 3)



Invitations for the meetings

Invitations for the consultation meetings were sent to institutional stakeholders 7-10 days in

advance. Community groups were notified 3-4 days in advance of meetings, as longer notice

periods tend to result in lower attendance levels in villages. Local communities were notified

in person whereas Invitations/notices to other stakeholders were sent out either by letter, fax

or email.

Disclosure documents

The BID and a fact sheet by MIOL was distributed among the stakeholders prior to and during

the meetings. For community meetings posters were used to explain the proposed Project

and aid the discussion. For meetings with the institutional stakeholders presentation slides

were used to aid the consultation process. Appendix 3 shows the different disclosure

documents used during scoping consultations.

Location of community meetings

2



The community meetings were held at each village within the study area . Within the villages,

meetings were held at centrally located open public areas to enable easy access by different



2



Study area is defined in the social baseline study (SRK, 2012)



U3823_Marampa_SEP_Final.docx



August, 2012

Page 19 of 24



SRK Consulting



Marmpa Iron Ore Project – ESIA SEP



stakeholders including participation of women, youth, elderly and any minority groups. The

meetings were held in locally popular language – Temne with translation into English for MIOL

and SRK representatives.

In addition, a public meeting was held at Lunsar town which was open to the general public.

Public notices were issued for participation in the meetings. This meeting was attended by

about 1000 people from the Lunsar town and various villages in the vicinity of proposed

Project site. It was also attended by the local leaders (both traditional and administrative).

The meeting provide a forum for different sections of the society to exchange their opinion on

the proposed Project which was largely in favour of the development.

Documentation

Record of stakeholder issues was kept at all meetings. These were compiled into an issues

and response table, which shows how these were addressed during the ESIA process

(Appendix 5). Copies of meeting minutes held during March 2011 (and example attendance

register) are presented in Appendix 2. Selected photos from the meetings held in March 2011

are provided in Appendix 4.



6.3.2 List of stakeholders consulted

Table 6-2 presents the list of stakeholders consulted during March 2011, along with a datewise schedule of the various meetings conducted.

Table 6-4: Meetings with various stakeholder groups in March 2011

Date



Place/venue



Stakeholder(s)



9 March 2011



49 Main Motor Road, Brookfields, Freetown







9 March 2011



Soldier Street, Freetown







9 March 2011



Upper Brook Street, Freetown







9 March 2011



Cotton Tree Foundation Office, King Street,

Freetown







10 March 2011



Lunsar-Makeni Highway, Lunsar







11 March 2011



Office of the Marampa Community Bank,

Lunsar



11 March 2011



Office of Port Loko District Council















11 March 2011



12 March 2011



District Agriculture Officer’s Office, Ministry

of Agriculture and Food Security, Port Loko

District

Town Hall, Lunsar



U3823_Marampa_SEP_Final.docx







Aminata Lamin (Programme

Director) -Mining and Extractive,

Network Movement for Justice

and Development (NMJD)

Joseph Rahall (Director) - Green

Scenery

Abdul Conteh (Director) and

Ansumana LM Swaray, (National

Coordinator) -Environmental

Forum for Action

Michael Kamara (Executive

Director) - Cotton Tree

Foundation

Osman Kargbo (Administrative

Officer), Luisa (Intern Plan

Officer) and 9 other staff

members Amazonian Initiative Movement

Aiah Fomba (Manager) Marampa Community Bank

Abdul Koroma (Deputy Chief

Administrator),

Sheik A M Gibril (Rural

Development Officer),

Hassan Bruce (Journalist,

Universal Radio)

Ministry of Agriculture and Food

Security



Open Public Meeting, attended by:

• General public,

• Paramount Chief,

• local villagers,

• Village Chiefs,

August, 2012



Page 20 of 24



SRK Consulting



Marmpa Iron Ore Project – ESIA SEP













13 March 2011



Foreroad Baka Village, Lunsar



land owners,

Provincial Secretary,

Member of Parliament,

Deputy Minister of Local

Government and Internal Affairs,

• AIG North,

• Religious leaders,

• Youth Groups,

• Women’s Groups,

• Port Loko District Council,

• NGOs,

• Chiefdom Council,

• MIOL/Cape Lambert

Foreroad Baka Women’s Association



13 March 2011



Mabesene Village, Lunsar



Mabesene Women’s Association



14 March 2011



DMO’s office, Port Loko Government

Hospital, Hospital Road, Port Loko



Dr Victor Max-Lebbie

Medical Officer



14 March 2011



PLTC Campus, Lungi Road, Prot Loko



14 March 2011



Murialdo Secondary School, Lunsar



Ahmed A Koroma (Vice Principal and

Director of Studies) - Port Loko

Teachers

College

(PLTC)

Administration

Fr. Giuliano Pini (Principal), Fr

Emmanuel Koroma, Mr Ambrose

Bangura (Vice Principal) - Murialdo

Secondary School



-



District



6.3.3 Outcomes of the consultation meetings

The outcomes of the consultation meetings, in the form of list of key issues, concerns and

expectations raised the stakeholders, is provided below. The issues were divided into

categories for ease of understanding and dealing with them. Appendix 4 presents the

complete list of the issues, concerns and expectations recorded during the consultation

meetings.

Employment





Local people/youth (born in the area) and land owners should be involved in the

employment and development process to avoid conflict.







Concerns over the decline in people working in agricultural production reducing the

availability of farm workers and increasing pressure on food resources.







Expect the Company to apply preferential employment of local people over outsiders.







Women must be considered for employment and child labour be avoided.







Concerned that the teachers and some senior students in the local schools may leave

the school to work for the Project. What can MIOL do to prevent this?







Rumours that one has to pay 200,000 to 400,000 Leones to get a job at the Project.



Environment





Apprehensions about noise pollution, air pollution, flora and fauna biodiversity loss.

How will MIOL mitigate these issues?







Apprehension about depletion of water table, which needs to be addressed.







Company should choose the vegetation species for rehabilitation, Gethropha is

detrimental to local water.







Concern over the inappropriate disposal of tailings.



U3823_Marampa_SEP_Final.docx



August, 2012

Page 21 of 24



SRK Consulting



Marmpa Iron Ore Project – ESIA SEP



Corporate Social Responsibility





Communities should be involved in rehabilitation programmes







Local people, should benefit from mining operations in their area







MIOL should develop tangible structures instead of just giving out money







Safe drinking water should be provided to the communities.







Preference towards local businesses and shops for purchase of provisions and

supplies.







MIOL should use Marampa Community Bank for domestic banking and to pay staff

salaries as this will allow for an improvement in community infrastructure



Stakeholder consultation process and participation





The authority of Paramount Chiefs is now declining MIOL should not rely on them too

much.

Company should identify other leaders and communicate directly with

community members. Dialogue with the community should be sustained







The Community Liaison Officer (CLO) will be the key person for community outreach.







MIOL should hold monthly meetings with the community.



Mining operations





What will MIOL do about tailing storage facilities?







There needs to be sufficient distance between the use of explosives and the

communities.



Resettlement and livelihoods restoration





Resettlement is a key issue and MIOL must do this sensitively and properly where they

should buy land for them and build houses for them.







MIOL should negotiate with plantation owners and the names of the landowners should

be recorded in the deal.







Landowners should be treated fairly, whereby they receive the true money value of

their land.







The rehabilitation of mined out areas is very crucial for the sustainability in agriculture.







A request for assistance and support in business activities and the construction of a

storage facility for crops and produce and agricultural expansion.



Health and Safety



7







Concerns over the effect of air pollution and dust from vehicles will have on human

health







Concerns over heavy machines shaking nearby houses and blasting activity damaging

their houses as structures are weak.







Concerns over increases in accidents due to an increase in traffic and the safety of

people when crossing railways and roads.







Toilet facilities and clean water supply should be provided.



FUTURE CONSULTATIONS

The stakeholder consultations that will take place on completion of the draft ESIA report will

comprise:





feedback consultations to update the stakeholders on predicted impacts and proposed



U3823_Marampa_SEP_Final.docx



August, 2012

Page 22 of 24



SRK Consulting



Marmpa Iron Ore Project – ESIA SEP



mitigation measures; and





a public hearing meeting by SLEPA to assess public opinion on the Project.



The approach and methodology for the feedback consultations will be similar to the scoping

consultations as described in Section 6.3.1. The location and methodology for the public

hearing meeting will be decided in consultation with SLEPA.



7.1.1 Consultations beyond the ESIA process

Beyond the ESIA process, consultations with the stakeholders will be continued by MIOL to

build and maintain mutually beneficial relationship with the Project stakeholders. This will

serve to maintain the dialogue and facilitate resolution of issues raised by stakeholders on an

on-going basis throughout the life of the Project. This SEP will be updated to reflect the

changing needs of the Project as it develops.



8



GRIEVANCE MECHANISM

For managing community relations MIOL will establish a mechanism for effective and speedy

resolution of stakeholder complaints and problems and also to provide a satisfactory response

to their queries and issues on an ongoing basis. Key features that MIOL would consider in

development of a grievance mechanism are provided below.



9







representatives from different stakeholder groups should be encouraged to participate

in the development of the grievance mechanism to ensure transparency in the process;







stakeholders should be informed about the existence and functioning of the grievance

mechanism to promote its utility;







the paramount chiefs and district officials should be invited to be part of a committee for

handling grievances;







responses should be provided to all queries and grievances in a time bound manner

with a commitment to a time frame for resolving the issues; and







when a dispute cannot be resolved, within a reasonable period, the grieving party

should be free to take the matter to courts as a final resort (in other words the

mechanism should not replace existing legal process but should, based on consensus,

seek to resolve the issues quickly without resorting to expensive and time-consuming

legal actions.



REFERENCES

EPFIs (2006) The “Equator Principles”: A financial industry benchmark for determining,

assessing and managing social & environmental risk in Project financing, Equator Principles

Financial Institutions, 2006

GoS (2008) Environmental Protection Agency Act, Government of Sierra Leone, 2008

GoS (2009), Mines and Minerals Act, Government of Sierra Leone, 2009

IFC (1998) Doing Better Business through Effective Public Consultation and Disclosure: A

Good Practice Manual, International Finance Corporation, 1998

IFC (2006) Performance Standards on Social & Environmental Sustainability, International

Finance Corporation June 2006

IFC (2007) Guidance Notes: Performance Standards on Social & Environmental

Sustainability, International Finance Corporation, 2007



U3823_Marampa_SEP_Final.docx



August, 2012

Page 23 of 24



SRK Consulting



Marmpa Iron Ore Project – ESIA SEP



IFC (2007) Stakeholder Engagement: A Good Practice Handbook for Companies Doing

Business in Emerging Markets, International Finance Corporation, 2007

SRK (2012) Socio economic baseline report for the Marampa Iron Ore Project, SRK

Consulting (UK) Ltd, April 2012



For and on behalf of SRK Consulting (UK) Limited



Lalit Kumar,

Senior Consultant, Social

SRK Consulting (UK) Limited



Hilde van Vlaenderen,

Principal Consultant, Social

SRK Consulting (UK) Limited



U3823_Marampa_SEP_Final.docx



August, 2012

Page 24 of 24



SRK Consulting



Marampa Iron Ore Project – Glossary, Abbreviations, Units



GLOSSARY OF TERMS

TERM



EXPLANATION



Affected Community



Local communities that are subject to risks or impacts from a Project.



Consultation



Consultation involves two-way communication between the client and the

affected communities. The consultation process should be undertaken in a

manner that is inclusive and culturally appropriate and that provides the affected

communities with opportunities to express their views on Projects risks, impacts

and mitigations measures, and allows the client to consider and respond to them.

The consultation process will ensure free, prior and informed consultation.



Information

Consultation and

Disclosure



The process of providing information to the affected communities and other

stakeholders that is timely, accessible, understandable, and in the appropriate

language(s). For Projects with potential adverse impacts, information on the

purpose, nature and scale of the Project, the duration of proposed Project

activities, and any potential risks to and potential impacts on such communities

should be included.



Local Community



Community within a Project’s area of influence.



Management measures



Remedial measures used to reduce the level of risk



Project (the)



The Marampa Iron Ore Project



Settlement



a groups of houses, similar to a village or hamlet



Stakeholder



groups or individuals that are ‘directly or indirectly affected by a Project as well

as …… may have interests in a Project and/or ability to influence its outcome

either positively or negatively’



U3823_Marampa_SEP_Final.docx



August, 2012

Page i of ii



SRK Consulting



Marampa Iron Ore Project – Glossary, Abbreviations, Units



ACRONYMS

BID



Background Information Document



EIA



Environmental Impact Assessment



ESIA



Environmental and Social Impact Assessment



IFC



International Financial Corporation



NGO



Non-governmental organisation



PS



Performance Standards



SEP



Stakeholder Engagement Plan



SL



Sierra Leone



SLEPA



Sierra Leone Environmental Protection Agency



SRK



SRK Consulting (UK) Limited



ToR



Terms of Reference



UK



United Kingdom



U3823_Marampa_SEP_Final.docx



August, 2012

Page ii of ii



SRK Consulting



Marampa Iron Ore Project – Technical Appendix 1



APPENDIX

1.



STAKEHOLDER DETAILS



U3823_Marampa_SEP_Final.docx



August, 2012

Page 1i of 1iii



SRK Consulting



Marampa Iron Ore Project – Technical Appendix 1



Appendix 1: Stakeholders details

Stakeholder category



Stakeholder name



Address



Government and regulatory

authorities



Port Loko District Council



Chief Administrator’s Office, Port Loko

District Council, Port Loko



Paramount Chiefs (Masimera, Marampa

and Maforki)



Marampa Paramount Chief’s residence

is on Lunsar Makeni Highway; other

chiefs are in their respective chiefdoms

(exact location to be checked with

PROs)



Lunsar Town Administration



Lunsar, Port Loko



Sierra Leone Environment

Agency (SLEPA)



Affected communities



Protection



SLEPA Office, 3rd Floor Youyi Building,

Brookfields, Freetown.

Contact: Mr Momodu A. Bah, Acting

Deputy Director

Incharge of EIAs, Field operations &

extensions, SLEPA,

3rd Floor, Youyi Building, Brookfields,

Freetown, Sierra Leone



Ministry of Minerals (Mining Division)



Mining Cadastre Office, Ministry of

Mineral Resources, 5th Floor Youyi

Building, Brookfields, Freetown



Ministry of Local Government



Ministry of Local Government, Youyi

Building, Brookfields, Freetown



Ministry of Land Country Planning and

Forests (Departments of Forests and

Wildlife)



Forestry Department, 1st Floor, Youyi

Building, Brookfields, Freetown



Ministry of Agriculture and Food Security



District Agriculture

MAFS, Port Loko



Villages falling within the potential Project

footprint area; villages impacted by

restricted access to land other natural

resources; villages downstream of water

supply area; host resettlement areas



Affected villages



Land owners/farmers



Affected villages



Foreroad Baka and Mabesene Women’s

Association



Foreroad Baka Village, Lunsar (suburb)



Lunsar residents



Lunsar town



U3823_Marampa_SEP_Final.docx



Officer’s



Telephone



Email



Mobile

number:

078350627,

076668698,

088351725



modbah@yahoo.com



Office,



August, 2012

Page 1ii of 1iii



SRK Consulting



Marampa Iron Ore Project – Technical Appendix 1



Stakeholder category



Stakeholder name



Address



Youth Groups



Lunsar town and affected villages



Religious Leaders

Non-government

Organisations (NGOs) and

special interest groups



Email



+(232)26204036

+(232)76645314



nmjd@nmjd.org



Lunsar town



Network Movement

Development (NMJD)



for



Justice



and



Green Scenery

Environmental

(ENFORAC)



Telephone



NMJD Office, 49 Main Motor Road,

Brookfields, Freetown



gscenery@yahoo.co.uk



Soldier Street, Freetown

Forum



for



Action



51 Upper Brook Street Freetown, Sierra

Leone West Africa, P. O. Box 1145



Mr.

Ansumana

Swarray

National

Coordinator

+ 232 (0) 76 463

653



enforac@yahoo.com



Mr. Abdulai Conteh

Deputy Chairman

+ 232 (0) 33 407

164



Other stakeholders

stakeholder groups



and



Cotton Tree Foundation



Cotton Tree Foundation Office, King

Street, Freetown



Amazonian Initiative Movement



Lunsar-Makeni Highway, Lunsar

24 New Makeni Road, PO Box 77

Lunsar, Marampa Chiefdom, Port Loko

District

Sierra Leone



Port Loko Teachers

Administration



College



(PLTC)



+232-76-738517



aimgn2001@yahoo.co.uk

aimsl2001@yahoo.co.uk



PLTC Campus, Lungi Road, Port Loko



Murialdo Secondary School



Murialdo Secondary School, Lunsar



District Medical Officer



DMO’s office, Port Loko Government

Hospital, Hospital Road, Port Loko



Marampa Community Bank



The

Manager’s

Office,

Community Bank, Lunsar



Journalist, Universal Radio (Media)



Port Loko town



U3823_Marampa_SEP_Final.docx



Marampa



August, 2012

Page 1iii of 1iii



SRK Consulting



Marampa Iron Ore Project – Technical Appendix 2



APPENDIX

2.



MEETING MINUTES



U3823_Marampa_SEP_Final.docx



August, 2012

Page 2i of 2i



Marampa Meeting Minutes

March 2011

Network Movement for Justice and Development (NMJD)

Meeting location: NMJD Office, 49 Main Motor Road, Brookfields, Freetown

Date and Time: 9th March 2011 at 08:06 hours

Attendees: Aminata Lamin (Programme Director, Mining and Extractive, NMJD), Simon Elson

(Cape Lambert) representing the Marampa Iron Ore Limited (MIOL), Aminata Kamara and Lalit

Kumar (SRK)

Simon Elson gave an introduction to the proposed project and the Marampa Iron Ore (Sierra

Leone) Limited (MIOL). A copy of the Background Information Document on the proposed

project was presented. Lalit Kumar explained the ESIA process, the stakeholder consultation

process and invited the participants to express their issues and concerns. The following key

points were raised:



























Aminata Lamin provided an over view of NMJD:

o Mining and extractives is one of focus area for NMJD, which is engaged in

various rights based campaigns on the issues of mining in Sierra Leone

o They build capacity of community members and organisations on mining law

and their rights to enable them negotiate and work with mining companies in a

non-violent manner

o They summarise the mining legislation and ESIA documents into simple

language for community to understand as part of community capacity building

o They are also working with the government to strengthen governance and

accountability

NMJD engages with the ministry of mines

Most mining companies do not like talking with communities and NGOs to avoid conflict

but this approach is short sighted. The companies should maintain direct contact with

communities to prevent conflict.

NMJD is member of the steering committee for EITI and she encouraged MIOL to

become a member of EITI and to join the chamber of commerce.

Aminata informed that due to weak governance mining companies in Sierra Leone are

violating the laws and people‟s rights. She thinks that where national laws are weak,

companies should use international standards.

She thinks that cost of resettlement of people, compensation for crops and community

infrastructure should be factored in the project cost.

Communities do not have negotiating power. They are negotiating with the government

that 1% of the profits should go directly to the affected community for their development.

She informed that the authority of Paramount chiefs is now declining and hence the

company should not rely on them too much. Instead MIOL should identify other leaders

and communicate directly with community members. The dialogue with the community

should be sustained.

NMJD is supporting another NGO called Campaign for Just Mining in Lunsar. This

campaign is focused on capacity building of the community members on the topics of

mining laws and their rights.

She was not clear on the relationship between MIOL and Africa Minerals Limited (this

was clarified by Simon).









She enquired if MIOL is active in Kambia District as one of their partner organisation

„Conscience International‟ that is active in the district has asked then for sensitisation

programme.

She reiterated that their organisation uses the right based approach – people should know

what is happening around them so that ever impact will be minimised. Flying fast could

create problems



Green Scenery Email: gscenery@yahoo.co.uk

Meeting location: Soldier Street, Freetown

Date and Time: 9th March 2011 at 09:25 hours

Attendees: Joseph Rahall (Director, Green Scenery), Simon Elson (Cape Lambert) representing

the Marampa Iron Ore Limited (MIOL), Aminata Kamara and Lalit Kumar (SRK)

Simon Elson gave an introduction to the proposed project and the Marampa Iron Ore (Sierra

Leone) Limited (MIOL). A copy of the Background Information Document on the proposed

project was presented. Lalit Kumar explained the ESIA process, the stakeholder consultation

process and invited the participants to express their issues and concerns. The following key

points were raised:































Purpose of meeting, overview

Small organisation but make a lot of noise

He said that it is not doing the ESIA but it is about companies not following procedures.

This ignites community conflict giving the example of African Minerals Limited (AML)

at Ferengbeya

He said that companies jump all other stages/procedures and obtain the ESIA process;

procedures make a company legitimate.

Talking to the people is not enough; companies should design programmes with the

communities and identify their needs and there are different needs.

His experience with community work is that people change their ideas, support and

messages passed on to them. When they change, they should be engaged.

Advised MIOL to carefully study the community dynamics and the Chiefs. The Chiefs

are sometimes a problem; hence the Company should engage the people.

Take time to study the community and talk to critical people in the community. Chiefs

are no longer in total control of everything.

Regarding the work GS does, they do a 3600; they look at the environment from an angle

of right, livelihood and conflict.

Green Scenery works in coalition with National Coalition on Extractives (NACE)

Examine technical issues. He said that NMJD deals with resettlement, social and

compensation issues.

GS advises companies where issues and conflict may arise.

Consultants may do a good job but after ESIA phase companies may oversight all steps

e.g. chemical disposal, tailings, water pollution, clearing of vegetation, possible

restoration etc.

On the issue of implementation, Consultants should design a framework on how to

monitor and include as an annex. He recommends that MIOL devices a framework on

reporting their performance. He cited Sierra Rutile Limited (SRL) and said that they have

not been able to present their annual environmental report and draw up a reporting

template as guideline to go by what the law says.















































He asked whether the Company can include activities to cope with climate impact.

Further more, Mr Rahall said that the work of MIOL will clear swamps and forests. He

asked how MIOL will assist with communities coping with climate change – machines

pollutants, carbon absorption, etc. This is not in the SLEPA 2008 but for good practice

round the world.

The Director asked about the relationship between London Mining, African Minerals and

MIOL. Simeon Elson gave historical background of the Company

He asked how the Company will manage the environment and development of people.

The Company is in an area of stark poverty. There is potential for conflict when the

community people see physical wealth in their area and see some youths being employed.

Youths do like each other (jealousy).

The Company should therefore establish good relations with the communities and with

youths.

Resettlement is a big issue. Government does not have a resettlement policy but

companies need to do it properly.

Re-vegetation is important – NGOs have been fighting with Sierra Rutile Limited (SRL)

on this issue. He reiterated the issue of companies moving fast with their operations and

leaving the procedures.

He also highlighted the issue of change of ownership. When companies sell, the new ones

do not usually take up liabilities of the old companies, e.g. SRL and Koidu Holdings

(KH). He asked if a bond will be left behind for new companies to take up. Government

does not have the capacity to monitor liabilities and risks and this is where the NGOs

intervene.

He said that the ESIA should not only be sent to SLEPA but should be made available to

other stakeholder groups to share their concerns before the ESIA disclosure.

He suggested that the communities should be involved in rehabilitation programmes e.g.

tree planting, as this will provide employment.

Communities should be engaged and educated to avoid threats. This may not involve too

many resources but will induce creative thinking.

MIOL is to keep a balance between community expectations and the Company.

Communities always see mining companies as government

The Community Liaison Officer (CLO) will be key person for community outreach.

On the relationship with NACE, Mr Rahall said that it is a coalition and Green Scenery is

hosting the Secretariat. Other members are NMJD, Christian Aid, Talking Drum, AntiCorruption Commission, Action Aid, Commission for Democracy and Human Rights and

MADAM- they help to sensitize the communities.

He also said that livelihood will be a big issue e.g. farmers may not have much land any

more.

He also mentioned resettlement – Where a village is relocated the chief will meet another

chief in the new area of location. He may not have the powers of a chief.



Environmental Forum for Action (ENFORAC)

Meeting location: Upper Brook Street, Freetown

Date and Time: 9th March 2011 at 10:29 hours

Attendees: Abdul Conteh (Director, ENFORAC), Ansumana LM Swaray (National Coordinator,

ENFORAC), Simon Elson (Cape Lambert) representing the Marampa Iron Ore Limited (MIOL),

Aminata Kamara and Lalit Kumar (SRK)



Simon Elson gave an introduction to the proposed project and the Marampa Iron Ore (Sierra

Leone) Limited (MIOL). A copy of the Background Information Document on the proposed

project was presented. Lalit Kumar explained the ESIA process, the stakeholder consultation

process and invited the participants to express their issues and concerns. The following key

points were raised:

 Ansumana Mansaray introduced the organisation comprising a consortium of

environmental NGOs, academic groups. They want to see change in management of

resources for a better Sierra Leone. Sierra Leone is endowed with abundant resources but

the country has been exploited without benefit to the people and the country.

 He said that MIOL are in the right direction. AML came to their office in 2010, two (2)

days to the disclosure. He said that their public participation is very poor; they rushed

with license procedures. He said that there will be a lot of Green House Effect from the 5

billion tons of potential iron ore. 200million tons of carbon dioxide will cost US$2.3

billion but only a fraction is being accounted for.

 Companies may get away with their responsibilities now but in the long run it will come

back to them.

 He stated that they are negotiating with SLEPA for international consultants to participate

with local consultants

 He said that social benefits in other mining companies are very poor.

 He raised concerns about visual impacts as the landscape will be destroyed, future

disaster and digging of pits.

 Abdul Conteh asked about what MIOL is doing for:

o Noise and air pollution

o Tailing storage facilities

o Drilling/blasting –effects on workers and the communities

o Flora and fauna

o Budget for mitigation



























He said that they will make noise if the companies go political. He mentioned the Equator

Principles

He also mentioned KEPCO, an international Korean Company.

Other issues include water – there is water crisis in the project area. He asked which type

of explosives/blasters that will be used, training of staff to use explosives safely and the

distance from the communities.

Mr. Swaray raised that there is heavy concentration on iron ore exploitation. He asked if

AML, LML and MIOL will work together to combat the impacts.

Mr. Swaray said that he cannot stop companies from mining but would not want the cost

of rehabilitation to be left on the Government.

He warned that Government connection is not enough; communities should be involved.

He would like to see the Mine Reclamation Plan as there is a lot of emphasis on this.

Abdul mentioned about the kind of plant species to be used as gethropha plant is not good

for local water bodies.

Mr. Swaray further said that monitoring is a grey area and that IUCM is interested in to

do State of Environment on monitoring. He said that companies do not like to be

monitored but advised companies to abide by international standards.

Mr Swaray said that ENFORAC has the legal mandate to monitor and are working with

SLEPA.

He advised MIOL not to depend on one or two guys but should work on national interest.

He expressed that ENFORAC would like to be part of the process; they do not want to be

informed. He said that their work is support organisations, ensure that community needs









are addressed and to develop sustainable environment. He asked MIOL to work with

them.

Mr. Swaray said that ENFORAC is a member of the Green Actors of West Africa and

ECOWAS Parliament.

In conclusion, he said that there is no Act on the Environment and there are many gaps on

EPA 2008 and the Mines and Minerals Act and the legal act is weak.



Cotton Tree Foundation



Meeting location: Cotton Tree Foundation Office, King Street, Freetown

Date and Time: 9th March 2011 at 11:40: hours

Attendees: Michael Kamara (Executive Director), Simon Elson (Cape Lambert) representing the

Marampa Iron Ore Limited (MIOL), Aminata Kamara and Lalit Kumar (SRK)

Simon Elson gave an introduction to the proposed project and the Marampa Iron Ore (Sierra

Leone) Limited (MIOL). A copy of the Background Information Document on the proposed

project was presented. Lalit Kumar explained the ESIA process, the stakeholder consultation

process and invited the participants to express their issues and concerns. The following key

points were raised:

 Michael Kamara said that his organisation had held a meeting with London Mining

 The organisation is multi-sector, focussing on business agriculture, environment (how the

environment can be rehabilitated), social (food security)

 He said that mining will have impact on the environment. He gave example of SRL

which he said had become a water body and created small rivers.

 He encouraged intervention in agriculture and recommended the use of plants to

rehabilitate the soil.

 He said that mining may bring in more people into the area but this might live less people

in the agriculture production.

 Cotton Tree Foundation has an agriculture centre which is based in Lunsar. Since 2005,

the organisation is supporting 5,000 families in agribusiness to date. The organisation

was established in 2003. There has been increase in labour cost.

 He cautioned on the problem to manage expectations.

 He said that business should maintain some distance from the Government as dependence

on government could create more problems. He cited that London Mining landed into

problems with providing jobs that are resulting into huge running cost as a result of

political influence. If the Company wants to work with the politicians, this is dangerous.

 He also cautioned on dependence on the Paramount Chiefs and encouraged discussions at

grassroots levels.

 In agriculture, he wants to see how the agribusiness could impact on the project. The

organisation provides farmers with inputs, seeds at 25% interest.

 They do fruit project and ginger. The problem was access to market but they started

exporting sesame to Japan.

 They also engage in rice mechanisation. Although rice is the staple food, cassava and

groundnut are also cultivated. As he intends to improve on revenue, ginger and cashew

are also part of the project.

 He stated education as the second core area of business. The organisation collaborates

with other actors to promote education. They help in training teachers, provide standard

buildings and good learning materials. They concentrate on primary, secondary and

















vocational skill training. He said that many people are trained as academicians but are not

trained as business people.

He cautioned that few educated people in the project area might inject some negative

influence. The Company should ass the level of reasoning of chiefs, councillors and

youths.

Understanding the people, culture and values is critical.

Company should show respect for those in the communities

The Director said that the organisation also mainstreams HIV/AIDS into the project.

He encouraged MIOL to network with the right actors

Cotton Tree has established contacts with some European partners for business

expansion.



Amazonian Initiative Movement (AIM)

Meeting location: Lunsar-Makeni Highway, Lunsar

Date and Time: 10th March 2011 at 08:06 hours

Attendees: Osman Kargbo, Administrative Officer AIM, Luisa, Intern from Italy, Plan Officer

and 9 others), Simeon Elson (Cape Lambert) Marampa Iron Ore Limited (MIOL), Aminata

Kamara and Lalit Kumar (SRK)

Simon Elson gave an introduction to the proposed project and the Marampa Iron Ore (Sierra

Leone) Limited (MIOL). A copy of the Background Information Document on the proposed

project was presented. Lalit Kumar explained the ESIA process, the stakeholder consultation

process and invited the participants to express their issues and concerns. The following key

points were raised:

 Osman Kargbo said that the organisation campaigns against harmful practices against

women and girls. They are operating in 5 (five0 chiefdoms targeting 30 villages. They are

specifically campaigning against Female Genital Mutilation (FGM). Campaign against

FGM is difficult in the area. The project is a pilot and in its third year.

 The Programme is supported by Plan International (SL) and a German organisation.

 Their campaign slogan is “Breaking the silence for the rights of women and girls.

 In sharing his experience, Osman said that the people find it hard to stop the FGM

practice because it is hard rooted tradition. Initial campaign was very challenging but

intense sensitisation has created awareness.

 Training programmes are conducted and those who feel convinced go through an award

ceremony. The people, children and elderly can now openly talk about FGM; myths

about FGM are taken away.

 Initial challenges included spells, threats and black magic.

 The Paramount Chief (PC) put a band on the campaign when they started in 2000.

 With intense campaign on human right issues, the PC can now condemn the practice

openly. Some practitioners of FGM have abandoned it.

 They have groups in schools. Children are informed that they have the right to take part

in decisions that affects them. No child should be initiated before 18 years.

 The challenge is alternative source of livelihood to traditional practitioners and how to

support children who do not want to go through the FGM. Some children are neglected

 AIM wants to help but lack funds

 Tools used in sensitisation are films shows and meeting of all local authorities.

 There are about 300 to 400 practitioners and children are also trained.























































Another challenge is how to distract the chiefs who give authority/licences to the

practitioners.

Some children go back to the act if they are not supported

Osman further said that they are using positive deviance approach. The are people/

”ambassadors” that go out to campaign against FGM.

Other human right violations which Osman said are rampant in the area include:

o Child abuse to wife battering.

o Teenage pregnancy,

o Child labour and,

o Early marriage/forced marriage

Many children in the area do not go to school especially on Tuesdays when there is a

weekly trade fair at Feredugu. Some children who go to such market never return and end

up in the streets.

The campaign is limited to 6 chiefdoms but the above situation is the same in other

communities.

Cecelia (Plan International) raised the issue on HIV and AIDS. She is concerned about

foreigners/employees coming from outside; the girl child getting into early sex. He

cautioned workers to be aware of HIV and AIDS.

Cecelia said that some chiefs/headmen complain about land grabbing.

Osman stated that some landowners do not receive the real money value due to the

communities. He mentioned that EITI and NACE sensitise the communities.

He also said that the landowners are not treated fairly.

Osman expressed dissatisfaction on the manner of recruitment, wherein the contract is

terminated without notice after 2 or 3 months. Outsiders get jobs overnight while people

in the area are left without jobs. He suggested that preference be given to indigenes.

Osman cited the demonstration by youths on LMC. The Ministry of Mines and other

government officials had to intervene.

Benefit should be given to people who are sacked as this has psychological impact.

Some workers do not have the proper gears. Company should give appropriate safety

gears especially workers involved in drilling.

Margaret stated that some people have lived in the quarters built by Delco for over 30

years but LMC has threatened to remove them. The people suggested for building of new

houses.

It is difficult to get rooms for rent in Lunsar due to influx.

Cecelia said that people have raised concern about chemicals used; the boreholes dug and

distance from the chemical to the well is short.

Abdul said that blasting could be too close to the township. Demolishing the houses left

by Delco could create tension; amicable decision should be reached.

Cecelia said that they would not like to what happened with KH. She said that some

companies do not want to talk to the communities; only top ranking in society. MIOL

should negotiate with the grassroots / land owners at all stages.

Plantation destruction- there is some conflict as names are written without assessment.

MIOL have to negotiate with plantation owners.

“Why can‟t all three companies come together to construct one route, road, railway, etc?”

The relationship between AML and MIOL was asked and felt that the communities are

cheated for carrying the same exploration license.

When will mining start?

Other concerns are with women, child labour and human resources









Luisa asked about how MIOL will do the monitoring and which areas of influence; how

long does it take to monitor.

How will MIOL address urgent hazards e.g. blasting- noise if it affects people.



Marampa Community Bank

Meeting location: The Manager‟s Office, Marampa Community Bank, Lunsar

Date and Time: 11th March 2011 at 09:46 hours

Attendees: Aiah Fomba, Manager), Simon Elson (Cape Lambert) representing the Marampa Iron

Ore Limited (MIOL), Aminata Kamara and Lalit Kumar (SRK)

Simon Elson gave an introduction to the proposed project and the Marampa Iron Ore (Sierra

Leone) Limited (MIOL). A copy of the Background Information Document on the proposed

project was presented. Lalit Kumar explained the ESIA process, the stakeholder consultation

process and invited the participants to express their issues and concerns. The following key

points were raised:

 The bank had operated before the war- it was a rural bank, private owned.

 The Bank was re-established in 2002 by the Government of Sierra Leone and started

operating on 7th February 2003 to provide financial services to the Marampa community.

 It is a limited liability that was given to the community on loan which is to be paid over

40 years period.

 One hundred million leones was given as initial capital part of which was used to offset

running costs.

 The community people are poor; initial they had no money to open accounts.

 Women who petty traders and bread winners- they found it difficult to pay back.

 There were bad debts when the loan scheme started.

 The bank got loan fro NACSA (National Commission for Social Action) and MITAF.

 Number of accounts increased in 2004 when the Government decided to pay teachers and

other workers through the bank.

 Loan scheme for teachers was established and this proved successful.

 Salary loans have helped many families to pay fees, travel abroad, start new businesses,

etc.

 The Authorities in Marampa (MP, PC and District Chairman) should work to promote the

Bank.

 There are over 80,000 shares to sell but there is no money for the people, little farming,

trading and transport.

 Mr Fomba welcomes the Company to do their domestic banking and to pay staff salaries

through the Marampa Community Bank. He wants the companies to come together to

improve community infrastructure.

 Over 70 MIOL staff members are banking with them and have taken loans.

 If the Bank becomes profitable, the profit will be ploughed back to the community.

MIOL have opened and impress account but looking forward to MIOL depositing some

of their money to expand their services. He said that they are partners in development;

they cannot develop if they depend solely on the community.

 IFAD (International Finance on Agriculture and Development) wants to come on board

to assist farmers.

 His concern is that the big banks will swallow them up.









He is aware of their limited capacity; but wishes MIOL should put percentage of their

money in the Bank. They cannot handle the foreign exchange.

The Manager suggested that authorities should take the lead to advocate for their

communities and not only for themselves. If MIOL helps the Bank to develop, they in

turn will help the communities.



Port Loko District Council

Meeting location: Chief Administrator‟s Office, Port Loko District Council, Port Loko

Date and Time: 11th March 2011 at 12:02 hours

Attendees: Abdul Koroma (Deputy Chief Administrator, Sheik A M Gibril, Rural Development

Officer), Hassan Bruce, (Journalist, Universal Radio) Simon Elson (Cape Lambert) representing

the Marampa Iron Ore Limited (MIOL), Aminata Kamara and Lalit Kumar (SRK)

Simon Elson gave an introduction to the proposed project and the Marampa Iron Ore (Sierra

Leone) Limited (MIOL). A copy of the Background Information Document on the proposed

project was presented. Lalit Kumar explained the ESIA process, the stakeholder consultation

process and invited the participants to express their issues and concerns. The following key

points were raised:

 The Deputy Chief Administrator (DCA) Thanked the Visiting Team and said that such

disclosures have been done by other companies.

 The project will be economically viable because it will bring benefit to the communities.

He also said that the country‟s as a whole will benefit but communities should benefit

also.

 He shared the experience he has had with AML and LMC. And cautioned MIOL to help

the communities and not to take away only.

 The DCA mentioned assistance in terms of health, trees, air pollution, and dust due to

vehicle movement.

 He said that MIOL should go by local laws. MIOL should incorporate facilities in their

social programmes such as PHU (Peripheral Health Units), hospitals, etc. MIOL should

develop tangible structures instead of giving out money.

 Employment – Community people should benefit. In line with the Mining Act, priority

should be given to the communities. He stressed that local labour should come from the

communities.

 Employment/requirement of technical labour could be explained during disclosure. When

the Company employs those on the ground, they feel part of the project; they own it and

act as securities.

 Sheik Gilbil said that MIOL needs to recognise basic development principles/corporate

social responsibilities, which some companies often neglect.

 Sheik Gibril advised that for any development programme, e.g. building a school, the

beneficiaries have to be involved in the initial planning.

 MIOL should have community development personnel to guide them on development

principles. He thanked MIOL for involving them and hopes to get feedback.

 Hassan Bruce (Journalist) said that from his experience, all mining companies share

similar issues- community interests are the same. Youths will be interested in

employment, expectations of unskilled labour, scholarships to disable students, etc.

 Council should be involved in all development programmes. He cited an example of

upgrading a bridge in Feredugu section, wherein the Councillor of the area had to stop the

project because he was not informed.

 Local youths, indigenes and land owners should be involved.

















The DCA asked about MIOL‟s relationship / future with other companies. He said that

there is a notion that LMC is part of MIOL. He asked about MIOL‟s concession area.

He asked how MIOL intends to cope with youth employment as it is a critical issue and

asked whether vacancies are advertised.

The DCA reiterated that the Company should contact the Council for community

programmes to avoid duplication.

He also said that people who are affected directly should be the first to benefit.

He said that companies get problems because they avoid the Councils. Company

information will be disseminated to the Government and other agencies.

Stakeholders present commended MIOL for this approach (involvement at initial stage).



Ministry of Agriculture and Food Security (MAFS), Port Loko District

Meeting location: District Agriculture Officer‟s Office, MAFS, Port Loko

Date and Time: 11th March 2011 at 12:50 hours

Attendees: Aminata Lamin (Programme Director, Mining and Extractive, NMJD), Simon Elson

(Cape Lambert) representing the Marampa Iron Ore Limited (MIOL), Aminata Kamara and Lalit

Kumar (SRK)

Simon Elson gave an introduction to the proposed project and the Marampa Iron Ore (Sierra

Leone) Limited (MIOL). A copy of the Background Information Document on the proposed

project was presented. Lalit Kumar explained the ESIA process, the stakeholder consultation

process and invited the participants to express their issues and concerns. The following key

points were raised:

 Philip Conteh said he was confused about LMC, MIOL and AML. He said that he has

seen environmental degradation around Mange Acre (a village beyond the project area).

He recommended planting of fast growing trees such as tactual grandis and acacia which

can grow big within two to three years.

 He said that cutting down tree decreases the water level and causes irregular rainfall.

 MAFS once established a nursery but it was destroyed by fire

 He said there is need to work closely with community youths and chiefs. The youth

should take responsibility. Trees will make effective fire belts.

 He expressed that MAFS (Port Loko) want to work in partnership in reforestation

programmes.

 Mr Conteh further said that the Company will bring many people to Port Loko in search

of jobs. He said that some of those who will not get jobs resolve to charcoal burning and

fuel wood, thus exploiting the forest further. He recommended the replanting of wood

lot. He said that effort should be made to develop the forest.

 The forest division is the smallest because MAFS concentrates more on crops and

livestock. Less emphasis is placed on forestry which could be another source of

livelihood.

 He expressed that the level of the water table is a serious problem as it is rapidly being

depleted. Women find it difficult to get water for their vegetable gardens.

 Some rivers have become extinct, so they need to have trees that provide canopy to

maintain the water level.

 Prot Loko is not like Kailahun (Eastern Province) where there are cash crops like kola

nut, cocoa, and coffee. The only suitable plantation in Port Loko is cashew.



































Desertification is moving very close to the area because of increased activities in forest

exploitation.

Influx of youths in Port Loko results to criminal acts, thieving; the police to provide

records. Some ex-combatants had engaged in bike riding.

Swamps and low lying areas should be developed for increased production.

The DAO also said that water management should be developed and trees to be planted

for availability of water. MAFS is interested in intensive farming rather that extensive.

Sensitisation has begun in Mange.

He said that the slash and burn is giving pressure on land.

The MAFS is encouraging farmers to increase production. IFAD and AFSAD were

developing something. There were problems with funding and procedures.

The Land and Water Division is responsible to train farmers on how to develop swamp.

MAFS also has a programme with WFP on food and safety nets.

Communities are being sensitised on the benefits of improved agriculture; with increased

in production, they can sell.

The Company will create access to market. An effective market can bring indirect

benefits.

Port Loko is a low income area (very dry. There are many inland valley swamps in Port

Loko. Lowland agriculture will reduce slash and burn.

Valuation of trees and crops is by MAFS

MAFS works with the Ministry of Interior and Local Government on matters of land

compensation

In closing, Philip Conteh said that rehabilitation of mined out areas is very crucial for

sustainability in agriculture.



District Medical Officer (DMO) Port Loko

Meeting location: DMO‟s office, Port Loko Government Hospital, Hospital Road, Port Loko

Date and Time: 14th March 2011

Attendees: Dr Victor Max-Lebbie (DMO, Port Loko), Simon Elson (Cape Lambert) representing

the Marampa Iron Ore Limited (MIOL), Aminata Kamara and Lalit Kumar (SRK)

Simon Elson gave an introduction to the proposed project and the Marampa Iron Ore (Sierra

Leone) Limited (MIOL). A copy of the Background Information Document on the proposed

project was presented. Lalit Kumar explained the ESIA process, the stakeholder consultation

process and invited the participants to express their issues and concerns. The following key

points were raised:

 The DMO mentioned dust in mining areas.

 Waterborne diseases also do occur as many people depend on wells and rivers (which dry

up in the dry season) for drinking and other domestic uses.

 People use water coming from upstream which is already contaminated by users up

stream as washing of dirty things and defecation is done there.

 Cholera and diarrhoea occur in the district although there has been no outbreak of cholera

in the district for the past six years.

 There is existence of disease surveillance in the district.































There was lassa fever case at Buya Romende which killed one pregnant woman; there

were cases in Makeni also. Lassa fever is endemic in the Eastern province.

Lassa fever is also found in the grassland/farmland in the North. Lassa is in urine, faeces

of a long mouth rat.

Laboratory/blood services are very basic. Sometimes samples are taken to Abidjan.

STIs and HIV/AIDS do occur. HIV and AIDS is about 1.3%.

Polio has been kicked out in children.

Consultants should talk to Lunsar office for more details.

The DMO cautioned on the water system and artificial lakes. He said that the Company

should take the environment into consideration.

He mentioned blasting – this might cause noise and houses might be affected.

He advise the Company to engage with the youths as it could be political

Unemployment – People may not have the relevant skills but might make noise for

people who come from outside.

Idle youth, dependent culture and inadequate skills were also mentioned.

He mentioned that Port Loko has fertile land.

The DMO said his door will be opened if there is anything in the health sector.



Port Loko Teachers College (PLTC) Administration

Meeting location: PLTC Campus, Lungi Road, Prot Loko

Date and Time: 14th March 2011 at 12:09 hours

Attendees: Ahmed A Koroma (Vice Principal and Director of Studies, PLTC), Simon Elson

(Cape Lambert) representing the Marampa Iron Ore Limited (MIOL), Aminata Kamara and Lalit

Kumar (SRK)

Simon Elson gave an introduction to the proposed project and the Marampa Iron Ore (Sierra

Leone) Limited (MIOL). A copy of the Background Information Document on the proposed

project was presented. Lalit Kumar explained the ESIA process, the stakeholder consultation

process and invited the participants to express their issues and concerns. The following key

points were raised:

 Mr Koroma said that Delco came up with good package of corporate social

responsibility. However, they reeled during operations. He welcomes MIOL as Sierra

Leone cannot process the iron ore.

 Companies provide employment (direct and indirect) apart from revenue that goes to the

Government.

 He said that biodiversity depletion can divert water to villages and get them extinct by

relocation.

 Soil depletion – good soils can no longer be fertile.

 Toxicity – plants may not do well.

 Operations may include removal of vegetation. No reforestation is done although it is in

the package. Companies concentrate on the quantity of ore rather than what they should

follow.

 Mr Ahmed Koroma asked how much the company pays for economic trees e.g. mangoes.

 Lease amounts depreciate - He asked what adjustments the Company makes to meet with

the rate of inflation.

 Planting economic trees will enable livelihoods for some people.































He also mentioned on the policy of the Company. He said that companies come with the

Managing Director, accountants, etc. He said that less will be spent on salaries if Sierra

Leoneans are employed for jobs they can do.

Congestion may bring health and social problems such as thieving. Those who seek

employment and do not get jobs resort to crime.

He said that mining companies usually concentrate assistance in primary and secondary

schools and leave the tertiary institutions.

He appealed for support stating that they had sent a proposal to MIOL for a generator and

electrification but there has been no reply.

The College intends to develop a technical institution.

Whatever benefit the College receives will be advertised and he believes that it will have

a ripple effect.

Blasting may destroy the houses

The company will occupy farmland

Mr Koroma also asked about who determines what is compensated to the people. He said

that it should be reasonable and adjustable.

He also mentioned destruction of land and land reclamation. The Company should

consider reforestation, reclamation and economic trees.

He reiterated that they lack the structures. Caterers could be trained under their technical

department (they currently do community health and business administration). He stated

that helping PLTC is helping the district.

Company should consider assistance in the education sector.

Safety aspect was also mentioned. Sharing his experience with Europe, he said that the

rail-road crossing could cause accidents.



Murialdo Secondary School

Meeting location Murialdo Secondary School, Lunsar

Date and Time: 14th March 2011 at 14:50 hours

Attendees: Fr. Giuliano Pini (Principal), Fr Emmanuel Koroma, Mr Ambrose Bangura (Vice

Principal), Simon Elson (Cape Lambert) representing the Marampa Iron Ore Limited (MIOL),

Aminata Kamara and Lalit Kumar (SRK)

Simon Elson gave an introduction to the proposed project and the Marampa Iron Ore (Sierra

Leone) Limited (MIOL). A copy of the Background Information Document on the proposed

project was presented. Lalit Kumar explained the ESIA process, the stakeholder consultation

process and invited the participants to express their issues and concerns. The following key

points were raised:

 Children suffer when a teacher leaves during school session.

 School teachers might leave. Mar Bangura asked if MIOL will fist find out about

employment records if a teacher applies for job.

 What incentive will be given to the school for teachers to stay?

 Teachers who want to leave should notify the school.

 Fr Emmanuel said that it is difficult to stop teachers.

 At Sierra Rutile, NGOs lobby companies to give incentives to teachers.











































There are lots of graduates in the area. Company should be careful not to sideline the

trained personnel. If chiefs select those that they like and are employed, even if they are

not trained, tensions might crop up.

Chiefs to campaign.

Pupils might leave school to work for the Company. Parents depend on the Catholic

mission for education; but if they get jobs and if teachers do not teach well, pupils might

leave.

MIOL should follow the employment process.

On the issue of salary payment, people lament that they get less salary than what they

sign for, a percentage is taken from their monthly salaries. MIOL to make follow ups

rather than leaving all the processes in the local authorities.

Categorise the kind of jobs, do a test and apply the process to wipe out those who are not

qualified.

Company should create avenues for incentives – scholarships should be given for

university and create support and assurance of employment when they return.

Workers interfere with girls in senior secondary school. MIOL to talk to employees/

discipline

Method of extraction will be similar to Delco- noise, dust, washer, etc.

The agric sector will be affected. Mining will interfere with swamps.

How will the Company store the concentrate?

There will be more demand on food. The soil is good as long as people plant on time and

get good seeds.

The environment to be protected.

There is technical vocational institute. LMC come to Murialdo‟s institute for workers.

There should be collaboration- teachers to give notice to the school.

The rate of unemployment is high and it was one of the causes of the war. MIOL should

try to employ the young people but child labour should be avoided.

Assistance to the school was promised but never given. MIOL never takes part in the

activities of this school.

They hoped that this consultation will be a continuous process.

People are sent out of houses because of increase in rent. Teachers cannot cope with

increase in rent. There are delays in salaries of teachers,

Job seekers who do not get jobs result to stealing.



Marampa Scoping Consultations- Ministries

March 2011

Ministry for Mineral Resources

Meeting location: Mining Cadastre Office, Ministry of Mineral Resources, 5th Floor Youyi

Building, Brookfields, Freetown

Date and Time: 1st July 2010 at 10.30 am

Attendees: Eugene Norman (Assistant Government Mining Engineer) and Alusine Timbo

(Assistant Government Mining Engineer), Simon Elson (Cape Lambert) representing the

Marampa Iron Ore Limited (MIOL), Emily Robinson and Lalit Kumar (SRK)















Simon Elson began by giving an introduction to the Marampa Iron Ore Limited (MIOL)

and explaining the status of the Marampa Mining Project. A Background Information

Document on the proposed project was presented to the Ministry representatives.

Mr Norman explained that the new Mining and Minerals Act had been implemented

since March 2010 and provided us with a document entitled “A Guide for License

Holders and Applicants”.

Emily Robinson explained that Cape Lambert intend to undertake an EIA as part of the

mining application and asked for any areas that the Ministry would like to be included.

Mr Norman explained that the EIA requirements should be discussed with SLEPA but

that from the Ministries perspective, the requirements will depend on the concession. The

areas he mentioned specifically that should be covered included landscape, geology and

social issues such as resettlement, economic considerations and community development.

The new Act provides guidance on social issues.

Mr Norman also explained the role of regional mining engineers in visiting sites and

monitoring/auditing the operations from a technical, environmental, social and health and

safety perspective, in line with the new act.



Sierra Leone Environmental Protection Agency (SLEPA)

Meeting location: SLEPA Office, 3rd Floor Youyi Building, Brookfields, Freetown

Date and Time: 2nd July 2010 at 10.15 am

Attendees: Momodu A Bah, Acting Deputy Executive Director (In-charge of EIA, Field

operations & Extensions), SLEPA, Simon Elson (Cape Lambert) representing the Marampa Iron

Ore Limited (MIOL), and Lalit Kumar (SRK)







Simon Elson explained the status of the Marampa Project and the Background

Information Document was presented to Mr Bah (SLEPA).

Mr Bah explained the steps leading to applying for the EIA licence. Which involved the

following (in sequence):

o Marampa Iron Ore Limited (MIOL) should give a formal letter to SLEPA

providing an introduction to the MIOL and a brief profile of the proposed project.

SLEPA will respond by opening a file for the project and sending application and

screening form to MIOL (the cost of forms is Le 200,000).

o MIOL should send filled in application and screening forms to SLEPA for

categorisation. Being a mining project the Marampa Project will classify as

category A project, hence SLEPA will send a formal letter to conduct the EIA.

o MIOL should provide draft Terms of Reference (ToR) for the EIA programme,

which SLEPA will review, discuss with MIOL/SRK and approve.



o

















On completion of the EIA as per the approved ToR, MIOL should provide 15

hardcopies of the completed EIA report to SLEPA along with electronic version.

SLEPA will send the EIA report to relevant ministries for review. SLEPA will

also issue notification in gazette about the EIA and provide a format to MIOL for

announcement in a local newspaper. MIOL should issue an advertisement in the

newspapers as per the format received from SLEPA.

o SLEPA will allow 14 days disclosure period to receive feedback from

stakeholders. On completion of the EIA, MIOL should organise consultation

meetings with stakeholders which should be held in the presence of SLEPA

representatives.

o On completion of the stakeholder meetings, MIOL should submit a disclosure

report to SLEPA.

o On completion of the 14 days disclosure period and receipt of disclosure report,

SLEPA will send the EIA to its board for approval. The board comprises of

experts from different ministries. Based on board‟s review the EIA licence is

issued which may be subject to fulfilling certain terms and conditions. The EIA

licence is non-transferable.

Mr Bah provided his contact address as follows:

Mr Momodu A. Bah, Acting Deputy Director

Incharge of EIAs, Field operations & extensions, SLEPA,

3rd Floor, Youyi Building, Brookfields, Freetown, Sierra Leone

Mobile number: 078350627, 076668698, 088351725

Email: modbah@yahoo.com

Mr Bah confirmed that the most recent regulations were contained in the EPA Act 2008

and the guidelines on EIA procedures issued in 2002 were still valid.

Mr Bah also informed that SLEPA has started the process of preparing sector specific

EIA guidelines with technical assistance from EU. However until these are ready

MIOL/SRK could refer to World Bank‟s guidelines for the mining and other relevant

sectors.

SRK informed Mr Bah that it has installed a meteorological monitoring station at

MIOL‟s project office in Lunsar. Mr Bah suggested that MIOL should formally inform

the Meteorological Department about installation of the monitoring station.



Forestry Department, Ministry of Agriculture

Meeting location: Forestry Department, 1st Floor, Youyi Building, Brookfields, Freetown

Date and Time: 2nd July 2010 at 11.30 am

Attendees: Mr Abdul-Abib F Conteh, Deputy Director, Forestry Division, Simon Elson (Cape

Lambert) representing the Marampa Iron Ore Limited (MIOL), and Lalit Kumar (SRK)











Simon Elson explained the status of the Marampa Project and the Background

Information Document was presented to Mr Conteh.

Mr Conteh informed that the Forestry Act 1988 was currently in the last stages of review

by the Law Reform Commission. It was due for presenting to the parliament and may

come into force in next 6 months. In the meantime he suggested that MIOL should refer

to the existing Act to comply with national regulations.

Mr Conteh asked MIOL to procure, from the office of Sierra Leone Information System

(SLIS), an official copy of the map showing boundaries of national parks, forest estates,











and wetland conservation sites in Sierra Leone to check if the project area was not

interfering with any protected areas.

Although the proposed project was unlikely to interfere with any existing protected area,

Mr Conteh suggested that MIOL should still send a formal letter to Minister of

Agriculture (and Forestry) informing about the intention to develop the Marampa project.

The letter should describe the location and project footprint area on the map and provide

names of villages and chiefdoms that are likely to be within the project footprint area.

The minister will send the above letter to Director of Forestry and other relevant

departments for review and issue permission to proceed with the proposed project.



Ministry of Internal Affairs, Local Government and Rural Development

Meeting location: Ministry of Local Government, Youyi Building, Brookfields, Freetown

Date and Time: 2nd July 2010 at 12.30 pm

Attendees: Director, Ministry of Local Government, Simon Elson (Cape Lambert) representing

the Marampa Iron Ore Limited (MIOL), and Lalit Kumar (SRK)

















Simon Elson explained the status of the Marampa Project and the Background

Information Document was presented to the Director.

The Director explained that the role of the ministry representative on the Minerals

Advisory Board was to oversee (if required) the agreement between land owners and

mining companies. This role has been given to the ministry as the Paramount Chiefs and

other community chiefs come under its jurisdiction. This becomes necessary because

land in provinces is held in community trust through the Paramount Chiefs. While the

right over minerals can be passed by the government on to the mining companies it still

needs permission from the community to mine.

He also informed that in the new Minerals Act (2009) there is provision for mining

companies to discuss with local community and agree upon its corporate responsibility in

terms of what developmental assistance will be given to community. The Ministry and

the Paramount Chiefs are usually key players in such negotiations.

It is Ministry‟s intention to help create cordial environment between project developers

and communities for peaceful co-existence.

The Director asked MIOL to send a formal letter to the Ministry to inform its intention to

develop the Marampa Mining Project and seek its cooperation in community relations.



Marampa Scoping Consultations- Stakeholders

March 2011

1. Foreroad Baka Women’s Association

Meeting location: Foreroad Baka Village, Lunsar (suburb)

Date and Time: 13th March 2011, 11 AM

Attendees: See attached (scanned) for list of group members, Simon Elson (representing the

Marampa Iron Ore (SL) Limited, Aminata Kamara and Lalit Kumar (both SRK)

Intro para











General introduction about the group (by the chair):

o There are many women‟s organisations in Lunsar

o Appreciate the current employment opportunities by MIOL

o Women carry majority of burden at household level, most men don‟t help with

household duties or in vegetable farming

o Women don‟t have formal education, they are skilled only in farming and

gardening

o Food insecurity is a key challenge faced by the members

o Vegetable farms are affected by brown coloured ants which damage the crops

o 13 women among those present for the meeting are single (are widow or do not

have support from men), however they have children to support

o There are three women in the group who can read and write

o The group is three years old, it has 51 members, meets twice a month and collect

Le2000 on monthly basis

o it last year received assistance from MIOL in the form of seeds for cultivating

groundnut

Some women want to work at the mine but are not considered for jobs. They expect

MIOL not to ignore women in the potential employment opportunities.

Expect assistance/support for business activities and with building up of a storage facility

for crops/produce.



2. Mabesene Women’s Association

Meeting location: Mabesene Village, Lunsar

Date and Time: 13th March 2011, 1 PM

Attendees: See attached (scanned) for list of group members, Simon Elson (representing the

Marampa Iron Ore (SL) Limited, Aminata Kamara and Lalit Kumar (both SRK)

Intro para





General introduction about the group (by the chair):

o The group had received support from MIOL for Cassava growing project on farm

if 3 Acres, but it did not succeed as the grasshoppers destroyed the crops

o Now the group is trying to cultivate leafy vegetables in the swamp areas

o The group was started in 1998 but had to leave the area during the war, on its

returned it was faced with difficulty of bringing people together



o



















Besides farming the group also does weaving and gara-tie dyeing (some women

also know sewing)

Expect MIOL to:

o continue supporting the group with seed supply for cassava and groundnut

o assistance in fighting with the problem of grasshoppers and other pests

o toilet facilities, water supply and expansion of agricultural assistance

They are happy that some people are getting jobs but none of their own family members

have succeeded in getting job. In order to get a job one has to pay 200 to 400 thousand

Leones.

Concerned that the blasting activity will damage their houses as the house structures are

already weak and some have cracks. Remember that during Delco operations the

vibrations due to blasting had caused damaged to houses. Sometimes stones/debris

would fly and land into the village.

The Magbenkte Village is experiencing increase in water level. It is surrounded by old

Dleco Lake, where some digging is being undertaken (not clear if this is in LM area).

Hence there is fear of flooding.

Other apprehensions are:

o Illness due to dust

o Heavy machines may shake houses

o Increase in accidents due to increase in traffic

o Jobs will be taken by outsiders as is the current practice



SRK Consulting



Marampa Iron Ore Project – Technical Appendix 3



APPENDIX

3.



DISCLOSURE MATERIAL



U3823_Marampa_SEP_Final.docx



August, 2012

Page 3i of 3i



MARAMPA IRON ORE PROJECT

BACKGROUND INFORMATION DOCUMENT

March 2011

This document provides information on the proposed Marampa Iron Ore Project and explains the Environmental and Social

Impact Assessment (ESIA) process that is being undertaken.

1. Background

The Marampa Iron Ore Project (the Project) is a hematite iron ore project which is currently at the exploration and evaluation

stage. The Project is owned by Marampa Iron Ore (SL) Limited (the Company), which is 100% owned by Marampa Iron Ore

Limited, a wholly owned subsidiary of Australian company Cape Lambert Resources Limited. The Project is located on

exploration license EXPL09/06, which covers a 305 km2 at Lunsar, in the Port Loko District of Sierra Leone. The license

area encloses but excludes the closed and abandoned Marampa mine, which was operated by Delco until 1975 and is now

owned by London Mining Plc.

The Company is currently studying the area from a technical perspective and they have appointed SRK Consulting (UK) Ltd

(SRK) to commence an Environmental and Social Impact Assessment (ESIA) process, known as an EIA in Sierra Leone,

which, during the course of the study, will assess potential impacts of the construction and operational phase of the proposed

mine. This assessment process will interact with the technical studies as much as possible.



Figure 1: Location of the Marampa Iron Ore Project

2. Project Description

The Company has completed initial exploration drilling of specular hematite deposits at the Gafal West Prospect and the

Matukia Prospect (see tentative project layout in Figure 2). The maiden Project mineral resource has been estimated at 197

million tonnes by Golder Associates Pty Ltd in accordance with the JORC Code. There is potential to mine this resource by

open pit mining methods, including drilling, blasting, loading and hauling operations, and processed at an on-site

beneficiation plant comprising; crushing, grinding, and concentrate cleaning via wet high-intensity magnetic separation.

Waste material will be stored in waste rock dumps and a tailings storage facility. The Company has undertaken a

preliminary engineering and infrastructure study in 2010, and is continuing with a pre-feasibility study as well as further

drilling of the two prospects through 2011. Construction of the Project, if determined feasible, would not occur until 2012 at

the earliest. Based on preliminary assumptions, water for the Project will be supplied via a pump from the nearby Rokel

River and power will be supplied from a purpose-built on-site power station. Other site infrastructure, such as the

beneficiation plant, offices, workshops and accommodation, will also need to be constructed. The ore would be transported

from the site via the 84 km existing railway to Pepel Port. The railway and port are currently in the process of being

refurbished by others, and will be operated and maintained by a third party.



3. Regulatory framework and ESIA process

The ESIA process is being undertaken in accordance with Sierra Leone laws and regulations, as well as internationally

accepted best practices. The process follows three main steps (see below). The Screening and Scoping Phase is to decide

if an ESIA is required and defines the contents of the assessment. The Impact Assessment Phase rates the significance of

the potential impacts to assess whether there will be any unacceptable impacts resulting from the Project that cannot be

managed. The ESIA team will also assess project alternatives and will provide environmental input into the Project decisionmaking processes.

SCREENING AND SCOPING PHASE













Initial site visit and review of existing data

Consultations with regulatory agencies to identify their requirements

Research of national and international regulations

Develop Terms of Reference for specialist studies with SLEPA

Consultations with community based stakeholders to identify their

concerns and issues



IMPACT ASSESSMENT PHASE

• Specialist baseline studies

• Identification and assessment of potential impacts on the

environment and local community

• Stakeholder consultations to report the outcomes of the ESIA



MANAGEMENT PLANNING PHASE

• Design of measures to reduce the significance of the impacts

• Development of a plan to manage and monitor the impacts



Review and decision by SLEPA



Specialist studies are being undertaken to determine the current environmental and social conditions of the study area.

The type of studies required has been determined from the screening and scoping phase, and include assessment of

potential impacts on climate and air quality, water resources (including surface water, groundwater and water chemistry),

soils, geochemistry, noise, landscape (visual impacts), ecology and biodiversity (flora and fauna), socio-economic factors,

archaeology and cultural heritage.

5. Consultation Process

Consulting with the Project stakeholders (the interested and affected parties) is a very important part of the ESIA process, so

that the Project developers and decision makers can take account of their views. For the Project, SRK intend to consult with

stakeholders at least twice; firstly during the Screening and Scoping Phase to identify potential issues and concerns of the

Project stakeholders and secondly on completion of the ESIA to report back findings of the assessment process. As the

Project becomes more definitive, stakeholders will also be able to make comments throughout the life of the Project through

a recognized pathway.

The scoping consultations are further split into two rounds, the first round with key governmental stakeholders was

completed in July 2010 and the second one covering the potentially affected community members, relevant Paramount

Chiefs, Village Chiefs, general public and any other stakeholders will take place in March 2011.

6. Issues and Concerns

Any issue and concerns raised by stakeholders, as well as the responses to them, will be recorded throughout the

assessment process and will be included in the final ESIA report. If you have any comments, please contact Chris Gybl

(Marampa Iron Ore (SL) Limited) email Information@miolb.com) or Nicola Rump (SRK Consulting email nrump@srk.co.uk).



Figure 2: Tentative Project Layout



 



 



 



 



 



 



 



 



 



 



 



 



 



 



 



 



 



Marampa Iron Ore Project 



 



 



General Fact Sheet 



 



 



 



 



 



 



 



 



 



 



 



 



 



 



 



 



 



 



 



 



 



 



 



 



 



 

Nominal Project Layout 



 



 

Updated: March 2011 

Contact: information@miolb.com 

 



Project 



Engineering Studies 



Infrastructure 



Mineral Resource 



Engineering Studies being conducted: 



Railway and Port 

















 











197.2 Mt @ 28.5% Fe 

As at 12 November 2010 

Drilling continues to target 500 Mt 



Production 







Initial 5 Mtpa 

Plant Expandable to 10 Mtpa 



Metallurgical Testwork 

Process Plant Development and Layout 

Geotechnical 

Hydrology 

Power Assessment 



Environmental and Social Studies 

$ 34 M 

$ 8 M 

$ 307 M 

$ 95 M 

$ 10 M 

$ 91 M 

$ 200 M 

$ 655 M 



Key Milestones Targetted 

















ESHIA Licence 

Mining Lease 

Feasibility Study 

Detailed Engineering 

Project Finance 

Construction 

First Production 

 

 

 

 



2011 

2012 

2012 

2012 

2011 / 12 

2012 

2013 



Baseline Studies being undertaken for ESHIA 



















Geomorphology and Soils Assessment 

Geochemistry 

Climate and Air Quality 

Noise Assessment. 

Ecology and Biodiversity Assessment 

(Stage 1 Complete) 

Water Resources 

Socio Economic 

Archaeology and cultural heritage 



Economic Impact 

800 



Permanent Workforce: 



630 



Indirect Jobs: 



~ 2,000 



Export Revenue:  LoM Nominally USD 7 Billion 

Royalties: 



 







Source from Rokel River 







Construct standalone Heavy Fuel Oil Power 

Station nominally 70 MW for 5 Mtpa plant 



 

 

 

 

 

 

 

 

 

 

 

Legend 



Total Construction workforce: 



 



Water 



Power 



Capital Investment – US$ 

Civil 

Mining 

Process Plant 

Infrastructure 

Mobile Fleet 

Indirect Costs 

Contingency 

Total 



Access agreement in place to Pepel Railway 

and Port 



3% of Revenue 



ESHIA 

Fe 



Mt 

Mtpa 

MW 

US$ 

LoM 



Environmental, Social and Health Impact 

Assessment 

Iron 

Million 

Million Tonnes 

Million Tonnes per Annum 

Mega Watts 

United States Dollars 

Life of Mine 



MARAMPA PROJECT DEVELOPMENT OVERVIEW

RESOURCE

ESTIMATION



DRILLING



EXPLORATION

2-3 YEARS

STUDY AND

RESEARCH



PUBLIC

CONSULTATIONS



FEASIBILITY

STUDIES

2011



CONSTRUCTION



NO

FURTHER STUDIES OR

NO PROJECT



IF POSITIVE?

YES



MINING



CONSTRUCTION

2012



PROCESSING



MINING

OPERATIONS

LATE 2013

COMMUNITY

DEVELOPMENT



TRANSPORTATION



MARCH 2011



SRK Consulting

Engineers and Scientists



LOCATION OF THE MARAMPA

PROJECT IN SIERRA LEONE



NOMINAL PROJECT LAYOUT

MARCH 2011



SRK Consulting

Engineers and Scientists



SCOPING CONSULTATIONS

WITH PROJECT STAKEHOLDERS



Environmental and Social Impact Assessment (ESIA)

Marampa Iron Ore Mining Project



PROJECT INTRODUCTION

• The project is owned by

Marampa Iron Ore

(Sierra Leone) Limited,

which in turn is owned

by Cape Lambert of

Australia

• Exploration license

EXPL09/06



PROJECT FACTS

Key facts

• 197.2 Mt (Nov 2010)

• Target 500 Mt

• Initial production 5Mtpa raise to 10 Mtpa



Water

• Source from Rokel River

Power

• Standalone Heavy Fuel Oil Power Station : 70MW

for 5 Mtpa



Nominal Project Layout



ECONOMIC IMPACTS

• Total investment:

$655 M

• Construction

workforce: 800

• Operation workforce:

630

• Royalties 3% of

revenue



Environmental and Social

Impact Assessment Process

• Sierra Leone

Environmental

Protection Agency

Act 2008

• International

standards and best

practices



LIST OF ENVIRONMENTAL AND SOCIAL

BASELINE STUDIES



















Ecology and biodiversity (flora and fauna)

Socio-economic

Water resources

Climate & air quality

Soils & Geochemistry

Noise

Landscape (visual impacts)

Archaeology and cultural heritage



ESIA AND CONSULTATION PROCESS

ENVIRONMENTAL AND

SOCIAL SCOPING STUDY

2010



SCOPING CONSULTATIONS WITH

STAKEHOLDERS

RELEVANT MINISTRIES (JULY 2010)

LOCAL STAKEHOLDERS (MARCH 2011)



ENVIRONMENTAL AND SOCIAL

BASELINE STUDY PROGRAMME

2011



IMPACT ASSESSMENT AND

MANAGEMENT PLANNING

2011



ESIA REPORT DISCLOSURE

AND FEEDBACK

CONSULTATIONS



IDENTIFICATION OF

STAKEHOLDER ISSUES AND

CONCERNS



QUESTIONS AND FEEDBACK FROM THE STAKEHOLDERS



SRK Consulting



Marampa Iron Ore Project – Technical Appendix 4



APPENDIX

4.



PHOTOS



U3823_Marampa_SEP_Final.docx



August, 2012

Page 4i of 4iv



SRK Consulting



Marampa Iron Ore Project – Technical Appendix 4



Open Pubilc Meeting, Lunsar



Open Public Meeting, Lunsar



U3823_Marampa_SEP_Final.docx



August, 2012

Page 4ii of 4iv



SRK Consulting



Marampa Iron Ore Project – Technical Appendix 4



Meeting with Amazonian Initiative Movement (AIM), Lunsar



Meeting with Mabesene Women’s Group



U3823_Marampa_SEP_Final.docx



August, 2012

Page 4iii of 4iv



SRK Consulting



Marampa Iron Ore Project – Technical Appendix 4



Meeting with Foreroad Baka Women’s Association



Village meeting in Mafira



U3823_Marampa_SEP_Final.docx



August, 2012

Page 4iv of 4iv



SRK Consulting



Marampa Iron Ore Project – Technical Appendix 5



APPENDIX

5.



ISSUES AND RESPONSE RECORD



U3823_Marampa_SEP_Final.docx



August, 2012

Page 5i of 5xxiii



SRK Consulting



Issue

No.



Date



Marampa Iron Ore Project – Technical Appendix 5



Meeting venue



Stakeholder



Description of Issue/Concern



Responses provided and required action

3

(if any)



Soldier Street,

Freetown/ Chief

Administrator’s

Office,

Port

Loko

District

Council,

Port

Loko

/Town

Hall, Lunsar /

Murialdo

Secondary

School, Lunsar



Green Scenery, Port Loko

District Council, Public Meeting,

Murialdo Secondary School,

District Medical Officer Port

Loko



Local youths, indigenes and land

owners should be involved in the

employment and development

process. This will avoid conflict.

How will this be undertaken? Will

vacancies be advertised?



MIOL appreciates it is important to establish

good relations with the communities

(including the youth) and is committed to

preferential employment of local people

(see Impact ED1 in the ESIS).



Employment

16,

81,

92,

157,

133,

80



09-Mar-11

11-Mar-11

12-Mar-11

14-Mar-11



A Recruitment Plan will be developed to

address this issue (see enhancement

measures listed for Impact ED1 in the ESIS)



46



09-Mar-11



Cotton

Tree

Foundation

Office,

King

Street,

Freetown



Cotton Tree Foundation



Concerns over the decline in

people working in agricultural

production due to employment

opportunities in mining. This will

reduce the availability of farm

workers and increase pressure on

food resources.



54,

74,

130



10-Mar-11

11-Mar-11

13-Mar-11



Lunsar-Makeni

Highway,

Lunsar / Chief

Administrator’s

Office,

Port

Loko

District

Council,

Port

Loko

/Mabesene

Village, Lunsar



Amazonian Initiative Movement,

Port Loko District Council,

Mabesene

Women’s

Association, Public Meeting



Preferential employment of local

people over outsiders.



3



Where actions over and above the commitments stipulated in the ESIA and specific to the comment raised are required, these are indicated in italics and will be followed up as part of the

implementation of the ESMS outlined in the ESIS.

U3823_Marampa_SEP_Final.docx



August, 2012

Page 5ii of 5xxii



SRK Consulting



Marampa Iron Ore Project – Technical Appendix 5



Issue

No.



Date



Meeting venue



Stakeholder



Description of Issue/Concern



Responses provided and required action

3

(if any)



55



10-Mar-11



Lunsar-Makeni

Highway,

Lunsar



Amazonian Initiative Movement



Compensation should be given to

employees

who

are

made

redundant as this can have a

psychological impact.



This will be part of the employment contract.

Impacts relating to retrenchment are

assessed in the ESIS (see Impact DC1) and

MIOL has committed to the mitigation

measures listed.



63,

119,

157



10-Mar-11

13-Mar-11



Lunsar-Makeni

Highway,

Lunsar

/Foreroad Baka

Village, Lunsar

(suburb)



Amazonian Initiative Movement,

Foreroad

Baka

Women’s

Association,

Murialdo

Secondary School



Women must be considered for

employment and child labour must

be avoided.



Agreed and this will be reflected in the

Human Resources policy to be developed

by MIOL (Section 11.1.1 of ESIS) and

Recruitment Plan (see enhancement

measures for Impact ED1 in the ESIS).



10-Mar-11



Lunsar-Makeni

Highway,

Lunsar



Amazonian Initiative Movement,

Public Meeting



Human resources must be carried

out in a legitimate manner. An

appropriate recruitment process

should be undertaken.



See above (Impact ED1 and associated

management measures)



93



12-Mar-11



Town

Lunsar



Public Meeting Chairman - Hon

Alhaji O Daramy



Local stakeholders should be

contacted because they have

technical and educated youths that

are capable of doing any company

job.



See above (Impact ED1 and associated

management measures)



149



14-Mar-11



PLTC Campus,

Lungi

Road,

Prot Loko



Port Loko Teachers College



Mining employees should be

trained through the technical

department of the college.



MIOL is committed to developing a training

and skills development plan as part of its

Recruitment Plan (see enhancement

measures listed for Impact ED1). MIOL will

consider inclusion of use of the technical

department in the training and skills

development plan.



150,

117



14-Mar-11

12-Mar-11



Murialdo

Secondary

School, Lunsar /

Town

Hall,

Lunsar



Murialdo Secondary

Public Meeting



Concerns teachers will leave the

school to work in mining. This will

disrupt the pupils progress. What

incentive will be given for teachers

to stay?



Noted. MIOL will continue dialogue with the

school to keep track of the problem and if

necessary jointly identify measures to

address it.



63

94



a,



Hall,



School,



U3823_Marampa_SEP_Final.docx



August, 2012

Page 5iii of 5xxii



SRK Consulting



Marampa Iron Ore Project – Technical Appendix 5



Issue

No.



Date



Meeting venue



Stakeholder



Description of Issue/Concern



Responses provided and required action

3

(if any)



152



14-Mar-11



Murialdo

Secondary

School, Lunsar



Murialdo Secondary School



Concerns that children will leave

school to work for the mining

company.



Child labour will not permitted as part of the

Human Resources Policy.



153



14-Mar-11



Murialdo

Secondary

School, Lunsar



Murialdo Secondary School



Concern

over

inconsistency

between

employees

monthly

salary and the salary they were

initially told. A percentage may be

taken from their monthly salaries.

MIOL should deal with salary

payments, not the local authorities.



Noted. See above (Impact ED1 and

associated management measures) and

MIOL human resources manager to follow

up on the issue of salaries.



154



14-Mar-11



Murialdo

Secondary

School, Lunsar



Murialdo Secondary School



Concern

about

foreigners/employees coming from

outside

and

increasing

the

vulnerability of young girls to

becoming involved in the sex

industry. MIOL need to talk to

employees about this.



This has been identified and assessed as a

potential impact in the ESIS (Impact SO2)

and MIOL has committed to the mitigation

measures listed.



Port Loko Teachers College



Mining companies concentrate

assistance

in

primary

and

secondary

schools.

Tertiary

institutions should be considered.



Noted. MIOL will consider inclusion in the

Community Development programme.



143



141



14-Mar-11



PLTC Campus,

Lungi

Road,

Prot Loko



Port Loko Teachers College



Money can be saved if jobs higher

up can be given to Sierra

Leoneans.



Noted and see above (Impact ED1 and

associated management measures), where

suitable skill levels exist local people will be

employed.



131



13-Mar-11



Mabesene

Village, Lunsar



Mabesene

Association



Alleged concerns that in order to

get a job one has to pay 200 to

400 thousand Leones.



Noted and see above (Impact ED1 and

associated management measures).

MIOL will investigate allegations and

develop a fair and transparent recruitment

plan.



Women’s



U3823_Marampa_SEP_Final.docx



August, 2012

Page 5iv of 5xxii



SRK Consulting



Marampa Iron Ore Project – Technical Appendix 5



Issue

No.



Date



Meeting venue



Stakeholder



Description of Issue/Concern



Responses provided and required action

3

(if any)



109



12-Mar-11



Town

Lunsar



Public Meeting attendee



Request for employment of local

youth.



Noted and see above (Impact ED1 and

associated management measures).



Concerns over mining operations

clearing swamps and forests.

Reforestation and economic trees

should be provided.



The preliminary Project layout has taken

these areas into account and where

possible they have been avoided. Only a

small area of gallery forest (1.25 ha) and no

swamp forest will be cleared. Impacts on

habitat are assessed in the ESIS (Impact

EB1) and appropriate compensation for

losses to local communities will be

addressed through a Resettlement Action

Plan (see mitigation measures listed for

Impact RL1).



Hall,



Environment

14,

18,

146



09-Mar-11

14-Mar-11



Soldier Street,

Freetown

/

PLTC Campus,

Lungi

Road,

Prot Loko



Green Scenery,

Teachers College



Port



Loko



30



09-Mar-11



Upper

Brook

Street,

Freetown



Environmental Forum for Action



Concerns over the greenhouse

effect from iron ore mining. Will

MIOL

include

activities

for

communities to cope with climate

change?



Noted. The contribution of the Project to

greenhouse gases or climate change has

not been included in the ESIA but is

considered to be negligible.



32c



09-Mar-11



Upper

Brook

Street,

Freetown



Environmental Forum for Action



What will MIOL do about flora and

fauna biodiversity loss from mining

activities?



Assessment of the impacts on biodiversity

resulting from the Project is included in the

ESIS (Impacts EB1-4), and MIOL has

committed to the mitigation measures listed.



33



09-Mar-11



Upper

Brook

Street,

Freetown



Environmental Forum for Action



The level of the water table is a

serious problem as it is rapidly

being depleted. This needs to be

addressed.



Impacts on groundwater levels resulting

from pit dewatering have been assessed in

Impact WR1 of the ESIS. MIOL has

committed to the mitigation measures listed,

which include provision of water to affected

communities if required. MIOL will continue

to

actively

consult

with

affected

communities in accordance with this SEP.



31



09-Mar-11



Upper

Brook

Street,

Freetown



Environmental Forum for Action



Concerns about visual impacts as

the landscape will be destroyed.



Visual impacts are assessed in the ESIS

(Impact LT3). MIOL has committed to the

mitigation measures listed to minimise



U3823_Marampa_SEP_Final.docx



August, 2012

Page 5v of 5xxii



SRK Consulting



Issue

No.



Date



Marampa Iron Ore Project – Technical Appendix 5



Meeting venue



Stakeholder



Description of Issue/Concern



Responses provided and required action

3

(if any)

visual impacts.



41



09-Mar-11



Upper

Brook

Street,

Freetown



Environmental Forum for Action



The Company should choose the

vegetation

species

for

rehabilitation

carefully,

as

Gethropha is detrimental to local

water bodies.



Local indigenous species will be used for

rehabilitation where possible, and expert

advice will be sought in this regard.

Consideration of this will be included in the

Rehabilitation Plan.



45



09-Mar-11



Cotton

Tree

Foundation

Office,

King

Street,

Freetown



Cotton Tree Foundation



Agricultural support should be

provided as plantations can help

rehabilitate the soil.



MIOL has committed to supporting various

livelihood

strategies

for

affected

communities (see mitigation measures

listed for Impact RL1 in the ESIS). MIOL will

consider inclusion of agricultural support in

Community Development programme.



71



11-Mar-11



Chief

Administrator’s

Office,

Port

Loko

District

Council,

Port

Loko



Port Loko District Council



Concerns over air pollution and

the effect dust pollution will have

on the environment.



Specialists have quantitatively modelled the

potential impacts on air quality in the

surrounding area, the results of which are

summarised in Impact AQ1 of the ESIS.

MIOL has committed to the mitigation

measures listed.



58



10-Mar-11



Lunsar-Makeni

Highway,

Lunsar



Amazonian Initiative Movement



Concerns over the chemicals used

in boreholes and the distance from

these to the wells. A sufficient

distance should be provided.



No chemicals will be used in boreholes. A

water quality monitoring programme is in

place to monitor changes to water quality on

an ongoing basis.



155



14-Mar-11



Murialdo

Secondary

School, Lunsar



Murialdo Secondary School



Mining will interfere with the

swamps and the agricultural

sector.



Impacts on wetland areas resulting from pit

dewatering and changes to surface water

flow have been assessed in Impacts WR1

and WR3 of the ESIS. MIOL has committed

to the mitigation measures listed, which

include making alternative wetland areas

available. Compensation for land lost will be

addressed through the RAP (see Impact

RL1).



U3823_Marampa_SEP_Final.docx



August, 2012

Page 5vi of 5xxii



SRK Consulting



Marampa Iron Ore Project – Technical Appendix 5



Issue

No.



Date



Meeting venue



Stakeholder



Description of Issue/Concern



Responses provided and required action

3

(if any)



146



14-Mar-11



PLTC Campus,

Lungi

Road,

Prot Loko



Port Loko Teachers College



Concerns over the destruction of

land and land reclamation.



Impacts due to land acquisition and

relocation are assessed in Impact RL1 in

the ESIA. MIOL has committed to the

mitigation measures listed, which include

preparation of a RAP in consultation with

communities. The concerns will be

addressed through the RAP.



136



14-Mar-11



PLTC Campus,

Lungi

Road,

Prot Loko



Port Loko Teachers College



Concerns over infertile soil and

depletion, resulting in plants not

being able to grow due to toxicity.



Impacts relating to soil erosion and land

capability are assessed in Impacts LT4 and

LT5. Changes in soil chemistry resulting

from fugitive dust are not expected, and

MIOL has committed to the mitigation

measures listed.



135



14-Mar-11



PLTC Campus,

Lungi

Road,

Prot Loko



Port Loko Teachers College



Changes in the water table can

result in biodiversity loss.



Agreed. Impacts on wetland areas resulting

from pit dewatering have been assessed in

Impact WR1 of the ESIS. MIOL has

committed to the mitigation measures listed.



122



13-Mar-11



Mabesene

Village, Lunsar



Mabesene

Association



A request for assistance in the

termination of grasshoppers and

other pests.



Request noted. MIOL is yet to decide which

community development initiatives to

support in consultation with communities.

MIOL will consider inclusion in Community

Development Programme.



118



12-Mar-11



Town

Lunsar



Public Meeting attendee



Concerns about the sludge which

will damage the swamps and

directly affect agriculture.



Waste will not be deposited in wetlands or

any other natural areas. Sewage sludge will

be deposited in a landfill after appropriate

treatment, and sludge from HFO's will be

removed from site for appropriate disposal.

MIOL will develop a Waste Management

Plan (Section 11.1.4 of the ESIS) detailing

the management of wastes produced.



Hall,



Women’s



U3823_Marampa_SEP_Final.docx



August, 2012

Page 5vii of 5xxii



SRK Consulting



Marampa Iron Ore Project – Technical Appendix 5



Issue

No.



Date



Meeting venue



Stakeholder



Description of Issue/Concern



Responses provided and required action

3

(if any)



85



11-Mar-11



District

Agriculture

Officer’s Office,

MAFS,

Port

Loko



Ministry of Agriculture and Food

Security



Environmental degradation around

Mange Acre (a village beyond the

Project area) has occurred and

planting fast growing trees such as

tectona grandis (Teak) and acacia

should

be

undertaken

for

prevention of soil erosion.



Noted. Impacts relating to soil erosion due

to clearing of vegetation have been

assessed in the ESIA as Impact LT4, and

MIOL has committed to the mitigation

measures listed, which include revegetation

of disturbed areas as soon as possible.

Expert advice will be sought and

recommendations

regarding

suitable

species for use during revegetation will be

included in the Rehabilitation Plan (Section

11.1.4 of the ESIS).



86



11-Mar-11



District

Agriculture

Officer’s Office,

MAFS,

Port

Loko



Ministry of Agriculture and Food

Security



Trees should not be cut down as

this interrupts the water table

which is currently a serious

problem.



Noted. Disturbance of trees and particularly

indigenous forest habitat will minimised –

measures to this effect will be included in

the

Construction

Management

Plan

(Section 11.1.4 of the ESIS).



88



11-Mar-11



District

Agriculture

Officer’s Office,

MAFS,

Port

Loko



Ministry of Agriculture and Food

Security



MAFS (Port Loko) want to work in

partnership

in

reforestation

programmes.



Noted. MIOL will engage in further

consultation with MAFS in this regard.



11



09-Mar-11



Soldier Street,

Freetown



Green Scenery



Concern over the inappropriate

disposal of tailings.



Tailings material will be disposed of in a

dedicated and appropriately designed

Tailings Storage Facility (see detail in

Section 4.4 of the ESIS and Appendix 5),

and used to backfill Matukia pit, with

suitable design requirements in place. No

tailings material will be disposed of

elsewhere.



09-Mar-11



NMJD

Office,

49 Main Motor

Road,

Brookfields,

Freetown



Network Movement for Justice

and Development



Allocation of 1% of revenues for

local development.



Noted. MIOL will investigate options for

investment in local development through a

Community Development Plan (Section

11.1.4 of the ESIS).



CSR

3



U3823_Marampa_SEP_Final.docx



August, 2012

Page 5viii of 5xxii



SRK Consulting



Marampa Iron Ore Project – Technical Appendix 5



Issue

No.



Date



Meeting venue



Stakeholder



Description of Issue/Concern



Responses provided and required action

3

(if any)



13



09-Mar-11



Soldier Street,

Freetown



Green Scenery, Environmental

Forum for Action



Communities should be helped to

cope with climatic impact.



Noted. However no impacts on climate

resulting from the Project are anticipated.



22



09-Mar-11



Soldier Street,

Freetown



Green Scenery



Communities should be involved in

rehabilitation programmes, such

as tree planting, as this will

provide employment.



Chapter 8 of the ESIA proposes a

Livelihood Restoration Plan.

MIOL will

consider the inclusion of specific Projects in

the livelihood restoration measures included

in the Community Development Plan

(Section 11.1.4 of the ESIS) in consultation

with community members



27,

70, 97



09-Mar-11

11-Mar-11

12-Mar-11



Upper

Brook

Street,

Freetown /Chief

Administrator’s

Office,

Port

Loko

District

Council,

Port

Loko / Town

Hall, Lunsar



Environmental Forum for Action,

Port Loko District Council,

Public Meeting



Local people, landowners and

children should benefit from

mining operations in their area and

help should be provided to the

communities.



Noted. The Project’s contribution to local

economic development has been assessed

in the ESIA (Section 8.1) and MIOL has

committed to the enhancement measures

listed, to improve benefits to local

communities.



32d



09-Mar-11



Upper

Brook

Street,

Freetown



Environmental Forum for Action



What will the budget be for

environmental/community

strategies which mitigate the effect

mining operations will have.



The budget estimate will be an outcome of

the detailed management action planning if

the Project goes ahead. MIOL will devise a

detailed management action plan, including

budgetary estimations.



73



11-Mar-11



Chief

Administrator’s

Office,

Port

Loko

District

Council,

Port

Loko



Port Loko District Council



MIOL should develop tangible

structures instead of just giving out

money, such as incorporating

facilities

into

their

social

programmes such as Peripheral

Health Units and hospitals.



Noted. MIOL will include this in the

Community Development Plan (Section

11.1.4 of the ESIS).



76



11-Mar-11



Chief

Administrator’s

Office,

Port

Loko

District

Council,

Port

Loko



Port Loko District Council



MIOL needs to recognise basic

development principles/corporate

social responsibilities.



Noted. MIOL has committed to developing a

Community

Development

Plan

in

consultation with local communities.



U3823_Marampa_SEP_Final.docx



August, 2012

Page 5ix of 5xxii



SRK Consulting



Marampa Iron Ore Project – Technical Appendix 5



Issue

No.



Date



Meeting venue



Stakeholder



Description of Issue/Concern



Responses provided and required action

3

(if any)



98



12-Mar-11



Town

Lunsar



Hall,



Public Meeting attendee



Medical assistance should be

provided through facilities and

especially a malaria control

programme as mosquitoes breed

in the ponds and pits mining

companies have produced.



Noted. MIOL will consider inclusion in

Community Development Plan (Section

11.1.4 of the ESIS).



104



12-Mar-11



Town

Lunsar



Hall,



Public Meeting attendee



A request to

scholarships.



This is an ongoing programme and could be

expanded if the Project goes ahead. MIOL

will consider inclusion in Community

Development Plan (Section 11.1.4 of the

ESIS).



100,

105



12-Mar-11



Town

Lunsar



Hall,



Public Meeting attendee



High quality schools, hospitals and

roads should be built.



This is not

responsibility.



106



12-Mar-11



Town

Lunsar



Hall,



Public Meeting attendee



Safe drinking water should be

provided to the communities.



91



12-Mar-11



Town

Lunsar



Hall,



Public Meeting attendee



Delco left houses, therefore the

Company has no right to destroy

them without building new ones.



MIOL will provide safe drinking water to

Project-affected communities if impacts are

shown to occur, currently no impacts on

water quality are predicted (Impact WR6).

Replacement housing will be built for

affected community members under the

RAP.



96



12-Mar-11



Town

Lunsar



Hall,



Public Meeting attendee



Preference

towards

local

businesses

and

shops

for

purchase of provisions and

supplies.



This is acknowledged in Chapter 8 of the

ESIS,

which

includes

enhancement

measures MIOL has committed to, to

maximise benefits to local suppliers (Impact

ED4

and

associated

management

measures).



101



12-Mar-11



Town

Lunsar



Hall,



Public Meeting attendee



Programmes in which women can

become involved should go

directly to them giving them the

opportunity to participate.



Noted. Impacts on vulnerable groups

(including women) are acknowledged in

Chapter 8 of the ESIA. MIOL will consider

vulnerable groups in the Community

Development Plan (Section 11.1.4 of the

ESIS).



U3823_Marampa_SEP_Final.docx



give



children



MIOL's



but



government's



August, 2012

Page 5x of 5xxii



SRK Consulting



Marampa Iron Ore Project – Technical Appendix 5



Issue

No.



Date



Meeting venue



Stakeholder



Description of Issue/Concern



Responses provided and required action

3

(if any)



83



11-Mar-11



Chief

Administrator’s

Office,

Port

Loko

District

Council,

Port

Loko



Port Loko District Council



People who are affected directly

should be the first to benefit



Noted. This is acknowledged in the ESIA,

and MIOL has committed to the

enhancement measures listed in Section

8.1, which focus on benefits to affected

communities.



57



10-Mar-11



Lunsar-Makeni

Highway,

Lunsar



Amazonian Initiative Movement



Concerns over displacement as

LMC has threatened to move the

people who are living in the

quarters built by Delco. Will new

houses be built? Demolition will

create tension therefore an

amicable decision should be

reached.



Impacts relating to other Projects are

beyond the scope of this ESIA or MIOL's

area

of

influence.

Relocation

of

communities affected by MIOL's Project will

be addressed via the RAP (Impact RL1).



82



11-Mar-11



Chief

Administrator’s

Office,

Port

Loko

District

Council,

Port

Loko



Port Loko District Council



MIOL should contact the Council

for community programmes to

avoid duplication.



Agreed. MIOL will follow up with the local

council in this regard when preparing the

Community Development Plan (Section

11.1.4 of the ESIS).



144



14-Mar-11



PLTC Campus,

Lungi

Road,

Prot Loko



Port Loko Teachers College



A proposal has been sent to MIOL

for a generator and electrification

but there has been no reply.



Noted. MIOL will take up the proposal for

consideration as part of the Community

Development Plan.



2



09-Mar-11



NMJD

Office,

49 Main Motor

Road,

Brookfields,

Freetown



Network Movement for Justice

and Development



The Project cost should include

the

cost

of

resettlement,

compensation for crops and

community infrastructure. Despite

the Government not currently

having a resettlement policy, it is

important that companies go about

resettlement correctly.



Agreed.

Cost for resettlement will be

included. MIOL has committed to a RAP

(Impact RL1), which will include this.



Business Operations



U3823_Marampa_SEP_Final.docx



August, 2012

Page 5xi of 5xxii



SRK Consulting



Marampa Iron Ore Project – Technical Appendix 5



Issue

No.



Date



Meeting venue



Stakeholder



Description of Issue/Concern



Responses provided and required action

3

(if any)



1, 116



09/03/2011,

12/03/2011



NMJD

Office,

49 Main Motor

Road,

Brookfields,

Freetown

/

Town

Hall,

Lunsar



Network Movement for Justice

and

Development,

Public

Meeting



Mining companies should use

international laws as national laws

are weak.



Agreed. MIOL is using not just national laws

but referring to international standards as

well for the ESIA process (Section 2.2 of

ESIS).



5,15



09-Mar-11



NMJD

Office,

49 Main Motor

Road,

Brookfields,

Freetown



Network Movement for Justice

and

Development,

Green

Scenery



What is the relationship between

London Mining, MIOL and African

Minerals Limited?



There is no relationship with London Mining

and African Minerals, except that African

Minerals is a shareholder in Cape Lambert

who own MIOL.



7



09-Mar-11



Soldier Street,

Freetown



Green Scenery



Concerns over companies moving

fast with their operations and

procedures not being followed

properly.



Noted. MIOL is strongly committed to

following the correct procedures.



20



09-Mar-11



Soldier Street,

Freetown



Green Scenery



Concern over the issue of change

in company ownership resulting in

a displacement of liabilities. Will a

bond be left behind for new

companies to take up? When

companies sell on mining Projects,

the new owners do not usually

take on the liabilities of the old

companies (example Sierra Rutile

and Koidu Holdings). In such

situations the government does

not have the capacity to monitor

liabilities, and NGOs tend to

become involved.



Noted. International good practice, which

MIOL has committed to requires the

company to make provision for rehabilitation

should it decide to close the operation.



72



11-Mar-11



Chief

Administrator’s

Office,

Port

Loko

District

Council,

Port



Port Loko District Council



It is important for MIOL to conform

to local laws.



Agreed. MIOL is committed to conforming to

all national laws and also to international

good practice.



U3823_Marampa_SEP_Final.docx



August, 2012

Page 5xii of 5xxii



SRK Consulting



Issue

No.



Date



Marampa Iron Ore Project – Technical Appendix 5



Meeting venue



Stakeholder



Description of Issue/Concern



Responses provided and required action

3

(if any)



Loko



61



10-Mar-11



Lunsar-Makeni

Highway,

Lunsar



Amazonian Initiative Movement



All three mining companies (MIOL,

AML and LMC) should come

together to construct one road and

railway.



Noted. A degree of collaboration in this

regard between AML and MIOL with regard

to shared use of rail (and possibly port)

infrastructure for product export has been

agreed to (Section 4 of the ESIS).



69



11-Mar-11



The Manager’s

Office,

Marampa

Community

Bank, Lunsar



Marampa Community Bank



MIOL should use Marampa

Community Bank for domestic

banking and to pay staff salaries

as this will allow for an

improvement

in

community

infrastructure.



Noted.



84



11-Mar-11



Chief

Administrator’s

Office,

Port

Loko

District

Council,

Port

Loko



Port Loko District Council



Company information will be

disseminated to the Government

and other agencies.



MIOL will provide the legally required

documents to relevant authorities and

communicate to stakeholders as specified

in this SEP.



139



14-Mar-11



PLTC Campus,

Lungi

Road,

Prot Loko



Port Loko Teachers College



What adjustments do MIOL make

in order to meet with the rate of

inflation?



This level of detail has not yet been

determined.



115



12-Mar-11



Town

Lunsar



Hall,



Public Meeting attendee



Rev JS Mans also recommended

that, in order to ensure justice, the

Headquarter/ administrative office

of MIOL should be located in

Lunsar and not in Freetown



Noted. However, the Company has decided

that its head office will remain in Freetown

at this stage.



112



12-Mar-11



Town

Lunsar



Hall,



Public Meeting attendee



All grievances should be reported

to the authorities or the Police.



Noted. MIOL will report relevant problems/

grievances, if criminal in nature, to the

police or relevant authorities. Reference to

this will be included in the Grievance

Management Plan (Section 11.1.4 of the

ESIS).



U3823_Marampa_SEP_Final.docx



August, 2012

Page 5xiii of 5xxii



SRK Consulting



Marampa Iron Ore Project – Technical Appendix 5



Issue

No.



Date



Meeting venue



Stakeholder



Description of Issue/Concern



Responses provided and required action

3

(if any)



12



09-Mar-11



Soldier Street,

Freetown



Green Scenery



Issue

of

implementation:

Consultants should design a

framework on how to monitor and

include as an annex. A framework

on reporting their performance

should be constructed.



Agreed. The Environmental and Social

Management System in Chapter 11 of the

ESIS includes specifications for monitoring

and

reporting.

An

environmental

management programme (EMP) is included

in Appendix F of the ESIS.



145



14-Mar-11



PLTC Campus,

Lungi

Road,

Prot Loko



Port Loko Teachers College



Who

determines

what

compensated to the people?



is



Government will make final decisions on the

compensation- decisions will be based on

Leone

legislation,

current

Sierra

international good practice and local prices.

Details on compensation will be specified in

the RAP (Impact RL1).



17



09-Mar-11



Soldier Street,

Freetown



Green Scenery, Public Meeting



Resettlement is a key issue and

companies must do this sensitively

and properly where they should

buy land for communities and build

houses for them.



Impacts relating to resettlement have been

assessed in Section 8.2 of the ESIS (Impact

RL1). These issues will be addressed more

thoroughly in the RF (Appendix D of the

ESIA) and RAP.



Stakeholder Consultation Process and Participation

4, 9,

48, 60



09-Mar-11



NMJD

Office,

49 Main Motor

Road,

Brookfields,

Freetown,

Soldier Street,

Freetown



Network Movement for Justice

and

Development,

Green

Scenery,

Cotton

Tree

Foundation,

Amazonian

Initiative Movement



The authority of Paramount Chiefs

is now declining and hence MIOL

should not rely on them too much.

Instead the Company should

identify

other

leaders

and

communicate

directly

with

community members.

The

dialogue with the community

should be sustained even after

permitting.



Noted. MIOL will ensure continuous

dialogue between the company and

stakeholders throughout the Project life

cycle, as described in this SEP.



8



09-Mar-11



Soldier Street,

Freetown



Green Scenery



A programme should be designed

which

identifies

communities

needs.



A Community Development Plan is

committed to and this will include evaluation

of community needs (Section 11.1.4 of the

ESIS).



U3823_Marampa_SEP_Final.docx



August, 2012

Page 5xiv of 5xxii



SRK Consulting



Marampa Iron Ore Project – Technical Appendix 5



Issue

No.



Date



Meeting venue



Stakeholder



Description of Issue/Concern



Responses provided and required action

3

(if any)



21



09-Mar-11



Soldier Street,

Freetown



Green Scenery



The ESIA should not only be sent

to SLEPA but should be made

available to other stakeholder

groups as well to share their

concerns

before

the

ESIA

disclosure.



When the ESIS is made public it will be

available to stakeholder groups, as per the

required SEP (Section 3.3.5 of the ESIA).



23



09-Mar-11



Soldier Street,

Freetown



Green Scenery



Communities should be engaged

and educated to avoid threats.



Agreed. Community engagement will take

place throughout the Project life cycle and

after closure as set out in the SEP.



24



09-Mar-11



Soldier Street,

Freetown



Green Scenery



A balance between the community

and

company’s

expectations

should be kept.



Agreed. Continued community engagement

throughout the Project is set out in the SEP.



25



09-Mar-11



Soldier Street,

Freetown



Green Scenery



The Community Liaison Officer

(CLO) will be the key person for

community outreach.



Agreed.



28



09-Mar-11



Upper

Brook

Street,

Freetown



Environmental Forum for Action



Concern over MIOL's public

participation in 2010 as it was very

poor. They do not want a repeat of

this.



Noted. MIOL is strongly committed to

following

good

practice

procedures,

especially with regard to community

consultation. MIOL to follow up on reasons

for this comment.



49



09-Mar-11



Cotton

Tree

Foundation

Office,

King

Street,

Freetown



Cotton Tree Foundation



MIOL should beware of the

uneducated people in the Project

area, as they can have a negative

impact.



Agreed. The company will have a dedicated

non-technical summary report of the ESIA

for disclosure of relevant Project related

information to communities as outlined in

this SEP. Consultations will take place

throughout the Project life cycle to ensure

communities are kept up to date with

information. The community liaison officer

will also facilitate dissemination of

information to communities.



U3823_Marampa_SEP_Final.docx



August, 2012

Page 5xv of 5xxii



SRK Consulting



Marampa Iron Ore Project – Technical Appendix 5



Issue

No.



Date



Meeting venue



Stakeholder



Description of Issue/Concern



Responses provided and required action

3

(if any)



50



09-Mar-11



Cotton

Tree

Foundation

Office,

King

Street,

Freetown



Cotton Tree Foundation



MIOL should understand the

people, culture, values and show

respect to the local communities

through involving them.



Agreed. Communities will be engaged with

at each step of the Project cycle as outlined

in this SEP. Dedicated social and natural

resource studies have taken place to gain

understanding of the local culture and

values (Section 6 of the ESIS).



79



11-Mar-11



Chief

Administrator’s

Office,

Port

Loko

District

Council,

Port

Loko



Port Loko District Council



Sheik Gibril requests feedback

from the meeting.



Noted. MIOL will follow up and ensure the

requested feedback has been provided.



78



11-Mar-11



Chief

Administrator’s

Office,

Port

Loko

District

Council,

Port

Loko



Port Loko District Council



The council should be involved in

all development programmes.



Government and governmental agencies

will be involved in community development

as laid out in the RF.



159,

99



14-Mar-11



Murialdo

Secondary

School, Lunsar



Murialdo Secondary

Public Meeting



Will this consultation be a

continuous process? Engagement

with stakeholders should continue.



Engagement with stakeholders will continue

throughout the Project life as outlined in this

SEP.



113



12-Mar-11



Town

Lunsar



Public Meeting attendee



A request for similar meetings to

be held by MIOL every month.



Noted. If the Project proceeds the frequency

of meetings will be reviewed and if

necessary the SEP updated to reflect the

needs of the community.



87



11-Mar-11



District

Agriculture

Officer’s Office,

MAFS,

Port

Loko



Ministry of Agriculture and Food

Security



It is important that work is

undertaken with community youths

and chiefs.



Noted.



77



11-Mar-11



Chief

Administrator’s

Office,

Port

Loko

District



Port Loko District Council



MIOL should have community

development personnel to guide

them on development principles.



A Community Development Plan is

committed to and this will include input from

relevant specialists (Section 11.1.4 of the

ESIS).



Hall,



School,



U3823_Marampa_SEP_Final.docx



August, 2012

Page 5xvi of 5xxii



SRK Consulting



Issue

No.



Date



Marampa Iron Ore Project – Technical Appendix 5



Meeting venue

Council,

Loko



Stakeholder



Description of Issue/Concern



Responses provided and required action

3

(if any)



Port



Mining Operations

32



09-Mar-11



Upper

Brook

Street,

Freetown



Environmental Forum for Action



International consultants have a

history

of

ignoring

their

recommendations

(eg.

on

chemical

disposal,

tailings,

pollution prevention, clearing of

vegetation and restoration) given

in management plans.



Noted. MIOL is committed to implementing

the measures listed in the EMP (Appendix F

of the ESIS). Adherence to the EMP may be

a condition of the Project’s environmental

authorisation.



32a



09-Mar-11



Upper

Brook

Street,

Freetown



Environmental Forum for Action



What will MIOL do about tailings

storage facilities?



Tailings material will be disposed of in a

dedicated and appropriately designed

Tailings Storage Facility (see Section 4.4 of

the ESIS and Appendix E), and used to

backfill Matukia pit (with appropriate design

in place).



37



09-Mar-11



Upper

Brook

Street,

Freetown



Environmental Forum for Action



Will AML, LML and MIOL work

together to mitigate impacts of iron

ore exploration?



Noted. No formal arrangement in this regard

has been reached yet. Cumulative impacts

(in most cases resulting from the multiple

mining Projects in the area) have been

assessed in Chapter 10 of the ESIS. MIOL

will consider approaching AML and LMC in

this regard.



38



09-Mar-11



Upper

Brook

Street,

Freetown



Environmental Forum for Action



The cost of rehabilitation should

not be to be left on the

government.



Agreed. MIOL will be responsible for the

cost of rehabilitation of the site, as

described in Section 4.11, and specified in

the EMP (Appendix F).



40



09-Mar-11



Upper

Brook

Street,

Freetown



Environmental Forum for Action



Request to see

Reclamation Plan.



A Closure and Rehabilitation Plan will be

developed if the Project proceeds and will

be made available upon request to

stakeholders.



43



09-Mar-11



Upper

Street,



Environmental Forum for Action



ENFORAC has the legal mandate

to monitor and are working with



Brook



U3823_Marampa_SEP_Final.docx



the



Mine



Noted.



August, 2012

Page 5xvii of 5xxii



SRK Consulting



Issue

No.



Date



Marampa Iron Ore Project – Technical Appendix 5



Meeting venue



Stakeholder



Description of Issue/Concern



Freetown



Responses provided and required action

3

(if any)



SLEPA.



44



09-Mar-11



Upper

Brook

Street,

Freetown



Environmental Forum for Action



ENFORAC have requested to be

part of the process and that MIOL

should work with them.



Noted. ENFORAC are registered as

stakeholders and will be consulted in future

as outlined in this SEP.



156



14-Mar-11



Murialdo

Secondary

School, Lunsar



Murialdo Secondary School



How will

stored?



Concentrate will be stored in stockpiles at

the rail loading spur before being exported

from the site. See Section 4.3 of the ESIS.



62



10-Mar-11



Lunsar-Makeni

Highway,

Lunsar



Amazonian Initiative Movement



When will mining start?



Stage 1 (oxide ore) mining is scheduled to

start in Q$ of 2014 subject to the Company

receiving financing.



64



10-Mar-11



Lunsar-Makeni

Highway,

Lunsar



Amazonian Initiative Movement



How

will

MIOL

undertake

monitoring and which areas are of

influence? How long does it take

to monitor?



MIOL will undertake monitoring as per the

requirements of the Environmental and

Social Management System (Section 11.3

of the ESIA). Monitoring programmes

recommended by specialists are included in

the specialist study reports (Volume 3 of the

ESIS). Monitoring will in most cases be

ongoing through the life of mine.



the



concentrate



be



Livelihoods (Agri schemes)

66, 52



10-Mar-11



Lunsar-Makeni

Highway,

Lunsar



Amazonian Initiative Movement



MIOL should negotiate with

plantation owners and the names

of the landowners should be

recorded in the deal. Landowners

should be treated fairly whereby

they receive the true money value

of their land.



MIOL will make the decision on

compensation in consultation with affected

land owners and government in line with

Sierra Leone legislation and international

standards.

Landowners will be paid

compensation at full replacement value.

Further detail on compensation will be

determined via the RAP (Impact RL1 in the

ESIS).



123 a



13-Mar-11



Mabesene

Village, Lunsar



Mabesene

Association



Assistance

for

agricultural

expansion should be provided.



Noted.

Decisions

on

community

development programmes will be made

during the development of the RAP. MIOL

will consider inclusion in the community

development programme.



Women’s



U3823_Marampa_SEP_Final.docx



August, 2012

Page 5xviii of 5xxii



SRK Consulting



Marampa Iron Ore Project – Technical Appendix 5



Issue

No.



Date



Meeting venue



Stakeholder



Description of Issue/Concern



Responses provided and required action

3

(if any)



140,

138



14-Mar-11



PLTC Campus,

Lungi

Road,

Prot Loko



Port Loko Teachers College



Economic trees such as Mango

trees, should be planted as these

provide livelihoods. How much

would MIOL pay for these?



Economically important trees lost through

land acquisition will be compensated (detail

will be determined via the RAP), and

community development plans will be

decided in consultation with the community.

MIOL will consider inclusion in the

Community Development Plan (Section

11.1.4 of the ESIS)



120



13-Mar-11



Foreroad Baka

Village, Lunsar

(suburb)



Foreroad

Baka

Association



Women’s



A request for assistance and

support in business activities and

the construction of a storage

facility for crops and produce.



121



13-Mar-11



Mabesene

Village, Lunsar



Mabesene

Association



Women’s



MIOL is expected to continue in

supporting this group with seed

supply for cassava and groundnut.



Noted.

Decisions

on

community

development programmes will be made in

consultation with the community members.

MIOL will consider inclusion in the

Community Development Plan (Section

11.1.4 of the ESIS)



103



12-Mar-11



Town

Lunsar



Hall,



Public Meeting attendee



What will happen if MIOL relocates

landowners?



MIOL will buy land for them and build them

houses, in accordance with a RAP (Impact

RL1), which will be developed in

consultation with the community.



107



12-Mar-11



Town

Lunsar



Hall,



Public Meeting attendee



What will happen to their land after

MIOL has left?



The land will be rehabilitated and handed

back to the community (Section 4.11).



108



12-Mar-11



Town

Lunsar



Hall,



Public Meeting attendee



When MIOL pay the landowners

their surface rent, they should tell

them then what will happen to their

land once the company has left.



Noted. Engagement with stakeholders on

issues such as this will continue throughout

the Project life as outlined in this SEP.



111



12-Mar-11



Town

Lunsar



Hall,



Public Meeting attendee



MIOL

should

address

relocation of communities

crop compensation.



the

and



This is being addressed in the resettlement

planning process (see RF in Appendix D

and Impact RL1) and will further be

addressed via the RAP.



90



11-Mar-11



District

Agriculture

Officer’s Office,

MAFS,

Port



Ministry of Agriculture and Food

Security



The rehabilitation of mined out

areas

is

crucial

for

the

sustainability of agriculture.



Disturbed areas will be rehabilitated, but not

necessarily to their original use. MIOL will

devise a Rehabilitation and Closure Plan

(Section 11.1.4 of the ESIS).



U3823_Marampa_SEP_Final.docx



August, 2012

Page 5xix of 5xxii



SRK Consulting



Issue

No.



Date



Marampa Iron Ore Project – Technical Appendix 5



Meeting venue



Stakeholder



Description of Issue/Concern



Responses provided and required action

3

(if any)



Loko



89



11-Mar-11



District

Agriculture

Officer’s Office,

MAFS,

Port

Loko



Ministry of Agriculture and Food

Security



Swamps and low lying areas

should be developed for increased

agricultural production.



Suggested noted.

Wetland areas also

serve important ecological functions, which

need to be maintained.



26



09-Mar-11



Soldier Street,

Freetown



Green Scenery



The issue of livelihood. Farmers

may not have much land anymore.



Noted.

The issue of livelihoods

discussed in Section 8.2 of the ESIS.



Council,

Women’s



Concerns over the effect air

pollution and dust from vehicles

will have on human health.



Impacts on air quality (including those

resulting from dust from vehicles) were

assessed by a specialist, the findings of

which are summarised in the ESIS (Section

9.1). MIOL has committed to the mitigation

measures listed.



is



Health and Safety

71,

127



11-Mar-11



Chief

Administrator’s

Office,

Port

Loko

District

Council,

Port

Loko

/

Mabesene

Village, Lunsar



Port Loko

Mabesene

Association



District



128,

124



13-Mar-11



Mabesene

Village, Lunsar



Mabesene

Association



Women’s



Concerns over heavy machines

shaking nearby houses and

blasting activity damaging their

houses as structures are weak.



Impacts resulting from vibrations and air

overpressure

have

been

modelled

assessed in the ESIS (Impact NV1).

Impacts on built structures are expected to

be insignificant (and lower than those on

humans).



129,

148



13-Mar-11



Mabesene

Village, Lunsar



Mabesene

Women’s

Association, Port Loko Teachers

College



Concerns over increases in

accidents due to an increase in

traffic and the safety of people

when crossing railways and roads.



Traffic safety risks are assessed in the ESIS

as Impacts TS1 and TS2. MIOL has

committed to the mitigation measures listed,

including provision of safe crossing points

where possible.



U3823_Marampa_SEP_Final.docx



August, 2012

Page 5xx of 5xxii



SRK Consulting



Marampa Iron Ore Project – Technical Appendix 5



Issue

No.



Date



Meeting venue



Stakeholder



Description of Issue/Concern



Responses provided and required action

3

(if any)



132



14-Mar-11



DMO’s

office,

Port

Loko

Government

Hospital,

Hospital Road,

Port Loko



District

Loko



Port



Concerns over the water system

and artificial lakes as waterborne

diseases can be transmitted.



Noted. Impacts on surface water quality

resulting from discharges are assessed in

Impact WR6 of the ESIA, and MIOL has

committed to the mitigation measures listed.

Ongoing water quality monitoring will take

place to timeously detect issues.



125



13-Mar-11



Mabesene

Village, Lunsar



Mabesene

Association



Women’s



Safety measures need to ensure

debris and stones do not fly into

the village from blasting activities.



Agreed, and addressed in Impact OH1 of

the ESIA. MIOL will ensure good practice

safety measures are in place during blasting

operations.



123



13-Mar-11



Mabesene

Village, Lunsar



Mabesene

Association



Women’s



Toilet facilities and clean water

supply should be provided.



MIOL cannot provide what usually is

government responsibility. However this

request would be considered during

ongoing consultations with community as

part of the Community Development Plan

(Section 11.1.4 of the ESIS).



126



13-Mar-11



Mabesene

Village, Lunsar



Mabesene

Association



Women’s



There is a fear of flooding due to

Magbenkte

Village

being

surrounded by old Delco Lake

where some digging is being

undertaken (not clear if this is in

London Mining area).



Changes to flood risk have been assessed

in the ESIS in Impact WR4, and is predicted

to be of low significance. Various good

practice measures are recommended to

further decrease any negative impacts on

local villages.



142



14-Mar-11



PLTC Campus,

Lungi

Road,

Prot Loko



Port Loko Teachers College



Concerns over health and social

issues associated with congestion.



114



12-Mar-11



Town

Lunsar



Public Meeting attendee - Dr.

Rev. Joseph Saidu Mans



It is requested that employees use

the St John of God Hospital and

the Baptist Eye Hospital for

medical tests and examination.



This risk is assessed in Impacts SR2, and

SO1-3 of the ESIS and MIOL has

committed to the measures proposed for

mitigating them.

Noted. MIOL will follow up in this regard at

the appropriate time.



Hall,



Medical



Officer



U3823_Marampa_SEP_Final.docx



August, 2012

Page 5xxi of 5xxii



SRK Consulting



Marampa Iron Ore Project – Technical Appendix 5



Issue

No.



Date



Meeting venue



Stakeholder



Description of Issue/Concern



Responses provided and required action

3

(if any)



65



10-Mar-11



Lunsar-Makeni

Highway,

Lunsar



Amazonian Initiative Movement



External workers should be aware

of an increased risk of HIV and

AIDS.



Workers will be made aware of risks and

preventative measures on commencement

of employment, as part of the health

awareness programme committed to by

MIOL, which are likely to be captured in a

Community Health and Safety Plan (Impact

SR2 of the ESIS). HIV awareness will be

included.



68



10-Mar-11



Lunsar-Makeni

Highway,

Lunsar



Amazonian Initiative Movement



How will MIOL address hazards

such as the effect blasting noise

will have on people.



This impact has been assessed by a noise

specialist, and reported as Impact NV1 in

the ESIS. The impact on local communities

is predicted to be of low significance, and

no mitigation measures are required.

Impacts on mine workers are an

occupational health and safety issue, and

the appropriate PPE will be used.



56



10-Mar-11



Lunsar-Makeni

Highway,

Lunsar



Amazonian Initiative Movement



Will appropriate safety gear be

supplied to the employees?



Yes, appropriate health and safety

measures will be followed with relevant

safety gear (PPE) being provided to all

employees with the expectation it will be

worn at all times



32



09-Mar-11



Upper

Brook

Street,

Freetown



Environmental Forum for Action



What will MIOL do about noise

and air pollution?



Specialists have quantitatively modelled the

potential impacts on air quality and noise in

the surrounding area, the results of which

are summarised in Impacts AQ1 and NV2 of

the ESIS. MIOL has committed to the

mitigation measures listed to manage these

impacts.



34



09-Mar-11



Upper

Brook

Street,

Freetown



Environmental Forum for Action



Which type of explosives/blasters

will be used? Will staff be trained

to use explosives safely?



The type of explosives is yet to be

determined. MIOL staff will be appropriately

trained and the appropriate safety

measures will be in place.



U3823_Marampa_SEP_Final.docx



August, 2012

Page 5xxii of 5xxii



SRK Consulting



Marampa Iron Ore Project – Technical Appendix 5



Issue

No.



Date



Meeting venue



Stakeholder



Description of Issue/Concern



Responses provided and required action

3

(if any)



32b



09-Mar-11



Upper

Brook

Street,

Freetown



Environmental Forum for Action



What will MIOL do about the

drilling/blasting effects on workers

and the communities?



This impact has been assessed by a noise

specialist, and reported in Impact NV1 of

the ESIS. The impact on local communities

is predicted to be of low significance, and

no mitigation measures are required.

Impacts on mine workers are an

occupational health and safety issue, and

the appropriate PPE will be used.



35, 59



09-Mar-11



Upper

Brook

Street,

Freetown



Environmental Forum for Action,

Amazonian Initiative Movement



There needs to be sufficient

distance between to use of

explosives and the communities.



Staff will be appropriately trained in the use

of explosives and the appropriate safety

measures will be in place.



U3823_Marampa_SEP_Final.docx



August, 2012

Page 5xxiii of 5xxii



SRK Consulting



Marampa Iron Ore Project ESIS – Technical Appendix D



APPENDIX D

D



RESETTLEMENT FRAMEWORK



U3823_Marampa_ESIS_Final.docx



September 2012

Page D1 of D1



A RESETTLEMENT FRAMEWORK FOR

THE MARAMPA IRON ORE PROJECT,

SIERRA LEONE



Prepared For



MARAMPA IRON ORE (SL) LIMITED



Report Prepared by



SRK Consulting (UK) Limited

UK3823



SRK Consulting



Marampa RF – Details



COPYRIGHT AND DISCLAIMER

Copyright (and any other applicable intellectual property rights) in this document and any

accompanying data or models which are created by SRK Consulting (UK) Limited ("SRK") is

reserved by SRK and is protected by international copyright and other laws. Copyright in any

component parts of this document such as images is owned and reserved by the copyright owner

so noted within the document.

This document may not be utilised or relied upon for any purpose other than that for which it is

stated within and SRK shall not be liable for any loss or damage caused by such use or reliance.

In the event that the recipient of this document wishes to use the content of this document in

support of any purpose beyond or outside that which it is expressly stated or for the raising of any

finance from a third party where the document is not being utilised in its full form for this purpose,

the recipient shall, prior to such use, present a draft of any report or document produced by it that

may incorporate any of the content of this document to SRK for review so that SRK may ensure

that this is presented in a manner which accurately and reasonably reflects any results or

conclusions produced by SRK.

The use of this document is strictly subject to terms licensed by SRK to its Client as the recipient

of this document and unless otherwise agreed by SRK, this does not grant rights to any third

party. This document shall only be distributed to any third party in full as provided by SRK and

may not be reproduced or circulated in the public domain (in whole or in part) or in any edited,

abridged or otherwise amended form unless expressly agreed in writing by SRK. Any other

copyright owner’s work may not be separated from this document, used or reproduced for any

other purpose other than with the document in full as licensed by SRK. In the event that this

document is disclosed or distributed to any third party, no such third party shall be entitled to place

reliance upon any information, warranties or representations which may be contained within this

document and the recipient of this document shall indemnify SRK against all and any claims,

losses and costs which may be incurred by SRK relating to such third parties.

© SRK Consulting (UK) Limited 2011



SRK Consulting (UK) Limited



SRK Legal Entity:



th



SRK Address:



5 Floor Churchill House

17 Churchill Way

City and County of Cardiff, CF10 2HH

Wales, United Kingdom.



SRK Project Director

and Project Manager:

Client Legal Entity:

Date:

Project Number:

Client Address:



U3823_Marampa_Resettlement_Final.docx



Fiona Cessford



Corporate Consultant (Environment)

Marampa Iron Ore Ltd

September, 2012

UK3823

Victoria Place

31 Victoria Street

Hamilton

Bermuda (British Overseas Territory)

HM10



September, 2012



SRK Consulting



Marampa RF – Executive Summary



A RESETTLEMENT FRAMEWORK FOR THE MARAMPA IRON ORE

PROJECT, SIERRA LEONE – EXECUTIVE SUMMARY

1. INTRODUCTION

Marampa Iron Ore Limited (MIOL) intends to develop an open pit iron ore mine in the vicinity

of Lunsar. The Project will require land acquisition and as a result some people will need to be

physically and/or economically displaced from the Project area. SRK Consulting (UK) Limited

(“SRK”) has been requested by Marampa Iron Ore Limited (“MIOL”, hereinafter also referred

to as the “Company” or the “Client”) to prepare a Resettlement Framework (”RF”).

Of the total area (2 173 ha) potentially impacted by Project infrastructure, approximately 89%

is currently used for agriculture. It is estimated 10 villages (162 households and 1780 people)

will require relocation and could lose some or all access to agricultural land, natural

resources, social infrastructure, sacred sites and access routes. In addition to the above

villages, 13 villages (270 households and 2936), which are on the outskirts of the Project

footprint, may lose some access to land and natural resources.

The RF is based on relevant Sierra Leone national laws and international best practices for

compensation and resettlement. In particular the IFC Performance Standard (PS) 5 on Land

Acquisition and Involuntary Resettlement is used as a guideline for this framework. A

comparison between the Sierra Leone laws and the international guidelines shows the latter

are more stringent in terms of: replacement value of lost assets, emphasis on compensation

in kind rather than cash, requiring more intensive consultations with Project Affected People

(PAP), recognising informal land owners/users (those who lack legal title), placing special

emphasis on vulnerable groups and providing for a cut-off date for eligibility for compensation.

IFC PS 5 on resettlement and land acquisition requires that any resettlement of households

only occurs if all possible measures have been exhausted to avoid resettlement. Where

resettlement cannot be avoided it must be minimised as far as practicably possible. In line

with IFC PS 5 this RF provides an approach for the development of a Resettlement Action

Plan (RAP) and provides guidelines for compensation of those who will be physically and/or

economically displaced by the Project land acquisition. The RF:





outlines international best practice (IBP) guidelines and national legal requirements for

compensation for loss of property, livelihood and relocation;







describes the social context of those who will be resettled; and







defines the tasks and steps which should be undertaken to plan the resettlement;

including identification of PAPs.



2. RESETTLEMENT PLANNING ACTIONS

The development of a RAP involves the following key actions:





identification and implementation of measures for minimising resettlement;







identification of affected people and assessment of eligibility for compensation;







development of an entitlement framework, outlining compensation criteria and rates;







identification of host areas for resettlement;







identification of procedures for monitoring and evaluating; and







identification of institutional arrangements for the execution of the resettlement and

compensation process.



A census and assets inventory will be undertaken to fully understand the current baseline

U3823_Marampa_Resettlement_Final.docx



September, 2012

Page i of iii



SRK Consulting



Marampa RF – Executive Summary



conditions of PAP and assess potential losses in terms of private and communal assets.

Following the survey a cut-off date will be announced to prevent opportunistic claims for

compensation. An agreement will need to be reached with the local authorities and the

affected communities on the procedures to be used in the event of disputes.

An entitlement framework, which describes the compensation for different impacts, will be

compiled. It will be based on valuation methods derived from both international best practice

and Sierra Leone national laws. Valuation rates should be ratified by a Resettlement Working

Group (RWG), relevant authorities and the affected stakeholders. The valuation process will

take cognisance of the compensation rates used by recent projects in Sierra Leone, such as

the London Mining Project and Addax Biofuel Project.

Resettlement will require the identification of a single large area or multiple smaller host areas

for residential resettlement purposes (for those physically displaced) and identification of

multiple areas of agricultural land for those economically displaced. Ideally for each affected

household several options will be explored. Assessment of different options will be conducted

in consultation with the affected villages and the RWG in terms of legal aspects and perceived

advantages and disadvantages of the various options.

Once the feasibility of the host areas has been established a detailed plan of the host areas

will be developed indicating any existing dwellings and infrastructure as well as the areas

allocated to new dwellings, additional infrastructure, agricultural land and the existing

transport network.

Both internal and external monitoring should be conducted to ensure the resettlement process

meets its set objectives and standards.



3. STAKEHOLDER ENGAGEMENT

Engagement with stakeholders facing involuntary resettlement is one of the main

requirements of IFC PS5. Consultations will comprise initial meetings with PAP at the start of

the resettlement process to gather their inputs and meetings at the completion of the planning

process to disclose the RAP. Consultations with PAP will be ongoing during the planning

process through the RWG and the Community Resettlement Committees (CRCs).

The RWG will comprise representation from MIOL, local government, affected people and

NGOs and is expected to take the lead on negotiations, reaching agreements and resolving

grievances. The CRCs will comprise affected people and be established in each (cluster or

single) village(s). These will assist with the implementation of the census and assets survey

and be involved in the negotiations and identification of the host areas.

The resettlement process will also need an effective grievance mechanism for the PAP to

resolve their issues. The mechanism should work in tandem with the RWG.



4. COMPANY RESPONSIBILITIES

MIOL is responsible for financing the resettlement and compensation activities, managerial

and technical resources and expertise. The Company will develop a Resettlement Unit which

will be managed by the Social Manager who is responsible for reporting to the General

Manager. MIOL may decide to contract out their resettlement responsibilities to an external

contractor with specific expertise in the area.

A detailed budget will be developed. The key components of the budget are:





the cost of replacement land;



U3823_Marampa_Resettlement_Final.docx



September, 2012

Page ii of iii



SRK Consulting



Marampa RF – Executive Summary







the cost of building replacement housing and community structures such as schools,

churches, grain banks, etc;







cash compensation for the crops/ trees and relocation;







the cost of implementing a livelihoods restoration programme for the directly affected

people; and







monitoring and evaluation costs.



The resettlement schedule should be linked with the Project’s construction schedule to ensure

timely availability of land for start of different Project activities.



U3823_Marampa_Resettlement_Final.docx



September, 2012

Page iii of iii



SRK Consulting



Marampa RF – Table of Contents



Table of Contents

1



INTRODUCTION ................................................................................................. 1



2



PROJECT DESCRIPTION .................................................................................. 1



3



POTENTIAL DISPLACEMENT ........................................................................... 2

3.1 Physical Displacement............................................................................................................. 2

3.2 Economic Displacement .......................................................................................................... 2



4



LEGISLATIVE FRAMEWORK ............................................................................ 5

4.1 Sierra Leone Legislation .......................................................................................................... 5

4.1.1 Land Acquisition law ...................................................................................................... 5

4.1.2 The Mines and Minerals Act .......................................................................................... 5

4.1.3 ENVIRONMENTAL AND SOCIAL REGULATIONS FOR THE MINERALS SECTOR . 8

4.2 International Best Practice ....................................................................................................... 8

4.3 Comparison of Sierra Leone Legislation and International Standards .................................... 9



5



SOCIO-ECONOMIC PROFILE OF AFFECTED AREAS .................................. 11

5.1 Demography .......................................................................................................................... 11

5.2 Livelihood Strategies ............................................................................................................. 11

5.3 Access to Land ...................................................................................................................... 11

5.4 Standard of Living .................................................................................................................. 12

5.5 Health..................................................................................................................................... 12



6



RESETTLEMENT PLANNING ACTIONS ......................................................... 12

6.1 Minimising Resettlement........................................................................................................ 13

6.1.1 Project Affected People ............................................................................................... 13

6.1.2 Types of Loss .............................................................................................................. 13

6.2 Eligibility: Cut-Off Date........................................................................................................... 14

6.3 Census and Assets Inventory ................................................................................................ 14

6.3.1 Census ........................................................................................................................ 14

6.3.2 Assets Inventory .......................................................................................................... 14

6.3.3 Census and Inventory Asset Methodology .................................................................. 15

6.4 Entitlement Framework .......................................................................................................... 16

6.4.1 Valuation ...................................................................................................................... 16

6.4.2 Compensation for Loss of Homesteads and Fixed Structures .................................... 16

6.4.3 Compensation for loss of Land .................................................................................... 16

6.4.4 Compensation for Crops and Trees ............................................................................ 17

6.4.5 Compensation for Disturbance of Graves and Sites of Cultural, Historical or Religious

Importance................................................................................................................... 18

6.4.6 Compensation for Loss of Natural Resources ............................................................ 19

6.4.7 Compensation for Affected Businesses ...................................................................... 19

6.4.8 Compensation for Loss of Communal Social Infrastructure ........................................ 19

6.5 Identification and Evaluation of Resettlement Sites/host areas ............................................ 20



U3823_Marampa_Resettlement_Final.docx



September, 2012

Page i of ii



SRK Consulting



Marampa RF – Table of Contents



6.6 Support provision ................................................................................................................... 20

6.7 Income Restoration and Sustainable Development Initiatives .............................................. 20

6.8 Vulnerable Individuals and Households ................................................................................ 21

6.9 Community Development Initiatives ...................................................................................... 21

6.10 Resettlement Process ............................................................................................................ 22



7



STAKEHOLDER ENGAGEMENT ..................................................................... 22

7.1 The Resettlement Working Group (RWG) ............................................................................. 22

7.2 Community Resettlement Committees .................................................................................. 23

7.3 Public Consultation ................................................................................................................ 23

7.4 Grievance Mechanism ........................................................................................................... 23



8



COMPANY RESPONSIBILITIES ...................................................................... 24



9



MONITORING.................................................................................................... 25

9.1 Internal Monitoring ................................................................................................................. 25

9.2 External Independent evaluation /audit ................................................................................. 26



10 BUDGET ............................................................................................................ 26

11 TIMING .............................................................................................................. 27

12 CONCLUSION ................................................................................................... 27

13 REFERENCES .................................................................................................. 27



List of Tables

Table 3-1: Approximate area of disturbance by main Project components ............................................ 2

Table 3-2: Villages potentially requiring resettlement ............................................................................. 2

Table 3-3: Villages which will lose access to land/ resources ................................................................ 3

Table 4-1: Comparison of Sierra Leone national legislations and international standards .................. 10

Table 6-1: Types of assets and resources impacted ............................................................................ 13

Table 6-2: Proposed Compensation Rates ........................................................................................... 17



List of Figures

Figure 3-1: Villages affected by land acquisition..................................................................................... 4



U3823_Marampa_Resettlement_Final.docx



September, 2012

Page ii of ii



SRK Consulting (UK) Limited

5th Floor Churchill House

17 Churchill Way

City and County of Cardiff

CF10 2HH, Wales

United Kingdom

E-mail: enquiries@srk.co.uk

URL: www.srk.co.uk

Tel:

+ 44 (0) 2920 348 150

Fax: + 44 (0) 2920 348 199



A RESETTLEMENT FRAMEWORK FOR THE MARAMPA IRON ORE

PROJECT, SIERRA LEONE

1



INTRODUCTION

SRK Consulting (UK) Limited (“SRK”) has been requested by Marampa Iron Ore Limited

(“MIOL”, hereinafter also referred to as the “Company” or the “Client”) to prepare a

Resettlement Framework ”RF” on the Mineral Assets of the Company comprising the

Marampa Iron Ore Project (The Project) located in Sierra Leone. MIOL intends to develop an

open pit iron ore mine in the vicinity of Lunsar. During the development of the Project land

acquisition and resettlement will be required.

This RF provides an approach for the development of a Resettlement Action Plan (RAP) and

provides guidelines for compensation of those who will be physically and/or economically

displaced by the Project land acquisition. This RF:



2







outlines international best practice (IBP) guidelines and national legal requirements for

compensation for loss of property, livelihood and relocation;







describes the social context of those who will be resettled; and







defines the tasks and steps which should be undertaken to plan the resettlement;

including identification of PAPs.



PROJECT DESCRIPTION

2



MIOL has an exploration licence for an area of 305.12 km . The proposed Project

2

footprint/development area is 52.3 km . The Project will be conducted in two stages; Stage

one will involve the construction of facilities to produce 2.5 Mtpa of iron concentrate through

the mining of oxide ore and Stage two will involve the expansion of these facilities and

construction of new facilities to enable the production of up to 15Mtpa of iron concentrate. The

expected life of the mine is a minimum of 14 years.

The construction period for the Project will be approximately 3 – 3 ½ years and during this

time temporary facilities will be provided to house construction personnel. The location of this

site is currently unknown. A fenced construction laydown area will be built in proximity of the

camp to store construction materials. Aside from the construction camp facilities the Project

infrastructure will be developed within the Project exploration limit.



Group Offices:

Registered Address: 21 Gold Tops, City and County of Newport, NP20 4PG,

Wales, United Kingdom.

SRK Consulting (UK) Limited Reg No 01575403 (England and Wales)



Africa

Asia

Australia

Europe

North America

South America



SRK Consulting



3



Marampa RF – Main Report



POTENTIAL DISPLACEMENT

The Project needs to acquire land for the development of MIOL’s mining infrastructure and

operations. As a result local people will be both physically and economically displaced from

the Project area. In line with international standards, any economic or physical displacement

of Project affected peoples (PAPs) requires the application of IFC Performance Standard

(PS5) on land acquisition and involuntary resettlement as well as compliance with Sierra

Leone requirements. According to PS5, involuntary resettlement refers to physical and

economic displacement as a result of Project-related land acquisition and/or restrictions on

land use. Of the total area (2 173 ha) that will be impacted by Project infrastructure,

approximately 89% is currently used for agriculture (Section 7, ESIA).

The scale of displacement is determined by the requirement for land by the main Project

components as presented in Table 3-1. Based on these estimates, the scope of both physical

and economic displacement is described in the following sub-sections.

Table 3-1: Approximate area of disturbance by main Project components

Project component



Disturbed area (ha)



Pits (four open pits)



550



Tailings Storage Facility (TSF)



695



Waste Rock Disposal (WRD)



800



Processing areas



113



Haul roads*



15



Total

*Based on a 10 m wide haul road



3.1



2 173



Physical Displacement

It is estimated that 10 villages will require relocation and will lose some or all access to

agricultural land. Table 3-2 provides information on the villages to be relocated (see also

Figure 3-1). Assuming there is one main structure per household a total of 162 private

structures and some community structures will be affected.

Table 3-2: Villages potentially requiring resettlement

Village Name



Population



Total Number

Households



of



Reason for relocation



Gbese



254



23



Near Run Of Mine (ROM) pad



Konta



146



11



Near Matukia haul road and plant (noise

and dust)



Ma Sesay



7



2



Near Rotret Pit



Mafuri



178



23



On Mafuri Pit



Magbungbu



100



7



On the edge of TSF



Marunku



519



40



On TSF



Maso



175



13



Near Gafal Pit



Matukia



271



19



On Matukia Pit



Rolal c/o Gafal



26



4



Near Gafal Pit



Rosint



104



20



On Mafuri Pit



Total



1780



162



Source: MIOL town population survey 2010 and SRK primary survey 2010



3.2



Economic Displacement

In addition to the above villages, the villages in Table 3-3 below, which are on the outskirts of



U3823_Marampa_Resettlement_Final.docx



September, 2012

Page 2 of 28



SRK Consulting



Marampa RF – Main Report



the Project footprint, may lose access to land and natural resources. Table 3-2 and Table 3-3

indicate that a total of 432 households will be impacted by land acquisition required by the

Project.

Table 3-3: Villages which will lose access to land/ resources

Village



Population



Total Number of Households



Makel



153



18



Mafira



94



15



Magbafat



542



34



Rolal-co-Mafuri



89



9



Monbaia



17



2



Matoko



328



37



Konta Bana



403



34



Manonko



446



31



Molumpo



137



12



Kalangba



133



15



Royema



449



44



Royail



108



12



Konta Loi



37



7



Total



2936



270



Source: MIOL town population survey 2010 and SRK primary survey



U3823_Marampa_Resettlement_Final.docx



September, 2012

Page 3 of 28



SRK Consulting



Marampa RF – Main Report



Figure 3-1: Villages affected by land acquisition



U3823_Marampa_Resettlement_Final.docx



September, 2012

Page 4 of 28



SRK Consulting



4



Marampa RF – Main Report



LEGISLATIVE FRAMEWORK

The Sierra Leone national legislation and IBP for compensation and resettlement are

described in this chapter.



4.1



Sierra Leone Legislation



4.1.1 Land Acquisition law

The Provinces Land Act, Chapter 122 of the Law of Sierra Leone (1960) relates to land

acquisition. Section 4 of the Provinces Act states a non-native cannot own free hold land. A

non-native can lease land in the provinces, but the initial lease cannot be for a period

exceeding 50 years; it can however subsequently be renewed for periods of up to 21 years.

A lease is defined in the Act as “a grant of the possession of land by the tribal authority (now

known as the ‘Chiefdom Council’), as lessor, to a non-native, as lessee, for a term of years or

other fixed period with a reservation of a rent”. The lease agreement is required to state:





the rent;







the term of years;







the purpose for which the land is to be used;







whether the interest is assignable;







whether buildings or permanent structures are to be erected and the rights of the

parties on the expiration/determination of the lease; and







that the rent is subject to review every seven years by the District Officer/Chief

Administration office (when the lease term exceeds seven years).



The lease must be made between the chiefdom council and the lessee. The lease requires

the rent to be split in accordance with the traditional approach of one-third being retained by

the Chief Administrative Officer, one-third being paid to the Chiefdom Council and one-third

being paid to the traditional landowners of the leased land.



4.1.2 The Mines and Minerals Act

The Sierra Leone Mines and Minerals Act 2009 outlines the legislation in terms of occupation

of land, resettlement and compensation. The relevant sections are outlined below:

Section 32

The holder of a mineral right shall not exercise any of his rights under the mineral right, except

with the written consent of the owner or lawful occupier or his duly authorised agent, in

respect of:





any land dedicated as a place of burial or which is a place of religious or other cultural

significance;







any land which is the site of, or which is within two hundred metres or such greater

distance as may be prescribed, of any inhabited, occupied or temporarily unoccupied

house or building;







any land which is within fifty metres or such greater distance as may be prescribed, of

land which has been cleared or ploughed or otherwise bona fide prepared for the

growing of, or upon which there are growing agricultural crops;







any land which is the site of, or within one hundred metres or such greater distance as

may be prescribed, of any cattle dip, tank, dam, or other body of water;







in respect of any land within any township, or within two hundred metres or such



U3823_Marampa_Resettlement_Final.docx



September, 2012

Page 5 of 28



SRK Consulting



Marampa RF – Main Report



greater distance as may be prescribed, of the boundaries of any township, except with

the written consent of the local authority having control over the township.

Section 33





The owner or lawful occupier of any land which within an area that is the subject of a

mineral right shall retain the right to graze stock upon or to cultivate the surface of such

land in so far as such grazing or cultivation does not interfere with the proper use of

such area for reconnaissance, exploration, or mining operations.







The rights conferred by a mineral right shall be exercised reasonably so as to affect as

little as possible the interests of any owner or lawful occupier of the land on which such

rights are exercised consistent with the reasonable and proper conduct of the

operations concerned.



Section 34

1



Subject to the provisions of any law relating to the acquisition of land titles and Section 38,

the holder of a large-scale mining license shall obtain a land lease or other rights to use the

land upon such terms as to the rents to be paid for the license, the duration or the extent or

area of the land to which such license shall relate, as may be agreed between such holder

and such owner or lawful user of the land or failing that, such agreement as may be

determined by the Minister on the advice of the Minerals Advisory Board.

Section 35

1. The holder of a mineral right shall on demand being made by the owner or lawful

occupier of any land subject to such rights pay such owner or lawful occupier fair and

reasonable compensation for any disturbance of the rights of such owner or occupier

and for any damage done to the surface of the land by his operations and shall on

demand being made by the owner of any crops, trees, buildings or works damaged

during the course of such operations pay compensation for such damage subject to the

following:

a)



b)



c)



d)



1



subject to Section 38, payment of rent under the provisions of Section 34 shall be

deemed to be adequate compensation for deprivation of the use of land to which

such rent relates;

in assessing compensation payable under this section, account shall be taken of

any improvement effected by the holder of the mineral right or by his

predecessor in title the benefit of which has or will inure to the owner or lawful

occupier;

the basis upon which compensation shall be payable for damage to the surface

of any land shall be the extent to which the market value of the land (for which

purpose it shall be deemed saleable) upon which the damage has occurred has

been reduced by reason of such damage, but without taking into account any

enhanced value due to the presence of minerals;

no compensation shall be payable to the occupier of a state grant of land in

respect of any operations under a mineral right existing at the date of such grant;

and



See below: Provinces Land Act, Chapter 122 of the Laws of Sierra Leone, 1960. Section 4.



U3823_Marampa_Resettlement_Final.docx



September, 2012

Page 6 of 28



SRK Consulting



Marampa RF – Main Report



e)



no demand made in terms of this subsection shall entitle the owner or lawful

occupier to prevent or hinder the exercise by the holder of a mineral right of his

rights thereunder pending the determination of compensation to be paid:



2. If the holder of a mineral right fails to pay compensation when so demanded under the

provisions of this section, or if the owner or lawful occupier of any land is dissatisfied

with any compensation offered, such compensation may be determined by the Minister

on the advice of the Mineral Advisory Board.

3. A claim for compensation under the provisions of subsection (1) shall be made within a

period of two years from the date when the compensation became due failing which,

notwithstanding the provisions of any other enactment, such claim shall not be

enforceable.

Section 36

1. The Government may, by order published in the Gazette, compulsorily acquire in the

name of the Republic, private land or rights over private land for use by the holder of a

large scale mining licence.

2. Before making an order under subsection (1) the Government shall be satisfied that:

a)



b)



the holder of a large-scale mining licence has taken all reasonable steps to

acquire on reasonable terms by agreement with the owner, the land which he

wishes to use or the right which he wishes to exercise and has been unable to do

so; and

the acquisition of such land or right is necessary for mining purposes or for

purposes ancillary to mining.



Section 37

1. Subject to Section 38, when land is acquired compulsorily pursuant to Section 36, those

persons having an interest in or rights over the land concerned shall be paid adequate

compensation by the holder of the mineral right determined on the same basis as

compensation for disturbance of rights pursuant to Section 35.

2. The holder of a large-scale mining licence shall, before entering into possession for

enjoyment of any land or before exercising any right over the land, make payment of

compensation as determined in accordance with subsection (1) to the person or persons

concerned or if the whereabouts of the person or persons concerned or any of them are

unknown, give such undertakings concerning the payment of compensation as the

Government may require.

Section 38

1. The Minister shall ensure that all owners or lawful occupiers of land who prefer to be

compensated by way of resettlement as a result of being displaced by a proposed

mining operation are resettled on suitable alternate land, with due regard to their

economic well-being and social and cultural value so that their circumstances are similar

to or improved when compared to their circumstances before resettlement, and the

resettlement is carried out in accordance with the relevant planning laws.

2. The cost of resettlement shall be borne by the holder of the mineral right:



U3823_Marampa_Resettlement_Final.docx



September, 2012

Page 7 of 28



SRK Consulting



Marampa RF – Main Report



a)

b)



as agreed by the holder and the owner or lawful occupier of land or by separate

agreement with the Minister, or

in accordance with a determination by the Minister, except that where the holder

elects to delay or abandon the proposed mining operation which will necessitate

resettlement, the obligation to bear the cost of resettlement shall only arise upon

the holder actually proceeding with the mining operation.



3. Subject to this section, the Minister and a person authorised by the Minister may take

the necessary action to give effect to a resettlement agreement or determination.



4.1.3 ENVIRONMENTAL AND SOCIAL REGULATIONS FOR THE MINERALS SECTOR

In 2011 the Sierra Leone government released draft regulations on environmental impact

assessments. Article 34 relates specifically to projects which involve resettlement. This article

states:



4.2







A new inter-ministerial committee entitled the “Resettlement Committee” dealing with

resettlement related issues shall be established in accordance with the provisions

contained in any law relating to the resettlement of local communities and to further

implement the objectives of Section 38 of the Mines and Minerals Act 2009;







Where a Category A project application involves the potential for resettlement, the

Executive Chairman or its Authorised Officer shall refer the Social Impact Assessment

(SIA) and the Social Management Principles (SMP) to the Resettlement Committee for

its consideration;







The Resettlement Committee shall review the SIA, the SMP and the Resettlement

Management Plan (RMP, internationally known as the RAP) in accordance with the

criteria set out in any law relating to the resettlement of local communities and make

recommendations in accordance with the procedures described therein; and







For a Category A project involving potential resettlement the board shall consider the

SIA in the light of comments and recommendations provided by the Resettlement

Committee.



International Best Practice

2



World Bank Operational Policy (OP) 4.12 (World Bank, 2004) is regarded internationally as

the standard for resettlement guidance. The objective of resettlement planning is to avoid

resettlement whenever feasible and to explore all viable alternatives, and when resettlement

is unavoidable, to minimise its extent.

IFC PS5 Land Acquisition and Involuntary Resettlement (IFC, 2012) was developed by the

IFC (as part of the World Bank group) from OP 4.12 and provides internationally accepted

policies and guidelines for resettlement. PS5 is deemed relevant as the Project development

will involve land acquisition and relocation of communities. PS5 applies to both physical and

economic displacement which results from the following land transactions:



2







land rights or land use rights acquired through expropriation or other compulsory

procedures in accordance with the legal system of the host country;







land rights or land use rights acquired through negotiated settlements with property

owners or those with legal rights to the land if failure to reach settlement would have

resulted in expropriation or other compulsory procedures;



(www.worldbank.org) and in the World Bank's Resettlement and Rehabilitation Guidebook.



U3823_Marampa_Resettlement_Final.docx



September, 2012

Page 8 of 28



SRK Consulting



Marampa RF – Main Report







project situations where involuntary restrictions on land use and access to natural

resources cause a community to lose access to resource usage;







certain situations requiring evictions of people occupying land without rights; or







restriction on access to land or use of other resources.



The main objectives of PS5 in relation to resettlement and land acquisition include the

following:





Avoid, or when not possible to avoid minimise displacement by exploring alternative

project designs.







Avoid forced eviction.







Minimise adverse social and economic impacts by:

a)



b)

c)





Prepare a RAP and have it accepted by the relevant authorities prior to implementing

resettlement activities. The RF is a stepping stone towards the RAP which can be

developed once the Project land acquisition impacts are more clearly defined.







Ensure provision of compensation and the restoration of livelihoods of those affected

prior to any actual resettlement. In particular, the policy requires that possession of land

for Project activities may take place only after compensation has been paid, or

alternatively, if adequate guarantees of compensation have been made to the PAP’s

satisfaction. If the latter is chosen, compensation payments must not be delayed once

resettlement has taken place. Resettlement sites, new homes and related

infrastructure, public services and moving allowances must be provided to the affected

persons in accordance with the provisions of the RAP.







Pay attention to the needs of vulnerable groups, generally defined as:

a)

b)

c)

d)

e)

f)

g)

h)

i)



4.3



providing compensation for loss of assets at replacement cost; and ensuring that

resettlement activities are implemented with appropriate disclosure of

information, consultation, and the informed participation of those affected;

improving or at least restoring the livelihoods and standards of living of displaced

persons; and

improving living conditions among displaced persons through provision of

adequate housing with security of tenure at resettlement sites.



those below the poverty line;

the landless;

the elderly;

women and children;

indigenous groups;

ethnic minorities;

orphans;

disabled people, and

other disadvantaged persons.



Comparison of Sierra Leone Legislation and International Standards

This RF is based on both Sierra Leone national laws on mining projects, and resettlement and

international best practice guidelines set by the World Bank and IFC. A comparison between

the Sierra Leone laws and the international guidelines is presented in Table 4-1 below. In

many areas the national laws and international guidelines are similar. In cases where one set

of guidelines is more stringent than the other, such as in the cases of resettlement assistance,

monitoring, consultation with directly affected parties, payment of compensation for land and



U3823_Marampa_Resettlement_Final.docx



September, 2012

Page 9 of 28



SRK Consulting



Marampa RF – Main Report



special provision for vulnerable groups, the more stringent should be followed. In addition to

the above, IFC standards make provision for a cut-off date for claiming eligibility for

compensation.

Table 4-1: Comparison of Sierra Leone national legislations and international standards

Area



Sierra Leone legislation



IFC PS 5



Preferred approach



Calculation of

compensation



Negotiated



Replacement costs or more



Replacement costs or

more



Compensation



Compensation can be in any

form



Strongly recommends in-kind

compensation, (replacement

housing and replacement land

especially for those with land

based livelihoods)



Recommend in-kind

compensation, but is

negotiable



Consultation with

PAP and host



Provides for participation of

local authorities insofar as

negotiation for compensation

arises



All affected parties should be

involved in planning and

implementing resettlement

programmes. Displaced

persons and host areas are

provided timely and relevant

info



All affected parties and

stakeholders need to be

consulted



Cut-off date



No moratorium provided by

the Government



If no moratorium is provided by

the Government, the Project

should establish and

disseminate a cut-off date. No

compensation is provided for

those affected after the cut-off

date



A cut-off date needs to

be established and

disseminated. No

compensation for PAPs

after cut-off date



Eligibility for

compensation

criteria



Those who have legal rights

to the land and those who do

not have formal legal rights

but have claim to such land or

assets provided that such

claims are recognised under

the law



All those who are physically

and/or economically-displaced,

including those without legal

status to occupy land



All those who are

physically and/or

economically-displaced,

including those without

legal status to occupy

land



Monitoring



No specific legislation



The Project is responsible for

monitoring of the resettlement

activities



The Project is

responsible for

monitoring of the

resettlement activities



Payment of

compensation

for land



Land lease is paid to local

authorities / not directly to the

landowners



Payment should involve

directly affected parties



Paid to local authorities

but with mechanism to

safeguard

compensation of directly

affected



Resettlement



Optional depending on choice

of affected



Recommended if affected

parties’ livelihoods are land

based



Recommended if

affected parties’

livelihoods are land

based



Resettlement

assistance



No specific legislation



Compulsory



Compulsory



Resettlement

decision



Negotiated between Project and

affected parties. If negotiation is

not successful forced removal is

possible



Negotiated between Project and

affected parties



Negotiated between

Project and affected

parties



Vulnerable

groups



No specific provisions for

vulnerable groups



Require special attention and

monitoring of vulnerable

groups.



Special attention for

vulnerable groups

required



U3823_Marampa_Resettlement_Final.docx



September, 2012

Page 10 of 28



SRK Consulting



5



Marampa RF – Main Report



SOCIO-ECONOMIC PROFILE OF AFFECTED AREAS

A short description of the socio-economic baseline of the Project area is presented to

contextualise the resettlement process. A detailed description of the social baseline conditions

of the Project area can be found in the Social Baseline report (SRK, 2012).

The Project is located in the northwest of Sierra Leone within the Port Loko District which

2

covers an area of 5,719km , has a population of approximately 478,000 and has ten

chiefdoms. The Project is located across three chiefdoms – Marampa, Masimera and Maforki.

The Project is situated in a rural area but close to the town of Lunsar, which is the largest

town in the area and is an important administrative, social and commercial centre for the local

people.



5.1



Demography

In the Project area people are settled in villages differing greatly in size from as small as 2 to

259 households. The average household per village is 38 and the average village population

is 344. There is a slight gender imbalance in the local population with 49.2% being male and

50.8% female. The household survey indicated that, 42% of the population is below the age of

15; 54% between 15 and 64, and 4% over 64. The main ethnic groups in area are the Temne,

followed by the Fula and the Susu, The population is largely Muslim.



5.2



Livelihood Strategies

The most important livelihood strategy in the Project area is subsistence farming, It is

practiced by 82% of households (SRK Household survey, 2011). The sale of surplus crops is

the most readily accessible income for most villagers. Some of the other important economic

activities in the district are small scale fishing, small businesses, small scale diamond mining,

charcoal production making and animal husbandry.

Access to natural resources is also important to villagers who are reliant on the land for

access to construction materials, firewood, wild foods and plants.



5.3



Access to Land

Access to land for farming and collection of natural resources is important for the livelihoods

of the local population. In Sierra Leone, there are two main systems of land holding: freehold

rights in the Western Area and a customary system in the provinces where land is principally

owned and controlled by families or traditional leaders.

In the Project area villages the customary land tenure rules, which were established in 1965

under Section 76 (1) of the Courts Act, apply. However, the validity of customary law is

dependent on its compatibility with statutory law. The following statutes are relevant to

customary landholding practices in Sierra Leone:





The Provinces Lands Act (Cap 122).







The Chiefdom Councils Act – (Cap 61).







The Local Government Act – 1994.



According to customary law, families, chiefdoms and communities hold the ownership of

property and therefore a plot of land can never be owned freehold. Land always belongs to

the communities or families/clans and is used by individuals under different forms of tenure

laid out by customary law. This principle is established by the Chiefdom Councils Act as well



U3823_Marampa_Resettlement_Final.docx



September, 2012

Page 11 of 28



SRK Consulting



Marampa RF – Main Report

3



as by Section 28 (d) of the Local Government Act 1994 (Ajei, 2008) . The Paramount Chief is

the custodian of the land on behalf of the entire chiefdom and ultimately grants access to land

to households besides mediating any land disputes.

In the context of resettlement, a national policy states that, as much as possible, land disposal

or acquisition of any kind should not render a land title holder (including customary land

ownership), his kith and kin and descendants completely landless, nor tenants on the land to

which they originally had legitimate title, save in the case of compulsory acquisition in the

public interest.



5.4



Standard of Living

The standard of living in the Project area is poor with only 8% of families, included in the SRK

household survey conducted in terms of the ESIA baseline, receiving a stable and regular

income. 80% of houses in the Project area consist of clay and earth. Houses typically have

two or three internal rooms and an outdoor cooking area. Approximately 15% of households

do not have bathrooms. 71% of households use paraffin lamps for lighting and 94% of

households use wood for cooking. Water quality in the study area was observed to be poor

and wells often dry out, causing villagers to have to walk long distances to collect water. The

SRK household survey also revealed that 81% of households deposit waste in areas close to

their homesteads.



5.5



Health

Health conditions are poor in the area and life expectancy in the district is 49 years. Prevalent

diseases in the area include malaria, diarrhoea, pneumonia/ respiratory infections and

malnutrition. Incidences of Sexually transmitted diseases and HIV/AIDS are on the increase.

The district has nine community health centres, four hospitals, 23 community health posts and

58 maternal child health posts. In addition to the health centres, there are six peripheral health

units (“PHU’s”) in Marampa Chiefdom, which provide primary health care. However the units

are understaffed and running costs are high. Education

In line with poverty and poor health conditions, education and literacy levels are also poor in

the area with 47% of people being illiterate (SRK Household survey 2011). Local people

understand the importance of education; however education is a risky investment for families

as it is expensive and there is no guarantee families will see a return on their investment. Very

few people in the area complete secondary school.



6



RESETTLEMENT PLANNING ACTIONS

To develop a RAP the following actions will be undertaken;





identification and implementation of measures to minimise resettlement;







identification of affected people;







assessment of eligibility for compensation;







execution of a census and assets register;







development of an entitlement framework, outlining compensation criteria and rates;







identification of host areas for resettlement;







development of procedures for resettlement and compensation;



3



Ajei, M.O (2008). Government of Sierra Leone/World Bank Mining Sector Technical Assistance

Project Resettlement Policy Framework Final Draft. Nimba Research & Consulting Co. Ltd.



U3823_Marampa_Resettlement_Final.docx



September, 2012

Page 12 of 28



SRK Consulting



6.1



Marampa RF – Main Report







identification of procedures for monitoring and evaluating the resettlement process; and







identification of institutional arrangements for the execution of the resettlement and

compensation process.



Minimising Resettlement

IFC PS 5 on resettlement and land acquisition requires that any resettlement of households

only occurs if all possible measures have been exhausted to avoid resettlement. Where

resettlement cannot be avoided it must be minimised as far as practicably possible. The

location of open pits is determined by the ore body. The relocation of the villages that are

located directly on the proposed open pits or in close proximity to them therefore cannot be

avoided. However the location of other infrastructure such as the TSF, the WRD and the

plant has, together with other technical factors, been determined so as to minimise any direct

impacts on existing villages. The alignment of the haul road also takes into consideration the

location of existing villages. Further exploitation of measures to minimise resettlement will be

undertaken during the RAP process.



6.1.1 Project Affected People

Project affected people (PAP) can be divided into two categories:





Affected households: households are affected if one or more of the household

members are impacted by physical or economic displacement including loss of assets,

land and property, and/or access to natural/economic/social resources.







Host area households: host area households refer to those households in the area(s)

where displaced peoples will be resettled. These area(s) will be selected prior to any

resettlement based on thorough investigation of suitable options. Households in the

selected host area(s) may be impacted by increased population pressure on social

and/or natural resources due to.



6.1.2 Types of Loss

It is anticipated that PAPs are expected to experience a loss or disruption of access to the

assets and resources outlined in Table 6-1. A detailed description of the number and type of

affected people in terms of the various eligibility criteria will need to be provided in the RAP.

Table 6-1: Types of assets and resources impacted

Category of loss



Description



Homesteads



It is estimated 10 villages (comprising 162 households, 1,780 people) within will

need to be entirely resettled.



Agricultural Land



It is estimated the 10 villages to be resettled will also lose their agricultural land.

In addition a further 13 villages (270 households (or 2,936 people)) may

experience partial loss of access to land which is currently being used for

agricultural purposes.



Sacred sites



Sacred sites including places/ features such as forests and bushes which are

important for customary rituals and culture, graves and cemeteries may also be

lost (or access to them may be disrupted).



Natural resources



Areas used by local inhabitants for harvesting of natural resources including

hunting, collecting of firewood or wild plants will be lost. Approximately 432

households will lose access to land based resources.



U3823_Marampa_Resettlement_Final.docx



September, 2012

Page 13 of 28



SRK Consulting



6.2



Marampa RF – Main Report



Small enterprises



Small businesses such as shops and kiosks which are operating in directly or

indirectly affected villages may experience loss of customer base or suppliers.



Social

infrastructure



Communal infrastructures in the 10 directly affected villages including schools,

health centres, religious and community buildings will be lost. This may also

affect neighbouring villages that are not relocated but share the use of those

resources.



Access routes



Access routes to natural resources, markets and other villages may be impacted.



Eligibility: Cut-Off Date

Eligibility for compensation is defined in terms of PAPs affected by the categories of loss

described above and whether they were present before an eligibility cut-off date. A cut-off

date signifies a date after which any building work or improvements on affected land will not

be compensated for. This includes new households moving into the area or current

households improving their houses. This cut-off date needs to be made public to all those

affected through a public consultation process and be well advertised throughout the Project

area. Sierra Leone national law does not make provision for the declaration of a cut-off date

(or moratorium); however it is required by IFC PS5.

MIOL will be responsible for identifying and effectively publicising the cut-off date. An

agreement will need to be reached with the local authorities and the affected communities on

the procedures to be used in the event of claims being submitted after the cut-off date, as well

as in the event of counter-claims and disputes.



6.3



Census and Assets Inventory

To develop the RAP a thorough understanding of the existing socio-economic context of the

affected households and an inventory of their assets are required. The process for achieving

this is set out in the following sections.



6.3.1 Census

A census will be undertaken of all households which will lose access to land for agriculture

and/or be physically displaced to fully understand their current baseline conditions. The

census should include:





demographics of each household;







illness amongst household members in the past year;







deaths and births within the household in the past year;







usage of communal social infrastructure;







access to land and access to resources on communal land;







livestock ownership;







household economic activities;







household income and sources;







details of loans / savings;







expenditure;







food availability, and







ownership of a predetermined collection of material possessions to be used as

indicators in ascertaining the socio-economic status of the households.



6.3.2 Assets Inventory

U3823_Marampa_Resettlement_Final.docx



September, 2012

Page 14 of 28



SRK Consulting



Marampa RF – Main Report



Inventories will need to be made of affected household and of communal assets. Aspects for

inclusion are outlined below.

Individual Household Assets

The assets inventory will record both permanent and temporary losses of physical

infrastructure and natural resources including:





homesteads and homestead structures including the number of buildings their size and

the condition (photographic evidence should also be taken);







family business-related structures;







graves associated with the household;







agricultural fields owned/rented/ leased, or given for use;







crops; and







economically beneficial trees, within the homestead and plantations.



The census and assets inventory provides a register of the legitimate beneficiaries within the

Project area prior to the cut-off date and also provides a baseline for monitoring.

Communal Infrastructure

An inventory of communal infrastructure in the affected area will also be required. This should

include:





schools;







health centres;







community toilets;







market areas;







churches/ religious buildings;







grain banks;







food drying areas;







sites of cultural or historical importance.







administrative buildings; and







recreational buildings or sports facilities.



6.3.3 Census and Inventory Asset Methodology

The following steps will be undertaken in the execution of the census, household assets

survey and community infrastructure audit:





recruitment and training of local fieldworkers;







design and piloting of the census and asset survey;







meeting with PAPs to explain the purpose and method of the surveys;







provision of an ID number to all households/individuals involved in the census. The

household head will be photographed with the ID number in front of his homestead

/affected structures/area;







photographing of all structures, with GPS coordinates of the main building;







interviewing the PAPs. Ensure the household head is present during the interview and

that he/she countersigns the inventory sheets as proof that he/she agrees to the assets

that have been recorded (Note: the signature of the household head does not signify

acceptance of a compensation package only recognition that the data were correct

when collected);ensure a community representative, also signs the inventory sheets as

a witness to the recording exercise, and



U3823_Marampa_Resettlement_Final.docx



September, 2012

Page 15 of 28



SRK Consulting







6.4



Marampa RF – Main Report



entry of data from the census and assets register and photographs in an electronic

database for record keeping and analysis.



Entitlement Framework



6.4.1 Valuation

Valuation will be based on both international best practice guidance and Sierra Leone national

law. Valuation rates and the process should be ratified by a Resettlement Working Group

(RWG) (see Section 7.1 below), relevant authorities and the affected stakeholders. The

valuation process should take cognisance of the compensation rates used by the London

Mining Project due to its close proximity.



6.4.2 Compensation for Loss of Homesteads and Fixed Structures

There are two options to compensate PAPs for loss of homesteads and fixed structures.

These are:

Option 1: Compensation for all homestead structures is provided in cash, that covers

replacement costs of materials, cost for transportation away from current homestead to the

new home and cost for labour to construct the new homestead.

Option 2: Compensation is provided by replacement (to the same or better standard) of the

primary structures of the homestead in an identified host area. It is recommended that a local

contractor is hired to build the houses and that local labour is employed, whilst MIOL ensures

quality control. In this option cash compensation will be given for secondary structures that

will not be replaced. Any of the structures which can be deconstructed and removed are

allowed to be taken to the new homestead. MIOL will undertake the transportation of

removable items to the new home.

Option 2 is the recommended option. In accordance with IFC PS 5 cash compensation for

structures is discouraged to avoid the risk cash is not spent on housing (which would leave

households without shelter). Compensation should be provided for loss of materials in the

case of incomplete structures but no compensation will be offered for abandoned structures.



6.4.3 Compensation for loss of Land

The Project will require the lease of land, which will be guided by Sierra Leone’s Provinces

Land Act, Chapter 122 of the Laws of Sierra Leone, 1960 (section 4.1.1). A land lease

contract will be required for the affected land in the Marampa, Maforki and Masimera Districts.

Lease rent will be paid. Government guidelines are US$3.60 per acre, with one third paid to

the Chiefdom council, one third to the District Council and one third to the respective

traditional landowners. It is the task of the District Council to pay out the fees to the respective

parties.

The process of paying out compensation for loss of land can be complex because:





land is not individually owned rather it belongs to family clans/ villages;







land has generally not been surveyed and no records of ownership exist and disputes

over land are common;







people using the land are either a member of a landowning family or rent land from the

land owning family, therefore tenants will be a vulnerable group as they will not receive

lease rent, and







land lease infers that land will be returned on completion or termination of the lease

agreement. In some instances land will not be returned and this should be taken into



U3823_Marampa_Resettlement_Final.docx



September, 2012

Page 16 of 28



SRK Consulting



Marampa RF – Main Report



account.

Affected households will be provided assistance to access alternative land. Livelihood

restoration programmes to enhance agricultural productivity will also be included in the RAP.



6.4.4 Compensation for Crops and Trees

Standing crops will be compensated for. The main crops are rice, cassava, groundnuts, maize

and sweet potatoes. Only exotic trees belonging to households or communities which have

been specifically planted and are used for food or other economic benefits will qualify for

compensation. The most common trees used for food and as a source of income are palm

trees, mangoes, bananas, oranges and pineapple.

The quantity of affected crops needs to be measured and number of trees counted by a team

including the affected person, a company representative, a representative of the Ministry of

Agriculture and a representative of the local chiefdom. The numbers of trees and areas of

crops will be included in the assets inventory.

According to IFC PS 5, crops and trees need to be compensated in line with the market rates.

The Government of Sierra Leone provides compensation rates, but these were determined in

2006 and are regarded as out-dated (see Table 6-2). It is therefore recommended the

compensation rates are guided by the recent rates identified for the Addax Biofuel Project in

Sierra Leone (See Table 6-2) and those use by London Mining and AML (if these can be

obtained from the relevant companies).

Table 6-2: Proposed Compensation Rates

Government Value 20062007 (SL Leones)



Item



Value 2010 (Addax

Project) (SL Leones)



Banana tree



20,000



26,620



Bread fruit tree



40,000



53,240



Cabbage ½acre



35,000



46,585



Cashew tree

Cassava ½ acre

Cassava ½ acre immature



50,000



148,000



150,000



350,000



50,000



175,000



Cassava not dense - grown in heaps ½ acre

mature



200,000



Cassava not dense - grown in heaps ½ acre

immature



100,000



Citrus tree



50,000



72,500



Cocoa tree



45,000



73,500



Coconut tree



40,000



73,500



Coffee 1 acre



35,000



46,585



Cucumber ½ acre



30,000



39,930



Economic tree (Timber individually owned)



20,000



54,400



150,000



199,650



Guava ½ acre



15,000



19,965



Hot pepper ½ acre



30,000



39,930



Kola nut tree



40,000



76,400



Krain krain ½ acre



50,000



66,550



Lettuce ½ acre



35,000



46,585



100,000



133,100



50,000



66,550



100,000



133,100



Groundnut ½ acre



Maize ½ acre

Mango tree improved

Millet ½ acre



U3823_Marampa_Resettlement_Final.docx



September, 2012

Page 17 of 28



SRK Consulting



Marampa RF – Main Report



Government Value 20062007 (SL Leones)



Item



Value 2010 (Addax

Project) (SL Leones)



Oil palm tree



25,000



33,275



Oil palm tree improved



40,000



57,000



Okra ½ acre



40,000



53,240



Paw paw tree



10,000



13,310



Pear / avocado tree



60,000



79,860



1,000



1,331



Plantain tree



20,000



26,620



Plum tree



50,000



66,550



Pineapple plant



Pumpkin ½ acre



30,000



39,930



Rice (inland valley swamp) ½ acre



200,000



266,200



Rice (upland) ½ acre



200,000



266,200



Sweet pepper ½ acre



36,000



47,916



Tomatoes ½ acre



35,000



46,585



Water melon ½ acre



40,000



53,240



Note: At the time of the writing of the report US$1 = 4,368 SLL



The crop/tree owner will be paid the agreed rate multiplied by the acres of crops/number of

plants/trees lost. This compensation fee is a one off payment. However the loss of fruits over

a period of time, until new seedlings are of fruit bearing age needs to be taken into account for

the calculation of the compensation fees. If the farmer does not own the land, the crop

compensation will still be paid to the farmer while any land compensation is paid to the owner

of the land. In line with IFC PS5 the Company will provide replacement seedlings to replace

the trees lost. According to IFC PS5 replacement seedlings will only be provided for fruit/nut

trees and not for timber trees.



6.4.5 Compensation for Disturbance of Graves and Sites of Cultural, Historical or

Religious Importance

There are three options for compensation for disturbance of graves:





homesteads may choose to re-bury remains of the deceased on or near their

resettlement plot,







communal re-burial may be arranged with local entities (municipality, and traditional

leaders, as well as religious leaders). In such cases an appropriate piece of land is to

be identified in consultation with the local authorities, and







homesteads may choose not to relocate graves, but may instead hold a ceremony in

accordance with local customs.



In the first two options appropriate timing and arrangements for the relocation and re-burial of

the deceased will be agreed upon with all stakeholders. The Company will meet associated

costs, which may include:





exhumation including permit (if required), transport and re-burial (re-interment) of the

deceased;







provision of a coffin from an approved supplier;







provision of a flat rate per grave to satisfy any customary cost;







all works associated with the burial; and







all reasonable costs associated with a ceremony if not relocating the grave.



Affected households/religious leaders are responsible for organising the appropriate

ceremonies in accordance with their religious beliefs and/or customs.

U3823_Marampa_Resettlement_Final.docx



September, 2012

Page 18 of 28



SRK Consulting



Marampa RF – Main Report



In terms of communal sacred sites or cultural heritage, a process for appeasement of

disturbance of the site and potentially the establishment of a new site will be negotiated with

affected communities. MIOL will cover the cost of obtaining the new site and the appropriate

ceremonies. Local communities and religious leaders will be responsible for organising the

ceremonies.



6.4.6 Compensation for Loss of Natural Resources

The extent and nature of loss of access to different types of natural resources will be

assessed in the RAP census and compensation strategies for each type of loss negotiated

with local communities and in the RWG. These may include:





development of wood lots in case of loss of timber and firewood;







development of nurseries for lost plants (especially wild herbs);







development of alternative livelihoods for those relying on natural resource production;

and







identification and arrangement of alternative grazing areas.



6.4.7 Compensation for Affected Businesses

Loss of local businesses will be compensated. For the valuation of the loss of an enterprise its

function, intensity of use (average monthly income), location, importance and market

catchment areas will be determined. Valuation will be based on the cost of re-establishing the

commercial activity at a new location. This may include costs for:





acquisition of new land;







material and construction costs of replacement structures;







compensation for lost stock;







compensation of lost income during period of closure during resettlement; and







compensation for loss of staff wages.



6.4.8 Compensation for Loss of Communal Social Infrastructure

The most important requirement of the IFC PS 5 is to ensur resettled households are not

worse off after the resettlement process. This may require the upgrading of existing social

infrastructure or building of new infrastructure in the host areas. Infrastructure should be equal

to or better than that being replaced. Community structures or resources to be upgraded or

developed may include:





health centres (including the clinic at Marunku);







community halls;







markets;







schools;







religious buildings;







village grain banks and drying floors or structures, and







wells/boreholes.



The valuation of community infrastructure and resources will require consultation with

community leaders, committees or individuals that have responsibility for community

structures of both the resettled community and the host community. The valuation will be

based on replacement costs of materials, buildings costs and the acquisition of additional

land. Not all community structures will need to be replaced - religious buildings are often not

rebuilt by companies, however compensation will be provided.

U3823_Marampa_Resettlement_Final.docx



September, 2012

Page 19 of 28



SRK Consulting



6.5



Marampa RF – Main Report



Identification and Evaluation of Resettlement Sites/host areas

Resettlement will require the identification of a single large area or multiple smaller areas for

residential purposes (for those physically displaced) and identification of multiple areas of

agricultural land for those economically displaced. Ideally for each affected household several

options will be explored. In order to assess the feasibility of different options the following is

required:





assessment of land ownership and tenure rights;







assessment of the need for improvement of infrastructure to accommodate additional

inhabitants;







assessment of the impact of resettlement on small businesses in resettled communities

and host community;







assessment of available agricultural land in the vicinity of the resettled communities;.







assessment of access to natural resources ;







assessment of access to livelihood strategies, and







assessment of disturbance of community and family support networks.



The assessment should be conducted:





in consultation with the affected villages, and







in consultation with the RWG in terms of legal aspects, perceived advantages and

disadvantages of the various options.



The process will involve:





pre-selection of candidate sites;







visits to pre-selected resettlement sites with affected community members;







selection of preferred sites in collaboration with relevant authorities;







conducting an Environmental and Social Impact Assessment (ESIA) to assess the

impacts on the selected sites, and







validation of the choice in general community meetings;



Once the feasibility of the host areas has been established a detailed plan for the host areas

will be developed indicating any existing dwellings and infrastructure as well as the areas

allocated to new dwellings, additional infrastructure, agricultural land and the existing

transport network.



6.6



Support provision

IFC PS 5 states that additional support may be required for PAPs during the resettlement

period. Depending on the timing of the resettlement, it is possible that households will not be

able to farm during a particular period. Others may need time to develop new livelihood

strategies. These households will require support and support packages will be developed

together with the affected households. It is recommended that this is done in cooperation with

competent organisations and in consultation with the RWG.



6.7



Income Restoration and Sustainable Development Initiatives

Besides the loss of assets, resettlement may lead to permanent disruptions of income-earning

or subsistence capacity. IFC PS 5 resettlement guidelines require that if Project-related

impacts are significant (with a 10% or greater loss), livelihood restoration needs to be

included in the RAP.

To restore livelihoods for the affected people, there may be a need to assist with the



U3823_Marampa_Resettlement_Final.docx



September, 2012

Page 20 of 28



SRK Consulting



Marampa RF – Main Report



preparation of new land and the provision of agricultural support and extension programme.

This may include:





provision of training on improved agricultural techniques, and







support for the purchase of agricultural equipment, fertilisers and improved seeds.



Skills replacement training will be provided for households in which the continuation of an

agricultural lifestyle is not possible or desired. The primary objective of the skills replacement

training will be to teach skills that could be of value in the local economy and could replace

agriculture in terms of income generated. Potential skills to be taught include building;

carpentry; plumbing; welding, Partnerships can be established with NGOs and other relevant

agencies to run the skills training.



6.8



Vulnerable Individuals and Households

Vulnerable individuals, households and groups need to be identified and receive specific

attention throughout the RAP in line with international best practice. Vulnerable groups are

those who are likely to be more affected by resettlement than the rest of the population as

they are less likely to have the capacity to deal with negative impacts, and to benefit from

enhancement measures. The groups listed below are generally defined as vulnerable;

however the Project should seek to identify specific vulnerable groups in their area:





the extremely poor (those below the general level of poverty which exists in the area);







female or child headed households;







households without access to land;







elderly, specifically households where no members are below the age of 60;







disabled or sickly people or those who cannot work land;







internally displaced and orphaned children, and







groups suffering social or economic discrimination such as indigenous groups.



It is often observed that vulnerable people do not participate in community life to the same

extent as the general population and therefore may be invisible to the Project. Efforts need to

be made to identify the vulnerable people. Vulnerable groups should be given specific

assistance at all stages of the Project but in particular during the resettlement process. These

groups should also be monitored and offered further assistance once they have been

compensated/ resettled. Specific assistance for vulnerable groups may take one or several of

the following forms:



6.9







provision for separate and confidential consultation;







priority in site selection in the host area;







relocation near to kin and former neighbours;







assistance with gathering materials from their home which can be moved to the new

site;







assistance with moving to the new site;







assistance with building structures and collection of materials;







assistance with compensation payment procedure;







priority access to mitigation and development assistance during the post-resettlement

period, particularly if the support networks that the vulnerable person was relying on

have been affected, and







access to health care if required during the resettlement and transition periods.



Community Development Initiatives



U3823_Marampa_Resettlement_Final.docx



September, 2012

Page 21 of 28



SRK Consulting



Marampa RF – Main Report



To comply with international best practice, Projects which involve involuntary resettlement either physical or economic - should seek to implement community development initiatives.

The aims of community development initiatives are to:





stimulate long-term community, economic and social development programmes; and







assist in building relationships between the company and other community

development programmes running in the Project area of influence.



Community Development Plans (CDP) should be developed using the data collected during

the census and as part of the social impact assessment process. Community development

benefits will apply to everyone living within the Project area of influence; however people

directly impacted by physical and or economic displacement and host communities should

receive priority in terms of development initiatives.



6.10 Resettlement Process

When relocated families take occupation of the new homestead the following points are

recommended best practice:



7







a reasonable and agreed time period should be allowed prior to relocating people so

they have time to salvage building materials from their old homestead;







transport should be provided for each homestead to move themselves and their

belongings to the new home including livestock, food and personal furniture,







households need to sign a document to forego all rights to the old homestead once

they have collected all of their belongings. The old residence should be demolished as

soon as possible to remove the risk of squatters; and







a company representative should visit households a month after they have moved in to

assess the new structure and note potential defects and arrange for repairs, the

company should provide a 5 year structural warrantee for the dwelling to cover design,

workmanship and material defects.



STAKEHOLDER ENGAGEMENT

Engagement with stakeholders facing involuntary resettlement is one of the main

requirements of IFC PS5. PAPs should have ample opportunity to participate in the planning

and execution of the resettlement programme which affect them.

Engagement should include a two way exchange of information allowing the Project staff to

provide the PAPs with timely information but also for the Project staff to listen to stakeholders’

concerns and opinions on the resettlement plan. The stakeholder engagement approach

should build upon the existing Stakeholder Engagement Plan (SEP) prepared by SRK for the

ESIA process.



7.1



The Resettlement Working Group (RWG)

The Project will assist in the development of a RWG to take charge of the resettlement

preparation and execution. The RWG should consist of:





a representative of MIOL;







representatives from relevant provincial government departments;







representatives from the traditional and community leadership;







representatives of directly affected land owners;







representatives of directly affected tenants;







a representative of local women’s organisations;



U3823_Marampa_Resettlement_Final.docx



September, 2012

Page 22 of 28



SRK Consulting



Marampa RF – Main Report







a representative of local youth organisations;







relevant local NGOs;







a representative of the District Council, and







a representative of the chiefdom council;



The main objectives of the RWG are:



7.2







to identify and approve the host area(s) where people will be resettled to;







to act as the primary channel of communication between the various stakeholders

involved in the resettlement process particularly between PAPs and the Project;







to act as a forum at which MIOL can consult on various resettlement aspects, i.e.

debate the Entitlement Framework (EF) that is generated for the RAP, and







to deal with grievances that arise during the resettlement process.



Community Resettlement Committees

Community Resettlement Committees (CRCs) will also need to be established in each

(cluster or single) village(s). The CRC should be made up of:





the village chief(s);







a representative of the tenants of the village;







a representative of the landowners of the village;







a representative of the youth organisation of the village, and







a representative of women’s organisations of the village.



The CRCs should meet on a regular basis to ensure the timely and effective flow of

communication between the Project and the communities. The CRCs should also assist with

the implementation of the census and assets survey and be involved in the negotiation of

identifying host areas.



7.3



Public Consultation

In addition to the RWG and the CRCs regular meetings, public meetings should take place

with the PAPs in the local areas. An initial meeting will need to take place before the RAP is

developed to ensure people are aware of the resettlement process. In this initial meeting

PAPs should be informed about the census and assets inventory which all households will

need to complete.

A second round of public meetings should occur after the RAP has been developed. This

second round of meetings is to disclose the RAP to the PAPs. Appropriate documentation

should be provided to PAPs and they should be allowed time to read the information and be

given opportunity to express their concerns and opinions.



7.4



Grievance Mechanism

IFC guidelines require a grievance mechanism, which should be an effective, accessible

method for individuals or groups of PAPs to raise grievances with the Project through an

official channel. PAPs should be able to raise grievances during community meetings, through

the Company community liaison officer or the RWG or CRC. The grievance mechanism

should follow the steps outlined below:

Step 1: Receipt of Grievance

Grievances received through any of the channels outlined above should be passed to the

community liaison officer who should enter the complaints into a complaints register. There



U3823_Marampa_Resettlement_Final.docx



September, 2012

Page 23 of 28



SRK Consulting



Marampa RF – Main Report



should be a register in each of the community liaison offices around the Project area (if more

than one) and grievances should be entered in English and Krio. Once the grievance has

been submitted a receipt should be supplied to the complainant.

Step 2: Assessment of the Grievance

The community liaison officer should initially attempt to resolve the grievance locally. If not

able to resolve the grievance it should be communicated to the Project’s social manager.

Step 3: Acknowledgement of Complaint/Grievance

The decision on how the issue will be resolved should be communicated to the complainant

both verbally and in writing. It should also be explained what the expected time frame for

resolving the grievance will be.

Step 4: Investigation and Resolution of Grievance

The Project should undertake an internal investigation to determine the underlying cause of

any grievance and if required make changes to internal systems to prevent the grievance

reoccurring. In order to fully investigate and resolve the grievance it may be necessary for the

Project to hold a meeting with the complainant. This should be done in consultation with the

RWG.

Once the investigation has been completed and necessary measures been taken, the results

will be communicated to the complainant and entered in the register. The complainant will be

asked to sign that he/she accepts as the ‘solution’.

The action to correct the grievance should be verified by the community liaison officer as

appropriate to the complainant. If the complainant disagrees with the decided course of

action, further corrective actions should be agreed and carried out by MIOL, or the

complainant should be advised of the next step in logging his/ her grievance e.g. elevating the

complaint to local or central government. If a complainant decides to open a legal case

against the company, MIOL should not obstruct this decision.



8



COMPANY RESPONSIBILITIES

In addition to the RWG and CRC, the Company has specific responsibilities for ensuring the

RAP is developed and executed in line with Sierra Leone national law and international best

practice. MIOL is responsible for all financial responsibilities, managerial and technical

resources and expertise. The Company should develop a Resettlement Unit which should be

managed by the Social Manager who is responsible for reporting to the General Manager.

MIOL may decide to contract out their resettlement responsibilities to an external contractor

with specific expertise in the area, in which case the steps listed below will be undertaken by

the contractor, who will report to the Social Manager. During development of the RAP, MIOL

(or the contractor) will:





develop a Terms of Reference for resettlement;







identify PAP who qualify for compensation;







develop an entitlement framework;







arrange for a cut-off date for compensation;







conduct the census and develop an assets register;









develop and execute a stakeholder engagement plan for the resettlement planning;

identify any specific vulnerable groups within the Project area (see 7.73);



U3823_Marampa_Resettlement_Final.docx



September, 2012

Page 24 of 28



SRK Consulting



Marampa RF – Main Report







coordinate the selection of alternative resettlement sites;







Project manage the development of the land-use plan for any host resettlement areas;







present, discuss and obtain approval for any developed land-use plans with relevant

government authorities;







ensure the RWG remains in operation after the RAP is finalised and until the Project is

implemented;







provide a representative to be part of the RWG meetings, and







provide administrative, managerial and technical support as required by the PAPs,

RWG or CRC.



During the implementation of the RAP, MIOL (or the selected contractor) will be responsible

for:



9







developing offer documents and discussing the terms and conditions with each

individual affected household;







planning and monitoring the replacement of communal social infrastructure;







planning and supervising the compensation activities;







providing transportation and assistance for moving people and belongings into new

houses;







design and implement community development and monitoring programmes to ensure

affected households are not worse off once they have been resettled;







providing continued assistance and monitoring of vulnerable groups;







establishing a monitoring programme to ensure PAPs are not worse off post

resettlement;







monitoring and reporting on the construction of replacement structures; and







managing of the grievance mechanism.



MONITORING

Monitoring of the resettlement process, which is an IFC PS5 requirement, enables the

Company to assess whether the procedures and objectives laid out in the RAP are being

accomplished. Monitoring should be both internal and external to ensure it meets international

standards.



9.1



Internal Monitoring

Internal monitoring should be implemented to allow the company (or contractor) to measure

the resettlement process against goals set out in the RAP. Internal monitoring will include

interviews with PAPs and MIOL staff involved in resettlement and compensation, review of

resettlement and compensation documents, surveys with resettled peoples and host

communities and observations in the villages. Internal monitoring will:





ensure that valuation and compensation has been carried out in line with national laws

and international best practice;







ensure stakeholders have received adequate notification of Project stages;







confirm all land-acquisition issues are resolved;







ensure the census has been carried out and has covered all PAP;







ensure all grievances are appropriately recorded and resolved;







ensure all agreed resettlement measures are implemented in accordance with the RAP;



U3823_Marampa_Resettlement_Final.docx



September, 2012

Page 25 of 28



SRK Consulting



Marampa RF – Main Report







confirm that the funds required to implement resettlement activities are provided in a

timely manner, are sufficient for purpose, and are spent in accordance with the RAP;

and







submit monitoring and evaluation reports periodically.



Monitoring will take place periodically both during the resettlement period and after

resettlement has taken place to ensure resettlement has not left the resettled people, or host

communities, worse off than pre resettlement.



9.2



External Independent evaluation /audit

In addition to internal monitoring, external monitoring should be conducted by an independent

group, the main aim being to assess the impact of resettlement and the resettlement process

and to ensure the objectives set out in the RAP have been executed. Monitoring should be

conducted twice a year for at least three years after resettlement has taken place. The initial

monitoring will evaluate the resettlement process and subsequent monitoring after the first

year will monitor conditions against baseline data collected in the census including:





housing - quality of roof, walls, floor;







agricultural yields;







possession of livestock;







land lease rent;







access to safe water;







distance to water source;







ownership of material assets;







patterns of employment and income generation activities;







income/expenditure/debts per household;







improvement in production/income for women/youths;







capacity building, skills / vocational training;







community infrastructure and access to transport routes/ public transport services;







children in school by age and sex;







distance to primary school;







access to sanitation;







incidence of disease;







distance to health centre, and







HIV/AIDS and STD prevalence aggregated by gender and age.



Once the external monitoring report has been completed MIOL will need to meet with the

RWG to discuss the findings and put in place remedial plans were necessary.



10



BUDGET

A resettlement action plan should provide an estimate of the budgetary requirements for

implementation of the resettlement measures. This section identifies the components that will

form part of the overall budget.

The key components of the overall budget should typically be:





the cost of replacement land;







the cost of building replacement housing and community structures such as schools,

churches, grain banks, etc;







cash compensation for the crops/ trees and relocation;



U3823_Marampa_Resettlement_Final.docx



September, 2012

Page 26 of 28



SRK Consulting



11



Marampa RF – Main Report







the cost of implementing a livelihoods restoration programme for the directly affected

people;







implementation costs (e.g. salaries, overheads and the cost of stakeholder

consultations);







the cost of training for the project implementation team; and







monitoring and evaluation costs.



TIMING

The resettlement schedule should define timing of the key steps and activities in the process.

These should be linked with the Project’s construction schedule to ensure timely availability of

land for start of different Project activities. The full schedule will be developed as part of the

RAP, however it should at least include the following activities/tasks:



12







create the RWG;







explore opportunities for minimising resettlement;







conduct census survey;







declare moratorium;







develop entitlement framework;







identify relocation sites;







negotiate entitlements; and







consultations with PAPs (on ongoing basis)



CONCLUSION

The RF provides an outline, which is in compliance with IFC PS 5 and Sierra Leone

requirements on land acquisition and resettlement, to ensure planning for an effective

resettlement programme for the affected parties. The RFP provides a basis for a Project

specific RAP to be produced.



13



REFERENCES

Ajei, M.O (2008). Government of Sierra Leone/World Bank Mining Sector Technical

Assistance Project Resettlement Policy Framework Final Draft. Nimba Research & Consulting

Co. Ltd.

GoS (2008) Environmental Protection Agency Act, Government of Sierra Leone, 2008

GoS (2009), Mines and Minerals Act, Government of Sierra Leone, 2009

IFC (2012) Performance Standards on Social & Environmental Sustainability, International

Finance Corporation June 2006

IFC (2007) Guidance Notes: Performance Standards on Social & Environmental

Sustainability, International Finance Corporation, 2007

IFC (2007) Stakeholder Engagement: A Good Practice Handbook for Companies Doing

Business in Emerging Markets, International Finance Corporation, 2007

SRK (2012) Socio economic baseline report for the Marampa Iron Ore Project, SRK

Consulting (UK) Ltd, April 2012



U3823_Marampa_Resettlement_Final.docx



September, 2012

Page 27 of 28



SRK Consulting



Marampa RF – Main Report



World Bank Operational Policy (OP) 4.124, World Bank, 2004



For and on behalf of SRK Consulting (UK) Limited



Lalit Kumar

Senior Consultant, Social

SRK Consulting (UK) Limited



4



Fiona Cessford

Corporate Consultant, Environment

SRK Consulting (UK) Limited



(www.worldbank.org) and in the World Bank's Resettlement and Rehabilitation Guidebook.



U3823_Marampa_Resettlement_Final.docx



September, 2012

Page 28 of 28



SRK Consulting



Marampa Iron Ore Project ESIS – Technical Appendix E



E



APPENDIX E

PRELIMINARY PROJECT DESIGN DRAWINGS



U3823_Marampa_ESIS_Final.docx



September 2012

Page E1 of E1



APPENDIX E1: PRELIMINARY WATER MANAGEMENT PLAN



1



Mining Solutions Consultancy Pty Ltd

ABN 16 082 728 836



Phone (+61 8) 9450 3399

Fax (+61 8) 9450 3377



5 Salter Point Parade, Salter Point, Western Australia 6152



www.miningsolutions.com.au



INTEROFFICE MEMORANDUM

To:



Jeff Hamilton



Date:



Co.:



Marampa Iron Ore Limited



Ref:



Cc.:



Tony Boucher



From:



Tamer Dincer



5 April 2011



Re: Marampa Iron Ore Project – Preliminary Mine Surface Water Management Plan



Introduction

The Marampa Iron Ore Project (Project) site is situated in a topographically low lying area with

numerous streams and swamps located at or close to the location of the proposed open pits

and waste dumps. Figure 1 shows the location of the proposed open pits in relation to the

streams, swamp areas and topography contours at 5m intervals.

The general direction of the surface water natural drainage at the project site is to the south

(Figure 1). The is no major drainage routes crossing through the Gafal and Rotret open pits as

they are located mostly at the higher ground. No significant flows are expected through the two

streams crossing the Matukia pit as the catchment areas feeding these streams are small.

The major stream crossing the Mafuri pit at the east (MFE) will be critical in the development of

the open pits as the catchment area is significant with limited drainage diversion options due to

the alignment of the hills in this area. Although relatively limited flows are expected, the stream

crossing the western end of the Mafuri pit (MFW) will also need diverting before the start of

mining MAfuri pit first in this area. The flows through the smallest stream at the centre of the

Mafuri pit (MFC) will be insignificant due to the small upstream catchment area.

Proposed Mining Strategy

The plan views of the preliminary mine site layout shown in Figures 2 and 3 summarise the

preliminary mining plan in two major phases. After building external waste dumps from the

earlier mined pit stages (Figure 2), the proposed mine development strategy facilitates the

backfilling of the earlier mined areas with the waste from the later mined pit areas (Figure 3).



The strategy will allow approximately 50% of the pit areas backfilled with waste and tailings,

significantly reducing the area otherwise required for the external waste dumps. The mining

and backfilling sequence can be further summarised as follows:



1







Development of the western part of the Mafuri pit earlier, which will be available for

waste backfilling after 2020 from the development of eastern pit areas (first concentrate

shipment planned for early 2015),







Completion of Rotret ultimate pit by 2025, which will be available for waste backfilling

from later pit stages developed in the Gafal West and Mafuri East areas,







Completion of Matukia ultimate pit by 2024, which will be available for tailings storage for

the rest of mine life, and







Completion of Mafuri eastern and Gafal western pit boundaries (joining boundaries)

latest will delay the MFE stream diversion towards the end of mine life.



In terms of surface water drainage, the timing and staging of the pit development in the Mafuri

central and eastern areas will be critical through mine life. The development of Mafuri pit stages

from west to east and Gafal pit stages generally from east to west will allow flexibility in planning

and construction of the major MFE stream diversion. As indicated by the preliminary economic

analyses, this strategy also provides favourable cash flow profile for the project from an

economic point of view.

The proposed external waste dumps for the open pits will not be affect the natural surface water

drainage generally as the waste dumps are generally located at the higher ground.

Surface Water Management Plan

The flat lying topography, the orientation of the hills and the general topographic inclination at

the site require that any diversion of surface water should also directed to the south while

preventing any significant rise of the accumulated water level in the catchment. Accumulated

water levels above approximately 70mRL will cover a relatively large area, potentially affecting

some road crossings and other structures during the rainy season.

The major drainage works in the area required for the development of Mafuri pit in stages can

be summarised as follows (Figures 2 and 3).

1. Excavation of the drainage channel and bund construction will be required to divert the

MFW stream before the start of mining Mafuri oxide pits (2016 Q3). The channel to the

west of pit boundary will be generally shallow except a ~200m section cutting thorough a

hill. Some sections will require only the construction of bunds to keep water away from

the pit. The drainage as shown in Figure 2 is located relatively close to the pit crest

considering the limited flows expected and waste backfilling of this section of the pit

relatively early in mine life.

2. Excavation of a major drainage channel will be required at the north of the Mafuri pit to

divert the water from the largest MFE stream before the development of last stages of

Mafuri and Gafal pits (~2023, Q4). The excavation of this channel with a maximum

depth of 10-12m and length of 600m will be the largest drainage work for the

management of surface water drainage for mining at the site.

3. As the channel excavation at the north of Mafuri (2) is completed, mining and waste

backfilling of the Mafuri pit in the central area needs to be finalised to allow diverted

water to cross the Mafuri pit area (west of 768,000mE). Although drainage over the

backfill material is not ideal, this would be the most feasible option considering the

topography constraints. Suitable materials and construction methods will be required to

seal the channel as much as possible over the waste backfill.



4. After the construction of the channels in 2 and 3 above, the water flow in the main MFW

stream can be diverted with a bund constructed along 959,150mN (~Year 2023, Q4).

This will accumulate approximately 3-4m deep water in the lower catchment as the

water level rise and flow through the newly excavated channel further north. The

approximate areal extent of water accumulation to the north of the proposed bund can

be seen in Figure 3.

The above is a summary of the major drainage works for scoping purposes based on a review

of the available data without undertaking any site visit. Mine water management plan for earlier

mine life needs further detailing in the feasibility study (and later during operations), including:





Properties of the ore and waste rocks with respect to exposure to water and drainage

may affect the mine design and water management plan.







Further minor drainage channel and bund construction may be required across the pit

and waste dump areas as necessary subject to local conditions and detailed mine

design.







Planning for water drainage on the waste dump surfaces, direction, treatment and

discharge of water flow from the waste dumps will be required as the mining operations

advance.







Planning for direction, treatment and discharge of the water dewatered from the pit

stages will be required as the mining and backfilling operations advance.







The proposed haul roads will require more detailed planning based on local variations

and detailed mine design & mining plan.







Although the topography and the location of the pits are the main factors for major

drainage works and a significant change is not expected, there might be social and

infrastructure limitations that may need incorporation in the feasibility study plans.



Disclaimer

This document has been prepared specifically for Marampa Iron Ore Limited by independent

consultants. The information contained in this report is based on sources believed to be

reliable, and all care has been taken in the preparation of the report. However, Mining Solutions

Consultancy, together with its members and employees, gives no warranty that the said sources

are correct, and accepts no responsibility for any resultant errors contained herein and any

damage or loss, howsoever caused, suffered by any individual or corporation.



Figure 1: Marampa Project Site: Major Streams, Swamps and Pit Areas



4



Figure 2: Site Layout before Waste Backfilling Rotret and Mafuri West



5



Figure 3: Site Layout after Rotret and Mafuri West Covered with Waste Dumps



6



APPENDIX E2: PRELIMINARY PROCESS FLOW DIAGRAMS



7



6/08/2012 3:28:10 PM - K:\Projects\M6037\3001 General\PFD\M6037-P120-3011-5001.dgn -



6/08/2012 3:37:33 PM - K:\Projects\M6037\3001 General\PFD\M6037-P120-3012-5001.dgn -



6/08/2012 3:38:08 PM - K:\Projects\M6037\3001 General\PFD\M6037-P120-3013-5001.dgn -



6/08/2012 3:38:59 PM - K:\Projects\M6037\3001 General\PFD\M6037-P120-3013-5002.dgn -



6/08/2012 3:39:45 PM - K:\Projects\M6037\3001 General\PFD\M6037-P120-3014-5001.dgn -



6/08/2012 3:40:28 PM - K:\Projects\M6037\3001 General\PFD\M6037-P120-3020-5001.dgn -



6/08/2012 3:41:00 PM - K:\Projects\M6037\3001 General\PFD\M6037-P120-3030-5001.dgn -



6/08/2012 3:41:59 PM - K:\Projects\M6037\3001 General\PFD\M6037-P120-3030-5002.dgn -



6/08/2012 3:43:07 PM - K:\Projects\M6037\3001 General\PFD\M6037-P120-3030-5003.dgn -



6/08/2012 3:44:05 PM - K:\Projects\M6037\3001 General\PFD\M6037-P120-3030-5004.dgn -



6/08/2012 3:44:38 PM - K:\Projects\M6037\3001 General\PFD\M6037-P120-3030-5005.dgn -



6/08/2012 3:45:28 PM - K:\Projects\M6037\3001 General\PFD\M6037-P120-3041-5001.dgn -



6/08/2012 3:46:56 PM - K:\Projects\M6037\3001 General\PFD\M6037-P120-3042-5001.dgn -



6/08/2012 3:47:30 PM - K:\Projects\M6037\3001 General\PFD\M6037-P120-3042-5002.dgn -



6/08/2012 3:49:12 PM - K:\Projects\M6037\3001 General\PFD\M6037-P120-3042-5003.dgn -



6/08/2012 3:50:18 PM - K:\Projects\M6037\3001 General\PFD\M6037-P120-3050-5001.dgn -



6/08/2012 3:51:01 PM - K:\Projects\M6037\3001 General\PFD\M6037-P120-3050-5002.dgn -



6/08/2012 3:51:36 PM - K:\Projects\M6037\3001 General\PFD\M6037-P120-3050-5003.dgn -



6/08/2012 3:52:15 PM - K:\Projects\M6037\3001 General\PFD\M6037-P120-3053-5001.dgn -



6/08/2012 3:53:10 PM - K:\Projects\M6037\3001 General\PFD\M6037-P120-3070-5001.dgn -



6/08/2012 3:53:53 PM - K:\Projects\M6037\3001 General\PFD\M6037-P120-3080-5001.dgn -



6/08/2012 3:54:42 PM - K:\Projects\M6037\3001 General\PFD\M6037-P120-3080-5002.dgn -



6/08/2012 3:55:49 PM - K:\Projects\M6037\3001 General\PFD\M6037-P120-3080-5003.dgn -



APPENDIX E3: TAILINGS STORAGE FACILITY DRAWINGS



8



SRK Consulting



Marampa Iron Ore Project ESIS – Technical Appendix F



APPENDIX F

F



ENVIRONMENTAL MANAGEMENT PROGRAMME



U3823_Marampa_ESIS_Final.docx



September 2012

Page F1 of F22



SRK Consulting



Marampa Iron Ore Project ESIS – Technical Appendix F



Appendix F: Preliminary Environmental Management Programme

The tables below list the management measures identified in the ESIA. The first table presents the commitments arising from the biophysical impact

assessment process and relate directly to the identified impacts in Chapter 7 of the ESIA. The second table presents the commitments arising from the social

impact assessment (Chapter 8), and the third table presents those arising from the community health, safety and security impact assessment (Chapter 9).

The fourth table is a table of general commitments, which are not specific to any individual impact but represent good industry practice.

These programmes have been developed as outlined in Section 11.1.4. The column headings are explained below.





Impact reference – this specifies the impacts the proposed management measure influences (Tables 1 to 3 only).







Objective - statement of the objective of the management action/s, which generally addresses the impact/s.







Reference number - a unique reference for the management measure.







Type – an abbreviation indicating the type of the management measure (IH = inherent design or management described in Chapter 4, MM = mitigation

measure, EM = enhancement measure, GP = good practice measure).







Management measure - a description of the measure or action, which will be clear, concise and specific enough to enable execution of the action.

Where relevant, the appropriate targets, indicators, trigger points and/or threshold levels will be incorporated into the management measure. If a set of

management actions is required to meet the objective, the ESMP will be simplified by making a commitment to develop an appropriate supporting

document in which the detail will be provided. Where the management measure cross references to another measure under a different impact it is

shown in italics.







Project phase – an abbreviation indicating the project phase/s when the management measure is applicable (DD= Detailed design, C = Construction,

O = Operation, D = Decommissioning, PC = Post Closure).







Timing – the time when the management action should be implemented and/or completed, and if relevant, how frequently it should be undertaken.







Achievement criteria – an indication of how achievement of the management measure will be assessed, which will be used to develop the monitoring,

inspection or audit programmes.



U3823_Marampa_ESIS_Final.docx



September 2012

Page F2 of F22



SRK Consulting



Marampa Iron Ore Project ESIS – Technical Appendix F



Table F1: Management programme to address identified biophysical impacts

Impact

Ref.



Objective



Ref

no.



1



Type



IH



Management measure



Rehabilitate the land and make it available for use by communities postclosure



Proj.

Phase



Timing



Achievement criteria



O, D,

PC



Progressive

rehabilitation ongoing

Land handed to

communities after

decommissioning



Closure and Rehabilitation Plan

developed in consultation with

communities; rehabilitated site

signed off by environmental

officer and if necessary regulatory

authorities



DD, C



Develop the plan prior

to construction

commencing;

implement it during

construction



Plan in place with evidence of

implementation. Compliance with

the plan included in the contract

documentation of contractors

appointed



Refer to mitigation measures listed for impact RL1



LT1



LT2



LT3



Minimise limits

on land use by

local

communities

due to land

modification



2



GP



Develop a Construction Management Plan that includes requirements to:

• Minimise the footprint disturbed during construction, operation and

decommissioning of the Project.

• Minimise the duration of the disturbance by starting rehabilitation as

soon as possible and progressively rehabilitating disturbed areas that

are no longer being used for the Project, and making them available for

communities to use.



3



GP



Prohibit unnecessary off road driving, and use planned and designated

access routes and lay-down areas only.



C, O, D



Ongoing



No visual evidence of Project

related use of non-designated

access routes or lay-down areas.



4



GP



Review and update the Closure and Rehabilitation Plan periodically to

address current site conditions; community expectations; and the results of

ongoing routine monitoring.



O, D



At least every three

years



Plan in place with record of

review outcomes



C, O



Open prior to

commencement of

construction and close

on decommissioning



Waste management plan

implemented; no visible Projectrelated waste or waste-related

complaints.



D



As soon as

infrastructure is no

longer needed



Records of consultation with

communities and government;

inventory of infrastructure left on

site, listing its post-closure use



Minimise

disruption to

community

access routes



Minimise visual

intrusion

associated with

mine activities

and

infrastructure



Refer to measures under RL2



5



IH



Develop a waste landfill site to handle non-mining waste generated by the

Project.



6



MM



At closure, remove mine infrastructure that does not have a continued use.



7



MM



Revegetate and landscape the site on closure, to reflect the surrounding

topography and vegetation as much as possible.



U3823_Marampa_ESIS_Final.docx



O, D



Phased rehabilitation

as operation tails off

and certain areas are

no longer in use.



Visual inspection; Rehabilitation

measures signed off by

Environmental Officer in

accordance with assessment

criteria stipulated in the final

closure plan



September 2012

Page F3 of F22



SRK Consulting



Impact

Ref.



Objective



Marampa Iron Ore Project ESIS – Technical Appendix F



Ref

no.



Type



Management measure



Proj.

Phase



Timing



Achievement criteria



8



MM



Consider the use of screening tools such as dense vegetation where

practical and appropriate to the surroundings.



DD



Prior to finalisation of

design



Signed off by appropriately

qualified engineer; visual

inspection; no community

complaints



9



MM



Clear vegetation in phases so that only those areas required for immediate

development are cleared.



C



Clear sections shortly

prior to construction in

that area



Schedule for clearing of areas

corresponding to construction

schedule



10



MM



Develop and implement a waste management plan that includes provision

for waste resulting from secondary developments and domestic waste

linked to the Project.



DD, C,

O, D



Develop plan prior to

construction;

implement it from

construction to

decommissioning



Completed Waste Management

Plan; no visible waste on mine

site and surrounding areas



11



GP



Paint buildings and structures or use materials with colours that reflect and

complement the natural colour and textures of the surrounding landscape.



DD



Finalisation of building

design



Visual inspection



GP



In accordance with a closure plan, the slopes of the WRF and any other

visually intrusive stockpiles will be reduced during closure to be more

consistent with the surrounding natural topography.



D



When

decommissioning the

site



Rehabilitation measures signed

off by Environmental Officer in

accordance with assessment

criteria stipulated in the final

closure plan



GP



Use directional lighting in areas operating at night, if communities are

affected by lighting.



C, O



Ongoing



Signed off by appropriately

qualified engineer; Visual

inspection; no community

complaints



12



13



LT4



Minimise

decrease in

land capacity

through loss of

topsoil.



GP



Refer to dust control measures under Impact AQ1.



14



MM



Avoid disturbance of slopes or sensitive areas such as drainage areas,

where possible.



C, D



Ongoing, especially

during site clearing



Visual inspection; signed off by

Environmental Officer



15



MM



Implement erosion control measures where steep slopes or large

unvegetated areas are created, or where sensitive areas such as river

banks are disturbed.



C, D



Vegetation clearing

and earth movement



Visual inspection; ; signed off by

Environmental Officer



16



MM



Inspect disturbed, rehabilitated, and sensitive areas such as river banks

affected by project infrastructure for visual signs of erosion and/or

deposition affecting either the Project’s or community’s use of the land. If

problems are identified, initiate remedial action.



C, O, D



Regular inspections, at

least on a 3-monthly

basis



Visual inspection and

maintenance of photographic

records. No community

complaints



17



MM



Clear and stockpile topsoil separately from subsoil / fill material, for use

during rehabilitation.



C



Clearing of vegetation

and earthmoving for

construction or

rehabilitation



Soil Management Plan in place;

visual inspection; signed off by

Environmental Officer



18



MM



Implement rehabilitation and establishment of vegetation cover as soon as

possible.



C, O, D



As soon as an area is

no longer in use



Progressive rehabilitation

strategy; signed off by

Environmental Officer



U3823_Marampa_ESIS_Final.docx



September 2012

Page F4 of F22



SRK Consulting



Impact

Ref.



LT5



WR1



Objective



Minimise

effects of windblown dust on

soil chemistry

and land

capability



Minimise

effects of pit

dewatering on

local

communities



Marampa Iron Ore Project ESIS – Technical Appendix F



Ref

no.



Type



Management measure



Proj.

Phase



Timing



Achievement criteria



19



GP



Maintain topsoil stockpiles to prevent their erosion or contamination with

subsoil or other materials.



C, O



Ongoing



Soil Management Plan in place;

visual inspection; signed off by

Environmental Officer



20



GP



Ensure stockpiled topsoil is used within two years and is not excessively

compacted to preserve a viable seed bank.



C, O, D



Ongoing, as and when

topsoil is cleared



Soil Management Plan in place;

visual inspection; signed off by

Environmental Officer



21



GP



Avoid driving over or otherwise compacting or disturbing topsoil.



C, O, D



Ongoing



Visual inspection



22



GP



Design roads, pipeline routes and landscape features to minimise disruption

of natural drainage patterns.



DD



Prior to construction



Map showing detailed design

relative to drainage lines; signed

off by Environmental Officer and

engineer



23



IH



Maintain a pond on the TSF



O



Ongoing



Visual inspection; signed off by

Environmental Officer



24



MM



Implement dust control measures, such as wetting down and maintaining a

pond at the tailings storage areas.



O



Ongoing, especially in

dry windy conditions



Plan in place with evidence of

implementation; no complaints

about dust



MM



On closure, put in place measures (such as revegetation) to ensure

continued erosion control of the tailings material.



D, PC



Progressive

rehabilitation as parts

of the TSF are no

longer in active use



Closure and Rehabilitation Plan in

place; dust monitoring results;

signed off by Environmental

Officer



26



GP



Using data collected during the monitoring programme, develop a Soils

Management Plan to evaluate the effects of blowing tailings dust on soils

and determine whether further management measures may be required to

mitigate impacts from windblown tailings.

The plan should determine:

• expected incremental increases in metals and effects of dilution;

• extent and effects of remobilisation;

• potential eco-toxicological effects; and

• removal standards if needed.



O



During early part of

operations



Plan in place with evidence of

implementation



27



IH



Relocate villages directly impacted by mining.



DD, C



Prior to construction of

pits



RAP developed and resettlement

implemented in accordance with

RAP; RAP close out audit



C, O, D,

PC



If monitoring shows

villages impacted then

ongoing until ground

water supply has

recovered



Monitoring of village water

availability; no complaints in this

regard



C



Prior to pit dewatering



Records of community

consultation and evidence of well

installed or repaired if required



25



28



MM



Provide affected villages with adequate water supply (including for irrigation

of crops).



29



MM



Consider installation of new wells / maintenance or repairs to existing

village wells.



U3823_Marampa_ESIS_Final.docx



September 2012

Page F5 of F22



SRK Consulting



Impact

Ref.



WR2



Objective



Minimise

effects of

surface water

abstraction



Marampa Iron Ore Project ESIS – Technical Appendix F



Ref

no.



Type



Management measure



Proj.

Phase



Timing



Achievement criteria



30



MM



If necessary, make alternative wetland areas available for rice cultivation.



DD, C



If monitoring shows

existing cultivated

wetlands impacted, as

and when necessary



Monitoring changes to extent of

cultivated wetland areas



31



IH



Re-use of water from tailings and other process waters to minimise

abstracted amount



O



Ongoing



Evidenced by water balance



32



GP



Minimise the abstracted volume, as far as practicable.



O



Ongoing



Water conservation methods

included in Water Management

Plan; signed off by Environmental

Officer



33



GP



Monitor either river stage or flow for the life of the mine to detect any

negative impacts to river flow.



O



Ongoing as specified in

monitoring programme



Records of monitoring results,

and investigation of any negative

impacts observed



34



IH



Scheduling of stream diversions only when required for pit infrastructure,

and reinstatement of natural stream drainage lines post-closure where

practicable.



C, O, D



As required during pit

excavation



Water Management Plan

indicating scheduling; signed off

by Environmental Officer



See measure 27 regarding relocation of affected villages.

Implement erosion control measures listed in LT4



WR3



Minimise

effects on

instream

ecology

resulting from

stream

diversion



35



MM



Design surface water diversion channels to mimic the natural instream

habitat as closely as possible, and rehabilitate using indigenous

vegetation. 



DD, C



Construction of

infrastructure



Construction signed off by

appropriately qualified engineer



36



MM



Include key instream habitat features, such as deeper pools, to maintain

fish populations during the dry season in stream diversion channels.



DD, C



During construction



Construction signed off by

Environment Officer



DD, C



Detailed design and

construction



Design signed off by appropriately

qualified engineer



DD, C



As specified in

monitoring programme,

with preliminary

evaluation after one

year



Monitoring data; evaluation report



C, O



Ongoing



Evidence of awareness

campaigns in local communities;

inclusion in ER&PP



DD



Prior to construction



Updated plan in place



See measure 22 on routing of roads etc to avoid drainage lines

37



38



WR4



Minimise flood

risk to local

communities

arising from

surface water

diversions



GP



GP



Use semi-permeable materials where possible in preference to

impermeable materials for surfaces such as roads and paving.



Monthly average flow for each river should be measured for at least a year,

and used to determine impacts during non-peak river flow.



Implement erosion / sedimentation control measures listed in Impacts LT4

and WR7 in and around diversion channels.

39



GP



40



GP



Include flood risk in the Emergency Response and Preparedness Plan

(ER&PP) and raise awareness with potential affected communities of the

risks and what to do in the event of a flood.

Update the preliminary Water Management Plan.



U3823_Marampa_ESIS_Final.docx



September 2012

Page F6 of F22



SRK Consulting



Impact

Ref.



Objective



WR5



Minimise

deterioration of

groundwater

quality as a

result of

seepage from

mine wastes



WR6



Minimise

discharge to

surface water



Marampa Iron Ore Project ESIS – Technical Appendix F



Ref

no.



Type



Management measure



Proj.

Phase



Timing



Achievement criteria



41



IH



Fit the TSF with an under-drainage system to collect any seepage and

return it to the processing area



DD, C



Design and

construction of TSF



Construction signed off by

appropriately qualified engineer



42



IH



Groundwater quality and quantities around the TSF will be monitored

frequently



O, D, C



As outlined in

monitoring programme



Boreholes in place; monitoring

data



43



IH



Have the design and operation of the TSF inspected by a qualified

geotechnical engineer at least once per year.



O



At least once a year



Inspection reports



44



GP



Undertake further geochemical characterisation of expected waste rock and

tailings material to confirm preliminary findings.



DD



Prior to construction



Characterisation data available;

revised designs if necessary



45



IH



Minimise release of storm water from the site by designing and constructing

storm water settlement ponds in accordance with Project design criteria.



DD, C



Design and

construction of ponds



Construction signed off by

qualified engineer



46



IH



Place bunding around the perimeter of the pit to prevent natural surface

drainage entering the pit.



DD, C



Prior to construction



Construction signed off by

qualified engineer



47



IH



Design the TSF such that upslope catchment areas will be small



DD



Prior to construction



Design signed off by qualified

engineer



48



IH



Treat sewage effluent from the construction camp, accommodation camp

and office/admin area at the beneficiation plant using containerised sewage

treatment plants



C, O



Ongoing



Sewage treatment facilities in

place; maintenance records;

monitoring data



49



IH



Construct drainage channels around the waste dump areas and through the

waste dump slopes, to direct the surface water flow to the settlement ponds.



C



Construction



Construction signed off by

appropriately qualified engineer



50



IH



Dispose of oils and other hazardous materials in accordance with the Waste

Management Plan.



C, O



Ongoing



Records of waste disposal



51



IH



Store hazardous materials in a suitably bunded area with an impermeable

surface, with the size of containment being at least 110% of the contents of

the largest tank within the facility, or provide facilities to direct excess

volume to an alternative spill containment facility.



C, O



Ongoing



Construction signed off by

qualified engineer; visual

inspections during operation



52



IH



Design, construct and operate the TSF to remain stable with no

uncontrolled discharges.



DD, C,

O



Ongoing



Visual inspections; No pollution

incidents reported



53



IH



Store mine site fuel in above ground steel tanks in a bunded facility at the

beneficiation plant. The tanks will be designed to international standards.



DD, C,

O



Design, construction

and operation of

storage tanks



Construction signed off by

qualified engineer; visual

inspections during operation



Plan and implement a comprehensive erosion control programme, including

erosion and dust control measures listed in Impacts LT4 and AQ1.

54



MM



Use sedimentation control techniques such as installation of straw bales

buffers in drainage lines downstream of potential sources of increased

sediment load.



DD, C,

O, D



Prior to clearing of

vegetation and ongoing



Visual inspection; monitoring data

of watercourses



55



MM



Implement a Water Management Plan for the site.



O, D



Ongoing



Plan produced and implemented;

no stormwater management

issues reported



U3823_Marampa_ESIS_Final.docx



September 2012

Page F7 of F22



SRK Consulting



Impact

Ref.



EB1



Objective



Minimise loss

of habitat and

individuals due

to site clearing



Marampa Iron Ore Project ESIS – Technical Appendix F



Ref

no.



Type



Management measure



Proj.

Phase



Timing



Achievement criteria



56



MM



Implement a comprehensive Rehabilitation and Closure Plan, which

includes rehabilitation of the backfilled pits, WRD and TSF to prevent postclosure discharge, and revegetation to ensure continued erosion control.



D, PC



Initiated during

decommissioning and

ongoing until complete



Signed off by environmental

officer; site rehabilitated and

returned to communities for use



57



MM



Where practicable, separate clean and “dirty” (i.e. with elevated levels of

contaminants) stormwater and handle to two categories differently.



C, O



During construction



Visual inspection; monitoring data

of watercourses



58



MM



Ensure clean water is piped to the outlet point and not allowed to flow freely

where it may cause erosion.



C, O



Ongoing



Visual inspection of release points



59



GP



Avoid construction activities in the Bankasoka River catchment area

(northern portion of the TSF area), which is ecologically sensitive



DD, C



Design and during

construction of TSF



Signed off by environmental

officer



60



GP



Implement a water quality monitoring programme (continuing post-closure)

to detect changes to surface water quality and take the required

remediatory actions.



O, D,

PC



As per monitoring

programme



Monitoring programme;

monitoring data



61



GP



Implement a surface water biomonitoring programme (as per the specialist

recommendations) to monitor effects on aquatic ecosystems.



O



As per monitoring

programme



Monitoring programme;

monitoring data



62



GP



Implement a Spill Management Plan, which includes preventive measures

such as secondary containment of pipelines crossing water courses and

bunding of hazardous liquids stored on site.



C, O, D



Ongoing



Plan in place; no spill incidents

reported



63



MM



Where possible adjust positioning of project infrastructure during planning to

avoid gallery forest and wetland habitats.



DD



Prior to construction



Evidence of exploring other

options when forest or wetland

areas are to be impacted



64



MM



C



During clearing of

vegetation



Evidenced by schedule for

vegetation clearing



Clear vegetation in phases working progressively in one direction so that

fauna have an opportunity to move to adjacent areas.

Stockpile topsoil as per the recommendations listed in Impact LT4, for use

during rehabilitation.



EB2



Minimise

spread of

invasive

species

resulting from

soil disturbance



65



MM



Implement an alien plant control management programme, including

training of personnel to implement the programme.



66



MM



Implement rehabilitation as soon as possible, and monitor rehabilitated

areas for growth of invasive species.



C, O, D



Ongoing



Completed alien plant control

management programme and

evidence of training and

implementation.



C, O, D



Ongoing



Evidence of progressive

rehabilitation; no invasive alien

plants in rehabilitated areas



C, O, D



Ongoing



Implement good practice measures listed in Impact LT1 to minimise the

disturbed area.

Implement erosion control measures as listed in Impact LT4.

67



MM



Remove invasive alien plants before they bear seed and dispose of

removed plants appropriately.



U3823_Marampa_ESIS_Final.docx



No evidence of alien invasive

plants in development footprint



September 2012

Page F8 of F22



SRK Consulting



Impact

Ref.



EB3



EB4



Objective



Minimise

disturbance

and

displacement of

wildlife due to

Project

activities



Avoid creating

an attractive

nuisance,

resulting in

impacts on

indigenous

ecosystems



Marampa Iron Ore Project ESIS – Technical Appendix F



Ref

no.



Management measure



Proj.

Phase



Timing



Achievement criteria



GP



Develop and implement a Wildlife and Habitat Management Plan that:

• protects gallery and swamp forest areas from disturbance (see Figure

5.12);

• provides awareness training to staff and contractors on: prevention of

injury of animals; identification of likely species found on site (and those

of conservation concern); identifications of animal hazards (such as

venomous snakes); and what to do if dangerous animals are

encountered;

• requires personnel to report kills of species of conservation concern to

the mine’s Environment Management team, who may investigate the

incident;

• encourages personnel to report sightings of wildlife of conservation

importance to the mine’s Environment Management team; and

• allows for the monitoring and, if necessary, eradication of any invasive

species occurring on site or in surrounding disturbed areas.



C, O, D



Develop during

construction with at

least annual review



Plan in place with evidence of

implementation and review



69



MM



Develop and implement a waste management plan that accommodates all

waste types produced on site, particularly food waste.



C, O, D



Plan developed prior to

construction and

implemented through

to closure



Completed waste management

plan and evidence of

implementation; no unmanaged

waste on site



70



MM



Manage the landfill site in accordance with good practice standards,

including access control and fencing.



O



Ongoing



Reflected in waste management

plan; no complaints or issues

relating to the landfill



71



MM



Monitor the incidence of drowning in water storage facilities and implement

preventive measures if required.



O



Ongoing



Records of monitoring and

preventive measures if required



MM



If required, a pest control programme should be implemented, and should

include monitoring of accidental death of non-pest species. Should the use

of rodent control measures be required, the use of natural predators eg

raptors should be considered, and pesticides that bio-accumulate should be

avoided.



Ongoing



Monitoring programme for

accidental deaths of non-pest

species if required; documented

pest control programme in place



68



72



Type



U3823_Marampa_ESIS_Final.docx



C, O, D



September 2012

Page F9 of F22



SRK Consulting



Marampa Iron Ore Project ESIS – Technical Appendix F



Table F2: Management programme to address identified social impacts

Impact

Ref.



ED1



ED2



Objective



Maximise

employment

benefits to local

communities



Maximise the

potential for

employee

training and

skills

development in

the local

community



Ref

no.



Type



Management measure



Proj.

Phase



Timing



Achievement criteria



1



IH



Focus recruitment of semi-skilled and unskilled labour to residents of local

communities.



C, O



During recruitment



Local content targets met



2



EM



Develop a local employment strategy giving preference to local candidates,

provided they meet the required eligibility criteria.



DD



Prior to recruitment



Completed Recruitment Plan



3



EM



Develop a fair and transparent local recruitment plan



DD



Prior to recruitment



Definition of local;

Recruitment Plan; records of

engagement with local

community



4



EM



Require contractors (by means of their contract) to give preference to local

employees, provided they meet the required eligibility criteria.



C, O, D



At tender stage and

ongoing



Records of tender evaluation

showing consideration of local

content; Contracts showing

relevant clauses



5



EM



Organise training for workers on management of household incomes.



O



Ongoing



Training material and registers



6



EM



Develop a programme for gradual ‘indigenisation’ of the workforce. This

includes a general and technical skills training programme.



O



Prior to recruitment



Evidence of implementation of

the programme and records of

“indigenisation” success.



7



EM



Develop and implement a construction and operational phase stakeholder

engagement plan (SEP). As part of this SEP document disclose the

recruitment process to manage community expectations (also related to

Impact SO2).



DD, C,

O



Prior to construction

and ongoing through

to closure



Completed SEP; records of

disclosure of recruitment

process to community



8



GP



Give preference to people directly affected by land acquisition to reduce the

magnitude of impacts described in Section 8.2.



C, O



During recruitment of

employees and

suppliers



Evidence in tender and

contract documentation; local

employment targets met



9



GP



Develop a programme of training prior to project start up to maximise potential

for local employment.



DD, C



Prior to construction

and operation



Training programme;

evidence of training

implemented



10



EM



Prepare and implement a training and skills development plan for ongoing

skills development of the Project workforce including contractors’ personnel.



DD, C,

O



Ongoing



Completed plan; Records of

training / skills development



11



EM



Support a ‘vocational training programme’ to assist local people to qualify for

semi-skilled positions.



C, O



Ongoing



Records of training

programme; monitoring of

success in achieving

qualifications and positions



12



EM



Encourage workers to introduce the learned skills and practices in their

homes



C, O



Ongoing



Include practical examples in

training material.



13



GP



Continue technical and financial support to educational institutions and

students.



O, D



Ongoing



Records of support provided.



U3823_Marampa_ESIS_Final.docx



September 2012

Page F10 of F22



SRK Consulting



Impact

Ref.



Objective



ED3



Encourage

government

investment in

areas local to

the Project to

maximise their

benefit



ED4



Maximise

opportunities

for local

suppliers and

contractors



Marampa Iron Ore Project ESIS – Technical Appendix F



Ref

no.



Type



Management measure



Proj.

Phase



Timing



Achievement criteria



14



GP



Disclose information on Project’s payment to government to the local

communities and other interested stakeholders as part of the SEP.



C, O



Ongoing



Records of disclosure to local

communities



15



GP



Liaise with government to promote the use of revenue from the Project in the

Project’s area of influence for local development.



DD, C,

O, D



Ongoing



Records of consultation with

government



16



EM



Identify the types of goods and services required and those that can be

sourced from within Sierra Leone.



DD, C,

O



Regular updates

throughout Project



Regularly updated database

of local suppliers and service

providers



17



EM



Develop a procurement programme to maximise the use of local suppliers.



DD



Prior to procurement



Documented procurement

programme with targets for

use of local suppliers



GP



Develop a supplier and contractor database, along with a process to review,

monitor and strengthen capabilities of local suppliers and contractors.



DD, C,

O



Ongoing



Functional database with

regular updates; records of

performance review and

monitoring



IH



Provide relocated households and communities with housing and social

infrastructure to equal if not better that lost, as per the RAP.



DD



During relocation



Records of housing and other

infrastructure lost and that

provided; records of

consultation with relocated

communities



20



MM



Prepare a Resettlement Action Plan (RAP) in agreement with affected

population, the Paramount Chief and key government and non-government

stakeholders as per the RF (Appendix D). The plan should provide details of:

• affected people;

• entitlements (cash or preferably in the form of replacement land for long

term sustainability of livelihoods);

• cash compensation for loss of any standing crops, plantations and trees;

• assistance for redevelopment of farms and plantations on new land;

• provision of improved replacement residential and community structures

as per the preference of local communities.



DD



Prior to relocation or

land acquisition



Completed RAP; records of

consultations with local

communities and other

stakeholders



21



MM



Build alternative access routes in consultation with users of affected routes

(see also Impact LT2).



C



During construction,

prior to disruption of

access



Records of consultation with

local communities; map

showing affected routes and

alternatives created



22



MM



Undertake a community development programme for people facing loss of

livelihood opportunities.



DD



Prior to resettlement

and land acquisition



Completed plan; evidence of

implementation



23



MM



Iteratively consult with affected people to identify and resolve their issues in a

timely manner.



DD, C,

O, D



Ongoing



Grievance Mechanism in

place; records of consultation

with affected communities



18



19



RL1



Minimise

impoverishment

of local

communities

through loss of

land and

resources



U3823_Marampa_ESIS_Final.docx



September 2012

Page F11 of F22



SRK Consulting



Impact

Ref.



Objective



Marampa Iron Ore Project ESIS – Technical Appendix F



Ref

no.



Type



Management measure



Proj.

Phase



Timing



Achievement criteria



24



MM



Implement a grievance mechanism for identification of resettlement related

issues and address them in a timely manner.



C, O, D



Ongoing



Grievance Mechanism with

record of any complaints and

how they were addressed



25



MM



Undertake post resettlement monitoring of affected parties to timeously detect

issues and take action if necessary.



C, O



Ongoing



Records of post-resettlement

monitoring and actions taken

if required



26



GP



Preferentially employ eligible members from directly affected families.



C, O, D



During recruitment



Records of directly affected

families, showing employment

status



Implement measures under Impact RL1.



RL2



Minimise

vulnerability of

communities



27



IH



Facilities and roads will be unfenced except for the beneficiation plant and

accommodation camp, allowing a degree of access by communities.



O



Ongoing



Design and construction

signed off by appropriately

qualified engineer



28



IH



Allow use of haul roads and other mine roads by communities, if safety

permits



O



Ongoing



Visual inspection and records

of accidents reported along

haul roads



No community complaints or

road safety incidents



29



MM



Provide safe crossing points across or around mine infrastructure where

existing tracks are affected.



DD, C



After discussion with

communities

regarding access

routes and prior to

construction



30



MM



Liaise with the affected communities to determine alternate routes around

mine area that cannot be crossed.



DD, C



Prior to construction

and stage 2

expansion



Record of meetings with

agreed route alignments on

map



31



MM



Maintain the selected bypass roads in the vicinity of the mine operations for

the duration of the life of the operation.



C, O, D



Ongoing



No community complaints or

road safety incidents



32



MM



At closure, liaise with communities to determine if previous routes should be

restored.



O, D



Prior to

decommissioning,

when developing final

closure plan



Records of meetings with

communities; maps showing

routes to be restored



U3823_Marampa_ESIS_Final.docx



September 2012

Page F12 of F22



SRK Consulting



Impact

Ref.



Objective



Marampa Iron Ore Project ESIS – Technical Appendix F



Ref

no.



Type



Management measure



Proj.

Phase



Timing



Achievement criteria



C, O, D



Ongoing



Records of consultation with

local communities on use of

the Grievance Procedure



Encourage local recruitment and procurement as per measures for Impact

ED1 and ED4.



SO1



SO2



Maintain

standard of

living of local

communities

affected by inmigration



Prevent

Project-related

increase in

social ills /

problems



33



MM



Encourage local communities to use the grievance procedure (measure 24)for

resolving their concerns.



34



GP



Facilitate joint planning with other industries, local government, Paramount

Chief and other stakeholders to minimise speculative migration.



DD, C,

O



Ongoing



Plan in place with records of

implementation including

records of communication/

information sharing.

Monitoring of speculative

migration



35



MM



Undertake awareness and educational campaigns (directly or through existing

institutions) for prevention of social ills.



DD, C,

O



Ongoing



Records of campaigns and

monitoring of success



36



MM



Provide employees and visitors to the site with cultural awareness training.



C, O



On arriving at site



Training material; records of

training attendance



37



MM



Provide assistance to the local health department (and NGOs) to strengthen

programmes for control of communicable diseases.



DD, C,

O



Ongoing



Needs assessment to

determine priority areas;

records of assistance

provided



Implement the management measures given under Impact SO1.



SO3



Minimise social

discord due to

perceptions of

unfair

distribution of

Project benefits



38



MM



Maintain transparency in the recruitment process.



DD, C,

O, D



Ongoing



Evidenced by Recruitment

Policy; Records of disclosure

to local communities



39



MM



Maintain regular communication with local communities and other

stakeholders to minimise tensions.



DD, C,

O, D



As per SEP



Records of communication



40



MM



Maintain and monitor the grievance mechanism for timely resolution of

community grievances.



DD, C,

O, D



Ongoing



Functional grievance

mechanism with records of

grievances raised and

resolved



DD, C



Ongoing



Records of stories recorded

made available to

communities



Implement measures under Impacts SO1, ED1 and ED4 to minimise

population influx.



AC1



Minimise loss

of community

access to

cultural

resources



Implement measures in Impact RL1 regarding protection of natural resources.

41



MM



Record mythological stories associated with specific sacred sites as part of

their relocation.



U3823_Marampa_ESIS_Final.docx



September 2012

Page F13 of F22



SRK Consulting



Impact

Ref.



DC1



Objective



Minimise

economic

decline

following

closure



Marampa Iron Ore Project ESIS – Technical Appendix F



Ref

no.



Type



Management measure



Proj.

Phase



Timing



Achievement criteria



42



MM



Conduct an independent social impact assessment prior to closure.



O



Prior to closure



Social impact assessment

including recommendations

for mitigation of impacts



43



MM



Develop a social closure plan including the following:

• design and implement a retrenchment policy and strategy in consultation

with workers and other stakeholders; and

• plan for post-project sustainability of community development activities.



O



Prior to closure, after

conducting an

independent social

impact assessment



Completed Social Closure

Plan, based on findings of

social impact assessment



44



MM



Allocate funds (in advance) for implementation of the social closure plan.



O



Prior to closure, after

development of social

closure plan



Approved budget allocation

for implementation of social

closure plan



45



MM



Re-train workers for increasing their chances for re-employment elsewhere

after Project closure.



O, D



Prior to closure, as

production tails off



Records of training



46



MM



Conduct stakeholder consultations on closure issues as part of the ongoing

stakeholder engagement process.



O, D



Ongoing



Records of consultations



47



GP



Promote and support building the capacity of local suppliers to diversify their

customer base and move beyond the Project area.



O, D



Prior to closure



Programme offering business

development advice to

suppliers affected by mine

closure



U3823_Marampa_ESIS_Final.docx



September 2012

Page F14 of F22



SRK Consulting



Marampa Iron Ore Project ESIS – Technical Appendix F



Table F2: Management programme to address identified health, safety and security impacts

Impact

Ref.



AQ1



NV1



Objective



Minimise the

generation of

dust from the

construction

and operation

of the mine



Minimise

disturbance of

local

communities

due to blasting



Ref

no.



Type



Management measure



Proj.

Phase



Timing



Achievement criteria



1



IH



Maintain a pond on the TSF to minimise dust



O



Ongoing



Visual inspection of pond

levels; no dust from the TSF



2



IH



Relocate villages close to mine infrastructure (where ambient dust levels are

predicted to be above guideline levels) (refer also to RL1 in Table F1)



DD



Prior to construction



Villages identified relocated in

accordance with RAP; Post

RAP audit



3



IH



Use water sprays to control dust.



C, O, D



Ongoing



Visual inspection of dust

levels; monitoring data

complies with standards



MM



Refer to the erosion control measures listed under Impact LT4.



4



MM



Maintain or reduce vehicle speeds on unpaved roads to 40 km/hr, especially

on roads passing near villages.



C, O



Ongoing



Visual inspection; random

speed checks



5



MM



Implement dust suppression measures in sensitive areas, such as wetting,

use of chemical dust suppressant and / or paving on roads with high vehicular

activity (for example, haul roads).



C, O, D



Ongoing, especially

during dry season



Visual inspection; monitoring

data complies with standards



6



MM



Control dust emissions on ore stockpiles through use of water spraying and/

or wind breaks.



O



Ongoing, especially

during dry season



Visual inspection; monitoring

data complies with standards



7



MM



Use dust suppression measures such as rock cladding or grassing, on the

side walls of the TSF and other exposed built up areas.



C, O



Once TSF has been

built and during any

subsequent alterations



Visual inspection; monitoring

data complies with standards



8



MM



Minimise the dry beach area of the TSF and wet the TSF surface if monitoring

results indicate dust generation from this source.



O



Ongoing



Visual inspection; monitoring

data complies with standards



9



MM



Minimize lengths of access roads and eliminate unnecessary traffic.



DD, C,

O, D



During detailed design

and ongoing



Maps showing road

alignments; visual inspection



10



GP



Investigate and respond to any air quality complaints picked up by the

Grievance Mechanism.



C, O, D



Ongoing



Records of complaints and

how they are addressed.



11



GP



Provide site workers with appropriate Personal Protective Equipment (PPE),

and implement standard international occupational health and safety

procedures.



C, O, D



Ongoing



Reflect in Health and Safety

Policy and all necessary PPE

provided and used



12



GP



Limit vehicle idling and keep vehicles well maintained.



C, O



Ongoing



Vehicle maintenance log



13



IH



Conduct blasting in accordance with international good practice standards, by

trained personnel



C, O



Ongoing



Blasting procedures in place



14



IH



Relocate villages close to mine pits (where air overpressure and vibration

levels are predicted to be above guideline levels)(see also RL1 in Table F2)



DD



Prior to construction



Villages identified relocated



15



GP



Re-assess impacts once detail regarding blasting regime is available.



DD



Prior to blasting



Evidence of re-assessment



GP



Monitor initial blasting to ensure compliance with specified air overpressure

and vibration criteria.



C



On commencement of

blasting regime



Records of monitoring and

compliance with criteria



16



U3823_Marampa_ESIS_Final.docx



September 2012

Page F15 of F22



SRK Consulting



Impact

Ref.



NV2



Objective



Minimise

increase in

background

noise levels

due to the

Project



Marampa Iron Ore Project ESIS – Technical Appendix F



Ref

no.



Type



Management measure



Proj.

Phase



Timing



Achievement criteria



17



GP



Schedule blasting outside of hours when people are most disturbed by noise

(such as at night).



C, O



Ongoing



Blasting schedule; no

complaints in this regard



18



GP



Inform local communities of blasting timetable in advance and provide

adequate notice of when blasts are required outside of the planned schedule.



C, O



Prior to blasting



Records of informing

communities



19



GP



Maintain records of each blast (including location of blast holes, design,

measured overpressure and vibration)



C, O



For each blast



Records kept



20



IH



Provide hearing protection for operators to comply with health and safety

guidelines.



C, O, D



Ongoing



Protective equipment

available and staff know how

to use



21



IH



Relocate villages close to mine infrastructure (where ambient noise levels are

predicted to be above guideline levels) (see also RL1 in Table F2)



DD



Prior to construction



Villages identified relocated



22



GP



Maintain vehicles and equipment in accordance with manufacturer’s

instructions to minimise noise.



C, O, D



Ongoing



Maintenance / servicing log;

no faulty equipment



23



GP



Avoid unnecessary revving of engines and switch off equipment when it is not

required.



C, O, D



Ongoing



No community complaints



24



GP



Start up vehicles and plant sequentially rather than simultaneously.



O



Ongoing



No community complaints



25



GP



Fit vehicles with broadband reversing alarms.



C, O, D



Prior to bringing

vehicle on site



Auditory inspection



26



GP



Undertake standardised noise measurements on major items of equipment

upon delivery to provide a noise reference against which regular checks can

be compared.



C, O



When equipment

arrives at site and at

regular intervals

thereafter



Log of measurements



27



GP



When plant equipment is due for replacement, the replacement equipment

should have a sound power level equal to or less than the plant that it is

replacing.



C, O



During sourcing of

replacement

equipment



Records of sound power level

of old and replacement

equipment



28



GP



Plan for operating times of noisy activities to be outside of hours when people

are most disturbed by increased noise levels (such as at night).



C, O, D



Ongoing



Schedule for noise generating

activities; no noise complaints



29



GP



Promptly investigate and respond to any noise complaints picked up by the

Grievance Mechanism.



C, O, D



Ongoing



Records of complaints and

how they are addressed



30



GP



Routine noise monitoring should be carried out at the surrounding receptors



C, O



On an annual basis



Records of monitoring



31



GP



Keep haul routes well maintained and avoid steep gradients.



C, O



When constructing

haul roads; ongoing

maintenance



Design of haul roads; road

maintenance schedule



32



GP



Minimize the drop height for materials.



C, O, D



Ongoing



Visual inspection



U3823_Marampa_ESIS_Final.docx



September 2012

Page F16 of F22



SRK Consulting



Impact

Ref.



TS1



Objective



Minimise

project-related

safety risks to

other road

users



Marampa Iron Ore Project ESIS – Technical Appendix F



Ref

no.



Type



Management measure



Proj.

Phase



Timing



Achievement criteria



33



IH



Underpasses will be constructed where the haul roads cross the Makeni

highway to avoid intersecting with the highway



DD, C



Design and

construction of haul

roads



Design drawings; visual

inspection



34



MM



Appropriately sign-post the site entrance and access to the Makeni highway.



C, O



Signs erected during

construction and

maintained through to

closure



Visual inspection



35



MM



Design site roads to a standard suitable for mine and construction traffic, and

maintain the roads to this standard.



DD, C,

O



Design of roads;

ongoing maintenance



Signed off by suitably qualified

engineer.



36



MM



Assess the condition of local roads and their capacity to accommodate the

mine-specific traffic and if necessary upgrade the roads prior to mine

construction



DD



Detailed design of

roads



Assessed by suitably qualified

engineer.



37



MM



In conjunction with the Government of Sierra Leone, devise and implement a

road maintenance programme for roads affected by the Project.



DD, C,

O



Consultation prior to

construction; ongoing

implementation



Records of consultation in this

regard and documented road

maintenance programme and

schedule



38



GP



Design and implement sheeting and correct positioning and securing of loads

on vehicles in line with international health and safety procedures.



C, O, D



Ongoing



Signed off by qualified Health

and Safety officer



39



GP



Control delivery of oversize loads to site during times of minimal highway

traffic as far as possible, and minimise travel outside daylight hours.



C, O, D



Ongoing



Schedule for deliveries of

oversize loads



40



GP



Minimise travel by heavy vehicles during heavy rains.



C, O, D



Ongoing



Records of travel times



Refer to measure 8 (LT2) in Table F1



TS2



SR1



Minimise

safety risks to

local

communities

using mine

site roads



Minimise risk

of human

rights abuses

due to conflict

with

communities



41



MM



Enforce speed limits and safe diving practice.



C, O, D



Ongoing



Training and disciplinary

procedures; random speed

checks



42



MM



Educate local communities on traffic safety.



C, O, D



Ongoing



Records of community

awareness programme on

traffic safety



Refer to measure 6 above (Table F3) on dust suppression

43



MM



Consider providing and maintaining access paths alongside roads for key

access areas.



DD, C,

O



Design of roads;

ongoing maintenance



Maps showing road and

access path layouts;

maintenance schedule



44



MM



Provide training to MIOL security staff and local police on the Voluntary

Principles on Security and Human Rights.



DD, C,

O



On recruiting security

staff and prior to

relocation of villages



Records of training provided;

no community complaints in

this regard



MM



Maintain the grievance procedure, and encourage and facilitate stakeholders

to use the mechanism to express concerns.



Ongoing



Grievance procedure in place;

records of informing

stakeholders on use of the

procedure



45



U3823_Marampa_ESIS_Final.docx



C, O, D



September 2012

Page F17 of F22



SRK Consulting



Impact

Ref.



SR2



OH1



OH2



Objective



Minimise risk

of exposure to

communicable

diseases



Minimise risk

of injury from

blasting



Minimise risk

of community

exposure to

toxic or

hazardous

substances



Marampa Iron Ore Project ESIS – Technical Appendix F



Ref

no.



Type



Management measure



Proj.

Phase



Timing



Achievement criteria



46



IH



Establish a clinic for mine employees to address health concerns



C



Prior to

commencement of

operation



Clinic operational; records

kept of visits and diagnoses



49



MM



Develop and implement management policies for HIV/AIDS, tuberculosis and

other potential communicable diseases focusing on prevention, control,

diagnosis and treatment in coordination with NGOs and local government.



DD



Prior to recruitment of

staff for construction

or operation



HIV/AIDS Management policy

in place



50



MM



Provide health awareness programmes and counselling services to

employees.



O



Ongoing



Documented health

awareness programme;

counselling service

operational



51



MM



Promote use and availability of condoms at the workers camp.



C, O



Ongoing



Condoms available; records of

awareness of use of condoms



52



MM



Undertake routine health screening of employees to detect and treat diseases

early.



C, O



On recruitment and

annual screening

thereafter



Records of health screening

and treatment provided if

necessary



C, O



Procedure in place

prior to blasting and

implemented prior to

each blast



Blasting procedure and safety

management plan; signed off

by qualified Health and Safety

officer



Conduct blasting using standard mining industry practices and procedures.

This includes the development and implementation of standard operating

procedures, blasting rules and a safety management plan that:

• Delineates the danger zone associated with each blast of at least 400m

and clear workers from this zone before, during and after each blast; and

• Provides an audible warning at least three minutes before a blast is fired.

Refer to mitigation measures listed under Impact EB4 for management of the

landfill site



53



IH



54



GP



Design hazardous material containment structures taking into consideration

natural hazards and the implications of these on structural integrity of the

containment facilities.



DD



Design of hazardous

liquid storage areas



Signed off by appropriately

qualified engineer



55



GP



Size containment areas to contain 110% of the contents of the largest tank

within the facility or provide facilities to direct excess volume to an alternative

spill containment facility.



DD



Design of hazardous

liquid storage areas



Signed off by appropriately

qualified engineer



56



GP



Pave (with an impermeable surface such as concrete) mine site fuel delivery

and dispensing pump areas and design these areas to drain into the adjacent

storage tank containment areas.



DD



Design of fuel storage

areas



Signed off by appropriately

qualified engineer



57



GP



Prohibit construction of hazardous material facilities (including temporary and

permanent refuelling areas) within drainage lines or the 1 on 100 year flood

lines of watercourses.



DD



Design of such

facilities



Signed off by appropriately

qualified engineer



C, O, D



Ongoing



Records of appropriate

treatment and disposal of

polluted water



58



GP



Treat (for example with an oil separator), evaporate or dispose of as a

hazardous material any polluted water collected in hazardous material

containment facilities.



U3823_Marampa_ESIS_Final.docx



September 2012

Page F18 of F22



SRK Consulting



Impact

Ref.



OH3



OH4



Objective



Minimise risk

of fire or

explosions



Minimise risk

of TSF failure



Marampa Iron Ore Project ESIS – Technical Appendix F



Ref

no.



Proj.

Phase



Type



Management measure



Timing



Achievement criteria



59



GP



Require vehicle maintenance to be undertaken in the designated workshops

where appropriate pollution control measures are provided to prevent leaks or

spills of fuel or lubricants reaching the environment.



C, O, D



Ongoing



Designated workshop for

vehicle maintenance; visual

inspection of pollution control

measures and signed off by

environmental officer



60



GP



Develop and implement a spill prevention and control system as part of the

Emergency Preparedness and Response Plan for the mine site



C, O, D



Develop plan prior to

construction, and

implement on an

ongoing basis



Spill prevention system;

appropriate management of

spills



61



IH



Make fire extinguishers available at storage areas for flammable substances,

and install a fire water system servicing the beneficiation plant and

accommodation areas.



C, O



Installed prior to

operation and in use

through operation



Signed off by qualified Health

and Safety officer



62



IH



Follow standard international good practice with regard to storage and

handling of combustible materials.



C, O



Ongoing



Signed off by qualified Health

and Safety officer



63



IH



Adhere to occupational health and safety guidelines with regard to safe

working conditions and the use of PPE.



C, O, D



Ongoing



PPE provided and used when

required; signed off by

qualified Health and Safety

officer



64



IH



Design TSF to be appropriate for the seismicity of the area and in accordance

with international good practice



DD



Design of TSF



Signed off by appropriately

qualified engineer



U3823_Marampa_ESIS_Final.docx



September 2012

Page F19 of F22



SRK Consulting



Marampa Iron Ore Project ESIS – Technical Appendix F



Table F4: General management controls representing good practice

Objective



Ref

no.



1



Spill

prevention

and

management

2



Hazardous

material

management



3



4



Management measure

Provide spill prevention and response training to staff , contractors and visitors, including:

• an explanation of good house-keeping practices;

• identification and use of equipment and engineering controls designed to prevent spills;

• description of proper spill response procedures; and

• indication of possible health, safety and environmental risks potentially occurring as a result of a spill.

In association with the incident reporting requirements (Section 11.3.2), record and report information on

spills including:

• location of spill;

• material type (hazard potential) and quantity released;

• quantity of material recovered;

• media affected (soils, water, air);

• actions taken to contain, recover and remove material released;

• methods and location of disposal of recovered material or affected media (refer to waste management

plan);

• cause of the spill; and

• how future spills could be avoided.

Develop and implement a Hazardous Material Management Plan including procedures for transport, handling

and storage of hazardous substances to minimise risk of accidental exposure. Hazardous materials include

explosives, fuel, lubricants, laboratory chemicals, hazardous waste etc. The plan will:

• include clear instructions on what to do should exposure occur;

• prohibit construction of hazardous material facilities including temporary and permanent refuelling areas

within drainages or the expected flood zones of ephemeral watercourses;

• require that any polluted water collected in hazardous material containment facilities is treated,

evaporated or dispose d of as a hazardous material;

• require vehicle maintenance be performed in designated workshops where appropriate pollution control

measures are provided.

Design mine waste, concentrate and hazardous material containment facilities with consideration of natural

hazards.



U3823_Marampa_ESIS_Final.docx



Proj.

Phase



Timing



Achievement criteria



C, O,

DC



On arrival at

Project sites



Training/induction logs



C, O,

DC



When spills occur



Records of spills showing

lessons learnt



C, O,

DC



When

transporting,

handling or storing

hazardous

materials



Plan in place, with

evidence of implementation



DD



During detailed

design



Record of design

considerations



September 2012

Page F20 of F22



SRK Consulting



Objective



Prevent

Project waste

causing harm

to local

communities

or ecological

systems



Marampa Iron Ore Project ESIS – Technical Appendix F



Ref

no.



Management measure



Proj.

Phase



Timing



Achievement criteria



13



Prepare construction and operation waste management plans and implement these consistent with Sierra

Leone regulations and international standards to the extent practicable. Include in the waste management

plans the following:

• a commitment to a waste hierarchy comprising a) waste avoidance, source reduction, prevention or

minimisation; b) waste recovery for materials that can be re-used; c) waste treatment to avoid potential

impacts to human health and the environment or to reduce the waste to a manageable volume; and d)

safe and responsible waste disposal;

• inventory of wastes identifying the source/s, characteristics and expected volumes;

• waste segregation requirements;

• location and type of waste collection points, which are conveniently located, have adequate capacity, are

frequently serviced and clearly labelled;

• storage requirements;

• opportunities for source reduction, re-use or recycling;

• targets for waste re-use, recycling and incineration;

• opportunities to minimise bulk or render waste non-hazardous;

• procedures for operating waste storage, treatment and disposal facilities;

• labelling requirements for waste disposed of offsite;

• method of tracking waste recovered, incinerated or disposed of to the site’s landfill;

• method of tracking quantity, date, transporter and fate of waste disposed of offsite;

• a contingency plan should waste disposal facilities be unavailable for a time; and

• training requirements for waste management staff and other employees and contractors.



DD, C,

O



Developed during

detailed design

with at least

annual review



Plan in place with evidence

of review



14



Recycle, compost or incinerate non-hazardous waste to the extent practicable.



C, O



Ongoing



Records of waste recycled,

composed or incinerated



15



Preferably return hazardous waste to the associated supplier or transport to other appropriately licensed

facilities off-site to the extent practicable and permitted.



C, O, D



Ongoing



Records of waste returned

to supplier



16



Provisionally store hazardous waste not transported off site in appropriate storage facilities on-site until their

final disposal is determined. Include a roofed enclosure over a concrete pad with a low concrete wall to

provide containment to hold 110% of the volume of stored hazardous liquids. Also include a fenced open

area of storage of empty containers. Restrict access to this area to qualified personnel only.



C, O, D



Ongoing



Visual inspection



17



Provide an open air non-hazardous waste transfer site on a pad with containment.



C



Construction of

infrastructure



Built according to design



18



Provide a 30 m peripheral buffer around the landfill area.



DD, C



Design and

construction of

waste facility



Built according to design



19



Establish a tire dump close to the landfill and progressively cap as tires are deposited.



DD, C



Design and

construction of

waste facility



Built according to design



20



Establish a bio-remediation area with graded base and perimeter embankment close to the landfill to treat

soils contaminated with hydrocarbons. Determine if treated soil can be used as an interim cover at the

landfill site.



DD, C



Design and

construction of

waste facility



Built according to design



U3823_Marampa_ESIS_Final.docx



September 2012

Page F21 of F22



SRK Consulting



Objective



Prevent or

minimise

occupational

health and

safety risks



Marampa Iron Ore Project ESIS – Technical Appendix F



Ref

no.



Management measure



Proj.

Phase



Timing



Achievement criteria



21



Establish a solid and liquid waste incinerator at the mine site.



DD, C



Design and

construction of

waste facility



Built according to design



22



Dispose of sludge from the sewage treatment facilities to the landfill or use in rehabilitation if appropriate.



C, O



Ongoing



Records of sludge

disposed of



23



Maintain sewage treatment facilities according to manufacturers’ specifications and Sierra Leone

requirements.



C, O



According to

manufacturer’s

instructions



Maintenance logs



24



Fit cooking areas with grease traps, and maintain these, to prevent excess oils and fats reporting to the

sanitation facilities.



C



Construction of

infrastructure



Visual inspection



25



Develop health and safety policy and plan to cover identified health and safety risks likely to occur during

construction, start up, operation, closure and rehabilitation phases of the project.



C, O



Developed during

detailed design

with at least

annual review



Policy and plan in place

with evidence of review



26



Systematically and continuously identify, assess and respond to health and safety risks throughout the

Project life cycle in accordance with the plan.



C, O, D



Ongoing



Record of risk identification

and management



27



Restrict the noise levels emitted from equipment or provide suitable personal protection devices if this limit

cannot be achieved.



C, O



Ongoing



Noise levels known and

equipment provided where

necessary



28



Provide fire protection systems to comply with the applicable national and international regulations.



C, O



Ongoing



Systems in place and

tested



29



Facilitate interaction between the health and safety and Environment teams.



C, O



Annual review



Records of meetings

between teams



30



Provide personnel with appropriate personal protection equipment (PPE) if they are obliged to work in areas

where occupation health and safety standards are exceeded. Provide staff and visitors with training on how

and when to use the PPE.



C, O,

DC



Ongoing



PPE available and staff

know how to use it



31



Prevent access to areas with high hazard potential and clearly mark such areas with suitable warning signs

showing written and visual representation of the hazard.



C, O,

DC, PC



Ongoing



High hazard areas

identified on a plan and

barriers in place with

suitable warning signs



U3823_Marampa_ESIS_Final.docx



September 2012

Page F22 of F22



SRK Consulting



Marampa Iron Ore Project ESIS – Technical Appendix G



APPENDIX G

G



PRELIMINARY ENVIRONMENTAL AND SOCIAL

MONITORING PROGRAMMES



U3823_Marampa_ESIS_Final.docx



September 2012

Page G1 of G11



SRK Consulting



Marampa Iron Ore Project ESIS – Technical Appendix G



Appendix G: Preliminary monitoring programmes

‘Project facilities’ refer to the different Project related installations. ‘Project area’ refers to the areas outside Project facilities but where Project personnel are

likely to be working.

Table G1: Preliminary environmental monitoring programme

Aspect



Land

disturbance



Water



Impact

reference



Type of monitoring



LT1, LT4,

EB1



Units



Frequency



Location/s



Records



Internal reporting



Extent of footprint area disturbed and/or

rehabilitated



m2



Monthly during

construction and then

as needed when land

disturbed or

rehabilitated



Within footprint of all

disturbed areas, including

along pipelines and roads



Log



Monthly report during

construction and

rehabilitation

Annual report during

operation



LT1, LT4,

LT5, WR6,

EC1



Visual inspections for signs of erosion or wind

deposition



None



Quarterly or on receipt

of grievance



Construction sites,

rehabilitated areas, road/

pipeline culverts and water

release points



Log



Annual report (nonconformances handled

as per Section 11.3.2)



LT2



Visual inspection of road condition



None



Quarterly or on receipt

of grievance



Haul roads and any bypass

roads developed around

project infrastructure



Log



Annual report (nonconformances handled

as per Section 11.3.2)



WR1



Volume and rate of water pumped from the

pits (pump ratings can be used)



m3/d and L/s



Daily when pit

dewatering occurring



Pit sump pumps



Database



Monthly report of max

and min rate and daily

volume



WR1, WR2



Groundwater levels in village wells within

drawdown cone



m below

ground level

(mbgl)



Continuously using

transducers or monthly

using dip meters



Monitoring boreholes as

shown on Figure 1



Database



Quarterly report of levels

and long term trends



WR1,

WR2, WR3



Cultivated wetland surface area and type of

crop grown



m2 and type

of crop



Start and end of each

rainy season



Cultivated wetland areas

downstream of mine

footprint areas



Database



Annual report



WR2



Rate and volume of water abstracted from

Rokel River



L/s and m3/d



Continuous during

abstraction



Point of abstraction



Database



Monthly report of max

and min rate and daily

volume



Database



Monthly water balance

showing daily/monthly

volumes



Database



Quarterly report of

results and long term

trends



WR2



Rate and volume of water used and recycled

at the mine site



m3/d and L/s



Continuous



Accommodation camp,

beneficiation plant, power

plant, TSF, storm water

ponds, water spray trucks

and any other key water

off-take points



WR5



Groundwater quality at the mine site and in

nearby communities for at least the following

parameters(a): pH, Eh, TDS, alkalinity,

temperature, dissolved oxygen, nitrate,

chloride, fluoride, sulfate, phosphate, Na, K,



ug/L, mg/L

or other

units as

appropriate



Quarterly for full

parameter suite, with

field pH, EC and

temperature collected

monthly when water



New holes installed around

the TSF, landfill and

hazardous materials

storage areas; monitoring

boreholes shown on Figure



U3823_Marampa_ESIS_Final.docx



September 2012

Page G2 of G11



SRK Consulting



Aspect



Marampa Iron Ore Project ESIS – Technical Appendix G



Impact

reference



Type of monitoring



Units



Ca, Mg, Al, Cr, Fe, Mn, B, Cu, Zn, As, Se, Mo,

V and U (U at the mine site only)



Air and

climate



Frequency



Location/s



levels recorded



1 (subject to review during

construction)



Records



Internal reporting



WR4,

WR5, EB3,

EB4



Surface water quality in water holding facilities

for at least the following parameters(a): pH, Eh,

TDS, TSS, alkalinity, temperature, dissolved

oxygen, nitrate, chloride, fluoride, sulfate,

phosphate, Na, K, Ca, Mg, Al, Cr, Fe, Mn, B,

Cu, Zn, As, Se, Mo, V and U



ug/L, mg/L

or other

units as

appropriate



Quarterly for full

parameter suite, with

monthly field pH, EC,

DO, turbidity, TSS and

temperature



Storm water settlement

ponds (following rain

events), tailings

supernatant pond, pit

sumps



Database



Quarterly report of

results and long term

trends



WR3



Flow rate and stage measurement for streams

in sub-catchments influenced by Project

infrastructure



m3/s and m



Monthly flow rate; daily

stage data



Monitoring points shown on

Figure 2



Database



Quarterly report of flows



WR6



Stream water quality for at least the following

parameters(a): pH, Eh, TDS, TSS, alkalinity,

temperature, dissolved oxygen, nitrate,

chloride, fluoride, sulfate, phosphate, Na, K,

Ca, Mg, Al, Cr, Fe, Mn, B, Cu, Zn, As, Se, Mo,

V and U



ug/L, mg/L

or other

units as

appropriate



Quarterly for full

parameter suite, with

monthly field pH, EC,

DO, turbidity, TSS and

temperature



Surface water monitoring

points shown on Figure 1

(subject to review during

construction)



Database



Quarterly report of

results and long term

trends



WR4, WR6



Record upset conditions when storm water

settlement ponds are full and discharges

occur. Sample the water released for the

same parameters as above. If possible,

record estimated volume of water released



ug/L, mg/L

or other

units as

appropriate



When upset conditions

occur



At the point of release



Log and

database



Annual report (nonconformances handled

as per Section 11.3.3)



WR6



Inspection of storage facilities to determine

need for sediment removal



None



Quarterly



Water holding facilities



Log



Annual report (nonconformances handled

as per Section 11.3.3)



AQ1



Weather conditions on site (wind, rainfall,

temperatures)



various



Monthly



Onsite weather station



Database



Quarterly report of

results and long term

trends



AQ1



Dust fallout over a monthly period



µg/m3



Monthly



Bucket monitoring stations

shown on Figure 3subject

to review during

construction)



Database



Quarterly report of

results and long term

trends



AQ1



PM10 and PM2.5 (24 hour reading)



µg/m3



Monthly



At monitoring stations

shown on Figure 3 (subject

to review during

construction)



Database



Quarterly report of

results and long term

trends



Database



Quarterly report of

results and long term

trends



AQ1



Ambient NO2 and SO2 24-hour concentrations

(using Radiello Badges)



µg/m3



U3823_Marampa_ESIS_Final.docx



Quarterly



Monitoring stations as

shown on Figure 3 (subject

to review during

construction)



September 2012

Page G3 of G11



SRK Consulting



Aspect



Noise and

vibrations



Ecological



Vehicles and

equipment



Marampa Iron Ore Project ESIS – Technical Appendix G



Impact

reference



Type of monitoring



Units



Frequency



Location/s



Records



Internal reporting



AQ1



Times and duration of upset conditions



Date and

time



When upset conditions

occur



HFO plant



Log



Annual report (nonconformances handled

as per Section 11.3.3)



Air overpressure (from blasting)



dBL



Initial 3 blasts and on

receipt of complaint



Closest villages or at

location of complainant



Log



Annual report



Blasting-related vibrations (measured as Peak

Particle Velocity)



Mm/s



Initial 3 blasts and on

receipt of complaint



Closest villages or at

location of complainant



Log



Annual report



NV2



Ambient noise levels over 24 hour period

(intermittent between weekday and weekend)



dB(A)



Monthly or upon receipt

of complaint



As shown on Figure 3 or at

location of complainant



Log



Annual report



WR3,

WR5, WR6



Aquatic biomonitoring programme - diatoms



Category (AF)



Annually (dry season)

during construction and

operation



As shown on Figure 4



Database



Annual report



WR3,

WR5, WR6



Aquatic biomonitoring programme - Fish



Number of

species



Annually (dry season)

during construction and

operation



As shown on Figure 4



Database



Annual report



WR1,

WR3, EB1



Spatial extent of wetland areas



m2



Start and end of rainy

seasons



Wetland areas downstream

of project areas



Database



Annual report



EB2



Visual inspections of presence of invasive

plant species



None



Quarterly



Disturbed and rehabilitated

areas, and adjacent areas



Log



Annual report on findings

and remedial measures



EB3, EB4



Records of wildlife kills by equipment, vehicles,

drowning or poisoning



None



On occurrence



Within Project areas



Log



Monthly report on

fatalities and remedial

measures



EB3



Records of major wildlife sightings



None



On occurrence



Within or near the Project

area



Log



Annual report on

observations



EB4



Records of prevalence of nuisance animal

species



None



On occurrence



Within or near the Project

area



Log



Annual report on

observations



AQ1, EB3,

TS1, TS2



Random speed checks



km/hr



Once every two weeks

at different locations

and times



Access and haul roads



Log



Annual report (nonconformances handled

as per Section 11.3.3)



NV2



Records of vehicle and equipment

maintenance



None



As per manufacturer’s

instructions



Mine truck shop and

equipment workshop



Log



None



NV2



Baseline noise emissions of new equipment



dB



On commissioning of

new equipment



Within 100m of equipment



Log



None



General



Records of hazardous materials acquired and

used



m3 or kg of

each type of

material



On arrival at site and

during construction/

operation



Warehouse or storage

facility



Log



Quarterly report



General



Inspections of hazardous substances

containment facilities, instrumentation and

detection systems.



None



At least monthly for

containment facilities

with instrumentation as



Hazardous material

containment facilities



Log



Annual report (nonconformances handled

as per Section 11.3.3)



NV1



Hazardous

materials



U3823_Marampa_ESIS_Final.docx



September 2012

Page G4 of G11



SRK Consulting



Aspect



Marampa Iron Ore Project ESIS – Technical Appendix G



Impact

reference



Type of monitoring



Units



Frequency



Location/s



Records



Internal reporting



per manufacturer’s

instructions



Waste



General



Volume of different wastes types disposed of

to landfill or removed to hazardous waste site



kg or tonnes



Daily



Waste disposal sites



Log



Quarterly report



General



Volume of different waste types recycled or

reused



kg or tonnes



Daily



Waste disposal sites



Log



Quarterly report



General



Volume of soil bio-remediated



kg or tonnes



When soil arrives at bioremediation site



Waste management site at

mine



Log



Quarterly report



U3823_Marampa_ESIS_Final.docx



September 2012

Page G5 of G11



SRK Consulting



Marampa Iron Ore Project ESIS – Technical Appendix G



Table G2: Socio economic monitoring programme

Aspect



Impact

reference



Type of monitoring



Units



Frequency



Location/s



Records



Reporting



Economic

development



ED1, ED2,

RL1, SO1,

SO2, SO3,



Source of employees (for MIOL and its

contractors) categorised by:

• skill level;

• whether they are local, provincial,

national and/or international;

• ethnicity

• gender;

• from a vulnerable group (for

example disabled).

Unemployment



Percentage of

employees in

each category



Ongoing throughout

the life of the project



Project facilities



Employee database

for MIOL and for its

contractors



Quarterly human

resources report



Percentage



Yearly



Lunsar and affected

villages



Government records;

Primary survey data



Yearly social

performance report



ED3



Government revenue used in areas

affected by the Project



Percentage



Yearly



Port Loko District



Government revenue

and budget records



Yearly social

performance report



ED4, SO1,

SO2, SO3



Origin of contractors and suppliers

(Local, provincial, national and/or

international)



Percentage



Quarterly



Project facilities



Contracts register



Quarterly report from

contractors/suppliers



RL1, RL2



Provision of improved replacement

housing, replacement farmland and

access to natural resources



Percentage



Quarterly



Project affected

villages



Resettlement

monitoring reports



Quarterly community

relations report



RL2, RL3



Access to social infrastructure such as

schools, health centre, grain banks,

markets for selling and buying, credit

facilities, religious centres, water

supply and sanitation



Percentage



Yearly



Project affected

villages



Resettlement

monitoring reports



Quarterly community

relations report



RL1



Restoration of livelihoods to the level

of pre-resettlement



Percentage



Yearly



Project affected

villages



Resettlement

monitoring reports



Quarterly community

relations report



RL1



Food security (post resettlement)



Percentage



Yearly



Project affected

villages



Resettlement

monitoring reports



Quarterly community

relations report



RL2



Access to social support networks



Percentage



Yearly



Project affected

villages



Resettlement

monitoring reports



Quarterly community

relations report



RL1, RL2,

RL3, SO3



Initiatives for promotion of alternative

livelihoods (focus on affected people

and vulnerable members)



Number and

type of initiatives



Quarterly



Project affected

villages



Reports on initiatives;

Meeting minutes



Quarterly community

relations report



RL1, RL2,

RL3, SO1,

SO2, SO3,

AC1, DC1



Community grievances or complaints



Number and

type of

complaints



Monthly



Project affected

villages



Grievance register;

Community meetings;

Letters; Media reports



Monthly community

relations report



ED1, SO1,

SO2



Resettlement

and loss of land

and social and

natural

resources



U3823_Marampa_ESIS_Final.docx



September 2012

Page G6 of G11



SRK Consulting



Marampa Iron Ore Project ESIS – Technical Appendix G



Aspect



Impact

reference



Type of monitoring



Units



Frequency



Location/s



Records



Reporting



Social order



SO1, SO2



Population



Population; Rate

of growth



Every three to five

years



Lunsar and affected

villages



Primary sample

survey; Government

statistics



Yearly social

performance report



SO2, SR2



Incidence of

diseases



Quarterly



Lunsar and affected

villages



Reports from health

centres; Employee

health screening

records



Quarterly social

performance report



SO2, SR2



Prevalence of communicable

diseases:

• STIs

• Tuberculosis and respiratory track

infections

• Malaria

• Diarrhoea

Prevalence of crime



Percentage

increase



Yearly



Project affected

villages



Community meetings;

Police records; media

reports



Quarterly social

performance report



SO2, SR2



Prevalence of commercial sex workers



Percentage

increase



Yearly



Project affected

villages



Community meetings;

Police records; media

reports



Yearly social

performance report



SO2, SR2



Prevalence of alcohol and drug abuse



Number of

incidences



Yearly



Project affected

villages



Community meetings;

Police records; media

reports



Yearly social

performance report



SO3



Disputes between residents of affected

villages and outsiders



Number of

incidences



Monthly



Project affected

villages



Community meetings

records



Monthly community

relations report



Archaeology

and cultural

heritage



AC1



Relocation of sacred bushes and

cemeteries to the satisfaction of

affected people



Percentage of

sacred bushes

and cemeteries



Quarterly



Project affected

villages



Community meetings

records



Quarterly social

performance report



Decommissioning and

closure



DC1



Number of retrenched workers reemployed in other mining projects or

alternative occupations



Percentage



Quarterly (during

decommissioning

phase)



Project affected

villages



Placement records







DC1



Persons provided with preretrenchment training and type of

training provided



Number of

persons and

type of training



Quarterly (prior to and

during

decommissioning

phase)



Project affected

villages



Training records



U3823_Marampa_ESIS_Final.docx



Employee

newsletters;

• Yearly human

resources report

Quarterly human

resources report



September 2012

Page G7 of G11



SRK Consulting



Marampa Iron Ore Project ESIS – Technical Appendix G



Figure 1: Locations of surface water and groundwater monitoring points



U3823_Marampa_ESIS_Final.docx



September 2012

Page G8 of G11



SRK Consulting



Marampa Iron Ore Project ESIS – Technical Appendix G



Figure 2: Locations of surface water flow gauging monitoring points



U3823_Marampa_ESIS_Final.docx



September 2012

Page G9 of G11



SRK Consulting



Marampa Iron Ore Project ESIS – Technical Appendix G



Figure 3: Locations of air quality and noise monitoring points



U3823_Marampa_ESIS_Final.docx



September 2012

Page G10 of G11



SRK Consulting



Marampa Iron Ore Project ESIS – Technical Appendix G



Figure 4: Locations of aquatic biomonitoring sampling sites



U3823_Marampa_ESIS_Final.docx



September 2012

Page G11 of G11



SRK Consulting



Marampa Iron Ore Project ESIS – Technical Appendix Error! Reference source not found.



APPENDIX H

H



MIOL POLICIES



U3823_Marampa_ESIS_Final.docx



September 2012

Page H1 of H1