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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

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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:



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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



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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

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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



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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



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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



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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

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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



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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



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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



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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



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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.



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

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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).



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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



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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.



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



2



2



Source: Cape Lambert, 2011



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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.



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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.



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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.



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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”



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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”);



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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.



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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



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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)



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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).



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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.



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Figure 3.1: Study areas for MIOP ESIA



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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.



























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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



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3.3.1



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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



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(“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.



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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



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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



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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



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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



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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).

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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.



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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.

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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



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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.



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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:

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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.



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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)



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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.



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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



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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).



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Figure 3.2: Overview of the stakeholder engagement process undertaken



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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



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3.4



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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.



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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).

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-



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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



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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.



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



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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.

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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



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Figure 4.3: Rotret prospect interpretive geology



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Figure 4.4: Gafal prospect interpretive geology



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Figure 4.5: Matukia Prospect Interpretive Geology



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Table 4-2: Indicative production schedule



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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.

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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.



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

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



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

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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



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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.

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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



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(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).



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Figure 4.9: Schematic process flow diagram for Stage 1

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

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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.



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Figure 4.11: Beneficiation plant layout for Stage 1



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Figure 4.12: Beneficiation plant layout, showing Stage 2 expansion

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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.



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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.



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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



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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



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

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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



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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:



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-



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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.



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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



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Bioremediation and then use for

rehabilitation



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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,



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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.



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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.



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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.



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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



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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



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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.



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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.



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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



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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



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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.



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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



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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



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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



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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



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Figure 5.5: Catchments in the Project area



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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



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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.



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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

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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



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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



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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.



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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.



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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

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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



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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



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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.



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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.



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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.



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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



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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.



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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.



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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

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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



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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



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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.



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



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6.2



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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



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6.3



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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



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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



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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.



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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

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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.



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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

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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.

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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.



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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



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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.



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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.



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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.



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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



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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

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6.9



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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

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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

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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).



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



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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



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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

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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

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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



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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).



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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

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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.



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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

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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.



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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.

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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;



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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).

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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



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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



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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.



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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

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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.



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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)



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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).



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



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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

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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.



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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

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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.



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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.



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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.

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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.



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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.



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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

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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.

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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

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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.



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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.



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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.



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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.

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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.



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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.



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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.



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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



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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.



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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



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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.



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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

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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.

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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,



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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.



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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



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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

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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.



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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



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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

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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;



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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



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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.



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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

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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.



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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



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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.



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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).



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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



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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



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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.

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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%.



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Figure 9.1: Maximum predicted 98

without management



Marampa Iron Ore Project ESIS – Main Report



th



percentile PM10 concentrations over the Project area,



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th



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

management

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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



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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.



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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



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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

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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

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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)



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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’.



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



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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

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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.



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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

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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.

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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



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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.



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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

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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.



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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



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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



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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



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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.

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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.



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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.



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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.



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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.

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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.



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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”.



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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.



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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

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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.



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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;



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-



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;



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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.



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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;



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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.



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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

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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.

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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



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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.



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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.



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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;



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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,



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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.



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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.



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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

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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.

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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.



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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



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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



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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

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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



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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.



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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



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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.



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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



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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



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Marampa Iron Ore Project ESIS – Technical Appendix A



APPENDIX A

A



SUMMARY OF APPLICABLE LEGISLATION AND

INTERNATIONAL GUIDELINES



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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.



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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



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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.



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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.”



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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.



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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



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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



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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



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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



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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



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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



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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.



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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



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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



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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



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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:



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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



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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:





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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.



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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



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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.



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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.



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Appendix A



Figure 3-1: International initiatives influencing the scope of and approaches to ESIA



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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:



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Freedom of association, collective bargaining, and industrial relations;

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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



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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



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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)



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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



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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



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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



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Outline

Determine the screening category the project belongs to.

Most mines fall in Category A (Projects with potential significant adverse social or



August 2012



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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.



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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;