Mine Closure Toolbox Examples Version 3 2019

MINE CLOSURE
TOOLBOX
EXAMPLES VERSION 3, 2019
ANGLO AMERICAN MINE CLOSURE TOOLBOX EXAMPLES VERSION 3 a

FOREWORD
Anglo American’s (AA) burning ambition is to be the most
valued mining company in the world by 2023. The purpose
of AA is to reimagine mining to improve people’s lives.
Mining plays a significant role in human and economic

development and, without the mining sector, society would
not enjoy a large number of the benefits that it does
today. The mining industry’s rich history also carries some
important lessons and one of these is the poor closure or
abandonment of mines by the industry worldwide. If AA is to
achieve its burning ambition and purpose, the closure team
must deliver value through integrated, risk and opportunities
based closure planning and execution, to establish safe,
stable and non-polluting post-mining landscapes that leave a
positive and sustainable legacy for stakeholders.
The updated Mine Closure Toolbox (MCT) (v3) has

incorporated the Integrated Closure Planning System
(ICPS) that was developed in 2015 and built on the
existing toolbox (v2) that was released in 2013. Importantly,
a Group wide closure standard was endorsed in June 2018
and this updated version of the MCT provides the guidance Some of the more immediate benefits from our updated
for AA operations to achieve the requirements outlined in MCT are increased integration with LoAP, potential lower
the standard. The updated version of the MCT increases closure liabilities, lower rehabilitation costs, more effective
the emphasis on the importance of designing, planning, social investment and engagement, and enhanced value to
operating and executing closure at AA operations, with a AA and its stakeholders.
focus on integration with Life of Asset Planning (LoAP).
The updated MCT is targeted at people in our operations Together, we create sustainable value that makes a real
across a range of disciplines, the tools provide practical difference.
support as to how to achieve the desired integrated
outcomes for AA. It is also important that a preferred future
for the mine footprint post-production is developed in Mark Cutifani
partnership with communities. The tool reinforces our desire Chief Executive
for improved community relationships and engagement. November 2019
FRONT COVER:
Kumba: Saldanha Iron Ore Terminal, South Africa.
ACKNOWLEDGEMENTS CONTENTS
The original report “Version 1, 2007” was developed EXAMPLE 1: ESTABLISHING THE ZONE OF
by Peter Coombes and Rudolph Botha from the INFLUENCE OF THE PROJECT 2
then Anglo Technical Division. The second version of
the MCT was developed by Rudolph Botha of AA’s EXAMPLE 2: SWOT ANALYSIS 4
Technical Solutions with the support and inputs of
various AA technical resources. This third version EXAMPLE 3: CLOSURE RISK ASSESSMENT 6
of the MCT was developed by Carl Grant and
Rudolph Botha and from AA’s Group Technical and EXAMPLE 4: CLOSURE BENCHMARKING REVIEW 26
Sustainability.
EXAMPLE 5: PHYSICAL CLOSURE COST
The authors would like to thank the various individuals CALCULATION SPREADSHEET AND DRAWINGS 30
across the Group who provided comment, examples
and factual data for incorporation into this revised EXAMPLE 6: COMPLETED GAP ANALYSIS
document. AND ACTION PLAN 31
For more information contact: EXAMPLE 7: REHABILITATION STRATEGY

Dr Carl Grant AND FIVE-YEAR REHABILITATION PLANS 68
Head of Mine Closure
Group Technical and Sustainability EXAMPLE 8: SUCCESS CRITERIA 70
201 Charlotte St
Brisbane, 4000 EXAMPLE 9: SOCIAL TRANSITION RISK
ASSESSMENT AND CASH FLOW 73
Email: carl.grant@angloamerican.com
EXAMPLE 10: HEALTH CONSIDERATIONS
Telephone: +61 7 3834 1215 IN MINE CLOSURE 98
or EXAMPLE 11: KEPNER TREGOE

OPPORTUNITIES ANALYSIS 102
Mr Rudolph Botha
Lead Mine Closure EXAMPLE 12: DEVELOPING CLOSURE
Group Technical and Sustainability OBJECTIVES AND KPI’S FOR SENIOR LEADERS 105
45 Main Street
Johannesburg, 2001 EXAMPLE 13: CLOSURE CRITERIA
EFFECTIVENESS REVIEW 108
Email: rudolph.botha@angloamerican.com
EXAMPLE 14: PROJECT MANAGEMENT
Telephone: +27 1 638 2254 FRAMEWORK (PMF) – STUDY AND PROJECT
EXECUTION PLAN TEMPLATE 112
EXAMPLE 15: QUANTITATIVE RISK SIMULATION

Published by Anglo American plc AND ANALYSIS 118
Designed and produced by Creativity EXAMPLE 16: EXECUTION PLANNING AND

SCHEDULING 124
EXAMPLE 17: WORK BREAKDOWN STRUCTURE 126
EXAMPLE 18: DEMOLITION PLAN 136
EXAMPLE 19: CLOSURE MAINTENANCE AND

MANAGEMENT PLAN 140
EXAMPLE 20: SUGGESTED STRUCTURE

FOR ANGLO AMERICAN CLOSURE PLANS 142
ACRONYMS 147
ANGLO AMERICAN MINE CLOSURE TOOLBOX EXAMPLES VERSION 3 1

Return to Contents page
EXAMPLE 1: ESTABLISHING THE ZONE OF

INFLUENCE OF THE PROJECT
The Navigation Plant at Landau Collieries, South Africa.
INTRODUCTION that are directly due to the development (e.g. loss of

fisheries due to water contamination). Induced impacts
The Zone of Influence (ZoI) is the area within which a are due to unplanned, unintended or secondary
development has material impacts or can influence impacts. activities that are ‘catalysed’ by the development (e.g.
Typically the ZoI is unique to each project, is larger than the illegal logging along access routes). Cumulative impacts
actual project footprint, and encompasses: are as a result of numerous individual activities, which
• The area of direct disturbance that includes the may be insignificant on their own, but which can interact
‘footprints’ of areas immediately adjacent to the or combine to cause significant impacts.
primary and service infrastructure, such as power lines, • The development’s primary labour sending and
pipelines, roads, railway lines, conveyors, borrow pits, money spending area(s) (i.e. the towns and communities
disposal areas, construction camps. that are likely to experience economic benefits from
• The area directly affected by the project’s adverse the project).
impacts, such as groundwater cones of depression, • Surrounding areas that could potentially benefit from
groundwater pollution plumes. the project through increased security such as sites of
• The area affected by secondary, induced or cumulative high biodiversity and protected areas.
impacts. Secondary impacts arise from other impacts
2 ANGLO AMERICAN MINE CLOSURE TOOLBOX EXAMPLES VERSION 3

Associated facilities should also be considered when but should be based on a sound business case established
determining the ZoI. These are facilities that are funded by considering the risks to the business. It is advisable to
separately by the company or third parties (e.g. government), start with a small, uncomplicated zone and then to enlarge
but whose viability and existence depend almost exclusively on it and increase its complexity, if necessary.
the project and whose goods or services are essential for the
successful operation of the project. In defining the boundary for the ZoI, the following should
be considered:
APPROACH • The influence of the project on the surrounding area and
the influence of the surrounding area on the project.
For each component covered by the baseline investigations, • Linkages with other developments in the area which
the boundary of the project’s extent of influence is could cause ‘ripple effects’ (cumulative impacts) within
determined independently. Thereafter, based on a the ZoI.
composite overlay of each component’s boundary, the • The influence on spatial planning of government
boundary for the overall ZoI is determined. The purpose is development plans and objectives.
not to define a sharp cut-off, but rather to define the area • Other initiatives that may affect the ZoI, such as
where the mine can make a real difference. The ZoI does enterprise development.
not have to be a single area – non-contiguous, niche zones
are acceptable. Spatial zones are most easily defined by Maps in a wide variety of formats, which contain spatial
administrative boundaries, however natural boundaries data on administrative boundaries, land-use, and
(e.g. catchments) and the dynamics of the environmental biodiversity for example, will be obtained during the
systems should also be considered. baseline investigations. To be useful as a planning tool,
the spatial data should be consolidated into a Geographic
The ZoI should not be enlarged to the extent that the Information System (GIS) (Figure 1).
project is in danger of becoming a surrogate government
24°0'0"W 26°0'0"W 27°0'0"W 28°0'0"W 29°0'0"W
!
!
!
NATIONAL PARK
PAN
PAN
23°0'0"N
!
! ! !
!
!
! !
!
! e
!
!
24°0'0"N
GAME RESERVE Letlhakane

Mine
ZONE OF INFLUENCE
Legend
! Town/Major village Mine Lease Area National Park/Game Reserve
25°0'0"N
Water Resources Fence Livestock Farm Wildlife Management Area

River
Tourism Camp Ranch
Tarred Road
Dirt Road Township Ranch
Landuse
Sub-district Lake
Ecology Boundary
Water Body
Social & Economic
N
0 5 10 20 30 40 50
Kilometers
Figure 1: Typical example of a Zone of Influence

EXAMPLE 2: SWOT ANALYSIS
Mogalakwena North Concentrator, South Africa.

INTRODUCTION diversification, good soil conditions, availability of good

quality water.
The purpose of the strengths, weaknesses, opportunities • Threats are unfavourable external conditions that
and threats (SWOT) analysis is to systematically evaluate the environment imposes on development, which in
the proposed project or existing operation within its unique, the absence of proactive management could lead to
surrounding environment. The SWOT analysis evaluates the the project’s underperformance or failure. Examples
actual development (internal) and the broader surrounding include high levels of unemployment and poverty in the
environment within which the development is located area, lack of skills and low levels of education in the
(external). Through this evaluation, an understanding area, lack of other significant economic hubs in close
is developed of the internal or inherent strengths and proximity to the area.
weaknesses of the project and the external threats and
opportunities that the surrounding environment imposes on Approach
or presents for the project. In this context:
• Strengths are internal attributes inherent to the project To implement a SWOT analysis, the following steps are
that can be used to exploit opportunities or reduce or suggested:
overcome threats that the surrounding environment 1. Give a presentation on the SWOT analysis technique, to
may offer or impose. Typical Examples are: physical ensure that all participants have a common knowledge
location close to facilities and labour; internal technical of the technique, process and expected end results.
knowledge; proven sustainable rehabilitation prescription; 2. Divide the participants into smaller sub-groups or work
good availability of monitoring data; potential high value teams, ensuring cross-representation of expertise within
post-mining land-uses (PML’s); and low dependency each team.
rates on the mine in surrounding communities. 3. Let each sub-group independently develop a list of
• Weaknesses are internal attributes inherent to the project strengths.
that would lead to residual impacts and/or contribute 4. Within the full workshop format, combine the individual
to cumulative impacts. Concerted efforts should be sub-team lists into an overall list that reflects the areas
made to reduce or eliminate weaknesses. Typical of consensus.
examples include: Lack of concurrent rehabilitation and 5. Through consensus prioritise the listed strengths,
proven sustainable prescription; presence of sensitive from what is considered to be most important to least
ecosystems or endangered species in the mine lease important.
area; requirement for water treatment in perpetuity due to 6. Repeat steps 3, 4 and 5 for weaknesses, opportunities
acid mine drainage; spontaneous combustion issues; and and threats.
lack of conceptual surface and groundwater models for
the closure scenario. The most significant strengths, weaknesses, opportunities
• Opportunities are favourable or unexploited external and threats should be identified. The project design and
situations that the environment offers development, management strategy should aim to harness the key
which can be harnessed for the project’s advantage strengths and opportunities while avoiding/overcoming the
by proactive management. Examples include threats and weaknesses. This should be reflected in the
unexploited market segments, communities seeking management plans.
poverty alleviation, a high assimilative capacity of the
natural environment, a need for rural water supply, a The outputs from the SWOT analysis should influence the
need for rural energy supply, rapidly growing market development of the closure vision and land-use plan.

EXAMPLE 3: CLOSURE RISK ASSESSMENT
General view of the Unki smelter across granulation to slag tapping in Zimbabwe.

INTRODUCTION
The purpose of this example is to illustrate and highlight

the risk based approach of the MCT.
The following key actions must form part of developing

risk-based closure criteria:
• Identify the key risk that needs to be assessed (e.g.
erosion from waste rock dump batters, visual impact of
tailings dam, local economic impact of mine closure);
• Once the key risks have been identified, list the most
appropriate closure criteria.
• Evaluate the acceptability of a reduced risk compared
to the associated cost of the implementation of the
closure criteria.
• Assess the effectiveness of the selected closure criteria
to mitigate the risk.
• The business case for the inclusion of every closure
criteria should be demonstrated. If you are not reducing
an unacceptable risk to an acceptable level, the cost of
implementing the closure criteria may not be justified.
The example on the next page shows the change in

the risk profile, in terms of pre- and post-implementation
of closure criteria.
It is recommended that only the consequence type with the

highest predicted risk is rated to save time. If there are two
consequence types that are seen to potentially have the
highest predicted risk, then both should be rated.

EXAMPLES OF CLOSURE RISK ASSESSMENT
RATED AS RISK BEFORE IMPLEMENTATION OF CLOSURE CRITERIA
LEGAL & REPUTATION/

ENVIRON- SAFETY REGU- SOCIAL/
MENTAL & HEALTH FINANCIAL LATORY COMMUNITY
Consequence
Consequence
Consequence
Consequence
Conequence
Probability
Probability
Probability
Probability
Probability
Rating
Rating
Rating
Rating
Rating
RISKS FOR TAILINGS FACILITIES AND DAMS AT CLOSURE
1. Tailings Dam
i Seepage from tailings leads to surface or groundwater pollution from 4 4 21
elevated metals or salts within the tailings.
ii Exposed tailings lead to air pollution from dust. 2 4 12
iii Geotechnical failure of tailings dam post closure. 3 3 13
iv Erosion from the revegetated tailings surface leads to sedimentation of 4 4 21

waterways.
2. Pollution Control and Dirty Water Dams

i Liner failure leads to groundwater pollution. 3 4 17
ii Dam overflow or failure leads to soil contamination. 2 3 8

POST-MITIGATION RESIDUAL RISK
LEGAL & REPUTATION/

ENVIRON- SAFETY REGU- SOCIAL/
MENTAL & HEALTH FINANCIAL LATORY COMMUNITY
Consequence
Consequence
Consequence
Consequence
Consequence
Probability
Probability
Probability
Probability
Probability
Rating
Rating
Rating
Rating
Rating
CLOSURE CRITERIA ADDITIONAL MITIGATION
1. Groundwater monitoring. 4 1 10
2. Groundwater modelling.
3. Geochemical testing of tailings.
1. Potential waste rock cladding of 600 mm. 2 1 3
2. Topsoil to be applied at 300 mm.
3. Planting and seeding of thornveld species.
4. Fertiliser addition.
5. Weed control.
1. Original design of tailings facility. 3 2 9 1. Post closure drainage design.
2. Pre closure and final geotechnical stability
review.
3. Operational management control
maintained.
1. Potential waste rock cladding of 600 mm. 3 3 13 1. Drainage and discharge strategy
2. Topsoil to be applied at 300 mm. and surface hydrology design.
3. Planting and seeding of thornveld species. 2. Undertake study to determne
4. Fertiliser addition. whether 600 mm of waste rock
5. Weed control. is required.
1. Groundwater monitors to detect liner 3 1 6

failure during LoA.
2. Removal of dam in closure.
1. Removal of any contaminated soil to 2 1 3
appropriate facility.
2. Removal of dam in closure (unless
required for post-mining land-use).

EXAMPLES OF CLOSURE RISK ASSESSMENT (continued)
REPUTATION/
ENVIRON- SAFETY & LEGAL & SOCIAL/
MENTAL HEALTH FINANCIAL REGULATORY COMMUNITY
Consequence
Consequence
Consequence
Consequence
Conequence
Probability
Probability
Probability
Probability
Probability
Rating
Rating
Rating
Rating
Rating
RISKS FOR WRD’s & STOCKPILES AT CLOSURE
1. Botha, Grant and Bell WRD’s
i Seepage from WRD’s leads to surface or groundwater contamination from 3 3 13
leaching of metals or salts.
ii Geotechnical failure of WRD. 4 3 18
iii Failure of rehabilitation leads to dust issues. 1 3 4
iv Death or injury resulting from accessing WRD’s. 4 3 18
v Design and operational implementation for water contol is inadequate. 3 3 13
vi Over-dumping on WRD leads to increased rehabilitation costs. 4 4 21
vii Erosion from the revegetated WRD surface leads to sedimentation of 3 4 17

waterways.
2. Low Grade Stockpiles

i Seepage from stockpiles leads to surface or groundwater pollution from 2 4 12
leaching of metals or salts within the stockpiles.
ii Erosion from closed rehabilitated stockpiles surface leads to sedimentation 2 4 12

of waterways.

REPUTATION/
Safety & Legal & SOCIAL/
Environmental Health Financial Regulatory COMMUNITY
Consequence
Consequence
Consequence
Consequence
Consequence
Probability
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Probability
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Rating
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Rating
1. Geochemistry evaluated. 3 1 6 1. Review report on geochemistry of

2. Groundwater monitoring. different waste rock types.
3. Further leachate studies recently 2. Geochemical kinetic testing of
conducted. waste rock types if required.
1. Monitoring of WRD’s during operational 4 1 10 1. Review geotechnical
phase. classification and design report.
2. Reshaping of WRD batters to 18 degrees.
1. Monitoring of rehabilitation and 1 2 2

maintenance.
1. Security during mining operational phase. 2 2 5

2. Reshaping WRD’s to 18 degrees.
3. Fencing for game and cattle in post-
closure farm enterprises.
1. Reshaping of WRD batters to 18 degrees. 2 2 5 1. Strategy for each waste rock
2. Topsoil to be applied at 300 mm. landform to be defined (e.g.
3. Planting and seeding of thornveld species. retain, discharge, or partial
Fertiliser addition. retain and release in large storm
4. Installation of structures according to events).
stormwater plan.
1. Preparation of WRD dumping plans. 3 3 13 1. Establish in-field marking system

for dump limits.
2. Use in truck alarms to indicate
dumping limits.
1. Reshaping of WRD batters to 18 degrees. 2 2 5 1. Install sediment traps in landform
2. Topsoil to be applied at 300 mm. discharge areas.
3. Planting and seeding of thornveld species.
Fertiliser addition.
4. Installation of structures according to
stormwater plan.
1. Groundwater monitoring during 1 2 2

operational phase.
2. Removal of stockpiles at closure phase.
3. Golders residue and geochemistry studies.
4. Testing and removal of contaminated
material.
1. Retain pollution control dams until all 1 2 2
stockpiles removed.
2. Stormwater design for plant area
implemented.

REPUTATION/
ENVIRON- SAFETY LEGAL & SOCIAL/
MENTAL & HEALTH FINANCIAL REGULATORY COMMUNITY
Consequence
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Conequence
Probability
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RISKS FOR OPEN PITS AT CLOSURE
1. Botha, Grant and Bell Pits
i Seepage from pit leads to ground water contamination. 4 4 21
ii Long term impact of pit on groundwater levels. 2 4 12
iii Geotechnical failure of pit wall with insufficient relaxation zone leading to the 5 4 24
abandonment berm being compromised.
iv Death or injury resulting from accessing pit, pit wall rockfall, swimming or 5 4 24
recreational use.

REPUTATION/
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1. Groundwater monitoring. 3 4 17 1. Post closure water balance

2. Groundwater modelling provided for prepared.
operational and high level closure 2. Water quality of pit lake
estimates. modelled.
3. Potential to enhance recharge
of pit lake by directing landform
and surface runoff toward pits.
1. Groundwater monitoring. 2 2 5
2. Groundwater modelling (50 years to
reach final water level).
1. Geotechnical monitoring during LoA. 3 3 13 1. Identification of Factor of
2. Control pre-split blasting. Safety (FoS) 1.5 relaxation zone
3. Top bench to be reshaped to 33% slope. through modelling.
4. Location of access berm and trench
beyond the zone of relaxation.
1. Pit Wall control - controlled blasting and 3 3 13 1. Install signage.

catchment berms. 2. Cut access ramps.
2. Install 2 m high berm with 1 m deep
trench on perimeter of pit outside
relaxation zone.

REPUTATION/
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RISKS FOR WASTE AT CLOSURE
1. Sewage Works
i Groundwater contamination from sewage spill. 2 3 8
ii Soil contamination from sewage spill. 1 2 2
2. Domestic Waste Site

i Sterlisation of land from waste site footprint. 1 3 4
3. Hazardous Waste Site

i Surface or groundwater pollution from hazardous waste site. 2 2 5
ii Soil contamination from hazardous waste site. 1 1 1
4. Other Waste
i Disposal of contaminated building rubble onsite. 2 3 8
ii Potential resource wastage by not recycling scrap metal. 3 1 6
iii Recycling of tyre stockpiles does not occur progressively during the LoA 3 3 13
v Radioactive Density Guages disposed of incorrectly. 4 2 14

REPUTATION/
Consequence
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1. Groundwater monitoring during LoA. 2 2 5 1. Pipeline integrity testing and

maintenance.
1. Test soil after demolition. 1 1 1
2. Identify contaminated soil.
3. Remove contaminated soil to
bioremediation facility.
1. Reshaping of domestic waste site. 1 2 2

2. Topsoil capping of 300 mm.
3. Planting and seeding of trees and
grasses. Fertiliser application.
4. Weed control.
1. Groundwater monitoring during LoA. 1 1 1

1. Any residual contamination will be 1 1 1
removed from site and disposed at
appropriate facility.
1. Testing of material for contamination. 1 2 2

2. Only clean material will be disposed on
site.
3. Contaminated material will be transported
to suitable facility and disposed.
1. Develop salvage strategy. 1 1 1
2. All scrap metal will be recycled.
1. Recycle tyres during LoA. 3 2 9 1. Develop disposal strategy if
contractor does not meet their
commitments.
1. Record location of radio-active waste. 4 1 10
2. Dispose of material to regonal supplier
during closure.

REPUTATION/
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RISKS FOR SURFACE INFRASTRUCTURE AT CLOSURE
1. Processing Plant:
i Resource wastage due to inability to sell or recycle components of the plant. 3 2 9
ii Surface or groundwater contamination from processing plant chemicals and 3 3 13

hydrocarbons.
iii Air pollution from dust due to inadequate closure revegetation. 2 4 12
2. Workshops and Offices:

i Resource wastage due to inability to sell or recycle components of the 3 2 9
workshop and offices.
ii Surface or groundwater contamination from workshop and office materials. 3 3 13
iii Air pollution from dust due to inadequate revegetation. 2 4 12
3. Electrical Sub-stations, Fuelling Stations and Explosives Magazines:

i Resource wastage due to inability to sell or recycle components of the 2 2 5
electrical, fuelling or explosives magazine infrastructure.
ii Ineffective disposal of hazardous wastes from electrical sub-stations. 3 3 13
iii Surface or groundwater contamination from hydrocarbon spills at fuelling 3 3 13

stations.
iv Surface or groundwater contamination at explosives magazine. 2 3 8
4. Mine housing, accommodation and service infrastructure in town:

i Resource wastage due to inability to sell or recycle components of the town 4 4 21
infrastructure.
ii Responsibility for service infrastructure is not taken over by municipality. 3 4 17

POST-MITIGATION RISK ASSESSMENT
REPUTATION/
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1. Develop asset disposal strategy. 2 2 5

2. Sell equipment as going concern.
3. Recycle material that cannot be sold as is.
1. Surface and groundwater monitoring 1 2 2
during LoA.
2. Testing of residual soil material post
demolition.
3. Removal of identified contaminated
material during closure.
1. Topsoil applied at 300 mm. 1 2 2
2. Planting and seeding of indigenous grass,
trees and shrubs. Fertiliser application.
3. Control of weeds.

during LoA.
2. Testing of material post demolition.
1. Topsoil applied at 300 mm. 1 2 2

1. Identify locations of PCB’s. 2 1 3
2. Dispose of PCB’s using appropriate
methods at an offsite location.
1. Regular leak detection. 2 1 3

2. Testing of soil material for contamination.
3. Identified contaminated material will be
processed through bioremediation plant.
during LoA.
2. Testing of material post demolition.
1. Develop asset disposal strategy. 3 3 13 1. Spread sale of houses out

2. Sell infrastructure as going concern. over the 20 year maintenance
3. Lease or donate buildings to third parties. and monitoring phase to avoid
4. Demolish other structures and recycle market saturation.
material.
1. Municipality owns assets with site paying 3 4 17 1. Engage municipality in transition
for operational costs. to operating these assets.

REPUTATION/
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RISKS FOR SURFACE INFRASTRUCTURE AT CLOSURE
5. Roads, Railways, Powerlines, Telephone lines, Pipelines and Fences:
i Compaction of roads not mitigated leading to poor establishment of 4 4 21
vegetation.
ii Decommissioning and removal of railway system costs more than current 4 4 21

liability allowance.
ii Resource wastage due to inability to sell or recycle components of railway, 3 2 9

telephone, pipeline and powerline infrastructure.
iii Inability to protect and make secure offsite infrastructure assets in the 4 4 21
closure phase.

REPUTATION/
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RISKS FOR BIO-PHYSICAL ASPECTS AT CLOSURE Rating

1. Biodiversity/Fauna/Flora/Protected Habitats/Ecosystems
i Loss of ecosystem composition, structure and/or function due to poor 3 3 13 3 3 13
rehabilitation standards.
ii Loss of species or ecosystems through clearing. 3 4 17
iii Inadequate management (e.g. fire, weeds, erosion, grazing) of rehabilitation 3 3 13

leads to failure.
iv Artisinal miners enter site and inadvertently destroy rehabilitated areas. 2 3 8
v Loss or damage of archaeological and heritage areas during closure. 2 3 8

POST-MITIGATION RISK ASSESSMENT
REPUTATION/
Consequence
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1. Identify which roads are to remain and 2 2 5

those to be removed.
2. Remove bitumen if necessary.
3. Deep rip compacted surfaces (>1 m).
4. Topsoil applied at 150 mm.
1. Currently removal of rail and recycle for 3 3 13 1. Confirm that responsibility
first 11 km. for decomissioning will be
2. Removal of ballast. transferred to landowners beyond
3. Shape and revegetate as per roads. the Min elease boundary.
2. E
nsure that reshaping costs are
included in the closure costing.

3. Recycle material that cannot be sold
as is.
1. None in current plan. 4 4 21 1. Include off-site security and safety
strategy within mine closure plan
and associated costing.

REPUTATION/
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1. Reshaping of areas to blend in with 2 2 5 3 2 9

surrounding topography.
2. Topsoil applied at 300 mm.
3. Seeding and planting of native grasses,
5. Monitoring and maintenance to return
grazing capacity.
1. Voluntary offsets areas identified and in 2 2 5
place.
2. Biodiversity action plans in place and
being implemented.
1. Develop a rehabilitation strategy 2 2 5 1. Monitor rehabilitated areas
incuding a vegetation management plan. against success criteria once
2. Fire and weed management plans within developed.
biodiversity action plan.
3. Implement maintenance as required.
4. Implement management plan.
1. Maintain security during closure phase. 1 2 2
2. Incorporate rehabilitated areas into game
farming enterprises with associated
fencing and security.
1. Implement heritage resourses 2 2 5
management plan.

REPUTATION/
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Consequence
Consequence
Consequence
Conequence
Probability
Probability
Probability
Probability
Probability
Rating
Rating
Rating
Rating
Rating
RISKS FOR BIO-PHYSICAL ASPECTS AT CLOSURE
2. Groundwater
i Calcification of groundwater aquifer leads to reduced flow and availability of 2 4 12
water to benificial users.
ii Permanent reductions in groundwater levels (close to pits). 2 5 16
iii Development of sinkholes (surface subsidence) due to dewatering of 4 3 18

dolomite aquifers.
iv Change in groundwater flow direction. 2 3 9
3. Surface water
i Fragmentation of drainage lines impacts ecological functioning. 4 4 21
4. Drought and Fire

i Drought leads to poor plant establishment and development of rehabilitation. 3 4 17
ii Fire leads to rehabilitation failure with poor regeneration. 3 3 13
5. Soil, land capability, land use

i Lack of topsoil leads to poor rehabilitation quality. 2 5 16
ii Poor topsoil stockpile management leads to lower availability and poor 2 3 8

rehabilitation quality.
iii Proliferation of weed species in rehabilitated areas and surrounding 3 3 13

vegetation.
iv Loss of agricultural land use from tailings dam footprint. 3 5 20

REPUTATION/
Consequence
Consequence
Consequence
Consequence
Consequence
Probability
Probability
Probability
Probability
Probability
Rating
Rating
Rating
Rating
Rating
1. Install necessary monitoring. 2 3 8 1. Develop and run model to

estimate calcification risk.
1. Install necessary monitoring. 2 5 16 1. Consider diversion of local run-off
2. Modle final pit water level. into pits.
1. Dolomite (subsidence) risk management 3 2 9

plan implemented.
2. Surface subsidence management
procedure.
3. Areas are identified, isolated and
backfilled.
1. Install necessary monitoring. 2 2 5
2. Model final pit water level.
1. Temporary diversion structures are 3 2 9

removed and origingal flowpath
reinstated.
2. Permanent diversion structures
engineered for 100 year ARI.
3. Quarterly flora and fauna monitoring in
undisturbed areas to assess impacts.
1. Water rehabilitated areas. 2 3 8 1. Water retaining strategy to enhace

2. Use drought tolerant species in the seed rehabilitation, deep contour ripping
mix. with winged tynes, water bunding
and/or water retention.
1. Ensure that species mixes contain fire 2 2 5 1. Fire control plan in place
adapted and fire resistant species. around rehabilitated areas to
2. Continue to implement fire management ensure wildfires do not enter
plan in closure phase. rehabiiliitation too early.
3 Retrain closure staff as fire fighting crew.
1. Directly place topsoil where possible. 2 2 5

2. Ensure topsoil stockpiles are constructed
to standard and protected.
3. Optimise utilisation of topsoil.
4. Use thinner topsoil coverage (150 mm)
on the top of dumps.
5. Use compost or cocoflex as a topsoil
substitute.
1. Directly place topsoil where possible. 1 2 2
2. Ensure topsoil stockpiles are constructed
to standard and protected.
3. Optimise utilisation of topsoil.
1. Weed management is included in the 2 2 5
Biodiversity Action Plan (BAP).
2. Monitor rehabilitated areas regularly and
apply adaptive management.
3. Implement defined actions where weed
proliferation is identifed.
1. Rehabilitation processes for different 3 2 9
domains with grazing as the primary
land-use.


REPUTATION/
Consequence
Consequence
Consequence
Consequence
Conequence
Probability
Probability
Probability
Probability
Probability
Rating
Rating
Rating
Rating
Rating
RISKS FOR BIO-PHYSICAL ASPECTS AT CLOSURE
6. Topography/visual
i Decrease in landscape character due to poor landform design to blend in 3 3 13
with surrounding topography

REPUTATION/
MENTAL
Consequence HEALTH FINANCIAL REGULATORY COMMUNITY
Consequence
Consequence
Consequence
Conequence
Probability
Probability
Probability
Probability
Probability
Rating
Rating
Rating
Rating
Rating
RISK ISSUES FOR SOCIO-ECONOMIC ASPECTS AT CLOSURE
1. Economic
i Under estimation of closure liability. 4 3 18
ii Under estimation of preliminary and general costs. 4 4 21
iii Increasing closure cost over time due to inadequate progressive 4 3 18
rehabilitation.
iv Inadequate monitoring delays lease relinquishment. 2 4 12

REPUTATION/
Consequence
Consequence
Consequence
Consequence
Consequence
Probability
Probability
Probability
Probability
Probability
Rating
Rating
Rating
Rating
Rating
1. Reshape WRD’s to 18 degrees. 2 1 3

2. Revegetation of WRD’s.
3. Monitoring and maintenance.

REPUTATION/
Consequence
Consequence
Consequence
Consequence
Consequence
Probability
Probability
Probability
Probability
Probability
Rating
Rating
Rating
Rating
Rating
1. Regular updates to closure costing rates. 3 2 9

1. The site uses 25% rate for P&G’s. 2 2 5
1. Implement rehabilitation strategy. 3 3 13 1. Development of 10 year
2. Undertake rehabilitation activities using rolling rehabilitation plans and
own equipment. associated costing as required
3. Bank guarantee provided to regulator. under new closure regulations.
1. Implement existing monitoring 2 3 8 1. Develop closure monitoring
programme. programme aligned with success
criteria.

5 X 5 MATRIX NEW
PROJECTS RISK MATRIX CONSEQUENCE (Where an event has more than one ‘Consequence Type’, choose the ‘Consequence Type’ with the highest rating)
Consequence type 1 – Insignificant 2 – Minor
Schedule. Less than 1% impact on overall project timeline. May result in overall project timeline overrun equal to or more than
1% and less than 3%.
Cost. Less than 1% impact on the overall budget of the project. May result in overall project budget overrun equal to or more than
1% and less than 3%.
Quality and Technical No significant impact on quality of deliverables or effect on Quality issues that can be addressed prior to handover or could
Integrity. production. affect production by more than 1% and less than 3%.
Safety. First aid case. Medical treatment case.

Occupational Health. Exposure to health hazard resulting in temporary discomfort. Exposure to health hazard resulting in symptoms requiring medical
intervention and full recovery (no lost time).
Environment. Lasting days or less; affecting small area (metres); receiving Lasting weeks; affecting limited area (hundreds of metres);
environment highly altered with no sensitive habitats and no receiving environment altered with little natural habitat and low
biodiversity value (e.g. urban /industrial areas). biodiversity value.
Legal and Regulatory. Technical non-compliance. No warning received; no regulatory Breach of regulatory requirements; report/involvement of authority.
reporting required. Attracts administrative fine.
Social/Communities. Minor disturbance of culture/social structures. Some impacts on local population, mostly repairable. Single
stakeholder complaint in reporting period.
Reputation. Minor impact; awareness/concern from specific individuals. Limited impact; concern/complaints from certain groups/
organisations (e.g. non-governmental organisations (NGOs) period.
PROBABILITY RISK LEVEL
5 – Almost 90% and 11 16
Certain higher (Medium) (Significant)
>90%. likelihood of
occurring.
4 – Likely Between 7 12
30%-90%. 30% and (Medium) (Medium)
less than
90%
likelihood of
occurring.
3 – Possible Between 4 8
10%-30%. 10% and (Low) (Medium)
less than
30%
likelihood of
occurring.
2 – Unlikely Between 2 5
3%-10%. 3% and less (Low) (Low)
than 10%
likelihood of
occurring.
1 – Rare Less 1 3
<3%. than 3% (Low) (Low)
likelihood of
occurring.
Risk Rating Risk Level Guidelines for Risk Matrix

21 to 25 High A high risk exists that management’s objectives may not be achieved. Appropriate mitigation strategy to be devised immediately.
A significant risk exists that management’s objectives may not be achieved. Appropriate mitigation strategy to be devised as soon as
13 to 20 Significant
possible.
A moderate risk exists that management’s objectives may not be achieved. Appropriate mitigation strategy to be devised as part of the
6 to 12 Medium
normal management process.
1 to 5 Low A low risk exists that management’s objectives may not be achieved. Monitor risk, no further mitigation required.

CONSEQUENCE (Where an event has more than one ‘Consequence Type’, choose the ‘Consequence Type’ with the highest rating)
3 – Moderate 4 – High 5 – Major
May result in overall project timeline overrun of equal to May result in overall project timeline overrun of equal to May result in overall project timeline overrun of 30%
or more than 3% and less than 10%. or more than 10% and less than 30%. or more.
May result in overall project budget overrun of equal to May result in overall project budget overrun of equal to May result in overall project budget overrun of 30% or
or more than 3% and less than 10%. or more than 10% and less than 30%. more.
Quality issues that can be addressed during ramp-up Quality issues that require significant intervention to Quality issues that require significant intervention to
or could affect production by more than 3% and less maintain performance or could affect production by achieve performance or could affect production by 30%
than 10%. more than 10% and less than 30%. or more.
Lost time injury. Permanent disability or single fatality. Numerous permanent disabilities or multiple fatalities.
Exposure to health hazards/agents (over the OEL) Exposure to health hazards/agents (significantly over Exposure to health hazards/agents (significantly over
resulting in reversible impact on health (with lost time) the OEL) resulting in irreversible impact on health with the OEL) resulting in irreversible impact on health with
or permanent change with no disability or loss of quality loss of quality of life or single fatality. loss of quality of life of a numerous group/population or
of life. multiple fatalities.
Lasting months; affected extended area (kiLoAetres); Lasting years; affecting area on sub-basin scale; Permanent impact; affecting area on a whole basin
receiving environment comprising largely natural habitat receiving environment classified as having sensitive or regional scale; receiving environment classified as
and moderate biodiversity value. natural habitat with high biodiversity value. highly sensitive natural habitat with very high biodiversity
value.
Minor breach of law; report/investigation by authority. Breach of the law; may attract criminal prosecution, Significant breach of the law. Individual or company
Attracts compensation/penalties/enforcement action. penalties/enforcement action. Individual licence law suits; permit to operate substantially modified or
temporarily revoked. withdrawn.
On going social issues. Isolated complaints from Significant social impacts. Organised community Major widespread social impacts. Community reaction
community members/stakeholders. protests threatening continuity of operations. affecting business continuity. “License to operate” under
jeopardy.
Local impact; public concern/adverse publicity localised Suspected reputational damage; local/regional public Noticeable reputational damage; national/international
within neighbouring communities. concern and reactions. public attention and repercussions.
RISK LEVEL
20 23 25
(Significant) (High) (High)
17 21 24
(Significant) (High) (High)
13 18 22
(Significant) (Significant) (High)
9 14 19
(Medium) (Significant) (Significant)
6 10 15
(Medium) (Medium) (Significant)

EXAMPLE 4: CLOSURE BENCHMARKING REVIEW
The main conveyor line from the stockpiles at the Saldanha Bay loading facility, South Africa.

INTRODUCTION for further investigation through benchmarking. For

each benchmarking topic, a team comprising a technical
Closure criteria are identified through the risk assessment expert and a site person with relevant expertise should
and gap analysis processes, to support the closure vision be identified. A high level search of existing studies from
and objectives. Existing closure criteria may not always similar mining scenarios should then be conducted at an
be the most suitable or may not reduce residual risk to an international, national, regional and local scale. These are
acceptable level. Undertaking a benchmarking exercise is summarised in a spreadsheet and then discussed further
a practical way of exploring alternative closure criteria that with the broader benchmarking team. A recommendation
may be more effective in reducing residual risk. Ultimately, is then made for identified closure criteria that may be
benchmarking seeks to reduce the closure risk, improve the seen as being more effective than what is currently
closure outcome and realise financial improvements. being proposed (Table 2). In some cases, a decision can
be made immediately to substitute the existing criteria
METHODOLOGY with the closure criteria identified in the benchmarking
exercise. In these cases, it is important that the closure
A good way of identifying closure criteria that may benefit liability is updated to reflect the cost of the substituted
from benchmarking is to look at the risk assessment for closure criteria. More commonly, closure criteria with
residual risks that are significant or high. These should be potential application will be identified that require further
listed and then discussed further with internal stakeholders investigation as to their suitability at the particular
to narrow down the list based on-site knowledge (Table operation. In these cases, the required studies should be
1). Three to five areas should be chosen on this basis identified and added to the Master Action Plan (MAP).
Table 1: Example of risk areas identified from the risk assessment that may be suitable for the benchmarking exercise. Those
that were chosen after discussion with site personnel are in bold.
Risk area Comment

Viability of township. Consolidate with social transitioning.
Social transitioning.
FRD erosion risks.
Geotechnical pit failure. Consolidate with social transitioning.
Regulated waste disposal. Exclude as treatment options known.
Mining infrastructure re-use. Consolidate with social transitioning.
Groundwater depression and contamination.
Alternative growth mediums with topsoil deficit. Consolidate with Landform design and material charaterisation.
Hydrocarbon contamination treatment. Exclude as treatment options are known.
Capillary rise of salts in rehabilitation. Consolidate with Landform design and material charaterisation.
Rehabiitation not meeting land-use. Consolidate with Landform design and material charaterisation.
Landform design and material characterisation.

Table 2: Social Transition – Example of benchmarking spreadsheet with recommendations for further work
SITE ID LOCALITY INFORMATION
Number Country Region Operation Source of Information 1. Social Transitioning Comment Recommendation
1 SA Western Namaqualand 1) “Living Edge of Koingnaas and Kleinzee Learnings on 1. Develop town transformation and
Cape Africa (LEAP)” info were proclaimed in proclamation and selling transition strategy.
to be sources from around 2010. of property, as well 2. Create a Future Forum to engage
De Beers (including as partnerships with external stakeholders.
Pre-Feasibility Study international NGOs and
(PFS)). PFS study. 3. Investigate options for re-use of
mining infrastructure post closure.
2) Info from William
McDonald. 4. Investigate accommodation options in
the game park.
3) https://en.wikipedia.
org/wiki/Kleinzee. 5. Evaluate the viability of the airport
as part of the game park and future
4) https://mg.co.za/ tourism.
article/2011-11-18-
diamond-mines-are-
not-forever/.
5) siteresources.
worldbank.org/
INTOGMC/.../3-Post-
Mining_Alliance-
22Apr09.pdf.
2 SA Northern Lime Acres 1) www.greenkalahari. Was established as Maybe not really relevant
Cape co.za/index.php/lime- a formal town in the to the current mining
acres. early 1930, linked to town.
2) https://en.wikipedia. Lime mining, and later
org/wiki/Lime_Acres. diamond mining, which is
still ongoing.
3 Namibia West Namdeb 1) Oranjemund town Original mine town Very applicable to the
Coast transformation data (10 000 people – 2017), mining town.
(lots). that was procalimed in
2) Freedthinkers projects 2011 and now town
and info. tranformation has been
going on for the part
3)www.travelnewsnamibia. three to five years, but
com/destinations/facts- progress is slow.
on-the-strange-town-of-
oranjemund.
4) https://en.wikipedia.
org/wiki/Oranjemund.
5) https://www.
youtube.com/
watch?v=IV0l3AMjwSc.
6) https://www.
industryabout.
com/.../diamond-
mining/38589-
oranjemund-diamond-
min.
4 Canada North Elliot Lake 1) Retrospect findings A former boom-and-bust The learnings from Elliot
America (Report done by DeBeers). uranium town, Elliot Lake lake, especially related
(Ontario) 2) https://www. fell on hard times in the to partnerships, funding
theglobeandmail.com/ early 1990s when the and timelines could be of
globe-investor/retirement/ last mines closed for great value to the mining
elliot-lake-offers-simple- good. Since then, with town.
rugged-beauty-and- some success, Elliot
affordability-for-seniors/ Lake has promoted
article1 934231/. itself as a retirement
community tailored for
3) www.cityofelliotlake. outdoors enthusiasts
com/en/cityhall/history. looking to stretch their
asp. retirement savings.
4) https://www. Elliot Lake Retirement
youtube.com/ Living, a private non-
watch?v=mwBqmx3Dei0 for-profit organisation
5) https://en.wikipedia. responsible for
org/wiki/Elliot_Lake. marketing the city to 50-
plus retirees, manages
more than 1,500 units
of rental properties once
owned by the area’s
mining companies.

Mafube Colliery, South Africa.

EXAMPLE 5: PHYSICAL CLOSURE COST

CALCULATION SPREADSHEET AND DRAWINGS
Mareesburg Tailings Facility which will be used to take material from the Mototolo Concentrator, South Africa.
INTRODUCTION estimate required for this mine is an “Improved class 5

estimate” (L: -20% to -50%; H: +30% to +100% with a
This example describes how to develop a closure liability contingency (P50) of 25% -40%). This example lists the
estimate, by giving guidance on how to develop the closure criteria and the assumptions that were made in
closure criteria, including assumptions related to the cost estimating the closure cost. The final LoA closure cost was
estimate. It also describes how to ensure the full scope determined, taking into consideration ongoing rehabilitation
of the closure plan is covered, by linking structures and throughout the operational phase of the mine.
facilities on the general layout drawing to cost items in
a spreadsheet. This example describes Mine A, that is The details of this example can be viewed in the
a mine situated in Botswana and has a remaining life of “Examples Document” of the Mine Closure Toolbox
asset of 24 years (2005 is the base date). The closure Version 2, dated 2013.

EXAMPLE 6: COMPLETED GAP ANALYSIS AND

ACTION PLAN
INTRODUCTION to a “Draft Closure Plan” by the end of 2020. The
proposed project schedule is attached as Appendix C.
This example focuses on the information gaps that
were identified during the gap analysis workshop CURRENT STATUS OF MINE CLOSURE
(Tool 2 of the MCT) that took place at a small open PLANNING
pit mining operation in Southern Africa referred to as
Mine B in June 2019. The completed “Gap analysis” Based on current mine planning, the mine is planned to
spreadsheet is attached in Appendix A. be closed by the end of 2032. This means that the mine’s
current level of mine closure planning should be at the level
Tool 3 of the Toolbox identifies the detailed steps that of a “Draft Closure Plan” as reflected in the “15-10 years”
must be taken to fill the gaps identified in the gap column of the spreadsheet contained in Appendix A. This is
analysis. It has been used to identify the outstanding however not the case, as the mine currently does not have
scope of work in updating the current mine closure a mine closure plan that addresses all the requirements as
plan. The various applicable “Tasks” and “Steps” from defined for a “Draft Closure Plan”.
Tool 3 are noted in the “Master Action Plan” (MAP) as
Appendix B. The process of developing a Draft Mine Closure Plan
(Improved Class 5 estimate) over the next 18 months is
The aim of the project is to upgrade the current reflected in the MAP in Appenidx B and its associated
mine closure plan from a “Preliminary Closure Plan” completion schedule in Appendix C.
New filter press under construction at Mototolo Concentrator - part of the mitigation for the Helena Tailings Dam Project, South Africa.

APPENDIX A: COMPLETED GAP ANALYSIS
EVALUATION SPREADSHEET: As completed on 5 June 2019
Time remaining
to scheduled
closure More than 25 years 25-15 years 15-10 years 10-5 years
Item description Preliminary Closure Plan Draft Closure Plan Detailed Closure Plan
Physical closure
Physical closure criteria
Infrastructure (on Following a risk-based Relevant discipline experts The closure criteria recommended The criteria have through
and off-site). approach, a complete set have undertaken a desktop by the relevant discipline onsite or industry execution
The mine has of closure criteria has been investigation into the closure experts have, where appropriate, been demonstrated and
one plant (10 developed and costed. The methodology and criteria, to been reviewed and updated accepted to be successful.
ha), including criteria used (BoE) in the confirm the current criteria or by undertaking a site-specific I&APs and authorities have
workshops, closure cost estimate are to establish more appropriate investigation into the closure been consulted and are in
offices, stores, based on experience and criteria (BoE). methodology. The granularity of the majority satisfied with the
plant fencing, available information. the criteria (BoE) has improved closure and success criteria.
and other and also includes infrastructure A detailed asset register is
infrastructure. maintenance requirements, available that differentiates
The offsite waste disposal and recycling between demolition, disposal
surface requirements, asset disposal and retention. An asset
infrastructure categories and an associated management strategy and
on the current register. plan, including the Stakeholder
property Engagement Plan (SEP),
constitutes some GAPS: master action plan and
power lines (17 1) Demolition waste disposal schedule with cashflow, have
km), overland and recycling requirements and been developed.
water supply volumes have not been defined
lines (30 km in sufficient detail.
from a wellfield), 2) The closure criteria are well
unsealed roads defined, but no consultation
(20 km) and has taken place with I&APs
some telephone to confirm the acceptability of
lines the closure criteria, especially
(12 km). related to social infrastructure
The current mine (e.g. on-site housing).
property also
contains eight
management
houses, a lapa
with eight
wooden cabins,
four units at a
caravan park,
five mobile units,
and three pre-
fabricated units
accommodating
90 employees).
Most employees
reside offsite.
Reference:
Presentation
by mine –
June 2019;
Preliminary
Closure Plan and
cost estimate
(including
detailed Basis
of Estimate
(BoE) for the
mine – March
2019. Asset
disposal register
dated Feb 2019.
Infrastructure
maintenance
plan dated April
2018.

5-0 years 0-15 years
5-3 years 2-0 years 0 - 5 years 5 - 15 years
Final Closure Plan Decommissioning Monitoring and Maintenance
Closure execution planning, The detailed closure execution The decommissioning plan includes A detailed post decommissioning
scheduling and costing have planning, scheduling and costing all the project management and risk monitoring and maintenance
been completed to a Prefeasibility have been completed and all controls associated with effective plan is in place that tracks
B “PFS-B” level, as per the AA execution documentation have project execution and tracking in risk management, financial
Investment Development Model been completed by improving the place. The success of the project is performance, ongoing progress,
(IDM) requirements with the key PBS-B study to that of a Feasibility tracked against Key Performance stakeholder engagement,
execution documents being (but Study (FS) level, as per the AA IDM Indicators (KPIs), such as budget, success criteria and ultimately
not limited to): requirements, that will contain the progress, community and regulatory relinquishment of assets.
following additional deliverables acceptability and meeting the
• Project Charter, Study Execution (but not limited to): overall agreed success criteria. See Tool 5 for details on
Plan, Project Execution Plan, Work project execution planning and
Breakdown Structure (WBS), • Logistics Management Plan, See Tool 5 for details on management.
Detailed Execution Schedule, Change Management Plan, project execution planning and
Project Risk Register; SEP, Legal Engineering Management Plan, management.
Register, Financial Plan, Model and Procurement Management Plan;
Report. Environmental Management
Plan, and Document Control
• Cost benefit analyses have been Management Plan.
undertaken on alternative uses for
infrastructure and equipment post • Where appropriate, some
closure (in line with the final land- of the work packages have
use plan). gone out to tender and are
ready for order placement and
• Work packages have been costed execution (especially the work
and the execution plan scheduled as scheduled for the 1st year of
and resourced. The trade-off study decommissioning).
between owner vs. contractor
execution has been completed.
• The relevant authorities have
signed off the closure and success
criteria. Other I&APs have been
engaged to the appropriate level of
influence.

APPENDIX A: COMPLETED GAP ANALYSIS (continued)
Time remaining
to scheduled
Physical closure
Mineral Waste Following a risk-based Relevant discipline experts Relevant discipline experts Final post closure landform
Landforms: approach, the closure criteria have improved the landform have undertaken a site-specific design and execution is fully
The mine has and conceptual final landform designs. High-level cost benefit investigation into the closure integrated into LoAP, as part
one fine residue designs are available and analysis has taken place to methodology and criteria, to of the ongoing deposition
deposit (FRD) based on the planned LoA evaluate significant technical, confirm the current criteria or strategies. The cost of closure
that is 20 m tonnage/volume of mineral environmental and operational to establish more appropriate execution is tracked as part
high and 25 ha residue and stockpile material. considerations, and the potential closure criteria. The executability of the operational financial
footprint, one The landform designs also impact on mining operations of the closure criteria and the reporting and the benefit
coarse residue consider the following key and costs. The landform designs cost effectiveness of the designs of integrated LoAP and
deposit (CRD) components: were improved by undertaking have been demonstrated by onsite closure strategies measured.
that is 40 m high the following: execution and rehabilitation. The The landform designs were
with a 50 ha 1) Material volumes and landform designs were improved improved by undertaking the
1) Material volumes and
footprint and a characterisation: by undertaking the following: following:
100 ha waste A high-level material balance characterisation:
rock dump that is is in place, reflecting key A detailed balance is in place 1) Material volumes and 1) Material volumes and
60 m high (20 m mineral residue volumes for hostile and non-hostile characterisation: characterisation:
benches). over the LoA, including the material, reflecting all current A detailed balance is maintained Detailed balance is in
required growth medium for and future mineral waste for hostile and non-hostile place for hostile and non-
Reference: rehabilitation purposes. Material volumes and requirements. material (live system), reflecting hostile material and it can
Presentation characterisations have been no shortfall in materials to execute be demonstrated that the
by mine – 2) Management of hostile
undertaken at a high level material: the closure plan. landform development
June 2019; to identify and quantify inert sequencing considers
Preliminary Geochemical testing (at least
material vs. hostile material (e.g. 2) Management of hostile scheduled material movements
Closure Plan and potential Acid Metalliferous static and kinetic tests) has
been completed on the various material: by waste type and costs are
cost estimate for Drainage (AMD), spontaneous Additional kinetic testing has supported by equipment
the mine – March combustion, dispersive material, hostile materials.
been completed where required requirements.
2019. General saline material). 3) Availability of footprint: and the monitoring programme is
layout drawing The final landform designs demonstrating successful onsite 2) Management of hostile
dated January 2) Management of hostile compliment the final land-use containment and remediation. material:
2019. Cost material: plan. Operational deposition Ongoing monitoring can prove
benefit analysis The required management strategies allow for reduction 3) Availability of footprint: landform stability and provides
dated September measures and closure criteria in future material double Final landform execution is seepage analyses, as well as
2015. have been included in the handling and optimisation of tracked to ensure it is aligned drainage/effluent water
Updated: landform design to address concurrent rehabilitation. with the plan and sufficient quality projections.
Landform design the long-term impacts of space is available for concurrent
4) Landform stability:
dated April 2018. hostile materials (e.g. selective rehabilitation. LoAP allows for 3) Availability of footprint:
Landform stability has been
Detailed material placement vs. capping and/or sufficient available areas to I&APs and authorities
re-evaluated, based on
balance dated lining). undertake landform closure have been engaged to the
erosion modelling results
January 2018. execution (shaping and appropriate level of influence
and more detailed long-term
3) Availability of footprint: rehabilitation). on the final landform designs
flooding designs. A monitoring
Stormwater The landform design does and are satisfied with the
programme is in place to
design and take into consideration the 4) Landform stability: closure and success criteria
validate landform stability
layout drawings current and future footprint Effectiveness of management (majority agreement).
predictions.
dated January requirements, especially measures and closure criteria
2019. Geochem considering final slopes. The 5) Water management: are being tracked and monitored 4) Landform stability:
report by enviro requirements of the final Water management design and required changes made to Final capping and or reshaping
lab dated landform designs are included ensures clean and dirty water improve long-term stability and designs have been completed
January 2018. in the LoAP parameters. separation post closure (e.g. reduce costs. and costed, including
storm water diversions). construction sequencing
4) Landform stability: GAPS: 5) Water management: requirements to
Landform stability has been 2) Management of hostile The effectiveness and long- maintain long term physical
evaluated through geotechnical material: Only static term sustainability of water and chemical stability.
and erosional studies. Key geochemical testing has management structures and
considerations include typical been completed on the measures are tracked and 5) Water management:
erosion challenges, possible various hostile materials. improved as required. The effectiveness and long-
flooding and where applicable term sustainability of water
earthquake conditions. 4) Landform stability: management structures can
Landform stability has been be demonstrated.
5) Water management: re-evaluated, based on
Conceptual water management erosion modelling results
planning has been undertaken and more detailed long-
and the closure requirements term flooding designs,
of these facilities included in however a monitoring
the design and costing. programme is not in place
to validate landform stability
predictions.
6) Current level of
confidence for mineral
waste landforms is not
aligned with that required
for a mine with between
15-10 years LoA (See Tool 2
requirements).
Closure execution planning, The closure execution PFS-B (See Infrastructure section for (See Infrastructure section for
scheduling and costing have been study has been improved to that detailed requirements). detailed requirements).
completed to a PFS-B level, as per of a FS level, as per the AA IDM.
the AA IDM. requirements. The specific mineral
residue and landform deliverables
The specific mineral residue and being (but not limited to):
landform deliverables being (but
not limited to): • Final agreed detailed landform
designs, including selective
• Final post closure landform placement of various closure phase
designs, supported by detailed mine related waste types (hostile and
equipment requirements. non-hostile material, generated
• Seepage analyses and the due to closure activities, e.g.
landform water balance and water demolition rubble, contamination
management plan, for facilities and below infrastructure, etc.) and
surrounding areas. the geochemical stability of the
facilities.
• Description of water management
and diversion works in a post- • Detailed engineering designs,
closure condition, including risk including contact and non-contact
assessment, and risk mitigation plan.water diversion and management,
landform water balance, stability
• The trade-off study between owner and seepage analyses, water quality
execution vs. contractor execution. and water treatment requirements,
are included in the final design
• The relevant authorities have and costed.
signed off the closure and success
criteria and other I&APs have been • The detailed execution planning,
consulted. scheduling and costing have been
undertaken and all execution
• Execution planning, scheduling and documentation have been
costing have been undertaken and completed (see Infrastructure
key execution documentation have section for more details).
been completed (see Infrastructure
section for more details).

Time remaining
to scheduled
Physical closure
Non-Mineral Following a risk-based Relevant discipline experts Relevant discipline experts have Relevant discipline experts
Waste: approach, a complete set have improved the non-mineral improved the non-mineral waste have improved the non-mineral
The mine has a of closure criteria has been waste strategy and plan by strategy and plan by undertaking waste strategy and plan by
small licensed developed and costed for undertaking the following: the following: undertaking the following:
domestic the non-mineral waste
disposal site, but facilities including long-term Identification and Identification and classification: A Identification and
disposes the bulk management. classification: All non-mineral Non-mineral waste register is in classification:
of their domestic waste streams have been place and is actively managed. Studies have been completed
waste at the Waste Identification and identified and current and on waste beneficiation and
classification: Key non-mineral future volumes have been Regulatory requirements:
local municipal Regulatory requirements related alternative solutions to waste
site. A 3rd waste streams are known and calculated. disposal and management
estimated current and future to the various waste streams
party disposes Regulatory requirements: are tracked in a live legal and (e.g. reclassification of waste).
of all hazardous volumes have been predicted. A non-mineral waste register
Regulatory requirements permitting system and forecasted
waste (18 ton Regulatory requirements: related to the various waste changes in legislation are is in place and is actively
per quarter) and Regulatory requirements streams are known (e.g. permit considered in the updated closure managed.
all hydrocarbon related to the various waste conditions) and forms part of criteria (e.g. more stringent future
waste is recycled Regulatory requirements:
stream are known (e.g. permit the closure criteria. legislation).
by the suppliers. The authorities have been
conditions) and forms part of
the closure criteria. Waste disposal options: A Waste disposal options: A detailed consulted to obtain agreement
Reference: high-level trade-off study cost benefit analysis has taken on the success criteria.
Presentation by Waste disposal options: A has taken place to compare place and the closure planning Waste disposal options: The
the mine – 5 decision on undertaking onsite onsite vs. offsite disposal and costing have been updated final waste management and
June 2019. or offsite disposal form part and the closure planning and accordingly. disposal strategy (including
General layout of the closure planning and costing have been updated
Waste management and facilities: permission for onsite disposal
drawing dated costing. accordingly.
Operational success can be of inert waste) has been
January 2019.
Waste management and Waste management and demonstrated and the costs agreed with the authorities
Non-mineral
facilities: Non-mineral waste facilities: Operational costs associated with non-mineral and the closure planning and
waste strategy
management procedures associated with non-mineral costing have been updated
dated June waste management is tracked and
are in place, including the waste management is known. accordingly.
2015. Live used to improve the costing in
management of onsite waste Onsite waste disposal facilities
legal data base the closure liability. Onsite waste Waste management and
disposal facilities. are managed. The current
and permitting disposal facilities are managed facilities: Discussion has
capacity of off-site waste
system called taken place with offsite
disposal facilities is known. and the effectiveness of closure
“Landfolio”. Cost waste disposal operators to
benefit analysis criteria is tracked. The current
Closure criteria: The closure secure future waste disposal
dated September risk assessment has been and future capacity of off-site
2015. Offsite waste disposal facilities have been capacity and corporate social
updated and all risks have
waste disposal investigated and forms part of the investment projects are in
been classified as either
capacity significant, insignificant or updated closure criteria. place to facilitate future offsite
report by GES unknown. The complete set Closure criteria: The closure risk disposal capacity.
consultant, date of closure criteria have been assessment has been updated Closure criteria: The closure
January 2018. updated to align with the and all previous unknown risks risk assessment has been
Update closure success criteria. updated and improved to
have been re-classified as either
risk assessment be more quantitative than
dated February significant or insignificant. The
complete set of closure criteria qualitative and by including
2019.
have been updated to align with I&APs inputs. The complete
the success criteria. set of closure criteria have
been updated accordingly.
GAPS:
Closure criteria: The closure
risk assessment has been
updated and all previous
unknown risks have been re-
classified as either significant
or insignificant, but success
criteria have not been
developed.

Closure execution planning, The closure execution PFS-B (See Infrastructure section for (See Infrastructure section for
scheduling and costing have been study has been improved to that detailed requirements). detailed requirements).
completed to a PFS-B level, as per of a FS level, as per the AA IDM.
the AA IDM. requirements (see Infrastructure
section for detailed requirements).
The specific non-mineral waste
deliverables being (but not limited
to):
• Final non-mineral waste disposal
strategy and option analysis.
• Detailed quantitative risk
assessment (pre and post
mitigation ranking) with appropriate
closure criteria.
• Detailed specialist studies used
to quantify risk and impacts (e.g.
seepage analyses, geochemistry
analysis, future predictive
modelling).
• The relevant authorities have been
involved in the finalisation of the
closure and success criteria and
other I&APs have been consulted.
• Detailed liability estimate
covering decommissioning and
post closure periods. Liabilities
estimate to differentiate between
latent, residual and current closure
liabilities.
• Execution planning, scheduling
and costing have been undertaken
and key execution documentation
have been completed (see
Infrastructure section for more
details).

Time remaining
to scheduled
Physical closure
Mining areas A complete set of closure Relevant discipline The previous closure criteria The criteria have through
(surface/ criteria has been developed experts have undertaken a recommended by the relevant onsite or industry execution
underground/ and costed following a risk- desktop investigation and discipline experts have, where been demonstrated and
seaborne): based approach. The criteria benchmarking (on high risk appropriate, been reviewed and accepted to be successful.
The open pit area used (BoE) in the closure and high cost components), updated by doing a site-specific I&APs and authorities
is approximately cost estimate are based on into the closure methodology investigation into the closure have been engaged at the
200 m deep experience and available and criteria, to confirm the methodology as well as focused appropriate level of influence
with a 150 ha information. The focus being current criteria or to establish benchmarking. The granularity of and are in the majority
footprint. on leaving behind safe, secure, more appropriate criteria the criteria (BoE) has improved satisfied with the closure
chemically and physically (BoE). The key critical closure and includes decommissioning, and success criteria. A
Reference: stable structures, that will criteria must cover (but is not closure and long-term monitoring detailed decommissioning
Preliminary not continue to pollute the limited to) the following: and maintenance requirements, and closure management
closure plan and environment post long-term and costs for each of the mining strategy (including the SEP;
cost estimate mitigation. The key critical Stability: areas. The previously identified master action plan/schedule
for the mine – closure criteria that must be Specialist studies will be key critical closure criteria has with cashflow) have been
March 2019. covered includes long-term undertaken on long-term been improved by undertaking the developed to facilitate the
General layout geotechnical and geochemical geochemical stability, following: successful execution of the
drawing dated stability, safety, security and using high level designs mining areas. The previously
January 2019. long-term impacts on the and available geochemical Stability: identified key critical closure
Current mine environment (e.g. ground and information. Detailed geotechnical and criteria have been improved by
design dated surface water) and people, and geochemical stability design undertaking the following:
December 2018. alignment with the final closure Safety and security: requirements, must form part
vision and land-use plan. Initial investigations into of LoAP and execution, and Stability:
long-term relaxation zones a predictive model has been Long-term geotechnical
GAPS: (~breakback zones), covering developed to quantify and and geochemical stability
1) Current level of people and the environment, manage the associated risks (e.g. modelling has been improved
confidence for the mining including components such identification of pit relaxation by ongoing calibration
area is not aligned with that as possible solutions for long- zones identification, subsurface to improve the predicted
required for a mine with term access control. support deterioration and long-term impacts and to
between 15-10 years LoA. subsequent surface settlement, demonstrate the success of
Relaxation: long-term metal leaching due implemented closure criteria.
Relaxation zone is the to AMD).
geotechnical prediction of Safety and security:
failure of pit walls based on Safety and security: The successful management
an identified Factor of Safety Detailed operation and closure of long-term safety and
defined by AA as 1.5. designs to identify and maintain security has been proven by
long-term relaxation zones, continuously improving the
Bio-physical (see bio-physical covering people and the delineation of the various zone
and social sections in Tool 2): environment, needs to be in place. of influences, covering people
Long-term impacts on Detailed security plans need to and the environment, including
surface and ground water be in place to not only address components such as long-term
resources (e.g. pit water operational risks but also the access control (e.g. sealing of
quality, future decant projected future closure and post shafts, installation of berms
management, interconnectivity closure risk components such and fencing, dense vegetation
of groundwater between as long-term access control and and cut off trenches around
pits/underground workings, others safety and security risks. final voids), prevention of
long-term health impacts on illegal mining, and safety and
people) are investigated. Bio-physical (see bio-physical and security risks.
social sections in Tool 2):
Land-use: Detailed studies must be Bio-physical (see bio-physical
The impacts of the mining completed, and plans must be in and social sections in Tool 2):
areas (i.e. final voids, shafts, Long-term impacts on surface
place to address long-term impacts
adits) on the final closure and underground water
on surface and underground water
vision and land-use plan needs resources (e.g. pit water quality, resources, and people have
to be assessed and aligned. been monitored and the
future decant, interconnectivity
closure criteria updated to
of groundwater between pits/
ensure an acceptable residual
underground workings, health
risk profile.
impacts on people).
Land-use:
Land-use: The closure criteria as defined
The closure criteria as defined and and costed for the mining
costed for the mining areas (final areas (final voids, shafts, adits)
voids, shafts, adits) must align fully are updated in line with the
with final closure vision and land- final agreed closure vision and
use plan. land-use plan.

Closure execution planning, The detailed closure execution The decommissioning plan includes A detailed monitoring and
scheduling and costing have been planning, scheduling and costing all the project management and risk maintenance plan is in place
done to a PFS-B level, as per the have been done and all closure controls associated with effective that tracks risk management,
AA IDM requirements with the key execution documentation have project execution and tracking in financial performance, ongoing
execution document being (but not been completed by improving the place. The success of the project progress, stakeholder engagement,
limited to): PFS-B study to that of a FS level, is tracked against the KPIs, such success criteria and ultimately
• Project Charter, Study Execution as per the AA IDM requirements. as budget, progress, community relinquishment of assets.
Plan, Project Execution Plan, Work and regulatory acceptability and
Breakdown Structure (WBS), meeting the overall agreed success See Tool 5 for details on
Detailed Execution Schedule, criteria. project execution planning and
Project Risk Register, SEP, Legal management.
Register, Financial Plan, Model and See Tool 5 for details on
Report. project execution planning and
management.

Time remaining
to scheduled
Physical closure
Physical liability estimate
Physical closure Class 5 estimate. Improved class 5 estimate. Class 4 estimate. Class 4 estimate.
liability estimate:
Preliminary L: -30% to -50%. L: -20% to -50%. L: -15% to -30%. L: -15% to -30%.
closure plan and H: +50% to +100%. H: +30% to +100%. H: +20% to +50%. H: +20% to +50%.
cost estimate
for the mine – Contingency (P50) of Contingency (P50) of Contingency (P50) of 20%-30%. Contingency (P50) of
March 2019. 30%-50%. 25%-40%. 20%-30%.
Reference:
Preliminary
closure plan and GAP:
cost estimate 1) Current level of
for the mine – confidence of the estimate
March 2019. is not aligned with that
General layout required for a mine with
drawing dated between 15-10 years LoA.
January 2019.
Current mine
design dated
December 2018.
Biophysical closure/rehabilitation
Biophysical closure criteria
Land-use and High-level land-use plan has A detailed land-use plan The assessed impacts have been The final land-use plan has
capability: been developed based on has been developed by the confirmed through additional been developed with I&APs
The mine owns assumed impacts, primarily relevant discipline experts studies and the land-use plan and authorities through
5 300 ha of focused on the local land and the impacts have been updated by also including focused the appropriate level of
land, of which capability before mining. The assessed. The land-use inputs from I&APs and authorities. engagement and influence
approximately land-use plan aligns with the plan aligns with the updated The land-use plan aligns with the and the closure criteria and
800 ha will be initial closure vision. closure vision (internally and agreed closure vision (internally success criteria updated
disturbed by the See Section 4F: Land access, externally developed). agreed and broadly external accordingly. The land-use plan
mining operation. displacement and resettlement acceptance). aligns with the agreed closure
The area has a vision (internally agreed and
low agricultural GAPS: majority external acceptance).
value, with a 1) Although the authorities
grazing potential have been engaged regarding
of one unit of the land-use plan, I&APs have
livestock per not been engaged to get
15 ha. Previous focused inputs and subsequent
land-use was broadly external acceptance.
grazing, game
farming and
some tobacco
farming.
Reference:
Environmental
impact study;
Preliminary
Closure Plan and
cost estimate
for the mine –
March 2019.
Land-use plan
dated January
2018.
The suggested rehabilitation The suggested rehabilitation The improved or modified The preferred rehabilitation
methods to achieve the methods to achieve the rehabilitation methods to achieve method to achieve the land-
land-use plan are based on land-use plan have been the land-use plan have been use plan from the testing
experience and known methods assessed by means of tested through on-site trials and/ phase that was demonstrated
from other sites. The landform concurrent rehabilitation and/ or concurrent rehabilitation, from to be successful is selected,
designs allow sufficient flexibility or rehabilitation trials on site which it can be demonstrated that and I&APs and authorities
to accommodate future (concurrent rehabilitation if they are successful. Appropriate have been engaged at the
changes to the final land-use LoM is more than 25 years) research programmes are in appropriate level of influence
(e.g. benches are constructed and improved or modified as place to investigate methods to and are, in general, satisfied
wide enough to accommodate required. establish required species (e.g. with the rehabilitation method
for increased shaping of batters seed dormancy, plant propagation and results.
to flatter slopes), concurrent methods).
rehabilitation and rehabilitation
trials are taking place, as GAPS:
appropriate. Appropriate research
programmes are not in place to
understand seed dormancies.

Class 3 estimate. Class 2 estimate. Class 1 estimate. Class 1 estimate.

L: -10% to -20%. L: -5% to -15%. L: -3% to -10%. L: -3% to -10%.
H: +10% to +30%. H: +5% to +20%. H: +3% to +15%. H: +3% to +15%.
Contingency (P50) of 15%-20%. Contingency (P50) of 10%-15%. Contingency (P50) of 5%-10%. Contingency (P50) of 5% -10%.
The authorities have agreed to the final closure vision and related See Tool 5 for details on project execution planning and
rehabilitation methods to achieve the land-use plan and other I&APs management.
have been engaged at the appropriate level of Influence, and majority
agreement obtained.
Closure execution planning, The detailed closure execution The success of the project is tracked A detailed monitoring and
scheduling and costing have been planning, scheduling and costing against the KPIs and meeting the maintenance plan is in place that
undertaken to a PFS-B level, as per have been undertaken and all overall agreed success criteria. tracks the success criteria and
the AA IDM requirements. closure execution documentation ultimately relinquishment of leases.
have been completed by improving See Tool 5 for details on
the PFS-B study to that of a project execution planning and See Tool 5 for details on
FS level, as per the AA IDM management. project execution planning and
requirements. management.

Time remaining
to scheduled
Rehabilitation A concurrent rehabilitation strategy and associated plans have A concurrent rehabilitation strategy and associated five year plans
(Strategy): been developed and signed off by site senior management, with procedures (including the post production period) have been
No endangered and action has been taken to ensure these are included in the developed for ongoing inclusion in the closure planning process
species are closure planning process and implemented. and relevant components implemented annually. Concurrent
present on the rehabilitation plans are included in the operational budgets and
site and the progress is measured, adaptively managed with mitigation as
area is not a required and ongoing reporting is taking place.
biodiversity
hotspot. Two
pans in the area
are not impacted
on by the mining
operation. The
land-use plan
is focused on
reinstating game
farming as the
most prominent
land-use, with
some grazing
and small-scale
farming.
Reference:
Updated
rehabilitation
strategy dated
December 2018.
Update 5-year
rehabilitation plan
dated December
2018.
Surface and The potential closure and post- The potential closure and The potential closure and The required closure criteria
Groundwater: closure impacts on surface post-closure impacts have post-closure impacts have been associated with significant
The estimated and groundwater are based on been identified and assessed confirmed through additional surface and groundwater
post- closure general experience and are not through an environmental specialist studies and post-closure risks can be considered
impact from a supported by detailed technical impacts assessment of environmental assessments, and proven if historical evidence
water resource investigations or significance the mine closure plan and the significant and insignificant is available, reflecting that
point of view is ratings (unless it formed part specialist investigations. All risks have been communicated they have been successfully
still in progress. of regulatory requirements for high, significant, medium, low to I&APs for comment. All implemented in similar
The post- closure mines with a LoA of more than and unknown risks have been unknown risks have been circumstances elsewhere, or
impact from 25 years). The potential closure identified. rated. A detailed solute transfer the proposed closure criteria
evaporation and post closure impacts have model with integrated surface to address high and significant
from the pit not been discussed in detail Hydrogeological and and groundwater numerical risks have been tested on
needs further with the authorities or other geochemical surface and components and geochemical site and demonstrated to
investigation. I&APs, other than through the groundwater models are in model and associated storm water be successful. I&APs and
normal regulatory processes. place and are calibrated on a management structures and authorities are satisfied
Reference: systems that are costed in the in the majority with the
regular basis with operational
Initial GAPS: closure liability are in place. closure criteria. Numerical
groundwater data.
1) Current level of solute models are updated
report dated – confidence in the surface with further field data as it
January 2015, and groundwater impacts becomes available.
done by GES and required actions is not
Consultant. aligned with that required for
Initial surface a mine with between 15-10
water report years LoA.
dated – January
2014, done by
GES Consultant.
EIA completed
December
2017 (excluded
long-term post
closure impacts
on surface and
groundwater).

A concurrent rehabilitation strategy and associated five year plans with The post production component of the rehabilitation strategy and
procedures (including the post production period) have been developed associated plans (including maintenance and management plans) have
for ongoing inclusion in the closure planning process and relevant been approved and executed accordingly. Plans are included in closure
components implemented annually. Concurrent rehabilitation plans are budgets and progress is measured and reported.
included in the operational budgets and progress is measured, adaptively
managed with mitigation as required and ongoing reporting is taking See Tool 5 for details on project execution planning and production
place. period) have been developed for ongoing inclusion in the closure
planning process and relevant.
The relevant authorities have signed off on the surface and groundwater The post production component of the ground and surface water strategy
closure criteria and other I&APs have been engaged at the appropriate and associated plans have been approved and executed. Plans are in
level of influence, and the majority agree with the closure criteria. closure budgets and progress is measured and reported. Long-term
residual and latent Impacts are known and are being monitored.
See Tool 5 for details on project execution planning and
management.

More than 25 years 25-15 years 15-10 years 10-5 years
Visual/aesthetic: Assumed visual and sense of An environmental impact All gaps and unknown risks The closure criteria have been
The maximum place impacts were based on assessment (including social) have been addressed through proven to be successful by
height of the available information of the was undertaken and the visual, additional specialist studies, means of successful onsite
residue facilities local mining area. sense of place and heritage including landscape studies (if, execution, and I&APs and
was set at 60m, impacts were assessed, appropriate), and all unknown authorities have been engaged
with 18-degree covering the full life cycle of risks and gaps have been closed at the appropriate level of
side slopes and the operation, including post with appropriate mitigation influence and there is majority
full vegetation closure phase impacts. identified. acceptance of the success
cover. Dust and appropriateness of the
monitoring is GAPS: mitigation measures.
taking place. 1) Current level of
confidence related to visual
Reference: impacts and required
On-site actions is not aligned with
monitoring that required for a mine with
programme; between 15-10 years LoA.
Environmental
impact study.
Land-use plan
dated January
2018.
The required closure criteria Operational management Operational management Operational management
have been developed based on measures are in place, and measures and closure criteria measures and closure criteria
available information on similar the closure criteria have been have been updated, and trials have been updated, and
rehabilitation requirements in developed and costed. have taken place to demonstrate successful onsite execution
the industry. the effectiveness of the mitigation has taken place with majority
GAPS: measures. acceptance of I&APs.
1) Current level of
confidence related to visual
impacts and required
actions is not aligned with
that required for a mine with
between 15-10 years LoA.
Biophysical liability estimate
Biophysical Class 5 estimate. Improved class 5 estimate. Class 4 estimate. Class 4 estimate.
closure liability
estimate: L: -30% to -50%. L: -20% to -50%. L: -15% to -30%. L: -15% to -30%.
Current estimate H: +50% to +100%. H: +30% to +100%. H: +20% to +50%. H: +20% to +50%.
excludes long-
term water Contingency (P50) of Contingency (P50) of Contingency (P50) of 20%-30%. Contingency (P50) of
management 30%-50%. 25%-40%. 20%-30%.
and mitigation
liability as well as
biodiversity offset GAP:
costs. 1) Current level of
confidence of the estimate
Reference:
is not aligned with that
Preliminary
required for a mine with
Closure Plan and
cost estimate
for the mine –
March 2019.

The final landform designs are aligned with the closure vision and The mitigation measures have been The residual risk profile is
final land-uses and the authorities have agreed on the mitigation and successfully executed according to acceptable to I&APs and the
rehabilitation methods and I&APs have been engaged at the appropriate closure execution plan. authorities and the long-term
level of Influence and there is majority agreement. sustainability of the solution have
been proven to be successful (e.g.
through monitoring).
Closure execution planning, The detailed closure execution The closure and post closure component to address the visual impacts,
scheduling and costing have been planning, scheduling and costing as well as the associated plans (including maintenance and management)
done to a PFS-B level, as per the have been done and all execution have been approved an executed. Closure budget is available, and
AA IDM. documentation have been progress is measured and reported. Long-term residual and latent Impacts
completed by improving the PFS-B are known and are being monitored.
study to that of a FS level, as per
the AA IDM requirements. See Tool 5 for details on project execution planning and
management.

L: -10% to -20%. L: -5% to -15%. L: -3% to -10%. L: -3% to -10%.
H: +10% to +30%. H: +5% to +20%. H: +3% to +15%. H: +3% to +15%.
Contingency (P50) of 15%-20%. Contingency (P50) of 10%-15%. Contingency (P50) of 5%-10%. Contingency (P50) of 5%-10%.

Time remaining
to scheduled
Social transition (including health)
Social transition criteria
Employees and The requirements of employees A current HIA is in place and The previously identified socio- The confirmed social
their dependants: and social transition criteria is updated as required, with economic needs, including an transition requirements and
The mine aligned with the final land- ongoing occupational HRA in-depth HIA, as well as the final land-use objectives
currently employs uses have been assumed conducted. closure vision are well recognised. have been identified in
1000 permanent and only a rapid Health These aspects have been more detail through social
staff and 500 Impact Assessment (HIA) has The needs of employees discussed with employees and transition planning and
contract staff. been carried out at project have been assessed and updated accordingly. A future re-confirmed by means of
The employees commencement (see the appropriate social transition forum consisting of management, employee involvement. A
dependants have Examples document – Example criteria developed and representative employees, union comprehensive, portable
been estimated 10). Only an initial profile of costed (mostly operational representatives and community skills plan (development and
at a 1 to 4 ratio. the operation’s employees has expenditure and possibly some members is in place. The redeployment), taking into
been generated. closure liabilities). operation’s employees’ capabilities account the requirements of
Reference: and career aspirations are known the remainder of the business
Presentation The needs of employees have and there is alignment with the plan, as well as employees’
by mine – 5 been assumed and appropriate operations’ business plan. individual and community
June 2019. social transition criteria members’ social needs, are
HR strategy developed and costed. The needs of employees have in place.
and detailed 5 been reassessed and appropriate
year plan dated social transition criteria developed The needs of employees are
December and costed (mostly operational known and appropriate social
2018.Detailed expenditure and possibly some transition criteria developed
Health Impact closure liabilities). and costed (mostly operational
Assessment expenditure and possibly some
(HIA) dated closure liabilities).
November
2017. Career
development
planning and
employee
training
document dated
May 2018.
No consultation specific to Employees have been Employees have been given the Employees are directly
mine closure planning is engaged at the appropriate opportunity to review the revised engaged at the appropriate
required at this stage, as there level of influence related mine closure plan and be part of level of influence throughout
is typically not a sufficiently to the mine closure plan by the closure plan development, by the process, to ensure that
detailed closure plan around providing them with balanced means of ongoing engagement issues and concerns are
which to consult. Discussion and objective information to with the operation. Feedback consistently understood and
around mine closure with improve their understanding of from stakeholders on issues, considered, and offered
employees is focused on high the issues, alternatives and/or alternatives and/or decisions has the opportunity to make
level key messages. solutions and to enable them been considered and incorporated substantive changes to the
to raise issues and concerns. into the closure plan, where closure plan and its criteria,
appropriate. where appropriate.
Interested and The requirements of I&APs Information on community The previously identified socio- The confirmed social
Affected parties and the social transition criteria health is obtained from economic needs, health needs transition requirements and
(I&APs): and final land-use have been appropriate sources (see AASW and the closure vision are well final land-use objectives
Neighbouring assumed and no community Section 4C: Community Health recognised. These aspects have have been identified in more
farmers, HIA has been completed (see and Safety Management). been discussed with I&APs detail and re-confirmed by
contractors, the Examples document – The needs of I&APs have and updated accordingly. The means of I&APs involvement.
suppliers, Example 10). The needs of been assessed through a operational budgets are geared Impacts on community
local and tribal I&APs have been assumed and Social Impact Assessment towards addressing the social health and well-being are
authorities, local appropriate social transition (SIA). Appropriate social transition mitigation measures managed (mitigated and/
schools as well criteria developed and costed. transition criteria (e.g. economic (e.g. economic diversification), by or enhanced) in partnership
as a few NGOs diversification and reduced using current vehicles such as the with key stakeholders. The
form part of the GAP: long-term dependency on AASW. The intention is to address social transition process is
I&AP database. 1) Current level of mining being a focus area) all social transition requirements managed through the AASW
confidence related to I&AP have been developed and through operational management and success is tracked and
Reference: impacts and needs are not costed (mostly operational and not have any closure liabilities. measured to ensure an
Closure gap aligned with that required for expenditure and possibly some Social transition criteria have acceptable residual social risk
meeting held on a mine with between 15-10 closure liabilities). (see AASW been updated and costed (mostly profile post closure.
5 June 2019. years LoA. Section 4A: Socio-economic operational expenditure).
SEP and I&AP Development (SED) Planning.)
database dated
March 2018.

Closure execution planning, The detailed closure execution The closure and post closure Post closure budget is available for
scheduling and costing have been planning, scheduling and costing component to address employee monitoring and maintenance phase,
done to a PFS-B level, as per the have been done and all closure impacts, as well as the associated and progress is measured and
AA IDM requirements with the key execution documentation have plans have been approved and reported long-term residual and
social transition deliverables being been completed by improving the executed. latent Impacts are known and are
(but not limited to): PFS-B study to that of a FS level, being monitored.
as per the AA IDM requirements. See Tool 5 for details on
• Detailed Human Resources (HR) project execution planning and See Tool 5 for details on
ramp down profile aligned with the management. project execution planning and
decision on contractor vs. owner management.
execution.
• Detailed reskilling and training
programme.
• Detailed health plan, covering exit
medicals and post closure health
care plans.
• A review of the health
components as conducted by an
independent agency.
The employees have been engaged at the appropriate level of influence SEP is in place to manage SEP is in place to manage
in each aspect of the decision-making process, through which majority expectations and mitigate impacts expectations and mitigate impacts
agreement with the mine closure plan and its final post-closure goals has during the decommissioning phase. during the monitoring and
been obtained. maintenance phase.
Execution planning, scheduling The detailed execution planning, The residual closure components to Post closure budget is available for
and costing have been done to a scheduling and costing have address the social transition, as well monitoring and maintenance phase,
PFS-B level, as per the AA IDM been done and all execution as the associated plans have been and progress is measured and
requirements with the key social documentation have been approved an executed. reported Long-term residual and
transition deliverables being (but completed by improving the PFS-B latent Impacts are known and are
not limited to): study to that of a FS level, as per See Tool 5 for details on being monitored.
the AA IDM requirements. project execution planning and
• A review of the community health management. See Tool 5 for details on
components by an independent project execution planning and
agency (see Section 4C: management.
Community Health and Safety
Management).
• The operational management
of the social transition can be
demonstrated (e.g. economic
diversification, reduced dependency
on mining) and residual post
closure social risk and costs have
been identified.

Time remaining
to scheduled
No consultation specific I&APs have been engaged I&APs have been given the I&APs are directly engaged
to mine closure planning at the appropriate level of opportunity to review the revised at the appropriate level of
is required at this stage, influence related to the mine mine closure plan and be part of Influence throughout the
as typically there is not a closure plan by providing them the closure plan development, by process, to ensure that issues
sufficiently detailed closure with balanced and objective means of ongoing engagement and concerns are consistently
plan around which to engage information to improve their with the operation at the understood and considered,
at the appropriate level of understanding of the issues, appropriate level of influence. and offered the opportunity
influence. If an appropriate plan alternatives and/or solutions Feedback from stakeholders to make substantive changes
does exist, engagement at the and to enable them to submit on issues, alternatives and/or to the closure plan and its
appropriate level of influence their issues and concerns. decisions has been considered criteria, where appropriate.
should be from cradle to cradle. and incorporated into the closure
High level key messages plan, where appropriate.
related to closure should be
developed.
GAPS:
1) Current level of confidence
related to I&AP consultation
required for a mine with
Authorities: The requirements of authorities Additional environmental The previously identified The confirmed social
Regional and are known from the various and social studies have been environmental mitigation transition/closure requirements
national (health legal processes, but the social conducted to improve the requirements and socio-economic and final land-use objectives
and safety and transition criteria and final land- confidence in the closure plan, needs, including health, and the have been identified in more
environment use have been assumed. The and the potential changes closure vision are well recognised. detail through closure planning
and mineral needs of the authorities have in closure impacts and These aspects have been and re-confirmed by means
regulations), been assumed to align with the associated closure criteria. discussed with authorities and of authority involvement.
Department of current legal commitments and Information on community updated accordingly. Impacts on community health
Water Affairs, no additional closure criteria health is available from and well-being are managed
Department of have been developed. A basic public sources. The baseline The legal risk register is (mitigated and/or enhanced)
Environmental legal risk register is in place environmental conditions are maintained and continuously in partnership with key
and Tourism covering the operational and known, and the wider strategic updated (live system). stakeholders. The legal risk
Affairs, closure phases. socio-economic opportunities register is maintained and
Department and constraints have been continuously updated (live
of Agriculture, identified. A closure vision system).
Department of with underlying principles has
Labour, local been reviewed and improved.
authorities, A legal risk register to ensure
Receiver of legal compliance during the
Revenue. operational, closure and post
closure periods is in place
Reference: including management plans
Closure gap and tracking tools.
meeting held
on 5 June
2019. SEP and
I&AP database
dated March
2018. Authority
engagement
system – Closure
module.
Authorities have been Authorities have been Authorities have been engaged at Authorities are directly
engaged through the various engaged at the appropriate the appropriate level of Influence involved throughout the
legal processes and the level of influence and given and given the opportunity to process, to ensure that issues
associated regulatory closure the opportunity to develop develop and review the revised and concerns are consistently
commitments made in this and review the revised mine closure plan (where understood and considered,
regard. mine closure plan (where appropriate), by means of ongoing and offered the opportunity
appropriate), by means of engagement with the operation. to make substantive changes
ongoing engagement with the Feedback from stakeholders to the closure plan and its
operation. on issues, alternatives and/or criteria, where appropriate.
decisions has been considered
and incorporated into the closure
plan, where appropriate.

The I&APs have been engaged at the appropriate level of influence in SEP is in place to manage SEP is in place to manage
each aspect of the decision-making process, through which majority expectations and mitigate impacts expectations and mitigate impacts
agreement with the mine closure plan and its final social transition and during the decommissioning phase. during the monitoring and
post-closure goals has been obtained. maintenance phase.
Closure execution planning, The detailed closure execution The closure and post closure Post closure budget is available
scheduling and costing have been planning, scheduling and costing components to address the for monitoring and maintenance
done to a PFS-B level, as per the have been done and all closure regulatory requirements, as well phase to track and ensure
AA IDM requirements with the key execution documentation have as the associated plans have been legal compliance and asset
regulatory deliverables being (but been completed by improving the approved an executed. relinquishment.
not limited to): PFS-B study to that of a FS level, See Tool 5 for details on
as per the AA IDM requirements. See Tool 5 for details on
• An updated legal risk register project execution planning and project execution planning and
including a management plan to management. management.
ensure legal compliance during the
closure and post closure periods
(e.g. any new legal requirements due
to changes in final closure plan).
• Master project execution schedule
that outlines the regulatory process
and key deliverable and milestones
to achieve asset relinquishment.
The authorities have been engaged at the appropriate level of influence SEP is in place to also manage SEP is in place to also manage
in each aspect of the decision-making process, through which majority regulatory engagements during the regulatory engagements during the
agreement with the mine closure plan and its final post-closure goals has decommissioning phase. monitoring and maintenance phase.
been obtained.

Time remaining
to scheduled
Stakeholder The operation’s SEP must The operation’s SEP must be The operation’s SEP will focus on the updated closure plan,
engagement: be in place and must include updated to cover the current including the closure execution components, aiming to transfer
Current SEP key concepts of closure closure plan as a whole, ownership of the closure plan from the operation to the I&APs
focus mainly on planning, such as the closure focusing on getting general that will remain in the area post closure by getting approval for the
the regulators vision, land-use plan, residual I&AP acceptance of the “success criteria” linked to an agreed closure vision and land-use
and employees, risk profile post closure the closure plan and associated plan.
with limited to no management of dependencies, closure criteria with the
engagement with and expectations including intent of delivering a set of This will be achieved through engagement with I&APs at the
external I&APs. the requirement for socio- acceptable “success criteria” appropriate level of nfluence and by directly involving authorities
economic diversification. No linked to an acceptable throughout the process, to ensure that issues and concerns are
Reference: detailed engagement on a closure vision and land-use consistently understood and considered and offered the opportunity
Closure gap closure plan is expected at this plan. This will be achieved to make substantive changes to the closure plan and its closure
meeting held on stage, as typically there is not through ongoing engagement and success criteria, where appropriate.
5 June 2019. a sufficiently detailed closure with I&APs and authorities
SEP and I&AP plan around which to engaged at the appropriate level of
database dated (except for operations with a influence and might also
March 2018. very long LoA – more than 25 include capacity building
years). If an appropriate plan around some technical
does exist, engagement at the subjects (e.g. AMD, landform
appropriate level of influence design).
should be from cradle to cradle.
GAPS:
1) Current level of
confidence related to I&AP
consultation is not aligned
with that required for a mine
with between 15-10 years
LoA.
Social liability estimate
Social transition Class 5 estimate. Improved class 5 estimate. Class 4 estimate. Class 4 estimate.
liability estimate:
All social L: -30% to -50%. L: -20% to -50%. L: -15% to -30%. L: -15% to -30%.
transition costs H: +50% to +100%. H: +30% to +100%. H: +20% to +50%. H: +20% to +50%.
are estimated
and included in Contingency (P50) of Contingency (P50) of Contingency (P50) of 20%-30%. Contingency (P50) of
the operational 30%-50%. 25%-40%. 20%-30%.
budgets as part
of the social
performance GAPS:
strategy and 1) Current level of
execution plan. confidence in the cost
estimate is not aligned with
Reference:
that required for a mine with
Closure gap
meeting held on
5 June 2019.
SEP and I&AP
database dated
March 2018.
Preliminary
Closure Plan and
cost estimate
for the mine –
March 2019.

The current operational SEP have been updated to a PFS-B and The SEP is in place to manage The SEP is in place to manage
subsequent FS level, as per the AA IDM requirements to focus on the to manage regulatory and to manage regulatory and I&AP
closure and post closure phases, covering (but not limited to): I&AP engagements during the engagements during the monitoring
decommissioning phase. and maintenance phase.
• A detailed communication strategy and plan, including key messaging,
single lines of communication and clear understanding of the success
criteria.
• Authorities and I&APs have been engaged at the appropriate level of
influence in each aspect of the decision-making process, through which
majority agreement with the mine closure plan and its final post-closure
goals has been obtained.

L: -10% to -20%. L: -5% to -15%. L: -3% to -10%. L: -3% to -10%.
H: +10% to +30%. H: +5% to +20%. H: +3% to +15%. H: +3% to +15%.

Time remaining
to scheduled
Other
Success criteria Indicative success criteria, Success criteria have been improved to not only reflect the Updated success criteria
(physical, bio- covering the physical, bio- legal requirements, closure vision, post-mining land-use, closure have been established to
physical, social physical, social and financial objectives and criteria, but also include parameters for measuring reflect any changes to the
and financial): components of closure the level of success through a monitoring programme that has been post-mining land-use and
Even though planning have been developed communicated to the authorities. include monitoring parameters
the operations (internal process only). The including SMART targets to
have detailed success criteria reflect the a defined level of success,
closure criteria, legal requirements, closure and has been approved by
a set of success vision, the post-mining authorities, with guidelines
criteria has not land-use, closure objectives for acceptable standards and
been developed and criteria, with an initial corrective actions.
to ensure there monitoring programme.
is alignment
with the land- GAP:
use plan and 1) Current level of
closure vision. confidence related to the
No engagement required success criteria
related to is not aligned with that
acceptable required for a mine with
success criteria between 15-10 years LoA.
has take
place with the
regulators.
Reference:
Closure gap
meeting held on
5 June 2019.
Risk A mine closure and post The closure and post closure The closure and post closure The closure and post closure
Assessment: closure risk assessment was risk assessment has been risk assessment has been risk assessment has been
Detailed risk undertaken (see the Examples updated and previous gaps updated and all previous updated and improved by
assessment was document – Example 3 and closed, so that most risks unknown risks have been re- including I&APs and authority
completed in Q1 Tool 1) covering the pre and can be classified as either classified as either significant inputs. The effectiveness
2019. post closure criteria ratings. significant or insignificant and or insignificant. Remaining of the controls (i.e. closure
Unknown risks have been limited unknown risks remain. significant and high residual criteria) are measured (see
Reference identified and an action plan Significant and high residual risks have been identifying and the Examples document –
Updated closure developed to close the gaps. risks have been identified and additional or alternative closure Example 13).
risk assessment additional or alternative closure criteria or actions investigated
dated February criteria or actions investigated and/or included to reduce the
2019. and/or included to reduce the unacceptable residual risks to an
unacceptable residual risks to acceptable level.
an acceptable level.
GAPS:
The current risk assessment
excludes the impacts from
I&APs and long-term risks
associated with surface and
groundwater.

Updated success criteria have been established to reflect any changes Progress against achieving the The achievement of the targets
to the post-mining land-use and include monitoring parameters including approved success criteria are (success criteria) are being signed-
SMART targets to a defined level of success, and have been approved being monitored and tracked by off by the authorities, to enable the
by authorities, with guidelines for acceptable standards and corrective the operation and authorities, relinquishment of the leases.
actions. and corrective actions (e.g.
maintenance) undertaken as
required.
The detailed closure and post The detailed closure and post The decommissioning plan includes The monitoring and maintenance
closure risk assessment has been closure risk assessment is all the risk controls associated with plan include all the risk controls
done to a PFS-B level, as per the completed by improving the PFS-B effective project execution and associated with effective project
AA IDM. study to that of a FS level, as per tracking in place. execution and tracking in place.
the AA IDM requirements.
See Tool 5 for details on See Tool 5 for details on
project execution planning and project execution planning and
management. management.

Time remaining
to scheduled
Other
Monitoring An initial monitoring A detailed monitoring and data management programme has been A detailed monitoring and data
programme: programme has been developed that covers all potential impact and risk areas identified management programme that
A detailed developed that covers all in the closure plan, is implemented, regularly reviewed and linked covers all potential impact
monitoring potential impact and risk areas to success criteria as communicated to the authorities. A detailed and risk areas identified in the
and data identified in closure plan, but operational maintenance and management plan is in place to closure plan, is implemented,
management may not have been linked to address issues (e.g. erosion, invasive species, bare areas) with regularly reviewed, adapted
programme success criteria. A high-level identified mitigation measures. according to current mine
that covers all operational maintenance and status and linked to the
potential impact management plan is in place to success criteria, as approved
and risk areas address potential issues (e.g. by the authorities. A detailed
identified in the erosion, invasive species). operational maintenance
closure plan is and management plan is in
in place and is place to address issues (e.g.
being funded erosion, invasive species,
through annual bare areas), with identified
budgets. adaptive measures to
improve on the success of
Reference: concurrent rehabilitation and
Updated to develop an optimal solution
monitoring (sustainable in the long-term,
and data executable and at acceptable
management costs). Actual costs of
programme concurrent closure activities
dated December are tracked and reported in
2018. the operations financials.
GAP:
Success criteria have
not been developed to
the appropriate level of
confidence and not yet
approved by the authorities.
Financial requirements and risk assessment
Overall Cost Class 5 estimate. Improved class 5 estimate. Class 4 estimate. Class 4 estimate.
Estimate
(Accuracy vs. L: -30% to -50%. L: -20% to -50%. L: -15% to -30%. L: -15% to -30%.
Maturity level): H: +50% to +100%. H: +30% to +100%. H: +20% to +50%. H: +20% to +50%.
Initial estimate
was completed, Contingency (P50) of Contingency (P50) of 25%-40 Contingency (P50) of 20%-30%. Contingency (P50) of
and this was 30%-50%. 20%-30%.
updated by site
staff. GAP:
Note: 1) Current level of
More confidence of the estimate
assumptions is not aligned with that
made as part required for a mine with
of identifying between 15-10 years LoA.
the closure
criteria leads to
lower levels of
confidence in the
estimate and not
the methodology
that is used for
calculation.
Reference:
Preliminary
Closure Plan and
cost estimate
for the mine –
March 2019;
Updated mine
closure estimate.

A detailed monitoring and data management programme that covers A detailed monitoring and data The achievement of the success
all potential impact and risk areas identified in the closure plan, is management programme that criteria is monitored via the data
implemented, regularly reviewed, adapted according to current mine covers all potential impact and management programme and
status and linked to the success criteria, as approved by the authorities. risk areas identified in the closure reported to the authorities, to
A detailed operational maintenance and management plan is in place to plan, is implemented, and success enable the relinquishment of the
address issues (e.g. erosion, invasive species, bare areas), with identified tracked and reported to the asset.
adaptive measures to improve on the success of concurrent rehabilitation authorities.
and to develop an optimal solution (sustainable in the long-term,
executable and at acceptable costs). Actual costs of concurrent closure
activities are tracked and reported in the operations financials.

L: -10% to -20%. L: -5% to -15%. L: -3% to -10%. L: -3% to -10%.
H: +10% to +30%. H: +5% to +20%. H: +3% to +15%. H: +3% to +15%.

Time remaining
to scheduled
Financial requirements and risk assessment
Estimate is based mainly on Estimate is based on reviewed Estimate is based on tested Estimate is based on tested
assumed closure criteria: closure criteria: closure criteria: closure criteria:
1) Low level of confidence in 1) Medium level of confidence 1) High level of confidence in 1) High level of confidence
closure plan with 50% or more in closure plan with between closure plan with between in closure plan with between
assumptions related to the 30% - 40% assumptions 20%-30% assumptions related to 15%-20% assumptions
closure criteria in the basis of related to the closure criteria the closure criteria in the basis of related to the closure criteria
the estimate. in the basis of the estimate. the estimate. in the basis of the estimate.
GAP:
1) Current level of
confidence in the closure
plan Is not aligned with
that required for a mine
with between 15-10 years
LoA, as there are too many
assumptions.
Overall closure Level 1 Schedule, top down Level 2 Schedule, top down Level 2 Schedule, top down Level 3 Schedule, top down
schedule: planning using high level planning using high level planning using high-level planning using high-level
Current level 2 milestones and key project milestones and key project milestones and key project events. milestones and key project
mine schedule. events. events. Semi-Detailed. events. Semi-Detailed.
Reference:
Mine closure
programme and
detailed level 2
schedule dated
March 2019.
Target Schedule Accuracy of Target Schedule Accuracy of Target Schedule Accuracy of Target Schedule Accuracy of
±50%. ±40%. ±30%. ±25%.
Overall financial The initial cashflow is linked to the closure schedule. Detailed cash flow linked to the closure schedule.
model and cash
flow:
Detailed cash
flow linked to the
closure schedule
is available.
Reference:
Cashflow dated
March 2019.
(Class 5). (Class 4).
Financial Select funding method. Financial provision Financial provision (Class 4).
provision: (Class 5).
Insurance policy
and some GAP:
guarantees are 1) Current level of
currently in place. confidence of the estimate
Reference: required for a mine with
Preliminary between
Closure Plan and 15-10 years LoA.
cost estimate
for the mine –
March 2019.
Mine closure Preliminary mine closure plan. Draft mine closure plan. Detailed mine closure plan.
plan (Based
on overall GAP:
confidence): 1) For the closure plan to be a “Draft closure plan”, all
Preliminary the gaps as identified in this assessment needs to be
Closure Plan and addressed (No highlighted columns to the left of the “15-10
cost estimate year”column).
for the mine –
March 2019.
Reference:
Preliminary
Closure Plan and
cost estimate
for the mine –
March 2019.

Estimate is based on proven Estimate is based on proven Estimate is based on actual Estimate is based on actual
closure criteria: closure criteria: historical onsite execution costs: historical onsite execution costs:
1) High level of confidence in 1) High level of confidence in 1) High level of confidence in 1) High level of confidence in
closure plan with between closure plan with less than 10% closure plan with less than 5% closure plan with less than 5%
10%- 15% assumptions related to assumptions related to the closure assumptions related to the closure assumptions related to the closure
the closure criteria in the basis of criteria in the basis of the estimate. criteria in the basis of the estimate. criteria in the basis of the estimate.
the estimate.
AA IDM requirements with the key Level 4 Schedule, top down Level 4 execution schedule, bottom up planning. Detailed, focused on
scheduling deliverables being (but planning using key project events. accurately managing and verifying the critical path, near critical path(s),
not limited to): The detailed execution planning, long lead items and planning of ongoing works.
• Level 4 Schedule, top down scheduling and costing have
planning using key project been done and all execution
events. Detailed with focus on documentation have been
identifying and verifying the critical completed by improving the PFS-B
path, key milestones and critical study to that of a FS level, as per
dependencies, long lead items and the AA IDM requirements.
planning of early works.
Target Schedule Accuracy of ±20%. Target Schedule Accuracy of Target Schedule Accuracy of Target Schedule Accuracy of
±15%. ±10%. ±10%.
Final cash flow linked to the closure Final cash flow linked to the closure Final cash flow linked to execution Final cash flow linked to monitoring
schedule. schedule. schedule. and maintenance schedule.
(Class 3). (Class 2). (Class 1). (Class 1).

Financial provision Financial provision Financial provision/Budget Financial provision/Budget
(Class 3). (Class 2). (Class 1). (Class 1).
Final mine closure plan and Final mine closure plan and Closure execution plan, with Detailed closure monitoring and
associated closure execution plan associated closure execution plan detailed annual plans, budgets and maintenance execution plan with
(PFS-B Level). (FS Level). schedules. detailed annual plans, budgets and
schedules.

APPENDIX B: COMPLETED MASTER ACTION PLAN
ID
number Source Main Task Name Sub Task Name
1 MCT V3 – Gap Analysis Update physical closure criteria for infrastructure Define demolition waste disposal and recycling
(5 June 2019). (on and off-site). requirements and volumes in sufficient detail.
2 MCT V3 – Gap Analysis Update physical closure criteria for infrastructure Include closure related engagement sessions into the
(5 June 2019). (on and off-site). current SEP to confirm the acceptability of the closure
criteria, especially related to social infrastructure (e.g. on-
site housing).
3 MCT V3 – Gap Analysis Update physical closure criteria for mineral waste Complete additional kinetic testing and update the
(5 June 2019). landforms. landform designs as required.
4 MCT V3 – Gap Analysis Update physical closure criteria for mineral waste Review the effectiveness and long-term sustainability of
(5 June 2019). landforms. water management structures and measures are improved
as required.
5 MCT V3 – Gap Analysis Update physical closure criteria for mineral waste Develop an maintain a live system to track the detailed
(5 June 2019). landforms. balance for hostile and non-hostile material to ensure no
shortfall in materials to execute the closure plan.
6 MCT V3 – Gap Analysis Update physical closure criteria for mineral waste Demonstrate the executability of the closure criteria and
(5 June 2019). landforms. the cost effectiveness of the designs by on-site execution
and rehabilitation.
7 MCT V3 – Gap Analysis Update physical closure criteria for mineral waste Tracking the effectiveness of management measures and
(5 June 2019). landforms. closure criteria to improve long-term stability and reduce
costs.
8 MCT V3 – Gap Analysis Update physical closure criteria for mineral waste Update the monitoring programme to track and measure
(5 June 2019). landforms. successful on-site containment and remediation.
9 MCT V3 – Gap Analysis Update physical closure criteria for mineral waste Review and update the LoA plans to ensure it allows for
(5 June 2019). landforms. sufficient available areas to undertake landform closure
execution (shaping and rehabilitation).
10 MCT V3 – Gap Analysis Update physical closure criteria for non-mineral Develop a set of success criteria to make sure there is
(5 June 2019). waste. alignment with the closure criteria and the final land-use
plan and closure vision.
11 MCT V3 – Gap Analysis Update physical closure criteria rerated to the Review previous closure criteria and updated by doing a
(5 June 2019). mining area. site-specific investigation into the closure methodology as
well as focused benchmarking.
12 MCT V3 – Gap Analysis Update physical closure criteria rerated to the Improve the granularity of the criteria (BoE) by including
(5 June 2019). mining area. decommissioning, closure and long-term monitoring and
maintenance requirements, and costs for the mining area.
13 MCT V3 – Gap Analysis Update physical closure criteria rerated to the Develop and include the detailed geotechnical and
(5 June 2019). mining area. geochemical stability design requirements into a predictive
model to quantify and manage the associated risks (e.g.
pit break back zones identification, subsurface support
deterioration and subsequent surface settlement, long-
term metal leaching due to AMD).
14 MCT V3 – Gap Analysis Update physical closure criteria rerated to the Develop detailed operation and closure designs to identify
(5 June 2019). mining area. and maintain long-term ZoI (failure zones), covering people
and the environment, needs to be in place .
15 MCT V3 – Gap Analysis Update physical closure criteria rerated to the Develop detailed security plans to not only address
(5 June 2019). mining area. operational risks but also the projected future closure and
post closure risk components such as long-term access
control and others safety and security risks.
16 MCT V3 – Gap Analysis Update physical closure criteria rerated to the Complete detailed studies to address long-term impacts
(5 June 2019). mining area. on surface and underground water resources (e.g.
pit water quality, future decant, interconnectivity of
groundwater between mines, health impacts on people).

RACI
Duration Start Finish Responsible Accountable Consult Inform % Complete

20 days Tue 19/05/28 Mon Engineering. Head of Environmental; Survey; Security. 0%
19/06/24 Engineering. Legal; Closure.
20 days Tue 19/05/28 Mon Social Performance. Head of Social Community Liaison; Exco team. 0%
19/06/24 Performance. Legal; Environmental;
Closure.
100 days Tue 19/05/28 Mon Closure. Head of SSD. Mining; Engineering; Security. 0%
19/10/14 Safety; Environmental.
10 days Tue 19/05/28 Mon Engineering. Head of Environmental; Security. 0%
19/06/10 Engineering. Survey; Legal; Social
Performance; Closure.
40 days Tue 19/05/28 Mon 19/07/22 Information and Head of IT. Environmental; Social 0%
systems management. Engineering; Performace;
Processing. Legal.
240 days Tue 19/05/28 Mon Closure. Head of SSD. Mining; Engineering; Security; 0%
20/04/27 Processing; Safety; Social
Environmental. Performance.
240 days Tue 19/05/28 Mon Closure. Head of SSD. Mining; Engineering; Security; 0%
Environmental. Performance.
20 days Tue 20/04/28 Mon Environmental. Head of SSD. Mining; Engineering; Security; 0%
Closure. Performance.
60 days Tue 20/05/26 Mon Mining. Head of Mining. Environmental; Social 0%
20/08/17 Engineering; Performace;
Processing; Safety; Legal.
Closure.
40 days Tue 20/05/26 Mon 20/07/20 Closure. Head of SSD. Mining; Engineering; Security. 0%
Processing; Safety;
Social Performance;
Legal; Environmental.
60 days Tue 19/05/28 Mon Closure. Head of SSD. Mining; Engineering; Exco team. 0%
19/08/19 Processing; Safety;
Social Performance;
Legal; Environmental;
Security.
Social Performance;
Security.
90 days Tue 19/05/28 Mon Environmental. Head of SSD. Mining; Processing; Engineering. 0%
19/09/30 Safety; Social
Performance; Legal;
Closure.
Social Performance;
Security.
40 days Tue 19/05/28 Mon 19/07/22 Security. Head of Security. Mining; Engineering; Exco team. 0%
Processing; Safety;
Social Performance;
Closure.
Performance; Legal;
Closure.

APPENDIX B: COMPLETED MASTER ACTION PLAN (completed)
ID
17 MCT V3 – Gap Analysis Update physical closure criteria rerated to the Review the updated closure criteria as defined and costed
(5 June 2019). mining area. for the mining areas (final voids, shafts, adits) to ensure
alignment with the final closure vision and land-use plan.
18 MCT V3 – Gap Analysis Update physical closure cost estimate. Develop a Class 4 estimate (L: -15% to -30% with H:
(5 June 2019). +20% to +50% and contingency (P50) of 20% -30%), as
required for a mine with a LoA of 15-10 years.
19 MCT V3 – Gap Analysis Update Biophysical closure and rehabilitation Include appropriate engagement sessions with I&AP in the
(5 June 2019). criteria related to land-use and land capability. current SEP to get focused inputs and subsequent broadly
external acceptance of the land-use and land capability
plan.
20 MCT V3 – Gap Analysis Update Biophysical closure and rehabilitation Develop and conduct a research programmes to
(5 June 2019). criteria related to land-use and land capability. understand seed dormancies.
21 MCT V3 – Gap Analysis Update Biophysical closure and rehabilitation Do a detailed closure and post-closure impact assessment
(5 June 2019). criteria related to surface and groundwater. to cover the surface and groundwater impacts, including
additional specialist studies.
22 MCT V3 – Gap Analysis Update Biophysical closure and rehabilitation Update the closure risk assessment and communicate the
(5 June 2019). criteria related to surface and groundwater. significant and insignificant risks to I&APs for comment.
23 MCT V3 – Gap Analysis Update Biophysical closure and rehabilitation Develop a detailed solute transfer mode; with a integrated
(5 June 2019). criteria related to surface and groundwater. surface and groundwater numerical; and geochemical
model; and associated storm water management
structures and systems, that are costed in the closure
liability are in place.
24 MCT V3 – Gap Analysis Update Biophysical closure and rehabilitation Develop detailed closure criteria using updated and
(5 June 2019). criteria related to surface and groundwater. detailed site wide water and solute balance and water
management plan for LoA, including all inflows and
outflows.
25 MCT V3 – Gap Analysis Update Biophysical closure and rehabilitation Conduct additional specialist studies, including landscape
(5 June 2019). criteria related to visual impacts/requirements. studies to ensure that all unknown risks and gaps have
been closed and the appropriate mitigation identified.
26 MCT V3 – Gap Analysis Update Biophysical closure and rehabilitation Update operational management measures and implement
(5 June 2019). criteria related to visual impacts/requirements. trials to demonstrate the effectiveness of the mitigation
measures.
27 MCT V3 – Gap Analysis Update Biophysical closure cost estimate. Develop a Class 4 estimate (L: -15% to -30% with H:
(5 June 2019). +20% to +50% and contingency (P50) of 20% -30%), as
28 MCT V3 – Gap Analysis Update Social transition requirements /criteria Assess the needs of I&APs through an SIA.
(5 June 2019). related to I&APs.
29 MCT V3 – Gap Analysis Update Social transition requirements /criteria Develop appropriate social transition criteria (e.g. economic
(5 June 2019). related to I&APs. diversification and reduced long-term dependency on
mining being a focus area) and associated costs (mostly
operational expenditure and possibly some closure
liabilities).
30 MCT V3 – Gap Analysis Update Social transition requirements /criteria Ensure that the operational budgets are geared towards
(5 June 2019). related to I&APs. addressing the social transition mitigation measures (e.g.
economic diversification), by using current vehicles such
as the Anglo Social Way.

RACI

Social Performance;
Security.
20 days Tue 20/08/18 Mon Finance. Head of Finance. Mining; Engineering; Exco team. 0%
Social Performance;
Security.
Closure.
240 days Tue 19/05/28 Mon Environmental. Head of SSD. Social Performance; Legal. 0%
20/04/27 Closure.
80 days Tue 19/05/28 Mon Closure. Head of SSD. Mining; Engineering; Safety; 0%
19/09/16 Processing; Social Finance.
Performance; Legal;
Environmental.
40 days Tue 19/05/28 Mon 19/07/22 Closure. Head of SSD. Mining; Engineering; Exco team. 0%
Processing; Social
Performance; Legal;
Environmental; Safety;
Security.
100 days Tue 19/05/28 Mon Environmental. Head of SSD. Mining; Processing; Exco team. 0%
Performance; Legal;
Closure; Engineering;
Finance.
Processing; Safety;
Social Performance;
Security.
Social Performance;
Security.
Performance; Legal;
Closure.
Social Performance;
Security.
Closure.
Closure.
Closure.

APPENDIX B: COMPLETED MASTER ACTION PLAN (completed)
ID
31 MCT V3 – Gap Analysis Update social transition requirements /criteria Give I&APs the opportunity to review the revised mine
(5 June 2019). related to I&APs. closure plan and be part of the closure plan development,
by means of ongoing engagement with the operation at
the appropriate level of influence.
32 MCT V3 – Gap Analysis Update social transition requirements /criteria Consider feedback from stakeholders on issues,
(5 June 2019). related to I&APs. alternatives and/or decisions and incorporated into the
closure plan, where appropriate.
33 MCT V3 – Gap Analysis Update social transition requirements related to Update the operation’s SEP to focus on the updated
(5 June 2019). SEP. closure plan, including the closure execution components,
aiming to transfer ownership of the closure plan from the
operation to the I&APs that will remain in the area post
closure.
34 MCT V3 – Gap Analysis Update social transition requirements related to Engage with I&APs at the appropriate level of Influence
(5 June 2019). SEP. to ensure that issues and concerns are consistently
understood and considered and offered the opportunity
to make substantive changes to the closure plan and its
closure and success criteria, where appropriate.
35 MCT V3 – Gap Analysis Update social transition cost estimate. Develop a Class 4 estimate (L: -15% to -30% with H:
(5 June 2019). +20% to +50% and contingency (P50) of 20%-30%), as
36 MCT V3 – Gap Analysis Update success criteria and monitoring Develop updated success criteria to reflect any changes
(5 June 2019). programme. to the post-mining land-use and include monitoring
parameters including SMART targets to a defined level of
success.
37 MCT V3 – Gap Analysis Update success criteria and monitoring Get the success criteria approved by authorities, with
(5 June 2019). programme. guidelines for acceptable standards and corrective actions.
38 MCT V3 – Gap Analysis Update the current risk assessment. Identify any remaining significant and high residual risks
(5 June 2019). and include additional or alternative closure criteria or
actions to reduce the unacceptable residual risks to an
acceptable level.
39 MCT V3 – Gap Analysis Improve the overall cost estimate accuracy and Develop a Class 4 estimate (L: -15% to -30% with H:
(5 June 2019). confidence. +20% to +50% and contingency (P50) of 20%-30%), as
40 MCT V3 – Gap Analysis Improve the overall cost estimate accuracy and Improve the level of confidence in closure plan by
(5 June 2019). confidence. reducing the assumptions related to the closure criteria in
the basis of the estimate to between 20%-30%.
41 MCT V3 – Gap Analysis Update the overall financial provision. Update the financial provision to align with a level 4
(5 June 2019). estimate.
42 MCT V3 – Gap Analysis Update the overall mine closure plan. Update the overall mine closure plan to a “Draft” mine
(5 June 2019). closure plan.

RACI

Social Performance;
Security.
Processing; Safety;
Social Performance;
Security.
Closure.
Social Performance;
Security.
Social Performance;
Security.
Social Performance;
Security.
Social Performance;
Security.
Social Performance;
Security.
Social Performance;
Security.
Social Performance;
Security.
Social Performance;
Security.
Social Performance;
Security.

APPENDIX C: COMPLETED MASTER ACTION PLAN SCHEDULE
ID Task Mode Task Name

ID ID Task Task
ModeMode
Task Task
NameName
1 Draft Mine Closure Plan Development
1 1 DraftDraft
MineMine
Closure
Closure
PlanPlan
Development
Development
2 Physical Closure
2 2 Physical
Physical
Closure
Closure
3 Update physical closure criteria for infrastructure (on and off‐site)
3 3 Update
Update
physical
physical
closureclosure
criteria
criteria
for infrastructure
for infrastructure (on and(on and
off‐site)
off‐site)
4 Define demolition waste disposal and recycling requirements and volumes.
4 4 Define
Define
demolition
demolition waste waste
disposal
disposal
and recycling
and recycling requirements
requirements and volumes.
and volumes.
5 Include closure related engagement sessions into the current SEP.
5 5 Include
Include
closure
closure
relatedrelated
engagement
engagement sessions
sessionsinto into
the current
the current
SEP. SEP.
6 Update physical closure criteria for mineral waste landforms
6 6 Update
Update
physical
physical
closureclosure
criteria
criteria
for mineral
for mineral waste waste
landforms
landforms
7 Complete additional kinetic testing & update the landform designs.
7 7 Complete
Complete
additional
additionalkinetickinetic
testing
testing
& update
& update the landform
the landform designs.
designs.
8 Review the effectiveness & sustainability of water management structures.
8 8 Review
Review
the effectiveness
the effectiveness & sustainability
& sustainabilityof water of water
management
management structures.
structures.
9 Develop a live system to track the material balance for hostile and non‐hostile material.
9 9 Develop
Develop
a livea system
live systemto track
to track
the material
the material balance
balance
for hostile
for hostile
and non‐hostile
and non‐hostile material.
material.
10 Demonstrate the executability of the closure criteria & cost effectiveness.
10 10 Demonstrate
Demonstrate the executability
the executability of the
ofclosure
the closure criteria
criteria
& cost & cost
effectiveness.
effectiveness.
11 Tracking management measures and closure criteria to improve stability and reduce costs.
11 11 Tracking
Tracking
management
management measures
measuresand closure
and closure criteriacriteria
to improve
to improvestability
stability
and reduce
and reducecosts.
costs.
12 Update the monitoring program.
12 12 Update
Update
the monitoring
the monitoring program.
program.
13 Review and update the LoM plans to include landform closure execution.
13 13 Review
Review
and update
and update the LoMthe LoMplansplans
to include
to includelandform
landform closure
closure
execution.
execution.
14 Update physical closure criteria for non‐mineral waste
14 14 Update
Update
physical
physical
closureclosure
criteria
criteria
for non‐mineral
for non‐mineral waste waste
15 Develop success criteria aligned with the closure criteria; final land use & closure vision.
15 15 Develop
Develop
success
success
criteria
criteria
aligned
aligned
withwith
the closure
the closure criteria;
criteria;
finalfinal
landland
use & useclosure
& closure
vision.
vision.
16 Update physical closure criteria related to the mining area
16 16 Update
Update
physical
physical
closureclosure
criteria
criteria
related
related
to the to mining
the mining areaarea
17 Review previous closure criteria and do focused benchmarking.
17 17 Review
Review
previous
previous
closureclosure
criteria
criteria
and doandfocused
do focused benchmarking.
benchmarking.
18 Improve the granularity of the criteria (Basis of Estimate).
18 18 Improve
Improve
the granularity
the granularity of the ofcriteria
the criteria
(Basis (Basis
of Estimate).
of Estimate).
19 Include geotechnical & geochemical stability design requirements into a predictive model.
19 19 Include
Include
geotechnical
geotechnical & geochemical
& geochemical stability
stability
design design
requirements
requirements into into
a predictive
a predictive
model.
model.
20 Develop detailed operation and closure designs.
20 20 Develop
Develop
detailed
detailed
operation
operationand closure
and closuredesigns.designs.
21 Develop detailed security plans.
21 21 Develop
Develop
detailed
detailed
security
security
plans. plans.
22 Complete detail studies on long‐term impacts on surface and underground water resources.
22 22 Complete
Complete
detaildetail
studiesstudies
on long‐term
on long‐term impactsimpactson surface
on surfaceand underground
and underground water water
resources.
resources.
23 Review the updated closure criteria a to align with the final closure vision & land use plan.
23 23 Review
Review
the updated
the updated closure
closure
criteria
criteria
a to aalign
to align
withwith
the final
the final
closure
closure
visionvision
& land& land
use plan.
use plan.
24 Update physical closure cost estimate
24 24 Update
Update
physical
physical
closureclosure
cost cost
estimate
estimate
25 Develop a Class 4 estimate.
25 25 Develop
Develop
a Class
a Class
4 estimate.
4 estimate.
26 Biophysical closure
26 26 Biophysical
Biophysical
closure
closure
27 Update Biophysical closure and rehabilitation criteria related to land use and land capability.
27 27 Update
Update
Biophysical
Biophysical closureclosure
and andrehabilitation
rehabilitation criteria
criteria
relatedrelated
to land
to land
use and
use and
landland
capability.
capability.
28 Include appropriate engagement sessions with I&AP on land‐use and land capability plan.
28 28 Include
Include
appropriate
appropriate engagement
engagement sessions
sessions
withwithI&API&AP on land‐use
on land‐use and land
and land
capability
capability
plan.plan.
29 Research programs to understand seed dormancies.
29 29 Research
Research
programs
programs to understand
to understand seedseeddormancies.
dormancies.
30 Update Biophysical closure and rehabilitation criteria related to surface and groundwater.
30 30 Update
Update
Biophysical
criteria
relatedrelated
to surface
to surface
and and
groundwater.
groundwater.
31 Do a detailed closure & post‐closure impact assessment and additional specialist studies.
31 31 Do aDodetailed
a detailed
closureclosure
& post‐closure
& post‐closure impact impactassessment
assessment and additional
and additional specialist
specialist
studies.
studies.
32 Update the closure risk assessment and communicate risks to I&APs for comment.
32 32 Update
Update
the closure
the closurerisk assessment
risk assessment and communicate
and communicate risksrisks
to I&APs
to I&APs
for comment.
for comment.
33 Develop a detailed solute transfer model that are costed & liability is in place.
33 33 Develop
Develop
a detailed
a detailed
solute solute
transfer
transfer
model model
that that
are costed
are costed& liability
& liability
is in is
place.
in place.
34 Develop detailed closure criteria.
34 34 Develop
Develop
detailed
detailed
closureclosure
criteria.
criteria.
35 Update Biophysical closure and rehabilitation criteria related to visual impacts / requirements.
35 35 Update
Update
Biophysical
criteria
relatedrelated
to visual
to visual
impacts
impacts
/ requirements.
/ requirements.
36 Conduct additional specialist studies, including landscape studies.
36 36 Conduct
Conduct
additional
additionalspecialist
specialist
studies,
studies,
including
including
landscape
landscape studies.
studies.
37 Update operational management measures and implement trials.
37 37 Update
Update
operational
operational management
management measures
measures and implement
and implement trials.trials.
38 Update Biophysical closure cost estimate.
38 38 Update
Update
Biophysical
cost cost
estimate.
estimate.
39 Develop a Class 4 estimate.
39 39 Develop
Develop
a Class
a Class
4 estimate.
4 estimate.
40 Social Transition
40 40 Social
Social
Transition
Transition
41 Update Social transition requirements / criteria related to I&APs
41 41 Update
Update
Social
Social
transition
transitionrequirements
requirements / criteria
/ criteria
relatedrelated
to I&APs
to I&APs
42 Assess the needs of I&APs through a Social Impact Assessment (SIA).
42 42 Assess
Assess
the needs
the needsof I&APs
of I&APs
throughthrough
a Social
a Social
ImpactImpact
Assessment
Assessment (SIA).(SIA).
Task Project Summary Manual Task
Task Task Project
Project Summary
Summary Manual Task Task
Manual
Project: Master Action Plan Exa Split Inactive Task Duration-only
Project: Master
Project:
Date: Wed Action
Master Exa ExaSplit Split
Plan Plan
Action
19/07/03 Milestone
Inactive Task Task
Inactive
Inactive Milestone
Duration-only
Duration-only
Manual Summary Rollup
Date:Date:
WedWed19/07/03
19/07/03 Milestone
Milestone Inactive Milestone
Inactive Milestone Manual Summary
Manual RollupRollup
Summary
Summary Inactive Summary Manual Summary
Summary
Summary Inactive Summary
Inactive Summary Manual Summary
Manual Summary
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Start-only Deadline
Start-only Deadline
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p External Tasks Manual Progress
ry Rollup External Tasks Manual Progress
External Milestone
ry External Milestone
ge 1 ANGLO AMERICAN MINE CLOSURE TOOLBOX EXAMPLES VERSION 3 65

13 13 ReviewReview and update
and update the LoMthe LoM plansplans to include
to include landform landform closure closure
execution.
execution.
14 14 Update Update
physical physicalclosure closure
criteriacriteria
for non‐mineral
for non‐mineral waste waste
15 15 APPENDIX C: COMPLETED Develop
Develop success
MASTER success criteria
criteria
ACTION aligned aligned
PLAN withSCHEDULE
with
the closure
the closure criteria;
criteria;
(continued) finalfinal
landland use & useclosure
& closure
vision.
vision.
16 16 Update Update
physical physicalclosure closure
criteriacriteria
related related
to the to mining
the mining areaarea
ID ID17
17 Task
TaskMode
ModeTask
Task
Task
Mode
Name
Name
Mode
Task
Task
NameName
ReviewReview previous
previous closureclosure
criteria
criteria
and do andfocused
do focused benchmarking.
benchmarking. Durat
Dur
18 18 Improve
Improve theappropriate
granularity
the granularity of social
the oftransition
criteria
the criteria
(Basis (Basis
of Estimate).
of(e.g.
Estimate).
43 43 Develop
Develop appropriate
Develop
appropriate
Develop social
appropriate
social transition
transition
social criteria
criteria
transition
(e.g.
(e.g.
criteria
economic
criteria
economic(e.g. economic
diversification).
diversification).
economic diversification).
diversification). 9090dad
19 19 Include
Includegeotechnical
geotechnical & geochemical
& geochemical stability
stabilitydesign designrequirements
requirements into into
a predictive
a predictive
model.
model.
44 44 Ensure
Ensurethatthat
Ensure
the
Ensure
the operational
operational
that thatthethe operational
budgets
operational
budgets areare
budgets
geared
budgets
geared are
towards
towards
are
gearedgearedsocial
social
towards
towards
transition.
transition.
social
socialtransition.
transition. 2020dad
20 20 Develop
Develop detailed
detailed operation
operation and closure
and closure
designs. designs.
45 45 Give
GiveI&Aps
I&Aps Give
the
Give
theI&Aps
opportunity
opportunity
I&Aps thethe opportunity
to
opportunity
toreview
reviewthe tothereview
torevised
revised
review themine
the
mine
revised
revised
closure
closure
mine mine
plan.
plan.
closure
closure plan.
plan. 2020dad
21 21 Develop
Develop detailed
detailed security
security
plans. plans.
46 46 Consider
Considerfeedback
Consider
feedback
Consider from
feedback
fromfeedback
stakeholders
stakeholders
from from stakeholders
stakeholders
ononissues,
issues,on alternatives
alternatives
on
issues,
issues, alternatives
and/or
alternatives
and/ordecisions.
decisions.
and/or
and/or decisions.
decisions. 2020dad
22 22 Complete
Complete detail detail
studiesstudies
on long‐term
on long‐term impacts impacts on surface
on surfaceand underground
and underground water water
resources.
resources.
47 47 Update
UpdateSocial
Social
Update
Update
transition
transition
Social
Social transition
requirements
requirements
transition requirements
requirements
related
relatedtoto related
Stakeholder
Stakeholder
related to to Stakeholder
engagement
Stakeholder
engagement engagement
engagement
planning
planning(SEP)planning
(SEP)
planning(SEP)
(SEP) 415
415d
23 23 ReviewReview the updated
the updatedclosure closure
criteriacriteria
a to a
align
to align
with with
the final
the final
closureclosurevision vision
& land
& land
use plan.
use plan.
48 48 Update
Updatethe the
Update
operation's
Update
operation's
thethe operation's
SEP
operation's
SEPtotofocus
focus
SEPon
SEPon
tothefocus
to
thefocus
updated
updated
on on theclosure
the
updated
closure
updatedplan.
plan.
closure
closure plan. plan. 1010dad
24 24 Update Update
physical physical
49 49 Engage
Engage with
with
Engage
I&Aps
Engage
I&Aps with atclosure
atwith
the
I&Aps closure
theI&Aps cost
appropriateatcost
appropriate
at the estimate
the estimate
appropriate
level
appropriate
levelofofInfluence
Influence
level levelof (Ongoing)
Influence
of(Ongoing)
Influence (Ongoing)
(Ongoing) 240
240d
25 25 Develop
Develop a Class
a Class
4 estimate.
4 estimate.
50 50 Update
UpdateSocial
Social
Update
Update
transition
transition
Social
Social transition
cost
cost
transition
estimate
estimate
cost costestimate
estimate 2020dad
26 26 Biophysical
Biophysical closure closure
51 51 Develop
Developa Develop
aClass
Class
Develop
4 4estimate.
aestimate.
Class
a Class 4 estimate.
4 estimate. 2020dad
27 27 Update Update
Biophysical
and and
rehabilitation
rehabilitation criteria criteria
related relatedto land
to land
use and
use and
land land
capability.
capability.
52 52 Success
SuccessCriteria
Criteria
Success
Success
&&Criteria
Monitoring
Monitoring
Criteria & Monitoring
&Program
Monitoring
ProgramProgram Program 150
150d
28 28 Include
Includeappropriate
appropriate engagement
engagement sessionssessions withwith I&API&AP on land‐use
on land‐use and landand land
capability
capability
plan.plan.
53 53 Update
Updatesuccess
success
Update
Updatecriteria
criteria
success
success
&&monitoring
criteria
monitoring
criteria & monitoring
&program
monitoring
program program
program 150
150d
29 29 Research
Research programsprograms to understand
to understand seed seed
dormancies.
dormancies.
54 54 Develop
Developsuccess
Develop
success
Develop criteria
criteria
success
success
including
including
criteria
criteriaSMART
including
SMART
including
targets
targets
SMARTSMARTtototargets
a adefined
targets
defined to level
atolevel
defined
a defined
ofofsuccess.
success.
levellevel
of success.
of success. 9090dad
30 30 Update Update
Biophysical
and and
rehabilitation
related relatedto surface
to surface
and and
groundwater.
groundwater.
55 55 Get
Getthe
thesuccess
success
GetGet thecriteria
the
criteria
success
success
totocriteria
bebecriteria
approved
approved
to be
to be by
approved
byapproved
authorities.
authorities.
by by authorities.
authorities. 6060dad
31 31 Do aDodetailed
a detailedclosure closure
& post‐closure
& post‐closure impact impactassessment
assessment and additional
and additional
specialist
specialist
studies.
studies.
56 56 Financial
FinancialRequirements
Financial
Requirements
Financial Requirements
Requirements
andandRisk RiskAssessment
and
Assessment
andRiskRiskAssessment
Assessment 6060dad
32 32 UpdateUpdate the closure
the closure
risk assessment
risk assessment and communicate
and communicate risks risks
to I&APs
to I&APs
for comment.
for comment.
57 57 Update
Updatethe the
Update
current
Update
current therisk
the
risk
current
assessment
current
assessment
riskrisk
assessment
assessment 1010dad
33 33 Develop
Develop a detailed
aanydetailed
solute solute
transfertransfer
model modelthat that
areresidual
costed
arereduce
costed& and
liability
& liability
is inthe
is
place.
in place.
58 58 Identify
Identify any
any
Identify
remaining
Identify
remaining
any remaining
significant
significant
remaining significant
andand
significant
high
high residual
and
residual
and high high
risks
risks
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Mon 20/01/20
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Mon 19/06/24
Tue 19/05/28 Mon 19/07/22
Mon 19/07/22
90
415 days days Tue 19/05/28 Mon 19/09/30
Tue 19/05/28 Mon 20/12/28
Tue 19/10/08 Mon 19/10/21
Mon 20/12/28
20 days Tue 19/05/28
240 days Tue 20/08/18 Mon 20/09/14
Mon 20/04/27
Tue 20/08/18 Mon 20/09/14
Mon 20/02/17
20 days320 daysTue 20/01/21
Tue 19/05/28 Mon 20/08/17
Mon 20/02/17
280
150 days days Tue 19/05/28 Mon
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40 days Tue 20/05/19
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Mon 20/12/14
Tue 19/05/28 Mon 20/04/27
Mon 20/09/21
Tue 19/05/28 Mon 20/07/20
Mon 20/12/14
Tue 19/05/28 Mon 19/09/16
Mon 20/12/14
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Tue 20/09/22 Mon 20/10/05
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Mon 20/11/02
Tue 19/05/28 Mon 19/11/11
Mon 20/10/19
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Tue 20/10/06 Mon 20/10/19
Tue 20/07/21 Mon 20/08/17
Mon 20/11/16
Tue 20/07/21 Mon 20/08/17
Mon 20/11/16
Tue 19/05/28 Mon 20/12/28
Mon 20/12/14
Tue 19/05/28 Mon 20/01/20
Mon 20/12/14
60 days Tue 19/05/28 Mon 19/08/19
Start-only Deadline
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EXAMPLE 7: REHABILITATION STRATEGY AND

FIVE-YEAR REHABILITATION PLANS
INTRODUCTION The next step is to develop a commitment to concurrent
(also known as progressive) rehabilitation and to reduce the
AA has developed a Group Rehabilitation Strategy (the rehabilitation backlog (land available for rehabilitation) over the
‘Strategy’) that commits AA to ensuring all rehabilitation areas remaining life of the asset. The targets should be integrated
are safe, stable, non-polluting and sustainable. The Group into the business plan to ensure resources and budgets are
Rehabilitation Strategy provides a standard for integrating allocated. Older operations with a significant backlog, due to
rehabilitation in business planning process and setting targets poor historical integration into the business plan, should be
to eliminate the rehabilitation backlog (defined as lease hold reducing it over the remaining life of the mine. Newer mines
area deemed not economically viable for future mining). with limited backlog should be committing to concurrent
The Group Rehabilitation Strategy is applicable to open cut rehabilitation opportunities through strategic waste deposition
operations and forms the basis for developing a Business Unit three-years after the initial disturbance. All rehabilitation
(BU) or operation specific Strategy. targets need to consider the budgeted LoA clearing rate
(excluding clearing for permanent infrastructure) to ensure
A Rehabilitation Strategy emphasises the senior leader’s backlog is managed appropriately.
commitment to optimise rehabilitation through ensuring
the backlog is managed, and to facilitate integration into The Strategy should also set out the process to develop
the business planning processes (i.e. LoAP). Successful sustainable rehabilitation prescriptions, success criteria and
concurrent rehabilitation programmes occur when activities monitoring, and maintenance and management programmes
are fully integrated into the various operational planning to facilitate the relinquishment process. These items will then
functions. The Rehabilitation Strategy should outline the be expanded in the five-year rehabilitation plan. The Strategy
rehabilitation vision and objectives for the operation, which should ultimately be signed off by the Business Unit Chief
align to the closure vision and post-mining land-use plan. Executive Officer (BU CEO) to ensure strategic alignment.
The AA Mine Closure Standard requires the development A five-year rehabilitation plan (‘Rehabilitation Plan’) must
of Five-Year Rehabilitation Plans, which should outline the: be developed and updated on an annual basis as per
• Process to integrate rehabilitation into the business plan. the AA Mine Closure Standard. A Rehabilitation Plan will
• Rehabilitation targets set on a rolling five-year period. build on the commitments made by the BU and operation
• Detailed rehabilitation prescriptions and trials to be to investigate rehabilitation opportunities and undertake
implemented. research trials towards closing knowledge gaps and driving
• Rehabilitation monitoring programme that is linked to relinquishment. It should be integrated into the LoAP and
the success criteria. the medium term mine plan and must include the following:
• Suggested management and maintenance activities. • High-level summary of the baseline environmental and
legal requirements for the site.
The proposed methodology to develop a rehabilitation • Summary of disturbance and rehabilitation profile (in
strategy (Figure 1) and a five-year rehabilitation plan is hectares) for each domain on-site, including areas
outlined below. available for rehabilitation.
• Annual rehabilitation targets for the five-year period.
METHODOLOGY • Rehabilitation prescriptions (i.e. landform design, growth
medium, erosion control measures, seeding/planting
The Strategy should be developed in a workshop with specifications, fertiliser rates) to be applied to each
the presence of key internal stakeholders (e.g. General rehabilitation area.
Manager, Technical Services Manager, Safety Health and • Estimated budget to rehabilitate according to the five-
Environment (SHE) Manager) to ensure Senior Leadership year plan.
direction and acceptance. The Strategy should set the • Review of the rehabilitation programme implemented in
high-level rehabilitation objectives for the site (safe, stable, the previous year including expenditure.
self-sustaining and non-polluting) as well as domain- • Rehabilitation monitoring programme to be
specific objectives. This means that a site can have implemented over the five-year period.
multiple rehabilitation objectives that are linked to each • Rehabilitation maintenance and management action
agreed post-mining land-use. An example of a specific plan and budget to ensure areas are being managed
rehabilitation objective for native vegetation is: to relinquishment.
‘To rehabilitate defined areas to a low-maintenance native Once drafted, the Rehabilitation Plan should be endorsed
vegetation with composition, structure and function by the relevant site leadership team (General Manager,
based on a relevant reference ecosystem (or agreed Finance Manager, Technical Services Manager, SHE
representative site) with a stable landform and self- Manager) to ensure the plan is resourced and budgeted
sustaining vegetation cover’. appropriately. The Plan should be developed in line with the
site’s budgeting cycle and updated on an annual basis to
reflect changes in the mine plan.

METALLURGICAL COAL REHABILITATION STRATEGY

AA Metallurgical Coal (Met Coal) has a disturbed ground footprint of greater than 24 000 ha. A five-point Rehabilitation
Strategy has been developed to focus rehabilitation efforts at Met Coal.
REHABILITATION OBJECTIVES AND TARGETS

✔ Rehabilitation areas will be safe, stable, non-polluting, sustainable and mee the agreed
post-mining land-use through innovation.
✔ Site-specific rehabilitation objectives will meet applicable stakeholdeer identified land-uses.
✔ Rehabilitation targets are reconciled, audited and included in CEO, Executive Head of
Open cut and Executive Head of Underground and site General Manager (GM) metrics to
promote accountability and tracked monthly and quarterly.
È
REHABILITATION PLANNING
✔ Operational and closure planning is integrated through collaboration to develop the best
overall rehabilitation plan, including consideration of the impact of business decisions.
✔ Annual rehabilitation target hectares are based on eliminating outstanding disturbance
liability and maintaining ratio of rehabilitation hectares to the area disturbed each year.
✔ Annual Rehabilitation Target = Annual clearing Rate (ha) + [Rehabilitation Backlog (ha)/
No. of Years Until Last Coal].
✔ Rolling five-year rehabilitation plans will be in line with Regulator and Internal Requirements.
È
REHABILITATION PRESCRIPTIONS
✔ A guideline, outlining the key considerations for developing site-specific five-year
rehabilitation plans, will be developed for Met Coal open cut and underground operations.
✔ Selective placement of problematic spill (e.g. acidic, dispersive, vulnerable to spontaneous
combustion) will be standard practice.
✔ Topsoil, growth medium and capping materials (i.e. rock for dispersive, clays for TFS75s)
will be selectively stripped and conserved for use in the rehabilitation process.
✔ Seed procurement processes will be auditable.
River pylons to be considered to reduce subsidence in waterways.
Site-specific and auditable rehabilitation standard operating procedures (i.e. landform
design, surface water and erosion control, subsidence management, seed lits, weed/
invasive species, monitoring protocol) will exist.
È
COMPLETION CRITERIA
✔ Site-specific rehabilitation completion criteria, with input from applicable stakeholders, will
be developed.
✔ Progressive certification of rehabilitated areas against defined completion criterial (also
known as success criteria) will be obtained to demonstrate commitent to our stakeholders.
È
MONITORING AND MAINTENANCE
✔ Monitoring and maintenance programmes will be developed to ensure the safety of our
surrounding communities and to facilitate the process of achieving sign-off on completion
criteria.
✔ Records related to rehabilitation design, construction, implementation and monitoring shall
be maintained.
Figure 1: Met Coal Rehabilitation Strategy.

Barro Alto Mine in Brasil as seen by drone.
EXAMPLE 8: SUCCESS CRITERIA

INTRODUCTION • Landforms are integrated into the surrounding
landscape and are non-polluting.
Success criteria (also known as completion criteria) are • Rehabilitation exhibits sustained growth and is resilient.
the agreed standards that must be met to facilitate lease • Management of rehabilitation can be integrated with
relinquishment. They include physical, biophysical and socio- surrounding areas and requires no additional ongoing
economic parameters and are generally defined through resources.
engagement with regulators and other external stakeholders. • Social transition has left a positive legacy and
Success criteria must complement and fully align with the sustainable post-mining livelihoods.
closure vision, objectives and closure criteria (Figure 1). They
should be SMART. Success criteria should be developed Each success criteria principle should be assessed at
in the early stages of the development of an operation and multiple time categories. An example of success criteria
should become more quantitative over time as concurrent time categories would be:
rehabilitation is undertaken and success criteria are tested. • Development and mining.
During engagement with regulators, it should be made clear • Rehabilitation process.
that success criteria will change over time as they are tested, • Early development (0-5 year old rehabilitation).
but this should not be used as an excuse to not attempt to • Established rehabilitation and relinquishment (> 5 year
develop them early in an operations life. It is important that an old rehabilitation).
appropriate monitoring programme is developed (if possible,
in collaboration with the regulators) to ensure that the right This step entails the use of the condition and commitments
data are being collected to determine whether success criteria register as developed in Tool 1. These should ideally be
are being met. If the success criteria are not being met, a contained within a register that is updated regularly with
maintenance programme should be developed. The proposed tracking of required actions (Table 1).
methodology for developing success criteria is explained below
and an example excel spreadsheet template is also provided. Success criteria should then be developed for each time
category and cross-referenced with the principle. The
METHODOLOGY criteria and intent stated as a question, the relevant domains,
guidelines for acceptance, the accepted standard and
Operations should develop high level principles that they potential corrective actions should then be developed (Table
are trying to achieve with the success criteria. An example 2), using the conditions and commitments as a starting point.
of success criteria principles would be:
• Meet rehabilitation objectives.

Figure 1: Relationship between closure vision, PMLs, objectives, closure criteria, success criteria and the monitoring
programme to facilitate progressive sign-off and relinquishment.
Table 1: Example of a conditions and commitments register.

REFERENCE/ REFERENCE
RELEVANT LICENCE IN ENVIRONMENTAL RESPONSIBLE
DOCUMENT NUMBER DOCUMENT COMMITMENT ASPECT DEPARTMENT COMPLIANCE
Pit and dump extention NC 30/5/1/2/2/ Section 12. Implement the Closure Toolbox and AA way as Topography. Land
and Environmental (10056) MR. per the Closure Plan. management.
Management
Programme (EMPr)
consolidation.
Pit and dump extention NC 30/5/1/2/2/ Section 12. Comply to the Mine residue classification and Topography. Env
and EMPr consolidation. (10056) MR. characterisation in compliance with GNR 635 of management.
August 2013, “National Norms and Standards
for the Assessment of waste for landfill disposal”
and GNR 636 of August 2013, “National Norms
and Standards for disposal of waste to landfill”, in
terms of NEMWA, 2008.
Pit and dump extention NC 30/5/1/2/2/ Section 12. Comply to the SIOM Code of Practice (COP) on Topography. Mining.
and EMPr consolidation. (10056) MR. mine residue deposits.
Pit and dump extention NC 30/5/1/2/2/ Section 12. Implement a topsoil management plan. Soils. Land
and EMPr consolidation. (10056) MR. management.
Pit and dump extention NC 30/5/1/2/2/ Section 12. Implement a rehabilitation programme. Land-use and land Land
and EMPr consolidation. (10056) MR. capability. management.
Pit and dump extention NC 30/5/1/2/2/ Section 12. Develop and Implement System and Operational Soils. Env
and EMPr consolidation. (10056) MR. Procedures and training programme in management.
compliance with ISO14001.
Pit and dump extention NC 30/5/1/2/2/ Section 12. Comply with the National Norms and Standards Land-use and land Env
and EMPr consolidation. (10056) MR. for the Remediation of Contaminated Land and capability. management.
Soil Quality (GNR.331 of 2014), thereunder.
Pit and dump extention NC 30/5/1/2/2/ Section 12. Implement the Closure Toolbox and AA way as Soils. Land
and EMPr consolidation. (10056) MR. per the Closure Plan. management.
Pit and dump extention NC 30/5/1/2/2/ Section 12. Develop and Implement System and Operational Soils. Env
Pit and dump extention NC 30/5/1/2/2/ Section 12. Reasonable precaution will be taken to prevent Soils. Env
and EMPr consolidation. (10056) MR. spillage and in case there is spillage, cleaning management.
procedures to be undertaken in order to comply
with the principles of pollution prevention and
duty of care (NEMA, 1998).
Pit and dump extention NC 30/5/1/2/2/ Section 12. Manage general and/or hazardous waste in a Soils. Env
and EMPr consolidation. (10056) MR. manner as to comply with NEM: WA, 2008. management.
Pit and dump extention NC 30/5/1/2/2/ Section 12. Implement Water management measures in Soils. Env
and EMPr consolidation. (10056) MR. compliance with NWA, 1998 and GN 704, 1999. management.
Pit and dump extention NC 30/5/1/2/2/ Section 12. Comply with the National Norms and Standards Soils. Env
and EMPr consolidation. (10056) MR. for the Remediation of Contaminated Land and management.
Soil Quality (GNR.331 of 2014), thereunder.

REFERENCE/ REFERENCE
RELEVANT LICENCE IN ENVIRONMENTAL RESPONSIBLE
DOCUMENT NUMBER DOCUMENT COMMITMENT ASPECT DEPARTMENT COMPLIANCE
Pit and dump extention NC 30/5/1/2/2/ Section 12. Implement Water management measures in Surface water. Env
Pit and dump extention NC 30/5/1/2/2/ Section 12. Comply with DWS’s Best Practice Guideline Surface water. Env
and EMPr consolidation. (10056) MR. Series in terms of integrated water and waste management.
management and monitoring.
Pit and dump extention NC 30/5/1/2/2/ Section 12. Implement a Surface water monitoring Surface water. Env
and EMPr consolidation. (10056) MR. programme. management.
Pit and dump extention NC 30/5/1/2/2/ Section 12. Develop and Implement System and Operational Surface water. Env
Pit and dump extention NC 30/5/1/2/2/ Section 12. Reasonable precaution will be taken to prevent Surface water. Env
and EMPr consolidation. (10056) MR. spillage and in case there is spillage, cleaning management.
procedures to be undertaken in order to comply
with the principles of pollution prevention and
duty of care (NEMA, 1998).
Pit and dump extention NC 30/5/1/2/2/ Section 12. Manage general and/or hazardous waste in a Surface water. Env
and EMPr consolidation. (10056) MR. manner as to comply with NEM: WA, 2008. management.
Pit and dump extention NC 30/5/1/2/2/ Section 12. Comply to the Mine residue classification and Surface water. Env
and EMPr consolidation. (10056) MR. characterisation in compliance with GNR 635 of management.
August 2013, “National Norms and Standards
for the Assessment of waste for landfill disposal”
and GNR 636 of August 2013, “National Norms
and Standards for disposal of waste to landfill”, in
terms of NEMWA, 2008.
Pit and dump extention NC 30/5/1/2/2/ Section 12. Implement the Closure Toolbox and AA way as Surface water Land
and EMPr consolidation. (10056) MR. per the Closure Plan. management.
Pit and dump extention NC 30/5/1/2/2/ Section 12. Comply to the SIOM Code of practice (COP) on Surface water. Mining.
and EMPr consolidation. (10056) MR. mine residue deposits.
Pit and dump extention NC 30/5/1/2/2/ Section 12. Implement Water management measures in Groundwater. Env
Pit and dump extention NC 30/5/1/2/2/ Section 12. Comply with DWS’s Best Practice Guideline Groundwater. Env
and EMPr consolidation. (10056) MR. Series in terms of integrated water and waste management.
management and monitoring.
Pit and dump extention NC 30/5/1/2/2/ Section 12. Implement a Groundwater monitoring Groundwater. Env
and EMPr consolidation. (10056) MR. programme. management.
Pit and dump extention NC 30/5/1/2/2/ Section 12. Conduct Site survey for red data and protected Natural flora and Env
and EMPr consolidation. (10056) MR. plants and animals (on greenfield areas). fauna. management.
Table 2: Example of the proposed structure of success criteria for one time category.
GUIDELINES FOR POTENTIAL
PRINCIPLE CRITERIA AND INTENT DOMAIN ACCEPTANCE ACCEPTED STANDARD CORRECTIVE ACTIONS
Rehabilitation Have clear land-use All – although Land-use objectives should Land-use objectives have Feedback from agencies
objective. objectives been developed objectives may vary be developed with input from been approved by the relevant and stakeholders to be
for the site? in different areas. relevant stakeholders. government agency. incorporated into the land-use
objectives.
Rehabilitation Has a clear rehabilitation All The rehabilitation objective The site specific rehabilitation Feedback from agencies
objective. objective been developed? should align with the objective has been endorsed and stakeholders to be
rehabilitation strategy and by the relevant government incorporated into the
closure plan, and any AA agencies following stakeholder rehabilitation objective.
guidelines. The rehabilitation input.
objective should allow site to
meet the land-use objectives.
Rehabilitation Has a clear rehabilitation All Rehabilitation plan should align Annual rehabilitation plans Review areas available and
objective. plan been developed, with the Closure plan, LoA have been developed and adjust plan accordingly.
covering rehabilitation for plan and short/medium term agreed by all relevant internal
each year? mine plan. stakeholders.
Plan is implemented as agreed.
Sufficient resources are
available to complete
progressive rehabilitation.
Integrated, Are the rehabilitation All Rehabilitation designs should The designs are consistent Redesign as required and
non-polluting designs appropriate? be developed to comply with the conditions and include include suitable structures.
landforms. with the commitments in the appropriate aspects such as
Environmental Management slope angles, slope lengths,
Programme (EMP). drainage lines, and stormwater
management structures.
Integrated, Are the rehabilitation All The rehabilitation techniques Agreed rehabilitation Develop and agree on
non-polluting procedures documented? should be documented, procedures have been rehabilitation procedures and
landforms. including technical designs, developed and have been document in the EMS and
moonscaping techniques, described in the Environmental Rehabilitation Strategy.
topsoil placement and seeding. Management System (EMS)
and Rehabilitation Strategy.
Integrated, Is adequate cover material All A supply of cover material There is appropriate topsoil, Source the cover material and
non-polluting available? should be sourced and its spoil and other non vegetative ensure its availability.
landforms. quality and characteristics cover available.
recorded.

EXAMPLE 9: SOCIAL TRANSITION RISK

ASSESSMENT AND CASH FLOW
View of the Mototolo Concentrator, South Africa.
INTRODUCTION of the social transition risk assessment and cash flow,

demonstrates the relationship between residual risk and
A social transition plan is developed using the risk the associated costs.
based MCT approach that aims to achieve a plan that is
practically and financially executable with an acceptable Social transition should not be a standalone component
residual risk profile. The aim of the social transition but integrated with the physical, bio-physical and financial
plan is to ensure that the reputation of the company components of LoAP. The risk assessment, with social
will be protected, resulting in long-term shareholder transition criteria and the subsequent basis of estimate
and stakeholder value and a future license to operate. documents should be used as live document going forward.
The basis of the social transition costs, are directly These documents should be used to change the current
linked to the mitigation of risks and the optimisation of operational activities and improve the overall confidence in
opportunities and hence will change as the risk profile the social transition plan components and reduce the funds
changes (lower cost vs. higher residual risk). The example required during the post closure phase.
SOCIAL TRANSITION RISK ASSESSMENT, CRITERIA AND LIABILITY ESTIMATE
SOCIAL
LIABILITY
DURING
DECOMMIS-
SIONING
OPERATING COSTS PHASE
WHILE STILL IN (0 TO 5 ACTIVE
PRODUCTION PHASE YEARS POST
PRE-MITIGATION (CURRENT AND PRODUCTION
RISK RANKING MITIGATION/CLOSURE CRITERIA ADDITIONAL) PERIOD)
Reputation/
Social/
Community/
Legal and Health and
Financial Regulatory Safety
Current Operating Estimated
Consequence
Consequence
Consequence
Operating costs in the Decommis-
Probability
Probability
Probability
DIRECT IMPACTS RISK ISSUES
costs last 5 years sioning Liability
Rating
Rating
Rating
ON SOCIO- FOR SOCIO-
ECONOMIC ECONOMIC (2019) (total cost Estimate
ASPECTS AT ASPECTS AT (Annual cost for 5 years (total cost for 5
CLOSURE CLOSURE Current Mitigating Actions in $m) in $m) years in $m)
1. Employees and dependants
1.1 Loss of The loss of salary 4 4 21 Utilise the existing stakeholder forms (engagement 1. $0,5m 1. $2,5m 1. $2,5m
security of and benefits forums) to: 2. $0,2m 2. $1,0m 2. None
income. for the mine 1. Maintain relationships between the mine and unions.
employees, such 3. Included 3. $0,5m 3. None
as medical aid, 2. Identify possible portable skills to build capacity with 4. Included 4. Included 4. None
housing, water employees.
5. Included 5. Included 5. None
and electricity 3. Implement training opportunities to transfer these
allowances, identified skills. 6. Included 6. $3,0m 6. None
which could
4. Identifying infrastructure with a beneficial post-mining 7. Included 7. Included 7. None
relate to a
re-use for possible handover, and plan and cost the 8. None 8. $10,5m 8. $5,2m
situation where
required modifications, if any.
employees might 9. Included 9. Included 9. None
not be able to 5. Develop and agree on the downscaling and
10. Included 10. (Included 10. Included
obtain alternative retrenchment plan with union and jointly agree on
11. Included in 2022 11. Included
employments redeployment strategies within the company.
only)
leaving them 6. Promote a culture of self-employment and self-
unemployed 11. Included
maintenance or none dependence on the mine (town
(reputation). transformation).
Total: $0,7m Total: $17,5m Total: $7,7m
Risk that current 2 3 8 7. Develop a skills development programme to maximise
home owners job opportunities and alternative livelihoods.
might experience
a reduction in 8. All retrenchments will be done as per Labour Act
property value and collective agreements.
and battle to pay 9. System to be put in place to track ex employees’ re-
the mortgage employment status post mine closure.
having to work 10. Current medical contributions by the company is
somewhere ells. 50% for medical aid, and will be increased to 75% for
Can’t sell the VSP candidates.
house and need
accommodation 11. The cost of repatriation is included in current HR
somewhere else. budget for relevant staff (approx. 60% of people).
The risk of 4 3 18
production
stoppages/
disruption due
to employees
reaction to
downscaling and
mine closure.
1.2 Reluctance of Risk of 4 4 21 1. Need additional mitigation. 1. None 1. None 1. None
employees to employees not
buy property in taking up the
local town due offer to buy
to short LoA. property in Total: $0 Total: $0 Total: $0
local town, and
rather stick to
current housing
conditions (free
water, etc.).
1.3 Illegal mining. Risk of illegal 3 4 17 4 3 18 5 3 22 1. Keep security in place and relook at future 1. $4,1m 1. $22m 1. $31,8m
mining by requirements related to town opening, and security risks 2. Included 2. Included 2. Included
employees and associated with possible increased in unemployment.
wider community, 2. The current rehabilitation plan covers some risks
resulting in safety associate with voids and large structures being made Total: $4,1m Total: $22m Total: $31,8m
and security safe.
risks. (reputation
and safety).

SOCIAL LIABILITY
DURING
MONITORING
PHASE
(10 YEAR
CARE AND ADDITIONAL
MAINTENANCE ACTIONS
PERIOD, POST REQUIRED ADDITIONAL
DECOMMIS- POST RISK CLOSURE
SIONING) POST-MITIGATION ASSESSMENT COST POST-MITIGATION
Reputation/ Reputation/
Social/ Social/
Community/ Estimated Community/
Legal and Health and Estimated Monitoring Legal and Health and
Financial Regulatory Safety Operating Decommis- and Financial Regulatory Safety
Estimated costs in sioning Maintenance
Consequence
Consequence
Consequence
Consequence
Consequence
Consequence
Monitoring and the last 5 Liability Liability
Probability
Probability
Probability
Probability
Probability
Probability
Current
Maintenance years Estimate Estimate
Rating
Rating
Rating
Rating
Rating
Rating
Operating
Liability Estimate Additional costs (total cost (total cost (total cost for
(total cost for 10 Actions (Annual cost for 5 years for 5 years in 10 years in
years in $m) Required in $m) in $m) $m) $m)
1. None 4 3 18 12. Need 12. None 12. (Antici- 12. None 12. None 4 3 18
clear strategy pated
2. None 13. None sales not 13. None 13. None
on selling of included)
3. None company assets 14. None 14. None 14. None
– including 13. None
4. None 15. None 15. None 15. None
covering 14. None
5. None 16. None 15. None 16. None 16. None
employee
6. None properties. 16. None
7. None 13. Clear town
8. N$2,2m transformation
strategy and
9. None budget and
10. None communication
11. None plan.
14. Housing
strategy must be
clear.
Total: $2.2m 15.Investor/ Total: $0 Total: $0 Total: $0 Total: $0
2 2 5 2 2 5
employee
confidence to
be establish.
16. Town
transformation
is looking at the
sustainability of
the education
and other
services –
linking with
government and
4 3 18 combining with 4 2 14
other mines, etc.
1. None 4 4 21 2. Clear town 2. Included 2. Included 2. Included 2. Included 4 3 18

transformation
strategy and
budget and 3. Included 3. Included 3. Included 3. Included
communication 4. Included 4. Included 4. Included 4. Included
plan.
3. Housing
Total: $0 Total: $0 Total: $0 Total: $0 Total: $0
strategy must be
clear.
4. Investor/
employee
confidence to
be establish.
1. $3,4m 3 3 13 3 3 13 4 3 18 3. Increase 3. None 3. None 3. None 3. None 3 3 13 3 3 13 4 2 14
2. Included police and 4. None 4. None 4. None 4. None
government
support.
Total: $3,4m 4. National park Total: $0 Total: $0 Total: $0 Total: $0
security to play
a role going
forward.

SOCIAL TRANSITION RISK ASSESSMENT, CRITERIA AND LIABILITY ESTIMATE (continued)
SOCIAL
LIABILITY
DURING
DECOMMIS-
SIONING
Reputation/
Social/
Community/
Consequence
Consequence
Consequence
Probability
Probability
Probability
Rating
Rating
Rating
1.4 Loss in critical There is a 2 3 8 1. Town transformation is looking at the sustainability 1. Included 1. Included 1. Included
skills. risk that the of the schooling and other services – linking with
schooling might government and combining with other mines, etc.
not be sustained Total:$0 Total:$0 Total:$0
in its current
form post mining,
resulting in
people moving
out of the area,
or incurring more
cost for schooling
and claim from
the company.
1.5 Loss in Employees 2 3 8 1. Town transformation process. 1. Included 1. Included 1. Included
income from that are also 2. Current SEP that communicates the current and 2. Included 2. Included 2. Included
businesses. business owners possible future state.
might claim
compensation Total: $0 Total: $0 Total: $0
from the
company for the
business that will
not be viable post
mining (short
LoA and unreality
expectations on
sustainability of
their business).
1.6 Inability to pay Risk that 4 4 21 1. If bought through the provident fund, the house 1. Included 1. Included 1. Included
mortgage. employees that would be paid at closure if needed. 2. Included 2. Included 2. Included
do buy there 2. Communication on the risk of buying a house is in place. 3. Included
houses in in 3. Included 3. Included
the local town 3. Insurance from banks that bond will be paid on
might not be retrenchment.
Total: $0 Total: $0 Total: $0
able to pay the
mortgage.
1.7 Loss in Risk that 4 4 21 1. Town transformation process. 1. Included 1. Included 1. Included
property value. employees that 2. Current SEP that communicates the current and 2. Included 2. Included 2. Included
do buy there possible future state.
houses in in the
local town might Total: $0 Total: $0 Total: $0
not be able to re-
sell the property
in future (loss in
property value).
1.8 Data and Risk of company 4 3 18 1. Non disclosure is included in employment conditions 1. Included 1. Included 1. Included
intellectual data and of employment. 2. $2m 2. $8m 2. $4m
capital loss/ information being 2. The safe keeping (legal requirement) and
theft. taken from the 3. Included 3. Included 3. Included
management of information (IM systems and servers).
company and
benefit other 3. Historic servers and software needs to be maintained
post mining (medical contributions). Total: $2m Total: $8m Total: $4m
entities.
1.9 Increase in Risk of increase 4 4 21 1. Access control will be in place, as it’s a national park. 1. Included 1. Included 1. Included
social ills. in crime and
cost of increase
insecurity, Total: $0 Total: $0 Total: $0
claimed by
employees.
1.10 Vandalism. The risk of 3 3 13 3 3 13 1. Existing security and local police will assist. 1. Included 1. $1m 1. Included
employee and
or other parties
vandalism Total: $0 Total: $1m Total: $0
company
property
(including
animals) post
opening of town
and with the
closing of the
mine.

SOCIAL LIABILITY
DURING
MONITORING
PHASE
(10 YEAR
CARE AND ADDITIONAL
MAINTENANCE ACTIONS
Social/ Social/
Consequence
Consequence
Consequence
Consequence
Consequence
Consequence
Probability
Probability
Probability
Probability
Probability
Probability
Current
Rating
Rating
Rating
Rating
Rating
Rating
Operating
1. Included 2 2 5 None required. 2 2 5
Total:$0

2. Included
Total: $0

2. Included
3. Included
Total: $0
1. Included 4 3 18 None. 4 3 18
2. Included
Total: $0
1. Included 4 2 14 4. Alternative 4. Included 4. Included 4. Included 4. Included 4 2 14

2. $2m additional
methods
3. Included to be Total: $0 Total: $0 Total: $0 Total: $0
Total: $2m investigated
(cloud, etc.).
1. Included 3 4 17 2. Risk to be 2. None 2. None 2. None 2. None 3 3 13

assessed
and security
improved.
Total: $0 Total: $0 Total: $0 Total: $0 Total: $0
1. Included 3 3 13 3 2 9 2. Capacity of 2. Included 2. Included 2. Included 2. Included 3 2 9 3 2 9

local police
and services/
Total:$0 infrastructure Total: $0 Total:$0 Total: $0 Total: $0
to be
investigated.

SOCIAL
LIABILITY
DURING
DECOMMIS-
SIONING
Reputation/
Social/
Community/
Consequence
Consequence
Consequence
Probability
Probability
Probability
Rating
Rating
Rating
1.11 Retaining There is a risk 4 4 21 1. A retention strategy/plan to be developed for the final 1. $0 1. $3.6 1. $0
employees with that employees 5 years to address this risk (strategy to include all critical
specific skills with specific skills and not only production critical skills). (Include
during closure skills required redeployment, retention bonuses, etc. in plan).
phase. during closure Total: $0 Total: $3.6 Total: $0
may leave prior to
closure, requiring
recruitment
of additional
employees
(adding costs).
1.12 Deterioration There is a risk 3 3 13 Review and generate competitive packages to stay 1. Included 1. Included 1. Included
of town of recruiting the competitive and flexible packages first in and first out
services. appropriate skills (FIFO, etc.).
during this phase, Total: $0 Total: $0 Total: $0
considering
deteriorating
services such
as schooling,
hospital, etc.
1.13 Main If the main 3 3 13 1. Confirmed with key contracting companies regarding 1. Included 1. Included 1. Included
contracting contracting their downscaling and retrenchment plans. Ongoing 2. Included
companies companies do engagement and monitoring with contractors regarding
treatment of not follow due downscaling of operations and closure. (Main contracts
employees at process when contain clause on retrenchment process). 2. Included 2. Included
mine closure. retrenching or 2. The SEP must includes the message related to
redeploying their contractor company responsibilities and contractor to
personnel when Total: $0 Total: $0 Total: $0
also comply with the labour act.
the mine closes
there could be
reputational
consequences
for the company.
1.14 Contractor Risk of additional 4 4 21 1. Continuous communication with contractors 1. Included 1. Included 1. Included
claims for cost due toe 2. Future communications on short notice, etc. 2. Included 2. Included 2. Included
early contract early terminations
termination. – short notice. 3. Possible re-negotiations for those contracts that 3. Included 3. Included 3. Included
extend beyond LoA.

1.15 Employee If HRA indicates 2 2 5 1. Conduct surveillance programmes and identify any 1. None 1. $0,5m 1. $1m
HRA. that many additional actions and costs. 2. None 2. $1,2m 2. $0,2m
employees may 2. Mandatory entry and exit medicals is in place.
require post- 3. Included 3. Included 3. Included
closure health 3. Historical and current statistics need to be collated, 4. None 4. None 4. None
management due analysed and tracked.
5. $0,8m 5. $4m 5. $4m
to occupational 4. VCT and Wellness Programmes (HIV/TB) to continue
and chronic and be tracked through medical aid system.
diseases, a post- Total: $0,8m Total: $5,7m Total: $5,2m
5. Disability payments will continue via disability
closure health
insurance.
management
plan may need
to be developed
(financial,
reputational,
social).

SOCIAL LIABILITY
DURING
MONITORING
PHASE
(10 YEAR
CARE AND ADDITIONAL
MAINTENANCE ACTIONS
Social/ Social/
Consequence
Consequence
Consequence
Consequence
Consequence
Consequence
Probability
Probability
Probability
Probability
Probability
Probability
Current
Rating
Rating
Rating
Rating
Rating
Rating
Operating
1. $0 3 3 13 None required. 3 3 13
Total: $0
Total: $0
2. Included
Total: $0

2. Included
3. Included
Total: $0
1. $0,4m 2 2 5 None required. 2 2 5
2. $0m
3. Included
4. None
5. $1,4m
Total: $1,8m

SOCIAL
LIABILITY
DURING
DECOMMIS-
SIONING
Reputation/
Social/
Community/
Consequence
Consequence
Consequence
Probability
Probability
Probability
Rating
Rating
Rating
1.16 Impact on Risk that labour 2 2 5 1. N
o additional mitigation anticipated (To be confirmed 1. None 1. None 1. None
public health sending areas with current study).
system in public health
labour sending system will not Total: $0 Total: $0 Total: $0
areas and be able to cope
local areas if with influx of
ex-employees ex-employees
all have to and dependants
access public returning
health facilities (requiring
post-closure. funding/support
from company).
OVERALL Totals (Excluding additional actions). $7,6m $57,8m $48,7m
2. Interested and Affected parties

2.1 Socio- An increase 4 4 21 1. Maintain operational broad-based stakeholder 1. $1m 1. $4m 1. $4m
psychological in the nature engagement meetings:
impact: and extent to 1.1 Determine and develop key messaging for mine
• Increased which people closure issues.
community experience a 2. Included 2. Included 2. Included
sense of loss 1.2 At stakeholder engagement sessions include these
negativity. key messages on closure issues.
of community
• Increase in identity and 2. Inform stakeholders on current and future mine
community cohesion, planning through appropriate communication platforms.
isolation. which could
2.1 Determine and develop key closure messaging (go 3. $0,5m 3. $3m 3. $0,1m
• Possible lead to a need
from broad/general issues to more specific issues over
collapse for increased 4. None 4. $1m 4. None
time).
of social counselling and
organisa- psychological 2.2 At stakeholder engagement sessions include these
tions initiated support for ex- key messages on closure issues. Total: $1,5m Total: $8m Total: $4,1m
by the mine. employees. This 2.3 Inform stakeholders on current and future mine
could result in a planning through appropriate communication platforms.
• Decline
situation whereby
in general 3. Counselling for employees and psycho-social support.
local business,
quality of life.
churches, etc. 4. Financial literacy, business acumen support to
might expect employees.
the company to
support them
after mine
closure.
2.2 Economic Dependency 2 4 12 3 3 13 Note: If other mines should close/downscale at the
impact: of businesses same time the risk may be higher. 1. $1,7m 1. $2,8m 1. $2,5m
• Down- on the mine 1. Identify and invest only in those social economic
scaling of resulting in a high development (SED), Corporate Social Investment (CSI),
mine-related risk of closing etc, projects that will not require ongoing financial input
and mine- down these by the mine:
dependent businesses and
therefore having 1.1 Review existing identified projects and update 2. None 2. None 2. None
businesses. process flow to identify projects to ensure closure
a negative impact
on the economic components are addressed.
sector of the 1.2 Review new SED strategy to ensure alignment.
local area (these Also identify gaps and actions.
also include
2. Identify service providers who are principally reliant
small and micro
on the mine for their business survival and determine
scale businesses
if the mine could support them in the interim. Identify
dependent on the Total: $1,7m Total: $2,8m Total: $2,5m
required actions and costs.
mine).
2.1 Determine who the key providers of services are
(through Supply Chain) and develop a register.
2.2 Consultants to investigate small scale service
providers (include in register).
2.3 Track service providers(large and small scale) with
the intention to reduce dependency over time.
2.4 Assistance to be given to the most vulnerable
businesses to diversify their businesses.

SOCIAL LIABILITY
DURING
MONITORING
PHASE
(10 YEAR
CARE AND ADDITIONAL
MAINTENANCE ACTIONS
Social/ Social/
Consequence
Consequence
Consequence
Consequence
Consequence
Consequence
Probability
Probability
Probability
Probability
Probability
Probability
Current
Rating
Rating
Rating
Rating
Rating
Rating
Operating
1. None 2 2 5 None required 2 2 5
Total: $0
$9,4m OVERALL $0 $0 $0 $0
Totals
(additional
actions only).
OVERALL $7,6m $57,8m $48,7m $9,4m
Totals
(including
additional
actions).
1. $2m 4 3 18 None. 4 3 18
2. Included
3. $0m
4. None
Total: $2m
2 3 8 3 3 13 None required. 2 3 8 3 3 13
1. None
2. None
Total: N$0

SOCIAL
LIABILITY
DURING
DECOMMIS-
SIONING
Reputation/
Social/
Community/
Consequence
Consequence
Consequence
Probability
Probability
Probability
Rating
Rating
Rating
2.3 Lack of There is a risk 5 4 24 4 4 21 1. LED/SED strategy to be implemented. 1. Included 1. Included 1. Included
alternative that there will 2. Investor conference to beheld to improve confidence 2. Included 2. Included 2. Included
socio- be a loss of for investment.
economic revenue (rates
opportunities/ and taxes) to the 2.1 Possible holiday housing and/or retirement
projects to municipality (risk opportunities to be investigated.
offset the to municipality) 2.2 Higher learning entities.
economic due to the lack 3. Included 3. Included 3. Included
2.3 Council providing serviced plots for development
impact of mine of alternative 4. $5,7m 4. $23,5m 4. $13m
and selling.
closure. socio-economic
projects that 2.4 Investigate options for government housing 5. $1,5m 5. $4,2m 5. Included
will create schemes.
employment. 3. Memorandum of Agreement (MoA) with town council. 6. Included 6. Included 6. Included
There is a risk 4. Overarching town transformation strategy and 7. Included 7. Included 7. Included
that the future timeline is critical beyond current LoA .
home owners 8. Included 8. Included 8. Included
will not be able 5. SPV projects (agriculture, tourism and renewable
to afford the energy) would be critical. Timeous job creations will be
a challenge (takes 15 plus years to create sustainable Total: $7,2m Total: Total: $13m
required rates
projects). Not currently in place. $27,7m
and taxes to
sustain the 6. Accommodation Strategy is critical.
municipality 7. Community Based Investment initiatives.
resulting in
the company 8. SEP (Focus is on creating awareness around the
having to pay the importance of paying rates and taxes).
shortfall on rates
and taxes to the
municipality.
There is also a
risk of failure to
attract credible
investors to
sustain/support
town.

SOCIAL LIABILITY
DURING
MONITORING
PHASE
(10 YEAR
CARE AND ADDITIONAL
MAINTENANCE ACTIONS
Social/ Social/
Consequence
Consequence
Consequence
Consequence
Consequence
Consequence
Probability
Probability
Probability
Probability
Probability
Probability
Current
Rating
Rating
Rating
Rating
Rating
Rating
Operating
1. Included 5 4 24 4 4 21 9. Investor 9. None 9. None 9. None 9. None 3 3 13 4 2 14
2. Included conference
to beheld
to improve 10. None 10. None 10. $20m 10. $25m
confidence
for investment
(post production
3. Included period). 11. None 11. None 11. $45m 11. None
4. Included 10. Re-focus
5. Included and alignment 12. Included 12. 12. Included 12. Included
of Group Included
commitment to
6. Included stay committed 13. Included 13. Included 13. Included
7. Included to Town 13.
Transformation Included
8. Included (Financial) until 14. Included 14. Included 14. Included
sustainability
(15 years post 14.
production). Included
11. Timeous
Total: $0 execution of Total: $0 Total: $0 Total: $65m Total: $25m
initiatives under
SED/LED and
SPV funding.
12. The period
that these
initiatives will
take for the
SPV initiatives
to materialise
will take 5-15
years.
13. Original SPV
objectives were
planned for Job
creation within a
long life of asset
but now the
focused moved
to closure
mitigation.
14. Framework
Agreement
partnership
between
Government and
the company
needs long-term
commitment.

SOCIAL
LIABILITY
DURING
DECOMMIS-
SIONING
Reputation/
Social/
Community/
Consequence
Consequence
Consequence
Probability
Probability
Probability
Rating
Rating
Rating
2.4 Government’s The mine 4 3 18 1. Government/Municipal capacity building programme 1. $0,1m 1. $0,4m 1. None
lack of capacity contributes initiative to be identified and costed. 2. Included 2. Included 2. Included
to take over to social 2. Possible Trust option for protection and management
community development 3. Included 3. Included 3. Included
of infrastructure (Government will lease from a Trust).
services in around the 4. Included 4. Included 4. Included
associated communities 3. Agreement with government to take over all services.
with health and and towns. 4. Primary-Private School to be funded by the company,
education. The risk is that the High School will be a Model C School (Part 5. Included 5. Included 5. Included
when the mine government and part company funded).
closes these
5. Review and establish the additional capacity 6. Included 6. Included 6. Included
contributions
requirements associate with the hospital and security
will dwindle and
(police) services and infrastructure (additional beds
fall-away over 7. Included 7. Included 7. Included
required and police cells, etc.).
time leaving the
municipality/ 6. Investigate options for a 3rd party to take over for 8. Included 8. Included 8. Included
region to pick- funding for the Private primary school and the Model C
up on these High School post closure.
Total: $0,1m Total: $0,4m Total: $0
services. 7. Investigate alternative housing options.
There is a also a 8. Company to match government’s investment in the
risk that current local area.
funding and
support related
to education
might not be
sustained post
mining (schools
might have to
close), resulting
in community
dissatisfaction
and reputational
risks.
2.5 Consultation If consultation 4 5 23 1. Stakeholder Engagement Plan (detailed, focused, 1. Included 1. Included 1. Included
with affected does not follow timeous) must be updated/adapted to include closure
parties. correct legal and issues and criteria. It is critical that there is ongoing
other procedures stakeholder engagement. It is important that there
uncertainties in is sufficient capacity and skills to implement the
communities and stakeholder engagement plan – post closure. (Note:
other affected Only one SEP required to ensure consistency of
parties in regards message.)
to closure 1.1. Develop a separate SEP for closure and then
issues may lead integrate into broader SEP.
to financial,
legal and/or
reputational risks.
2.6 Community There is a risk 4 4 21 4 4 21 1. Community health risk assessment prior to closure to 1. None 1. None 1. $0,2m
health/safety that there may establish baseline. 2. $0,2m 2. $1m 2. $2m
impact post be health/ 2. Post-closure data management and integrity will
closure. safety impacts be maintained (Occupational hygienist will remain
on surrounding employed till post decommissioning). 3. Included 3. Included 3. Included
communities
3. Management of land tenure post-closure (prior to 4. $1,2m 4. $2,8m 4. $3m
and tourists
post closure closure certificate) will be maintained.
(asbestos, old 4. Emergency response planning during closure and
buildings, voids, post-closure phase to be maintained.
long term health 5.Included 5.Included 5.Included
4.1 MoU in place with council for current services.
impacts etc.).
4.2 Cost reflected only includes current operational
6. Included 6. Included 6. Included
expenditure and not replacement of equipment.
5. Closure specific requirements in the bio-physical
closure plan (Will address the related social risks
(shaping of dumps, management of voids and ponds Total: $1,4m Total: $3,8m Total: $5,2m
etc.).
6. Review current Rehabilitation Plan of 2019.
7. All contractors handling asbestos related
infrastructure go through asbestos handling training
prior executing the job.

SOCIAL LIABILITY
DURING
MONITORING
PHASE
(10 YEAR
CARE AND ADDITIONAL
MAINTENANCE ACTIONS
Social/ Social/
Consequence
Consequence
Consequence
Consequence
Consequence
Consequence
Probability
Probability
Probability
Probability
Probability
Probability
Current
Rating
Rating
Rating
Rating
Rating
Rating
Operating
2. Included
3. Included
4. Included
5. Included
6. Included
7. Included
8. Included
Total: $0
1. Included 3 3 13 None required 3 3 13
Total: $0
1. None 4 2 14 4 2 14 None 4 3 18 4 3 18
2. None
3. Included
4. $1m
5.Included
6. Included
7. Included
Total: $1m

SOCIAL
LIABILITY
DURING
DECOMMIS-
SIONING
Reputation/
Social/
Community/
Consequence
Consequence
Consequence
Probability
Probability
Probability
Rating
Rating
Rating
2.7 Media The risk of 5 3 22 4 4 21 1. Unpack current concerns and expectations and either 1. Included 1. Included 1. Included
(includes social increased address as part of the SEP process and or as part of
media). negative the current operational risk management plan and I&AP
publicity based issues log. 2. Included 2. Included 2. Included
on non-factual 2. Targeted Media intervention. 3. Included 3. Included 3. Included
sensualisation.
3. Pro active business update and factual data supply to
Employees, government and other key stakeholders. Total: $0 Total: $0 Total: $0
2.8 Increase in There is a risk 4 4 21 1. Appropriate programmes which address social ills, 1. $0,5m 1. $2m 1. $2m
social ills in that social ills drug and alcohol abuse, violence, teenage pregnancies 2. None 2. None 2. None
town. will increase etc.
significantly, 3. Included 3. Included 3. Included
2. Improve home-owner security.
also considering 4. None 4. None 4. None
the lack of 3. Security forces require collaboration.
employment post 4. Review and improve existing capacity.
mining. This will 6. Included 6. Included 6. Included
5. Clarification of roles and responsibilities for the
be exacerbated
handling of social ills incidents.
as a result of
mine closure 6. Collaboration and engage with government for public Total: $0,5m Total: $2m Total: $2m
and increase in health services.
unemployment.
2.9 Closure vision/ There is a risk 3 3 13 1. To be dealt with in the SEP (especially in terms of 1. Included 1. Included 1. Included
land-use plan that the current closure vision and post closure land-use). 2. Included 2. Included 2. Included
may not be vision and land- 2. Studies are done to prove land capability and viability
aligned with use plan is not of land for various uses post-closure.
expectations acceptable to
of the affected parties Note: What can and cannot be achieved at closure
should drive engagement with I&APs. Total: $0 Total: $0 Total: $0
communities. and any change
to the vision and
land-use plan will
result in a change
in the closure
liability estimate.
Stakeholder
conflicts in terms
of the desired
post-mining land-
use/s may result
in delayed site
relinquishment
and/or attaining
mine closure.

SOCIAL LIABILITY
DURING
MONITORING
PHASE
(10 YEAR
CARE AND ADDITIONAL
MAINTENANCE ACTIONS
Social/ Social/
Consequence
Consequence
Consequence
Consequence
Consequence
Consequence
Probability
Probability
Probability
Probability
Probability
Probability
Current
Rating
Rating
Rating
Rating
Rating
Rating
Operating
1. Included 4 3 18 4 3 18 None required 4 3 18 4 3 18
2. Included
3. Included
Total: $0
1. None 4 3 18 None 4 3 18
2. None
3. Included
4. None
5. Included
6. Included
Total: $0
1. Included 3 3 13 None required 3 3 13

2. Included
Total: $0

SOCIAL
LIABILITY
DURING
DECOMMIS-
SIONING
Reputation/
Social/
Community/
Consequence
Consequence
Consequence
Probability
Probability
Probability
Rating
Rating
Rating
2.10 Unsustain- Risk of failure to 5 3 22 5 4 24 1. Identify and invest only in those social economic 1. Included 1. Included 1. Included
ability of the implement long- development (SED, CSI, etc.) projects that will not
local town term objectives/ require ongoing financial input by the mine:
(Town Transfor- projects in 1.1 Review existing identified projects and update
mation, Social support of town process flow to identify projects to ensure closure 2. Included 2. Included 2. Included
Way). sustainability. components are addressed. 3. Included 3. Included 3. Included
Risk of failure 2. Review new SED strategy to ensure alignment. Also 4. Included 4. Included 4. Included
to implement identify gaps and actions.
accommodation/ 5. Included 5. Included 5. Included
housing strategy 3. LED strategy to be executed.
that will impact 4. Investor conference to be held.
on town 7. Included 7. Included 7. Included
5. MoA with town council.
sustainability. 8. Included 8. Included 8. Included
6. Town conditioning report.
Loss of support 9. Included 9. Included 9. Included
for town 7. Overarching town transformation strategy and
transformation timeline.
from key 11. Included 11. Included 11. Included
8. Decision making framework with monetary and
stakeholders. authority levels. 12. Included 12. Included 12. Included
Risk that banks 9. Town infrastructure master plan. 13. Included 13. Included 13. Included
will not provide
10. Asset register and conditioning assessment report. 14. Included 14. Included 14. Included
finance for
bonds and 11. SPV (Agriculture/Tourism/Alternative Energy). 15. Included 15. Included 15. Included
other business 12. Accommodation Strategy.
opportunities, due
to the current/ 13. Higher learning entities.
perceived risk. 14. SEP to include wider collaboration with other 16. Included 16. Included 16. Included
businesses and wider region. 17. Included 17. Included 17. Included
15. Housing strategy which includes selling of houses 18. Included 18. Included 18. Included
to both employees, government employees and private
enterprises.
16. Council providing serviced plots for development 19. Included 19. Included 19. Included
and selling.
17. Investigate options for government housing Total: N$0 Total: N$0 Total: N$0
schemes.
18. Review and revise housing and employment
conditions strategy.
19. Steercom (Regional Councilor, Mayor, the Attorney
General as the Patriot).
(See recommended and additional actions as listed for
Action 2.3).
2.11 Expectations If expectations 5 4 24

and concerns and concerns 1. Unpack current concerns and expectations and either 1. Included 1. Included 1. Included
raised in NGO/ raised by address as part of the SEP process and or as part of
CBO reports. NGOs are not the current operational risk management plan and I&AP
addressed issues log.
prior to and
during closure
there may be
further negative
publicity in this
regard striking
community
unhappiness
and potential for
increasing costs
during closure.
2.12 Significant There is a risk 5 3 22 1. Bio-physical rehabilitation criteria will be 1. None 1. None 1. None
health of significant implemented, as per the rehabilitation plan. (Note: The
and safety health and safety cost associated with bio-physical closure is already
implications implications due included in the overall mine closure plan liability 2. Included 2. Included 2. Included
due to illegal to illegal mining estimate).
mining post post production/ 2. Security controls will be in place. Total: $0 Total: $0 Total: $0
production/ closure.
closure. (Fatalities).

SOCIAL LIABILITY
DURING
MONITORING
PHASE
(10 YEAR
CARE AND ADDITIONAL
MAINTENANCE ACTIONS
Social/ Social/
Consequence
Consequence
Consequence
Consequence
Consequence
Consequence
Probability
Probability
Probability
Probability
Probability
Probability
Current
Rating
Rating
Rating
Rating
Rating
Rating
Operating
1. Included 5 3 22 5 3 22 (See 1. Included 1. Included 1. Included 1. Included 3 3 13 4 2 14
recommended
and additional
actions as listed
2. Included for Action 2.3). 2. Included 2. Included 2. Included 2. Included
3. Included 3. Included 3. Included 3. Included 3. Included
10. Included 10. Included 10. 10. Included 10. Included
11. Included 11. Included Included 11. Included 11. Included
Included
13. Included 13. Included 13. Included 13. Included
12.
14. Included 14. Included Included 14. Included 14. Included
Included
14.
Included
15.
Included
16.
Included
Included
18.
Included
19.
Included
Total: N$0 Total: N$0 Total: N$0 Total: N$0 Total: N$0
5 1 15 None 5 1 15
1. Included
Total: $0
1. None 5 2 19 None 5 2 19
2. Included
Total: $0

SOCIAL
LIABILITY
DURING
DECOMMIS-
SIONING
Reputation/
Social/
Community/
Consequence
Consequence
Consequence
Probability
Probability
Probability
Rating
Rating
Rating
2.13 Human rights Risk of human 4 2 14 1. Conduct a human rights and heritage impact due 1. None 1. None 1. $1m
and heritage rights and diligence for closure – can be included in human rights
impacts. heritage impacts and heritage risk assessment.
at closure. 2. Included 2. Included 2. Included
2. Operate according to company policy and standards
and within the legal frameworks. 3. Included 3. Included 3. Included
3. Human Rights Due Diligence Training for employees.
Total: $0 Total: $0 Total: $1m
2.14 Informal Influx of people 3 4 17 1. Town Plan has formal areas dedicated to Informal 1. None 1. None 1. None
settlements. into the town settlements.
putting pressure
on infrastructure Total: $0 Total: $0 Total: $0
and increase of
social ills.
2.15 Less funding Such NGOs may 1 4 7 4 3 18 1. Unpack current concerns and expectations and either 1. Included 1. Included 1. Included
for NGOs demand on-going address as part of the SEP process and or as part of
which the mine support. the current operational risk management plan and I&AP
support as the issues log. 2. Included 2. Included 2. Included
Some CBOs may
mine funds will be unhappy with 2. Investigate possibility of third party to take over
no longer be mine closure financial responsibilities. Total: N$0 Total: N$0 Total: N$0
available. and seek media
CBO attention to place
unhappiness company in bad
with mine light.
closure.
OVERALL Totals (Excluding additional actions). $12,4m $44,7m $27,8m
3. Authorities
3.1 Consultation There is a risk 3 3 13 3 3 13 Same as above – SEP (Key stakeholders/sectors). Included Included Included
with authorities. that social
transition needs
and requirements
of relevant
authorities
have not been
agreed through
collaborative
consultation,
resulting in
inappropriate
social transition
criteria. Closure
success criteria
not agreed with
government.

SOCIAL LIABILITY
DURING
MONITORING
PHASE
(10 YEAR
CARE AND ADDITIONAL
MAINTENANCE ACTIONS
Social/ Social/
Consequence
Consequence
Consequence
Consequence
Consequence
Consequence
Probability
Probability
Probability
Probability
Probability
Probability
Current
Rating
Rating
Rating
Rating
Rating
Rating
Operating
2. Included
3. Included
Total: $0
1. None 3 4 17 None 3 4 17
Total: $0
1. Included 1 2 2 3 3 13 None required 1 2 2 3 3 13
2. Included
Total: $0
$3m OVERALL $0 $0 $65m $25m

Totals
(Additional
actions only).
OVERALL Totals $12,4m $44,7m $92,8m $28m
(including
additional
actions).
Included 3 3 13 3 2 9 None required 3 3 13 3 2 9
Total: $0

SOCIAL
LIABILITY
DURING
DECOMMIS-
SIONING
Reputation/
Social/
Community/
Consequence
Consequence
Consequence
Probability
Probability
Probability
Rating
Rating
Rating
3.2 Legal 1. If legal 3 3 13 3 3 13 5 2 19 1. SEP 1. Included 1. Included 1. Included
obligations with obligations with 2. Identify and agree on closure success criteria as well 2. $1m 2. $3m 2. $1m
regulators. regulators are as legal process to be followed.
not implemented 3. None 3. $1m 3. None
it may impact 3. Legal view of the potential requirements with regard
the closure to IUCN category 6.
period and final
relinquishment
of the site (cost Total: $1m Total: $4m Total: $1m
implications).
2. Uncertainty
related to
the Legal
requirements
associated to
relinquish assets/
land.
3. The risk that
newly defined
end-land-use
requirements
based on current
International
Union for
Conservation of
Nature (IUCN)
for category 6
could have new
requirements
which could
financially and
reputationally
impact the
company.
3.3 Permits 1. There is a 3 4 17 1. Legal review of current agreements associated with 1.$0,1m 1.$0,2m 1.$0,3m
requirements risk that future water supply/licenses. 2. Included 2. Included 2. Included
for final land- requirements for 2. Review of availability and future allocation of water
use. water abstraction resources.
permits might 3. None 3. None 3. None
not be approved 3. Define way forward, plan and schedule.
or timeously
issued for imple- Total: $0,1m Total: $0,2m Total: $0,3m
mentation of
closure related
Socio-Economic
opportunities
(e.g. Mining
VS upstream
Agriculture
Strategies).
2. License
agreements
associated with
air travel.

SOCIAL LIABILITY
DURING
MONITORING
PHASE
(10 YEAR
CARE AND ADDITIONAL
MAINTENANCE ACTIONS
Social/ Social/
Consequence
Consequence
Consequence
Consequence
Consequence
Consequence
Probability
Probability
Probability
Probability
Probability
Probability
Current
Rating
Rating
Rating
Rating
Rating
Rating
Operating
1. Included 3 3 13 3 2 9 5 1 15 None required 3 3 13 3 2 9 5 1 15
2. None
3. None
Total: $0
1.$0,1m 3 3 13 None required 3 3 13

2. Included
3. None
Total: $0,1m

SOCIAL
LIABILITY
DURING
DECOMMIS-
SIONING
Reputation/
Social/
Community/
Consequence
Consequence
Consequence
Probability
Probability
Probability
Rating
Rating
Rating
Overall totals (excluding additional actions). $1,1 $4,2m $1,3m
Owner’s Team (salary and housing). $0 $0 $25m
Grand total (including additional actions). $21,1m $106,7m $167,8m

Total including
additional
actions.
Grand total (excluding additional actions). $21,1m $106,7m $102,8M

($65m excluded
for additional
mitigation).
Total
EXCLUDING
ADDITIONAL
ACTIONS.
Consequences
1 2 3 4 5
5 11 16 20 23 25
Probability 4 7 12 17 21 24
3 4 8 13 18 22
2 2 5 9 14 19
1 1 3 6 10 15
Refer to Example 3 Closure Risk Assessment for the details on the AA 5x5 risk matrix.

SOCIAL LIABILITY
DURING
MONITORING
PHASE
(10 YEAR
CARE AND ADDITIONAL
MAINTENANCE ACTIONS
Social/ Social/
Consequence
Consequence
Consequence
Consequence
Consequence
Consequence
Probability
Probability
Probability
Probability
Probability
Probability
Current
Rating
Rating
Rating
Rating
Rating
Rating
Operating
$0,1m OVERALL $0 $0 $0 $0
Totals
(additional
actions only).
$8m OVERALL $1,1 $4,2m $1,3m $0,1m
Totals (including
additional
actions).
$45,5m
$320M
(Post production
cost - $213,3m).
$20,5m
($25m excluded
for additional
mitigation).
$230M
(Post production
cost - $123,3m).
($90m excluded
for additional
mitigation).

SOCIAL TRANSITION CASH FLOW
OPERATING
COSTS
($MILLIONS)
(WHILE
STILL IN LOA COSTS DECOMMISSIONING PHASE
TABLE MAIN SUB PRODUCTION ($MILLIONS) ($MILLIONS)
NUMBER CATEGORY CATEGORY PHASE) (LAST 5Y OF PRODUCTION) (YEARS 0 TO 5)
Current Year -5 Year- 4 Year -3 Year -2 Year -1 Total Year 1 Year 2 Year 3 Year 4 Year 5 Total
(2017) (2019) (2020) (2021) (2022) (2023) for (2024) (2025) (2026) (2027) (2028) for
phase phase
1.1 Employees Managing $0,7 $1,5 $1,5 $2,7 $3,4 $6,7 $15,8 $3,4 $2,5 $0,5 $0,5 $2,3 $9,2
and employee
dependants. dependency.
1.2 Managing $2,0 $1,4 $1,4 $1,4 $1,4 $1,4 $7,0 $0,9 $0,9 $0,9 $0,9 $0,9 $4,5
employee and
data retention.
1.3 Managing $0,8 $4,0 $4,0 $3,2 $5,1 $6,5 $22,8 $0,6 $0,6 $0,6 $0,6 $0,8 $3,2
employees
health and
safety.
1.4 Managing $0,0 $1,2 $1,2 $1,2 $1,2 $1,4 $6,2 $1,4 $1,2 $0,7 $0,5 $0,5 $4,3
issues related
to contractors.
1.5 Managing $4,1 $1,2 $1,2 $1,2 $1,2 $1,2 $6,0 $6,6 $6,6 $6,6 $4,5 $3,2 $27,5
impacts on
public health
services and
public safety.
Totals $7,6 $9,3 $9,3 $9,7 $12,3 $17,2 $57,8 $12,9 $11,8 $9,3 $7,0 $7,7 $48,7
(including
additional
mitigation).
2.1 I&APs. Managing $1,5 $1,4 $1,4 $1,4 $1,4 $1,4 $7,0 $1,5 $1,5 $1,4 $1,4 $1,3 $7,1
community
expectations
and impacts.
2.2 Managing $2,7 $2,3 $2,3 $2,3 $2,3 $2,0 $11,2 $2,1 $2,1 $1,1 $0,4 $0,4 $6,1
impact on
businesses.
2.3 Managing $1,0 $1,0 $1,0 $1,0 $1,0 $1,0 $5,0 $2,0 $2,0 $1,5 $0,4 $0,0 $5,9
impact on
community
health and
safety.
2.4 Managing $7,2 $6,1 $5,1 $4,1 $4,1 $2,1 $21,5 $2,0 $1,8 $1,7 $1,7 $1,5 $8,7
impacts
on town’s
sustainability.
Totals $12,4 $10,8 $9,8 $8,8 $8,8 $6,5 $44,7 $7,6 $7,4 $5,7 $3,9 $3,2 $27,8
(including
additional
mitigation).
3.1 Authorities. Managing $0,1 $0,1 $0,1 $0,0 $0,0 $0,2 $0,4 $0,1 $0,1 $0,0 $0,1 $0,1 $0,4
consultation
with
authorities.
3.2 Managing $1,0 $0,9 $0,9 $0,7 $0,7 $0,6 $3,8 $0,2 $0,2 $0,2 $0,2 $0,1 $0,9
legal
obligations.
Totals $1,1 $1,0 $1,0 $0,7 $0,7 $0,8 $4,2 $0,3 $0,3 $0,2 $0,3 $0,2 $1,3
(including
additional
mitigation).
4.1 Owner’s 4) Owner’s $0,0 $0,0 $0,0 $0,0 $0,0 $0,0 $0,0 $5,5 $5,5 $5,0 $4,5 $4,5 $25,0
team. team to
execute
project and
sustain
investor
conference
in the town
(salaries and
housing).
Phase totals $21,1 $21,1 $20,1 $19,2 $21,8 $24,5 $106,7 $26,3 $25,0 $20,2 $15,7 $15,6 $102,8
(Including
additional
mitigation).
Phase totals $21,1 $21,1 $20,1 $19,2 $21,8 $24,5 $106,7 $39,3 $38,0 $33,2 $28,7 $28,6 $167,8
(excluding
additional
mitigation).

LOA AND
MONITORING AND MAINTENANCE PHASE DECOMMISSIONING DECOMMISSIONING
($MILLIONS) AND MONITORING AND MONITORING
(YEARS 6 TO 15) AND MAINTENANCE AND MAINTENANCE
Year 6 Year 7 Year 8 Year 9 Year Year Year12 Year Year Year Total PHASES PHASES ONLY
(2029) (2030) (2031) (2032) 10 11 (2035) 13 14 15 for ($MILLIONS) ($MILLIONS)
(2033) (2034) (2036) (2037) (2038) phase (YEARS -5 TO 15) (YEARS 1 TO 15)
$0,0 $0,0 $0,0 $0,0 $0,0 $0,0 $0,0 $0,0 $0,0 $0,0 $0,0
$0,2 $0,2 $0,2 $0,2 $0,2 $0,2 $0,2 $0,2 $0,2 $0,2 $2,0
$0,5 $0,5 $0,4 $0,4 $0,4 $0,4 $0,4 $0,4 $0,4 $0,4 $4,2
$0,0 $0,0 $0,0 $0,0 $0,0 $0,0 $0,0 $0,0 $0,0 $0,0 $0,0
$0,4 $0,4 $0,3 $0,3 $0,3 $0,3 $0,3 $0,3 $0,3 $0,3 $3,2
$1,1 $1,1 $0,9 $0,9 $0,9 $0,9 $0,9 $0,9 $0,9 $0,9 $9,4 $115,9 $58,1
$0,1 $0,1 $0,1 $0,1 $0,1 $0,1 $0,1 $0,1 $0,1 $0,1 $1,0
$0,0 $0,0 $0,0 $0,0 $0,0 $0,0 $0,0 $0,0 $0,0 $0,0 $0,0
$0,0 $0,0 $0,0 $0,0 $0,0 $0,0 $0,0 $0,0 $0,0 $0,0 $0,0
$0,2 $0,2 $0,2 $0,2 $0,2 $0,2 $0,2 $0,2 $0,2 $0,2 $2,0
$0,3 $0,3 $0,3 $0,3 $0,3 $0,3 $0,3 $0,3 $0,3 $0,3 $3,0 $75,5 $30,8
$0,0 $0,0 $0,0 $0,0 $0,0 $0,0 $0,0 $0,0 $0,0 $0,0 $0,1
$0,0 $0,0 $0,0 $0,0 $0,0 $0,0 $0,0 $0,0 $0,0 $0,0 $0,0
$0,0 $0,0 $0,0 $0,0 $0,0 $0,0 $0,0 $0,0 $0,0 $0,0 $0,1 $5,6 $1,4
$2,0 $1,4 $1,0 $0,8 $0,5 $0,5 $0,5 $0,5 $0,4 $0,4 $8,0 $33,0 $33,0
$3,4 $2,8 $2,2 $2,0 $1,7 $1,7 $1,7 $1,7 $1,6 $1,6 $20,5 $230,0 $123,3
$5,9 $5,3 $4,7 $4,5 $4,2 $4,2 $4,2 $4,2 $4,1 $4,1 $45,5 $320,0 $213,3

EXAMPLE 10: HEALTH CONSIDERATIONS IN MINE

CLOSURE
Saldhana Iron Ore stockyard, South Africa.
INTRODUCTION 1. OCCUPATIONAL HEALTH RISK

MANAGEMENT
At AA we put our people’s health and wellbeing at the
heart of our business. Our ambition is to positively influence 1.1 Introduction
the optimal health balance between the person and their
environment. Zero harm at the work floor and healthy All operational requirements and expected deliverables
lifestyle enhancement are the focus of AA’s health function. with regards to health and wellness apply until such
time the site is formally closed. Sites undergoing closure
Health is also at the heart of the community concerns are required to develop, implement and maintain an
about mining. Mining operations which discharge pollutants occupational health programme. If properly implemented
into the surrounding environment over the life of asset have and complied with, this would protect the health of
the potential to impact on human health if not mitigated. workers by assessing, monitoring and reducing their
Exposure to the various mining products and raw materials exposure to health risks. The AA Group SSD Occupational
can have negative impacts on human health. Hygiene Standard (AA SSD.S.004) will be used as the
framework for the development and implementation of
Many of these communities become directly or indirectly such a programme. This programme will have a number of
dependent on the mining industry for their livelihoods processes which shall cover all components of the closure
throughout the life of asset. Managing the impact of mine plan and process.
closure on these communities must become an integral
part of mine closure planning, with a special focus on 1.2 Occupational Hygiene
mitigating negative impacts, including health, and extending
sustainability beyond mine closure. A closing site is required to establish and maintain
occupational hygiene processes (including a system
Sections 1 to 7 provide guidance on the practical of occupational hygiene measurements), in order to
aspects of managing the health impacts on workers understand occupational exposure to health risks.
involved in mine closure tasks and activities and the
surrounding communities. The purpose of the guidance 1.3 Medical Surveillance
is to:
• Prevent sickness resulting from closure related work. A closing site is required to establish and maintain a system
• Maintain physical and psychological health and wellness of medical surveillance. A closing site must ensure access
to maximize productivity and minimise medical costs to to the full-time or part-time services of an occupational
both the company and employees. hygienist and an occupational medical practitioner to assist
• Comply with occupational health legislation, Group in the establishment and maintenance of the occupational
Health, Wellness and Sustainability policies and Duty of health processes.
Care.
• Limit any negative impacts on the health and wellbeing 1.4 Occupational Health Record Keeping
of surrounding communities.
• Partnering with government or non-governmental Record keeping in occupational health falls into three
organisations to drive community health initiatives main areas: occupational hygiene, medical surveillance
contained in sustainable mining plans. and human resources. The purpose of record keeping
is to provide a record of employees’ work, exposure and
medical surveillance history during their time with the
company. This information is used to improve the risk

management process, to assist with compensation where The HMP should be based on the impacts identified, their
necessary and may be used as evidence in civil claims. The public health significance, and the priority attributed by the
information system should be designed in such a way as to affected communities. The HMP should not only address
provide a link between occupational hygiene data, medical health outcomes, but also health determinants (e.g. income
surveillance data and the record of service kept by the and social status, social support networks, education,
personnel department. employment and working conditions, social environments,
physical environments, personal health practices and
Records should be kept for an appropriate length of time. For coping skills, healthy child development, biology and genetic
occupational health information, this is often determined by endowment, health services, gender and culture), health
legislation and may be as long as 40 years. For the purposes equity/inequality and the cumulative impacts of the operation.
of standardization, AA’s policy is to keep occupational health
information for 40 years after exposure ceases or according Refer to ICMM’s Good Practice Guidance on Heath Impact
to legislative requirements, whichever is the longer. Assessment 2010, available at www.icmm.com/library/
hia. This practice guidance can be used in conjunction with
Since the employees work history forms part of the ICMM’s Good Practice Guidance on Occupational Health
exposure profile, provision should be made to keep that Risk Assessment - first issued in 2009 and updated in 2016
portion of the personnel file, which contains details of job available at http://www.icmm.com/gpg-occupational-health.
history and movement within the company for the same
length of time. The latter document is intended for mining and metals
managers and advisors who are responsible for ensuring
The worker’s medical record should remain confidential and, the occupational health and well-being of employees and
where this is kept off-site, the responsible occupational third party contractors. Although the guidance focuses on
medical practitioner should be satisfied that this is in the occupational health risks to employees and contractors
accordance with good medical practice and ethics. It is in a mining and metals operation, it is important to note
essential that the links between exposure data, the work that these risks can also affect the wider community living
history and the medical record be maintained for the full around that operation.
length of time.
3. HEALTH RISK ASSESSMENTS
2. HEALTH IMPACT ASSESSMENTS
An HRA is the structured and systematic identification
An HIA is a systematic approach to predicting and and analysis of workplace hazards to assess their potential
managing the potential positive and negative health effects risks to health and determine appropriate control measures
of mining operations and projects on local communities to protect the health and well-being of workers. The HRA
and wider society. An HIA should be undertaken as early process is a partnership between occupational health
as possible in the project design (iteratively and in parallel advisors, occupational hygiene advisors, managers and
with project planning), with HIA outcomes timed to inform operational staff who use their knowledge, experience and
key decisions. It should then be updated as required, during skills to support the HRA process. The initial HIA will be
the operation’s life of asset. Through the HIA process, all based on what will be required to make the community
the significant community health and well-being impacts sustainable post-closure and should draw on information
will be identified, measures will be prioritised to minimise obtained from the HRA of employees and contractors
the negative and maximise the positive health impacts, the of the operation, because the same risks can also affect
findings will be reported, and a HMP will be developed to the wider community living adjacent to the operation.
implement the recommendations of the HIA. The data from the HRA need to be incorporated into

the environmental health assessments. Operations are an important component of the implementation of the HMP
required to identify and understand the health issues or the integrated ESHMP.
and health service delivery issues in communities where
mining operations exist, through appropriate baseline data. 6. DEVELOPMENT OF SUSTAINABLE
Opportunities to address community health issues should COMMUNITY HEALTH
be identified and evaluated.
An evaluation of the operation and its potential impacts
Refer also to ICMM’s Good Practice Guidance on on local communities’ health and well-being should be
Occupational Health Risk Assessment - first issued in undertaken at regular intervals (e.g. every 3 years), by an
2009 and updated in 2016 available at http://www.icmm. independent agency as part of an adaptive operational
com/gpg-occupational-health. management process. Three aspects of an operation can
be evaluated: its process, its impact (short term impacts)
4. INTEGRATED ENVIRONMENTAL, SOCIAL and its outcomes (long term impacts). This will inform
AND HEALTH IMPACT ASSESSMENTS the refinement of the in-depth HIA to be part of the final
closure plan.
As the operational plan is developed in more detail, a more
formal, in-depth HIA is discussed with I&APs. The in-depth A formal and documented mechanism must be established
HIA should be completed with the assistance of relevant for following people considered to be “at risk”, into the
specialists, either as a standalone assessment or as part of future, post-closure. This will involve specific follow-up
an integrated ESHIA. There are important overlaps between for particular exposure groups, and general follow-up
health, environmental and social issues, because many for the remainder of the affected parties. Social issues
health determinants are also recognised components of EIA such as housing, living conditions, water and sanitation
and SIA. Advantages of an integrated ESHIA include the services, local infrastructure development, local workforce
assurance that the scope of the HIA is fit-for-purpose, the development and training, and local institution capacity
provision of a more robust assessment of the health impacts, development all have effects on the health of communities
a reduction in duplication of fieldwork and community in mining regions.
consultations, and the identification of more comprehensive
risk-based health management measures. More recently, Refer also to ICMM’s Community Development Toolkit,
HIAs have seen a transformation with an increased focus London, 2010, available at www.icmm.com/community-
on the potential impacts of projects or operations on overall development-toolkit. The toolkit provides practical guidance
community health and well-being, with an equal emphasis for all stages of the community development process
on disease epidemiology and prevention. This transformation – from exploration through construction, operations, and
has increased the overlap and interdependencies between eventually decommissioning and closure, including the
EIA and HIA methodologies. post-closure environment.
5. MANAGEMENT OF HEALTH IMPACTS ON 7. EMERGENCY MEDICAL CARE

COMMUNITIES
Each closing site shall have a designated person in charge
Impacts on community health and well-being are of emergency medical response and a detailed medical
managed (mitigated and/or enhanced) in partnership emergency response plan for the handling of medical
with stakeholders. Local stakeholders include community emergencies. This must be done at site level, not regionally,
representatives, government officials, health service/ and will detail the response from first aid through to
public health officials, and community health and evacuation with clearly defined responsibilities. Contracting
development workers. Health care providers are well companies should ideally be catered for in the existing AA
recognised as important contributors to health status arrangements for the evacuation of their employees from
and play an important role in influencing the health of operational sites. This must be covered in the contract
communities. To obtain a holistic view of how mining affects between AA and the contracting company. If alternative
community health, it is important to include perspectives arrangements are made, these must be to the same standard
from community residents who have experience with as those for AA employees at operational sites.
social determinants of health (e.g. gender, age, income,
education). Community health monitoring (surveillance) is

Landau Collieries – Kromdraai, South Africa.

EXAMPLE 11: KEPNER TREGOE OPPORTUNITIES

ANALYSIS
View of the mine and beneficiation plant of the Minas Rio Project, Brasil.
INTRODUCTION operations, environment, social (including community and

HR), legal, financial, safety and health. The first step in the
The Kepner Tregoe (KT) decision analysis tool, often used process is to clearly state the decision that is going to be
in mining project evaluation, has been adapted to prioritize made. For example, the decision identified for a diamond
integrated planning opportunities related to closure to mine was to “Prioritize the top few integrated planning
increase the likelihood of realizing the potential value. The opportunities that leads to sustainable outcomes and meets
methodology is explained below and an example excel stakeholder expectations, which realize the maximum value
spreadsheet template is also provided. leading to positive reputational outcomes”. The potential
integrated planning opportunities are then brainstormed,
METHODOLOGY with existing options taken from closure plans provided as
a starting point (Table 1). The next step is to identify the
The KT analysis is undertaken as a one or two-day objectives that an opportunity should meet. These are split
workshop with representation from all relevant internal into ‘Musts’ (mandatory requirements) and ‘Wants’ (desired
stakeholders including mine planning, engineering, requirements – Figure 1).
Table 1: Example of brainstormed integrated planning opportunities and their prioritisation through group voting.
Opportunities Votes
1 1. Plant old waste rock deposits (WRDs) rehabilitation with trees instead of reshaping them. 1
2 Characterise the material to be mined so that it can be selectively placed. 2
3 Investigate tailings material or compost as potential growth medium. 5
4 Investigate alternative productive land-uses (e.g. solar/wind/hydro power, biofuels, agriculture on tailings dams, mining museum, 9
university training).
5 Use pit water as resource in closure. 4
6 Investigate option of joining NE WRD’s into a mega dump. 2
7 Rehabilitate only outer slopes and offset cost of inner slopes to improve surrounding land productivity. 7
8 Use slimes dams surfaces for agricultural purpose due to availability of water. 2
9 Investigate alternative landform designs (e.g. moonscaping) to conserve topsoil. 8
10 Create waste disposal facilities on-site. 1
11 Irrigation of surrounding land to increase carrying capacity. 1
12 Optimise in-pit dumping opportunities in the short term. 10
13 Collaborate with neighbouring mines for regional closure planning. 2

Project name:
ICPS WORKSHOP
Develop objectives and classify into MUSTS and WANTS
Objectives (selection criteria)
MUST
Reduce the closure liability or prevent it from increasing.
Improve integration of closure into mine plan.
Integrated planning opportunities need to be able to be implement from
LoA through medium- to short-term planning.
Operationa cost impact neutral (-2%) or positive.
Implementation can be undertaken in a sustainble way meeting she
requirements.
WANTS Classify objectives into MUSTS and WANTS.
Is this objective mandatory?
Is this objective measurable?
Is this objective realistic?
}
Yes to all 3 – MUST
Works can be implemented now (realise value within two years).

No negative impact to mine production rates. All other objectives are WANTS.
Which MUST objectives are reflected in the WANTS?
No additional resources (e.g. Equipment, capital) to implement unless
funded by the opportunity.
Meets reasonable community expectations and assist with social licence
to operate.
Potential to increase LoA.
Potential to fund closure activities by generating cash flow at end of LoA.
Risk to mining schedule and production must be low to moderate.
Reduce haul distance.
Optimise progressive rehabilitation.
Minimise footprint.
Maximise backfill.
Figure 1 : Example of definitions of MUSTS and WANTS.
Wants are then rated individually against each other opportunities are chosen and detailed implementation
as being of higher importance, similar importance or plans including an action plan with RACI and high-level
lower importance to obtain a weighting (Figure 2). The schedule are developed to assess whether the opportunity
brainstormed opportunities are then assessed against the should be progressed further (Figure 5). Responsibility,
‘Musts’ and any opportunities that do not meet all of them Accountability, Consult, Inform (RACI) involves identifying
are eliminated. The remaining opportunities are then rated Responsibility (who is responsible for doing the task),
against the ‘Wants’ on a scale of 1-10 (Figure 3). This Accountability (who is accountable for making sure the
score is multiplied by the weighting to get a total score for task is done), Consult (who should be consulted when the
each opportunity (Figure 4). A high-level risk assessment task is undertaken) and Inform (who should be informed
exercise is then undertaken, listing only on the top 3 risks when the task is being undertaken and completed. The
associated with each opportunity, focusing on identifying action plan and project implementation plan are then
any potential fatal flaws. Depending on the stated decision tracked over the following 6-12 months and realised value
at the start of the process, the most highly scored few was estimated where relevant.
How important is the ROW compared to the COLUMN?
Much more important

1 2 3 4 5 6 7 8 9 10 11
More important
No additional resources (e.g. equipment, capital) to

Equally important
Risk to mining schedule and production must be

Potential to fund closure activities by generating
Meets reasonable community expectations and
Less important
Work can be implemented now (realise value

Much less important
implement unless funded by the opprtunity

No negative impact to mine production
assist with social licence to operate
Optimise progressive rehabilitation

Potential to increase LoA
cash flow at end of LoA
Reduce haul distance
Minimise footprint
Maximise backfill
within two years)
low to moderate
5 Potential to increase LoA
Potential to fund closure acivities by generating cash flow at end

6
of LoA
7 Risk to mining schedule and production must be low to moderate
8 Reduce haul distance
9 Optimise progressive rehabilitation
10 Minimise footprint
11 Maximise backfill
Figure 2: Example of weighting wants against each other.
Optimise
Pit backfilling Pit backfilling Optimise Optimise scheduling
options at options at topsoil progressive of low grade
Alternative Grant Botha management rehabilitation material
1 Works can be implemented now (realise 10 7 10 10 5
value within two years
2 No negative impact to mine production 7 7 10 10 10
rates
3 No additional resources (e.g. equipment, 10 3 10 5 5
capital) to implement unless funded by the
opportunity
4 Meets reasonable community expectations 10 10 10 10 0
and assist with social licence to operate
5 Potential to increase LoA 3 3 0 0 0
6 Potential to fund closure activities by 0 5 3 3 0
generating cash flow at end of LoA
7 Risk to mining schedule and production 5 3 10 10 7
must be low to moderate
8 Reduce haul distance distance 10 5 0 0 0
9 Optimise progressive rehabilitation 7 7 10 10 7
10 Minimise footprint 10 10 5 5 7
Figure 3: Example of scoring opportunities against the Wants (note that only scores of 0, 3, 5, 7 and 10 are allowed).

Decision and Risk Matrix Results
Alternatives
1 Grant Pit backfilling options
2 Botha Pit backfilling options
3 Optimising topsoil management
4 Optimise progressive rehabilitation activities
5 Optimise scheduling of low grade material in WRD
600,0
548
500,0
459
400,0 411
Total Score
382
300,o
278
200,0
100,0
0,0
1 2 3 4 5
Alternatives
Risk: 18 (S) 18 (S) 20 (S) 16 (S)
Figure 4: Example of final scoring for opportunities and associated highest risk.
Environment Manager
Senior Mine Engineer
Senior Mine Engineer

Technical Services
Acting Manager
Medium Term
R = Responsible
Mine Planner
Long Term
A = Accountable
Mine GM
Finance
C = Consulted
I = Informed
1. Pit backfilling options. Time
(days)
Project Management. 5 A C I R C C
Project Scope. 2 A C I R C C
Project Schedule. 1 A C I R C C
Run mine schedule to optimise waste movement for phase 5-8 with access road into backfill area. 2 A C I R C C
Run mine schedule to opimise waste movement for phase8-6 with backfill. 2 A C I R C C
Make decision on option to move forward. 0 A R
Redesign pit and roads/ramps to match new designed backfilling option. 20 A R
Re-run the mine schedule. 10 A R
Re-run HME requirements. 3 A
High level geotechnical review. 5 A C
Estimate Capex, Opex and mine closure liability. R A
Compare to base case and make decision to proceed or not. 1 A R
Presentation to Mine leadership team. 1 A R
Make decision to proceed or not. 0 A R C
Undertake more detailed LoA, medium and short term planning. R
Figure 5: Example of detailed implementation plan and associated RACI chart.

Gahcho Kué Mine, Canada.

EXAMPLE 12: DEVELOPING CLOSURE

OBJECTIVES AND KPI’S FOR SENIOR LEADERS
INTRODUCTION • Liaise with Group Finance to obtain bank guarantees or
bonds (Finance Manager).
The following objectives and Key Performance Indicators • Develop and implement five-year plans that optimise
(KPI’s) related to Mine Closure Planning have been drafted temporary progressive rehabilitation (Environmental
to assist Senior Leaders at AA operations in developing Manager/SSD Manager).
commitments as part of the performance management • Work with Technical & Sustainability staff to proactively
process. The objectives are higher level targets that would identify and explore opportunities to reduce closure liabilities
be included in Key Result Areas for relevant staff, with and risks (Environmental Manager/Technical Manager).
the KPI’s being the measurable outputs of meeting these • Develop a Stakeholder Engagement Plan specifically
defined objectives. Not all of the objectives and KPI’s for closure (Social Performance and Government
will be relevant to all operations, but should be seen as Relations Manager).
a starting point to developing breakthrough outcomes in
closure planning and concurrent rehabilitation. KPI’S
OBJECTIVES • Reduce closure liability or operational expenditure by

$x M (GM/Finance Manager/Environmental Manager).
• Provide the necessary resources to update closure • Improve confidence level in closure liability estimate by
plans aligned with the MCT every three years x% (Environmental Manager).
(Environmental Manager). • Meet Temporary progressive rehabilitation target of x
• Provide the necessary resources to implement the ha (Environmental Manager/SSD Manager).
Master Action Plan developed from the Gap Analysis, • Number of mine planning opportunities that decrease
Risk Assessment and Opportunities Analysis conducted closure liability or create value that are realised
as part of the ICPS (Environmental Manager). (Environmental Manager/Technical Manager).
• Calculate LoA and premature closure liabilities at least • Closure plan updated on time and meeting all MCT
once a year (end of financial and end of calendar year) requirements (Environmental Manager/Head of SSD).
according to agreed Group Principles and communicate • Reduce three significant or high rated closure risks to
outputs to Group Finance and Mine Closure Planning moderate or low (post-mitigation – Environmental Manager).
Department (Finance Manager). • Number of closure plan actions completed
(Environmental Manager).

EXAMPLE 13: CLOSURE CRITERIA

EFFECTIVENESS REVIEW
Barro Alto scenic viewpoint, Brasil.
INTRODUCTION or higher rating). These should first be listed in a table and

those that can be assessed for effectiveness based on the
The closure risk assessment ratings assume that all remaining LoA identified (Table 1).
closure criteria are 100% effective. We know this is rarely
the case. While not all closure related criteria can be The identified closure criteria to address the significant
tested for effectiveness during operations (e.g. demolition, or high residual risk should be identified along with the
decommissioning), some can, particularly those related to process to verify effectiveness (Table 2). The following
concurrent rehabilitation. A closure criteria effectiveness should be assessed for each risk and classified as fully
review should be carried out between successive updates effective, partially effective or ineffective:
of closure plans. For closure criteria that are not fully
effective, actions plans should be developed to address the • Formal procedure and/or standard.
identified issues. • Management system in place.
• Evidence of Planning.
METHODOLOGY • Required budget in place.
• Evidence of reporting.
Critical closure criteria are those that have a post mitigation • RACI in place and active.
residual risk rating of significant or high (Anglo 5x5 – 13
Actions should be developed for any partially effective to the Master Action Plan (MAP) and tracked for completion
closure criteria and urgent action should be taken for any between successive updates of the closure plan.
identified ineffective controls. These actions should be added
Table 1: Example of critical closure criteria with significant or high residual risks.
RISK CONTROL CLOSURE CRITERIA REVIEW PROCESS
Significant/High Residual Risk
Dam overflow. Monitoring and Trigger Action Response Plan Review existing monitoring programme and TARP
(TARP). and inspect in the field.
Inadequate dam maintenance. Inspection and maintenance schedule. Review schedule and audit in the field.
Inability to cap ES void. Dewater, consolidate and cap. Not relevant as plan is to challenge capping requirement.
Spon Com from coal seams in high or low wall. Sustainable high wall rehabilitation and capping Review sustainable high wall technique and capping
of low wall. procedures and inspect trial areas in the field.
Blasting on high walls moves less material Dozer push at higher cost. Financial risk only so suggest CCE not value adding.
than design.
Failure of sustainable high wall technique Sustainable high wall rehabilitation. Covered in the previous risk.
leads to erosion.

Table 2: Finalised site critical control specification summary.
Critical Control Routine Monitoring

Critical Control Critical Control
Specification Subject to
Critical Control Critical Control Critical Control - Criteria for Higher Level
Number Title Owner Effective Control By Who Frequency Assurance
CC#1 Spontaneous Mine Manager 1. Implement Contract Monthly No
combustion sustainable high Supervisor
wall treatment.
2. Capping of
high risk low wall
material with
inerts based on
risk.
3. Coverage of
high risk material
with pit water.
4. Visual
inspections and
other monitoring.
CC#2 WRD Mine Manager 1. Reshaping of Contract Monthly No
rehabilitation WRD batters to Supervisor
18 degrees.
2. Topsoil to be
applied to a
minimum depth of
100 mm.
3. Planting
and seeding of
endemic species.
Fertiliser addition.
4. Monitoring of
rehabilitation and
maintenance.
5. Implementation
of post-closure
monitoring
programme.
CC#3 Void water quality Mine Manager 1. Capping of Carl Grant Quarterly No
tailings (2 m
thick).
2. Groundwater
monitoring.
3. Groundwater
modelling.
4. Geochemical
testing of tailings.
CC#4 Offset quality Mine Manager 1. Follow Carl Grant Annual No

restoration
plan including
appropriate
capping of
landform.
2. Maintain
compliance with
Rehabilitation
and Offset
Management
Plan.
3. Implementation
of post-closure
monitoring
programme.
CC#5 Closure liability Mine Manager 1. Conduct Rudolph Botha Biannually Yes ( )
regular review of
the template and
closure costings.
2. Continue
Annual Review
process with
DP&E and DRE.

Critical Control Effectiveness Monitoring and
Reporting
RACI in
Formal Management Evidence Required Evidence Place,
Requirements to verify Procedure System in of Budget in of and CCE
Effectiveness Owner Frequency & Standard Place Planning Place Reporting Active Status
1. Verify correct Carl Grant Monthly Partial Partial Yes Partial Partial Yes Action
implementation of the Required
sustainable highwall
rehabilitation methdology.
2. In field inspection of
capping thickness in
WRD’s.
3. Monitoring of
rehabilitation success.
4. Maintenance
requirements identified
and implemented.
1. Verify reshaping of Carl Grant Monthly Partial Partial Yes Yes Partial Yes Action
WRD batters to 18 Required
degrees.
2. Verify topsoil or OGM
being applied at correct
depth or rate.
3. Verify planting and
seeding of correct
endemic species and
appropriate fertiliser
addition.
4. Monitoring of
rehabilitation and
identification of required
maintenance.
5.Verify implementation
of required maintenence
using agreed procedures,
with follow-up monitoring.
1. Investigate justification Carl Grant Quarterly Partial Partial Partial Yes Partial Yes Action
for not capping tailings. Required
2. Review geochemical
analysis of void water
monitoring results from an
ecotoxicology perspective.
3. Review void modelling
and update with new data
(evaporation).
4. Review geochemical
testing results for tailings
and overburden.
1. Follow restoration plan Carl Grant Annual Yes Partial Partial Partial Yes Yes Action
including appropriate Required
capping of landform.
2. Maintain compliance
with Rehabilitation and
Offset Management Plan.
3. Implementation of
post-closure monitoring
program.
1. Conduct regular review Rudolph Biannually Yes Yes Partial Yes Yes Yes Action
of the template and Botha Required
closure costings.
2. Continue Annual Review
process with DP&E and
DRE.

EXAMPLE 14: PROJECT MANAGEMENT

FRAMEWORK (PMF) – STUDY AND PROJECT
EXECUTION PLAN TEMPLATE
Amandelbult’s Tumela 1 Shaft, South Africa.

INTRODUCTION stakeholders and state the investment vision.
This Project Execution Plan Template defines the minimum The Investment Team also identifies the key objectives
criteria that must be delivered by the Investment Team at for which the key performance indicators (KPIs) can be
the end of the Opportunity, Concept, Pre-Feasibility A, Pre- defined: usually related to safety, capital cost, schedule
Feasibility B and Feasibility Stages. The Project Execution (project completion and /or first production) and capacity.
Plan template is intended to be tailored to the appropriate
level to suite the effort/scope of the study effort. The As a guide, the Project Objectives consider the following
intent of the document is to have one consolidated Project/ items when being developed (notwithstanding being
Study Execution Plan for the owner’s scope and any key covered elsewhere with a greater level of detail):
contractors associated with the delivery of the Investment. • Business objective requirements.
• Stakeholder requirements.
The Investment Charter Sections 1 through 5 content • Any special requirements for working within an existing
shall be addressed per the major section headings with operation.
appropriate detail to match the study level as per the • Any special environmental considerations and
guidance provided in the Investment Charter template. requirements.
The Planning Basis Sections 6 through 27 shall be tailored • Any local content requirements.
to be applicable to the project/study effort requirements. • The use of safety factors in equipment sizing to mitigate
Each section represents typical content and it is at the production risks.
Investment Teams discretion to determine applicable • Sparing philosophy for the investment.
content for their project.
2.1. PROJECT BACKGROUND AND HISTORY
INVESTMENT CHARTER 2.2. PROJECT/STAGE OBJECTIVES
1. BUSINESS GOALS AND OBJECTIVES 2.3. CLIENT (OPERATIONS) USER
REQUIREMENTS
This section should summarize the business case and
include the business objectives. It should describe how 2.4. KEY AND CRITICAL SUCCESS FACTORS
the investment fits into the corporate portfolio and 2.5. PROJECT OBJECTIVE CRITICAL ISSUES,
strategy. Describe the investment history and background RISKS AND OPPORTUNITIES (SWOT)
with key reasons for developing this investment. The
investment purpose and mission need to be clearly 3. SCOPE OF INVESTMENT
stated and explained. It is important that the team has a 3.1. BACKGROUND AND LOCATION
good understanding of the body of work that has been
conducted prior to this point in time. Summarize the issues
faced and resolved in the previous study work and residual 3.2. DESCRIPTION OF FACILITIES
issues and risk that need to be addressed in the next stage.
3.3. EXECUTION DESCRIPTION
The section should list both the highest ranked
opportunities and risks associated with the investment
along with a brief description of the path forward on the 3.4. PROJECT DELIVERABLES [STAGE
opportunities or the mitigation plan on the risk including DELIVERABLES]
exit strategies as appropriate.
3.5. BATTERY LIMITS AND EXCLUSIONS
1.1. BACKGROUND AND INVESTMENT
HISTORY [BRIEF STAGE BY STAGE LOOK
BACK] 3.6. CRITICAL SCOPE ISSUES, RISKS AND
OPPORTUNITIES [INCLUDED ITEMS
1.2. BUSINESS CASE SUCH AS NEW TECHNOLOGIES OR
POTENTIALLY RISK LOCATIONS]
1.3. BUSINESS OBJECTIVES
1.4. INVESTMENT CRITICAL ISSUES RISKS
4. EXECUTION APPROACH AND WORK
AND OPPORTUNITIES
PLAN
2. PROJECT OBJECTIVES This section should describe the Execution Approach and
This section should summarize the Stage specific Project Work Plan for the Stage specific work. The work should be
Objectives and how they will achieve the goals of the consistent with the Project Objective, Business Objectives
Business Objectives This section should list the opportunities and IDM Guidance.
and risks associated with this stage of work to allow for the
Development of the investment along with a brief description
of the path forward on the opportunities or the mitigation
plan on the risk including exit strategies as appropriate.
Set out the objectives from the perspective of all

4.1. BACKGROUND 6. RISK MANAGEMENT PLAN
4.2. MANAGEMENT PLAN APPROACH
6.1. BACKGROUND AND OBJECTIVES
6.2. RISK MANAGEMENT PROCESS/
4.2.1. GOVERNANCE STRUCTURE
DEFINITION OF RISK
6.3. RISK IDENTIFICATION AND MITIGATION
4.2.2. PROJECT SPONSOR
AND ESTIMATE THE RELATED IMPACTS
ON SCHEDULE AND COSTS ROLES AND
4.2.3. STEERING COMMITTEE RESPONSIBILITIES
7. ORGANISationAL PLAN
4.2.4. PROJECT TEAM COMPOSITION
OWNER/CONTRACTORS [INCLUDE
ORG STRUCTURE AND NARRATIVE OF 7.2. ORGANISATIONAL STRATEGY
EXECUTION APPROACH (E.G. OWNER 7.3. ORGANISATION CHART
MANAGED, EPCM, ETC.)]
7.4. ROLES RESPONSIBILITIES AND
RESOURCES (RACI)
4.3. PROJECT KEY MILESTONE CHART/
SCHEDULE [INCLUDE STAGE AND 7.5. CRITICAL ISSUES
OVERALL PROJECT MILESTONES] 8. FUNDING AND FINANCING PLAN
4.4. EXECUTION APPROACH RISK AND
OPPORTUNITIES [INCLUDE ANY NON- 8.2. INSURANCE PHILOSOPHY
TRADITIONAL EXECUTION APPROACHES 8.3. FUNDING STRATEGY
OR AREAS OF PARTICULAR RISK TO
APPROACH] 8.4. FINANCING STRATEGY/HEDGING
8.5. TAXES AND EXEMPTIONS
4.5. BUDGET SUMMARY [INCLUDE SUMMARY REQUIREMENTS
OF BUDGET REQUEST FOR THE STAGE 8.6. ROLES, RESPONSIBILITIES AND
BY MAJOR WBS CATEGORY, HIGHLIGHT RESOURCES
ANY EARLY CAPITAL SPENDS, LIST SUNK
COST BY STAGE] 8.7. CRITICAL ISSUES
9. REGULATORY, ENVIRONMENTAL AND
4.6. CRITICAL ISSUES PERMITTING MANAGEMENT PLAN
5. SUSTAINABILITY APPROACH 9.2. EIS
This section should describe the Strategy for the 9.3. REGULATORY APPROVALS
sustainability of the Investment and identify critical
commitments (future and current) for the success of the 9.4. PERMITTING REQUIREMENTS
business case. It will need to identify any critical activities/ 9.5. PERMITS CONDITIONS INCLUDING
negotiations that will need to occur during this stage. OFFSET STRATEGY
5.1. BACKGROUND AND COMMITMENT 9.6. MONITORING AND CONTROL METHODS
STRATEGY
9.7. ROLES, RESPONSIBILITIES AND
RESOURCES
5.2. EXTERNAL STAKEHOLDERS LIST 9.8. CRITICAL ISSUES
10. PRIME CONTRACTING PLAN
5.3. COMMUNICATIONS and ENGAGEMENT
STRATEGY [INCLUDE LOCAL 10.1. BACKGROUND AND OBJECTIVES
AND REGIONAL COMMUNITIES, 10.2. CONTRACTING STRATEGY
GOVERNMENT AGENCIES, NGO’S,
MEDIA, ETC.] 10.3. CONTRACT SEGMENTS
10.4. CONTRACTOR SELECTION PROCESS
5.4. COMMITMENT COST REGISTER AND 10.5. CRITICAL ISSUES
ASSOCIATED SCHEDULE
11. ENGINEERING MANAGEMENT PLAN (E/
EP/EPCM/EPC/SELF EXECUTE)
5.5. CRITICAL ISSUES, RISKS AND
OPPORTUNITIES
11.2. DESIGN MANAGEMENT PHILOSOPHY
11.2.1. BIM 15.5. MATERIAL PROCUREMENT
11.2.2. MODULARISATION STRATEGY 15.6. FIRST FILL AND SPARE PARTS
PROCUREMENT
11.3. STANDARDS AND SPECIFICATIONS
15.7. EXPEDITING, DILIGENCE AND
11.4. DESIGN MANAGEMENT TOOLS AND
INSPECTION
TECHNIQUES
15.8. LAY-DOWN/MARSHALLING YARD AREAS
11.5. ENGINEERING QA/QC MANAGEMENT
15.9. EQUIPMENT AND MATERIAL
11.6. DRAWING AND DOCUMENT CONTROL
PRESERVATION, WAREHOUSING AND
REQUIREMENTS
STORAGE
11.7. ENGINEERING AND TECHNICAL
FUNCTION INTEGRATION
RESOURCES
11.8. VALUE IMPROVEMENT PRACTICES
15.11. CRITICAL ISSUES
11.9. ROLES, RESPONSIBILITIES
16. CONSTRUCTION MANAGEMENT PLAN
12. OWNER SCOPE DESIGN MANAGEMENT
16.2. CONSTRUCTION MANAGEMENT
PLAN
STRATEGY
16.3. CONSTRUCTION SAFETY INCLUDING
12.2. INTEGRATION PLAN OWNERS/ LOCK-OUT PROCEDURES (FOR
CONTRACTORS (EPCM, ETC.) BROWNFIELD PROJECTS) TEMPORARY
12.3. GEOSCIENCE PLAN CONSTRUCTION FACILITIES/SERVICES
12.4. MINE PLAN 16.4. CONSTRUCTION EQUIPMENT
12.5. METALLURGICAL AND PROCESS PLAN 16.5. EQUIPMENT/MATERIAL LOGISTICS
12.6. INVESTMENT ASSURANCE PLAN 16.6. CONSTRUCTION QA/QC
12.7. OTHERS AS REQUIRED 16.7. PUNCH LIST PROCESS
12.8. ROLES AND RESPONSIBILITIES 16.8. CRISES MANAGEMENT APPROACH
12.9. CRITICAL ISSUES 16.9. ROLES RESPONSIBILITIES AND

RESOURCES
13. CONSTRUCTABILITY PLAN
17. HUMAN RESOURCES/LABOR RELATIONS
13.2. CONSTRUCTABILITY PROCESS PLAN
13.3. ROLES, RESPONSIBILITIES AND 17.1. BACKGROUND AND OBJECTIVES
RESOURCES
17.2. SITE STRATEGY
17.3. PROJECT STRATEGY
14. LOGISTICS PLAN
17.4. WORK FORCE REQUIREMENTS
14.2. TRAFFIC AND TRANSPORTATION RESOURCES
MANAGEMENT
14.3. CUSTOMS REQUIREMENTS
MANAGEMENT 18. PRE COMMISSIONING PLAN (C0)
14.4. ROLES AND RESPONSIBILITIES 18.1. BACKGROUND AND OBJECTIVES
14.5. CRITICAL ISSUES 18.2. PRE-COMMISSIONING MANAGEMENT

STRATEGY
15. PROCUREMENT AND MATERIALS
MANAGEMENT PLAN 18.3. PRE-COMMISSIONING
CONSIDERATIONS
18.4. PRE-COMMISSIONING SEQUENCE
15.2. PROCUREMENT AND MATERIAL
MANAGEMENT STRATEGY 18.5. SAFETY REVIEW, INCLUDING LOCK-OUT
PROCEDURES AND TRAINING
15.3. PROCEDURES, PROTOCOLS,
PROCEDURES TOLLS 18.6. SYSTEM HANDOVER REQUIREMENTS
15.4. LONG LEAD PROCUREMENT 18.7. ACCEPTANCE CRITERIA

18.8. ROLES RESPONSIBILITIES AND 21.10. CRITICAL ISSUES
RESOURCES
22. QUALITY ASSURANCE/QUALITY
18.9. CRITICAL ISSUES CONTROL MANAGEMENT PLAN
19. COMMISSIONING AND START-UP 22.1. BACKGROUND AND OBJECTIVES
MANAGEMENT PLAN (C1-C4)
22.2. QA/QC METHODS AND TOOLS,
19.1. BACKGROUND AND OBJECTIVES TECHNIQUES
19.2. COMMISSIONING AND STARTUP 22.3. DOCUMENT CONTROL/RECORD
MANAGEMENT STRATEGY KEEPING
19.3. COMMISSIONING AND STARTUP 22.4. QA/QC CLOSEOUT/HANDOVER REPORT
CONSIDERATIONS
22.5. ROLES RESPONSIBILITIES AND
19.4. COMMISSIONING AND STARTUP RESOURCES
SEQUENCE
19.5. SAFETY REVIEW, INCLUDING LOCK-OUT
23. SAFETY MANAGEMENT PLAN
PROCEDURES AND TRAINING
19.6. SYSTEM HANDOVER REQUIREMENTS
23.2. SAFETY MANAGEMENT STRATEGY
19.7. ACCEPTANCE CRITERIA
23.3. SAFETY RULES AND REGULATIONS
RESOURCES 23.4. PERSONNEL SAFETY
19.9. CRITICAL ISSUES 23.5. TRAINING
20. COST MANAGEMENT PLAN 23.6. ROLES AND RESPONSIBILITIES
20.1. BACKGROUND AND OBJECTIVES 23.7. CRITICAL ISSUES
20.2. WBS INCLUDING CBS, WORK 24. HEALTH MANAGEMENT PLAN
PACKAGES, CODE OF ACCOUNTS, ETC. 24.1. BACKGROUND AND OBJECTIVES
20.3. ESTIMATE AND BUDGET BASIS AND 24.2. HEALTH MANAGEMENT STRATEGY
ASSUMPTIONS
24.3. HEALTH RULES AND REGULATIONS
20.4. COST CONTROL APPROACH
24.4. ROLES AND RESPONSIBILITIES
20.5. CHANGE AND TREND MANAGEMENT
APPROACH 24.5. CRITICAL ISSUES
20.6. SYSTEMS DESCRIPTION 25. INFORMATION MANAGEMENT PLAN
20.7. PROJECT PROGRESS REPORTING 25.1. BACKGROUND AND OBJECTIVES
20.8. RISK AND CONTINGENCY MANAGEMENT 25.2. SCOPE
APPROACH 25.3. ORGANISATION
20.9. ROLES, RESPONSIBILITIES AND 25.4. COMMUNICATION MANAGEMENT
RESOURCES
25.5. INFORMATION REPOSITORIES/
20.10. CRITICAL ISSUES EXCHANGE
21. SCHEDULE MANAGEMENT PLAN 25.6. BUSINESS SYSTEMS
21.1. BACKGROUND AND OBJECTIVES 25.7. IT INFRASTRUCTURE
21.2. SCHEDULE BASIS AND ASSUMPTIONS 25.8. ROLES AND RESPONSIBILITIES AND
21.3. SCHEDULING STRATEGY RESOURCES
21.4. SCHEDULE CONTROL 26. OPERATIONAL READINESS PLAN
21.5. SCHEDULE HIERARCHY 26.1. BACKGROUND AND OBJECTIVES
21.6. SCHEDULE RISK ANALYSIS AND 26.2. INITIAL AND SUSTAINED OPERATIONS
OUTCOME CONSIDERATIONS
21.7. PROGRESS AND PERFORMANCE 26.3. OR MANAGEMENT STRATEGY
CONTROL 26.4. TRAINING PLAN
21.8. SYSTEM DESCRIPTION 26.5. OPERATIONS HANDOVER
21.9. ROLES, RESPONSIBILITIES AND REQUIREMENTS
RESOURCES 26.6. ACCEPTANCE CRITERIA

26.7. ROLES, RESPONSIBILITIES AND 27.2. MARKET CRITERIA
RESOURCES
27.3. SUPPLY AGREEMENTS AND PENALTIES
27.4. ROLES AND RESPONSIBILITIES
27. MARKETING PLAN
Sishen Mine, South Africa – Inspection being done on locomotive and rail.

EXAMPLE 15: QUANTITATIVE RISK SIMULATION

AND ANALYSIS
A distant view of the Dishaba Mine, South Africa.


INTRODUCTION
The accuracy of the closure cost estimate might not be at the required level from an investment review point of view based
on the inherent nature of a closure plan (scope not always finalised and not always agreed with the regulator until late in
the LoA). It is therefore important that an accurate contingency estimated process is followed. A Quantitative Risk Analysis
(QRA) consists of the establishment of a quantitative model and applying probabilistic parameters (e.g. Monte Carlo
analysis), that will give an accurate contingency liked to the accuracy of the estimate (P50 vs P80 vs P90). This example
contains extracts from a QRA, to demonstrate the benefits of this approach.
TYPICAL QRA OUTPUTS
Figure 1 below illustrates a typical example of the % confidence of the base estimate and the additional contingency
required to obtain a 90% confidence level with a legend on how it must be interpreted:
Iterations
Value
Base estimate Acceptable risk

confidence level
Contigency Required
required confidence level
Figure 1: Illustration of confidence level related to contingency

The Monte Carlo simulations provided the following results:
Figure 2 is a waterfall chart that illustrates exclusions, reductions and additions in values on the original study phase 1
capex budget that was applied to determine a base capital estimate for 2012 on which a Monte Carlo analysis could be
performed. The original budget of $US205 M was reduced to $US105.4 M.
Original to Base Estimate Capex Waterfall ($’000 000)
Original Study Total Project Phase 1 Capex Budget (based on 2011 figures) $205.9
Exclude initial capitalised operating cost estimate $18.8
Exclude initial contingency estimate $23.6
Reduced consultants, study and execution cost $11.1
Outsourcing mining earth moving equipment $6.5
Reduced plant construction, packaging, shipping, erection and commissioning $20
Reduced bulk earthworks, roads and civils $20.9
Outsourcing generator sets and electrical/mechanical reduction $8.4
Reduced building costs $5.2
Reduce equipment, LDVs, IT, labs, worshop and services, trucks – to Franceville $7.7
Reduced upgrade of roads to Franceville $2.7
Reduced IT infrastructure $1.9
Excluded railway station $2.0
Additional locomotive and wagons cost $3.9
Additional plant modifications and EFL $1.2
Additional site establishment and infrastructure design work $0.8
Additional SHE permits and mining rights (including $11.2m packaged plant cost $22.4
New 2012 baseline estimate with 8% escalation $105.4
$0 $50.0 $100.0 $150.0 $200.0 $250.0

Figure 2: Typical base estimate capex waterfall, to be used in a Monte Carlo analysis

Uncertainty associated with the project’s capital estimate is represented by the risk profile below (histogram and
cumulative distribution curve graph, as illustrated in Figure 3 below).
Capex Monte Carlo distribution.
91.64 109.81
5.0% 90.0% 5.0%
8 100.0%
7 87.5%
6 75.0%
5 62.5% TOTAL (excl tax)/

Monte Carlo Capital Cost
Minimum $80 826 550.89
4 50.0% Maximum $123 601 922.15
Mean $100 827 868.43
Base estimate = 105418508

Std Dev %5 508 004.58
Values 5 000
90% = $107 919 312.79

10% = $93 700 105.15
3 37.5%
2 25.0%
1 12.5%
0 0.0%%
80 85 90 95 100 105 110 115 120 125
Values in Millions ($)
Figure 3: Typical risk profile demonstrated by a histogram and cumulative distribution curve, using Monte Carlo Analysis for
Capex cost.
The top capital sensitivity drivers to the estimate cost are shown in the tornado graph below (the cost sensitivity of an item
is a measure of the correlation between the cost of the item and the cost of the project).
Capex Monte Carlo distribution.
Regression coeffients
CAPEX – Project Team Procurement 0.49

CAPEX – Locomotives and wagons 0.48
CAPEX – Road upgrade (external 18 km – from production 0.42
CAPEX – Plant erection and commissioning 0.27
CAPEX – Mining rights 0.26
CAPEX – Buildings and infrastructure 0.25
CAPEX – Part 1 – ROAD AND BULK EARTHWORKS 0.25
CAPEX – Consultant cost 0.13
CAPEX – Part 2 – WATER MANAGEMENT 0.10
CAPEX – Modifications to the original plant 0.09
CAPEX – Part 3 – SLURRY AND RETURN WATER 0.07
CAPEX – Project team cost 0.07
CAPEX – Eath moving equipment 0.03
CAPEX – SHE permits 0.03
CAPEX – Electrical reticulation 0.03
CAPEX – Part 4 – SEWAGE TREATMENT PLANT

-0.05
0.00
0.05
0.10
0.15
0.20
0.25
0.30
0.35
0.00
0.40
0.45
0.50
Coefficient value
Figure 4: Typical tornado graph, reflecting cost sensitivities.
Uncertainty associated with the project’s operational expenditure estimate over five years is represented by the risk profile
as reflected in Figure 5 on the next page (histogram and cumulative distribution curve graph).
Opex Monte Carlo distribution
202.64 218.04
5.0% 90.0% 5.0%
9 100.0%
8 88.9%
7 77.8%
6 66.7%
rand total/total Opex
G
cost
5 55.6%
Minimum $196 411 087.08
Maximum $225 398 673.05
4 44.4% Mean $210 290 699.84
Base estimate = 2132399838

Std Dev $4 668 579.92
10% = $204 155 056.96
90% = $216 281 759.57

3 33.3% Values 5 000
2 22.2%
1 11.1%
0 0.0%
195 200 205 210 215 220 225 230
Values in millions ($)
Figure 5: Typical risk profile demonstrated by a histogram and cumulative distribution curve, using Monte Carlo Analysis for
Opex cost.
The same principle as with the capital estimate distribution applies where the range between the lowest cost and the
most likely cost is on average much higher than the range between the most likely cost and the highest cost. The base
operational expenditure estimate of $US213.24 M over five years therefore has a very high confidence level of 75%.

General view of Amandelbult’s Tumela 1 Shaft, South Africa.

EXAMPLE 16: EXECUTION PLANNING AND

SCHEDULING
INTRODUCTION Moonscapes/ha. 200 ea/ha
Excavator travel speed normal. 2.7 km/hr
This example contains an illustration of the requirements
Travel time between moonscapes. 0.22 min
and deliverables associated with execution planning and
Travel time between moonscapes/rows. 0.11 min
scheduling. Key components such as resource availability,
assumptions related to production and non-production time, Loads per moonscape. 2 ea
as well as describing the key activities, key dependencies, Time to create moonscape – cycle. 1.20 min/moonscape
equipment availability and utilisation (see Table 1 below), etc. Time to create moonscape/ha. 4.0 hrs/ha
are required as part of the planning process. Moonscaping excavator. 2 493 m2/hr
Examples of key planning inputs Moonscaping excavator. 1 589 m /hr effective
2
Moonscapes/ha. 200 ea/ha

Resources:
• 2 x Bulldozers – CAT D9. Excavator travel speed normal. 2.7 km/hr
• 2 x Excavators Large – Liebherr 984. Travel time between moonscapes. 0.22 min
• 1 x Excavator Small – Liebherr 944. Travel time between moonscapes/rows. 0.11 min
• 1 x Team of six workers (Need two teams to achieve Loads per moonscape. 2 ea
planting target).
Time to create moonscape – cycle. 1.01 min/moonscape
• 1 x Road Grader.
Time to create moonscape/ha. 6.5 hrs/ha
• 1 x Bio-Physical Contractor (Building of concrete wall).
• 1 x Bio-Physical Long Slopes (Probably helicopter). Time to plant and close. 0.9 min/moonscape
• 4 x Physical Contractors. Planting small excavator. 1 529 m2/hr
• 4 x Transition Contractors. Planting small excavator. 975 m2/hr effective
Production and non-production time:
• All rehabilitation team work 5 days per week. EXAMPLES OF KEY ACTIVITIES
• The rehabilitation team work from Mondays to Fridays.
• The rehabilitation team work from 07H00 to 16H00 Bio-Physical Activities
(nine hours) on work days.
• The rehabilitation team work 45 hours per week. Step 1: Prepare Dump
• The rehabilitation team don’t work on public holidays. Shaping – Large excavator
• The plan allows for planting only in January, February Shaping – Bulldozer
and March and also constrains the small excavator from Moonscaping – Bulldozer
other activities. Stormwater drain – Small excavator
• The plan allows wetting only in January, February, March Roads – Small excavator
and April. Roads – Grader
Step 2: Plant Dump

BioPhysical – Shaping – Large excavator. m²/hr 180
Planting – Small excavator
BioPhysical – Shaping – Bulldozer. m²/hr 227 Planting dump – Local workers
BioPhysical – Moonscaping – Bulldozer. m²/hr 2 065 Wetting W1 – Watertanker + light vehicle
BioPhysical – Stormwater Drain – Small m²/hr 1 079 Wetting W2 – Watertanker + light vehicle
Excavator. Wetting W3 – Watertanker + light vehicle
BioPhysical – Roads – Small excavator. m²/hr 1 079 Wetting W4 – Watertanker + light vehicle
BioPhysical – Roads – Grader. m²/hr 58 606
BioPhysical – Planting – Small excavator. m²/hr 975
Physical Activities
BioPhysical – Planting Dump – Farm m²/hr 487
workers.
Step 1: Demolish infrastructure
BioPhysical – Wetting W1 – Watertanker + m²/hr 1 301
4x4 light vehicle.
Remove – Workshop Cranes – Contractor
Remove – Light steel – Contractor
4x4 light vehicle.
Remove – Medium Steel – Contractor
Remove – Heavy Steel – Contractor
4x4 light vehicle.
Remove – Double brick wall single story – Contractor
Remove – Double brick wall multi-level – Contractor
4x4 light vehicle.
Remove – Reinforced concrete floor 250 mm – Contractor
BioPhysical – Ripping – Bulldozer. m²/hr 1 061
Remove – Concrete slab 340 mm – Contractor

Excavating foundations – Contractor Water management

Remove – Railway – Contractor Air Quality Management
Remove – Weighbridge – Contractor Heritage or Infrastructure Management
Remove – Conveyor System – Contractor Rehabilitation monitoring
Slope Stability Management
Other transition activities Legal Assessment
Game Farm Management Mine residue deposits Management
Original EXCEL base outcome New XPAC base outcome
60.00 60.00
50.00 50.00
40.00 40.00
ZAR Millions
ZAR Millions
30.00 30.00
20.00 20.00
10.00 10.00
0.00 0.00
15
17
19
21
23
25
27
29
31
33
pr 35
15
15
17
19
21
23
25
27
29
31
33
pr 35
15
20
20
20
20
20
20
20
20
20
20
20
20
20
20
20
20
20
20
20
20
20
20
20
20
e
e
– Physical EXCEL base – BioPhysical EXCEL base – Physical EXCEL base – BioPhysical EXCEL base
– Transition EXCEL base – Transition EXCEL base
Figure 1: Reflecting a typical analysis comparing the results from 2 different scheduling systems (EXCEL and XPAC).
As part of execution planning and scheduling it is important to evaluate the accuracy and the overall confidence in the
models used. Figure 1 above is a typical result where an old and a more advance new planning system was used, and the
results compared in an attempt to measure the confidence in the new system/model.
Table 2: Typical cash flow linked to the execution plan

Code Data Field Name
01/Jan/2015 01/Jan/2016 01/Jan/2017 01/Jan/2018 01/Jan/2019 01/Jan/2020 01/Jan/2021 01/Jan/2022 01/Jan/2023 01/Jan/2024 01/Jan/2025 01/Jan/2026
01/Jan/2016 01/Jan/2017 01/Jan/2018 01/Jan/2019 01/Jan/2020 01/Jan/2021 01/Jan/2022 01/Jan/2023 01/Jan/2024 01/Jan/2025 01/Jan/2026 01/Jan/2027
bud Budget
bio Bio-Physical
fix Fixed R 5 289 869.86 5 337 899.61 17 736 654.25 9 445 679.68 15 918 186.32 17 777 711.47 19 584 065.22 20 525 376.67 32 294 086.13 10 284 734.18 15 377 428.70 13 073 321.78
bas Baseline R 0.00 8 127 222.25 6 399 703.58 12 698 059.88 6 949 840.00 3 093 193.36 10 593 027.13 18 128 052.51 3 563 444.00 11 057 194.07 4 090 765.98 5 744 241.00
Comp
kio Comp
KIO R 0.00 2 872 445.88 798 649.28 0.00 838 829.90 0.00 0.00 4 920 520.78 1 953 410.26 0.00 465 728.36 0.00
tot Total Bio-Physical R 5 289 869.86 16 337 567.74 24 935 007.10 22 143 739.56 23 706 856.21 20 870 904.83 30 177 092.35 43 573 949.96 37 810 940.40 21 341 928.25 19 933 923.05 18 817 562.78
sp1
phy Physical
fix Fixed R 0.00 1 405 023.24 22 961 203.52 9 141 676.53 10 269 846.24 11 158 579.66 0.00 0.00 0.00 0.00 0.00 0.00
bas Baseline R 0.00 81 851.06 211 890.37 20 087.25 365 460.42 0.00 146 824.07 0.00 0.00 292 162.28 0.00 0.00
kio
Comp KIO
Comp R 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
tot Total Physical R 0.00 1 486 874.30 23 173 093.89 9 161 763.78 10 635 306.66 11 158 579.66 146 824.07 0.00 0.00 292 162.28 0.00 0.00
sp2
tra Transition
fix Fixed R 6 203 948.25 37 642 656.18 56 517 844.73 21 189 887.00 24 745 501.26 12 654 664.25 8 134 659.27 10 445 038.16 10 445 038.16 10 445 038.16 10 777 352.36 9 629 158.16
bas Baseline R 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
kio
Comp KIO
Comp R 829 759.67 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
tot Total Transition R 7 033 707.92 37 642 656.18 56 517 844.73 21 189 887.00 24 745 501.26 12 654 664.25 8 134 659.27 10 445 038.16 10 445 038.16 10 445 038.16 10 777 352.36 9 629 158.16
sp3
tot Total Costs All R 12 323 577.78 55 467 098.21 104 625 945.72 52 495 390.34 59 087 664.13 44 684 148.74 38 458 575.70 54 018 988.12 48 255 978.56 32 079 128.69 30 711 275.41 28 446 720.94
Developing an operational cash flow (see Table 2) once the scheduling has been completed is part of optimising the
execution plan. This often involves the leveling out the opex costs over the scheduled execution period and in doing so
improving the net present cost of the project. Having a linked cash flow to the work breakdown structure and execution
schedule improves the confidence in the execution plan. The execution schedule and cash flow can also be used to de-risk
the project by rescheduling activities as appropriate (e.g. deferring the demolition of the plant because there could be a
potential future buyer and hence early demolition could destroy future value).
EXAMPLE 17: WORK BREAKDOWN STRUCTURE
The Oaks rehabilitation in South Africa.

INTRODUCTION
Developing a detailed Work Breakdown Structure (WBS)

using the execution schedule to at least level 3 (work
package level) is a key component of any project execution
plan. An example of a typical WBS layout is provided
(Figure 1), with a more detailed breakdown of the WBS
components to 3 levels, that links to the various work
packages and the associated project budget items also
provided (Table 1, every WBS item is linked to a cost
number, to track and manage the budget).

MC
Mine Closure Plan
MC 0 MC.1 MC.2 MC.3

Milestones 1000. Mining 2000. Site Development 3000. Process Facility
MC.1.4 MC.2.1 MC.3.4

1400.Fixed Mining 2100. General Site 3400. Recovery Plant
Equipment Development and Layout (Portion of Building 80)
MC.1.5 MC.2.2 MC.3.7

1500. Electrical Power 2200. Access Roads 3700. Paste Fill Plant/Bulk
Supply and Distribution Sample Plant (Building 24)
MC.1.6 MC.2.3 MC.3.9

1600. Surface Facilitites 2300 Air Strip 3900 Process Building
(Building 80)
Figure 1: Typical mine closure plan WBS layout

MC.4 MC.5 MC.6 MC.9
4000. Utilities 5000. Ancillary Buildings 6000. WMP and Water 9000. Indirect
Waste MGM
MC.4.1 MC.5.5 MC.6.1 MC.9.1

4100. Power Plant and 5500. Ancillary Buildings 6100. North Pile 9100. EPCM
Distribution (Utilities Complex
Building 66)
MC.4.2 MC.5.6 MC.6.3 MC.9.3

4200. Fuel Storage and 5600. Cold Storage (Inc 6300. Water Management 9300. Temporary Construction
Distribution Cement Storage) and Treatment – Overland Facilities and Equipment
Pipeline Removals
MC.4.2.1 MC.5.8 MC.6.5 MC.9.4

Fuel Storage Area 1 5800. Plant Mobile and 6500. Off-site Hazardous 9400. Construction Camp
Utility Equipment Waste Disposal and Catering
MC.4.2.2 MC.9.5
Fuel Storage Area 2 9500. Transportation during
Demolition Activities
MC.4.2.3 MC.9.8
Fuel Storage Area 3 9800. Mobilisation and
Demobilisation by Winter Road
MC.4.2.4
Fuel Storage Area 4
MC.4.2.5
Distribution
MC.4.2.6
Other Fuel Storage Tanks
MC.4.3
4300. Glycol System
MC.4.7
4700. Services Complex
(Building No. 73) and Utilidor
(Building No. 68)

Table 1: Detailed mine closure – WBS
Level Code Description

1 1.0.00.00 Mine Closure.
2 1.1.00.00 Decommissioning of Structures.
3 1.1.01.00 Permitting.
4 1.1.01.01 Permitting for 2019 Season.
3 1.1.02.00 General Conditions.
4 1.1.02.01 Construction and Project Management – 2019 Season.
4 1.1.02.02 Pre-Mobilisation Planning – 2019 Season.
4 1.1.02.03 Procurement/Contracting – 2019 Season.
4 1.1.02.04 Mobilisation and Site Preparation – 2019 Season.
4 1.1.02.05 Utility Isolation – 2019 Season.
4 1.1.02.06 Site Accommodation and Services – 2019 Season.
4 1.1.02.14 Demobilisation – 2020 Season.
4 1.1.02.15 Close-out Report – 2020 Season.
4 1.1.02.22 Pre-Mobilisation Planning – 2023 Season.
4 1.1.02.23 Procurement/Contracting – 2023 Season.
4 1.1.02.24 Mobilisation and Site Preparation – 2023 Season.
4 1.1.02.27 Demobilisation – 2023 Season.
4 1.1.02.28 Close-out Report – 2023 Season.
3 1.1.03.00 Demolition – 2019 Season
4 1.1.03.01 Primary Crusher.
4 1.1.03.02 Primary Crusher Product Conveyor to Splice House.
4 1.1.03.03 Splice House.
4 1.1.03.04 Primary Crusher Product Conveyor to Transfer House.
4 1.1.03.05 Radial Stacker Feed Conveyor and Reclaim Area.
4 1.1.03.06 Primary and Secondary Scrubber Feed Conveyors.
4 1.1.03.07 Feed Conveyors Take up Building.
4 1.1.03.08 Back Feed Conveyor from HPRC to Transition House.
4 1.1.03.09 Back Feed Conveyor from Transition House to Transfer House.
4 1.1.03.10 Transition House.
4 1.1.03.11 Transfer House.
4 1.1.03.12 Conveyor to Processed Kimberlite.
4 1.1.03.13 Processed Kimberlite Tower.
4 1.1.03.14 Process Plant.
4 1.1.03.15 Workshop/Warehouse.
4 1.1.03.16 Security/Admin Building.
4 1.1.03.17 Fuel Tank Farm and Fuel Dispensing Stations.
4 1.1.03.18 Construction Camp.
4 1.1.03.19 TAJ/Exploration/Environmental Storage.
4 1.1.03.20 Miscellaneous Storage Tanks.
4 1.1.03.21 Exploration Tango Office.

4 1.1.03.22 Managers Offices.
4 1.1.03.23 Heated Storage/ERT Building.
4 1.1.03.24 Environmental Lab Building.
4 1.1.03.25 Dewatering Infrastructure (except wells).
4 1.1.03.26 Open Pit.
3 1.1.04.00 Disposal – 2019 Season
4 1.1.04.01 Primary Crusher.
4 1.1.04.02 Primary Crusher Product Conveyor to Splice House.
4 1.1.04.03 Splice House.
4 1.1.04.04 Primary Crusher Product Conveyor to Transfer House.
4 1.1.04.05 Radial Stacker Feed Conveyor and Reclaim Area.
4 1.1.04.06 Primary and Secondary Scrubber Feed Conveyors.
4 1.1.04.07 Feed Conveyors take up building.
4 1.1.04.08 Back Feed Conveyor from HPRC to Transition House.
4 1.1.04.09 Back Feed Conveyor from Transition House to Transfer House.
4 1.1.04.10 Transition House.
4 1.1.04.11 Transfer House.
4 1.1.04.12 Conveyor to Processed Kimberlite.
4 1.1.04.13 Processed Kimberlite Tower.
4 1.1.04.14 Process Plant.
4 1.1.04.15 Workshop/Warehouse.
4 1.1.04.16 Security/Admin Building.
4 1.1.04.17 Fuel Tank Farm and Fuel Dispensing Stations.
4 1.1.04.18 Construction Camp.
4 1.1.04.19 TAJ/Exploration/Environmental Storage.
4 1.1.04.20 Miscellaneous Storage Tanks.
4 1.1.04.21 Exploration Tango Office.
4 1.1.04.22 Managers Offices.
4 1.1.04.23 Heated Storage/ERT Building.
4 1.1.04.24 Environmental Lab Building.
4 1.1.04.25 Dewatering Infrastructure (except wells).
4 1.1.04.26 Open Pit.
3 1.1.05.00 Demolition – 2020 Season
4 1.1.05.01 Water Treatment Plant and Outside Office.
4 1.1.05.02 Sewage treatment Plant.
4 1.1.05.03 Incinerator Plant.
4 1.1.05.04 Boiler No. 1 (Accommodation Complex).
4 1.1.05.05 Boiler No. 2 (Processing Plant).
4 1.1.05.06 On-Site Piping.
4 1.1.05.07 Off-Site Piping – Fine Processed Kimberlite Slurry.
4 1.1.05.08 13.8 KV Site Overhead Lines and 115 KV Transmission Lines at Victor Site.
4 1.1.05.09 Quarry Pump House.
4 1.1.05.10 Environmental Lab.
4 1.1.05.11 SHR and E Office.
4 1.1.05.12 Mining Office.
4 1.1.05.13 Accommodation Complex and Administration Office.
4 1.1.05.14 Remainder of 115 KV Transmission Lines to Attawapiskat.

Mine Closure – Work Breakdown Structure (WBS) (continued)

3 1.1.06.00 Disposal – 2019 Season.
4 1.1.06.01 Water Treatment Plant and Outside Office.
4 1.1.06.02 Sewage treatment Plant.
4 1.1.06.03 Incinerator Plant.
4 1.1.06.04 Boiler No. 1 (Accommodation Complex).
4 1.1.06.05 Boiler No. 2 (Processing Plant).
4 1.1.06.06 On-Site Piping.
4 1.1.06.07 Off-Site Piping – Fine Processed Kimberlite Slurry.
4 1.1.06.08 13.8 KV Site Overhead Lines and 115 KV Transmission Lines at Victor Site.
4 1.1.06.09 Quarry Pump House.
4 1.1.06.10 Environmental Lab.
4 1.1.06.11 Safety, Human Resources and Environmental Office.
4 1.1.06.12 Mining Office.
4 1.1.06.13 Accommodation Complex and Administration Office.
4 1.1.06.14 Remainder of 115 KV Transmission Lines to Attawapiskat.
3 1.1.07.00 Demolition – 2023 Season.
4 1.1.07.01 13.8 KV Site Overhead Lines.
4 1.1.07.02 Off-Site Piping.
4 1.1.07.03 River Pump House.
4 1.1.07.04 Emergency/Backup Generators.
4 1.1.07.05 Electrical Switchyard/Substation.
4 1.1.07.06 KDR and Other Temporary Facilities.
1.1.07.07 Underground Power Lines.
3 1.1.08.00 Disposal – 2023 Season.
4 1.1.08.01 13.8 KV Site Overhead Lines.
4 1.1.08.02 Off-Site Piping.
4 1.1.08.03 River Pump House.
4 1.1.08.04 Emergency/Backup Generators.
4 1.1.08.05 Electrical Switchyard/Substation.
4 1.1.08.06 KDR and Other Temporary Facilities.
1.1.08.07 Underground Power Lines.
3 1.1.09.00 Dewatering and Monitoring Wells
4 1.1.09.01 Dewatering Wells
4 1.1.09.02 Monitoring Wells
2 1.2.00.00 Site Characterisation and Soil Remediation.
3 1.2.01.00 Remediation.
3 1.2.02.00 Post Closure Phase 2 ESA.
2 1.3.00.00 Stabilisation Works.
3 1.3.01.00 Stabilisation Works.
4 1.3.01.01 Pit Perimeter Placement of Berm Barricade, Warning Signs.
4 1.3.01.02 Barricade Pit Ramp.
4 1.3.01.03 Emergency Pit Overflow Channel (estimated @ $541,926.00).
4 1.3.01.04 Central Quarry Pond Backfill/Bank Sloping/Reclamation Cover.
4 1.3.01.05 Central Quarry Channel Restoration and Connection to NGC (fish habitat).
4 1.3.01.06 East Overburden Pond Connection to NGC (fish habitat).
4 1.3.01.07 South Quarry Connection to SGC (fish habitat).
4 1.3.01.08 Fine Processed Kimberlite Cell #1 Toe Drain.
4 1.3.01.09 Victor Pit Beach Rock Armoring (estimated @ $6,831,231.00).
4 1.3.01.10 Ground Water Remediation (Sulphate Management) – Slurry Cutoff Ditch.
4 1.3.01.11 Demolition Landfill.

2 1.4.00.00 Land Reclamation.
3 1.4.01.00 Permitting.
3 1.4.02.00 General Conditions.
4 1.4.02.01 Overall Mobilisation and Demobilisation.
3 1.4.03.00 Site Preparation and Reclamation.
4 1.4.03.01 Project 1: East Overburden Stockpile (EOVB) – Site Preparation and Reclamation.
4 1.4.03.02 Project 2: South Quarry (SQ) – Site Preparation, Resloping and Reclamation.
4 1.4.03.03 Project 3: Waste Rock Stockpile (WRS) – Site Preparation and Reclamation.
4 1.4.03.04 Project 4: Demolition Landfill.
4 1.4.03.05 Project 5: Low Grade Stockpile (LGS) – Site Preparation and Reclamation.
4 1.4.03.06 Project 6: Fine Processed Kimberlite Cell #1 and PFK Cell #2 – Site Preparation and Reclamation.
4 1.4.03.07 Project 7: Polishing Pond (PP) Pond Perimeter – Reclamation.
4 1.4.03.08 Project 9: Process Plant and Main Camp – Site Preparation and Reclamation.
4 1.4.03.09 Project 10: Transportation Corridors – Site Preparation and Reclamation.
4 1.4.03.10 Project 12: Bio-Remediation Cell – Site Preparation and Reclamation.
4 1.4.03.11 Project 13: Demolition, Site Clean-up and Disposal of Solid Waste and Salvageable Material.
4 1.4.03.12 Airstrip.
4 1.4.03.13 CQ Discharge Channel.
4 1.4.03.14 Airport Road.
4 1.4.03.15 Pit Slopes.
4 1.4.03.16 Main Haul Road.
4 1.4.03.17 Water Intake Road.
4 1.4.03.18 Water Intake.
4 1.4.03.19 End Pit Lake.
4 1.4.03.20 Polishing Pond.
4 1.4.03.21 SQ Discharge Channel.
3 1.4.04.00 Seeding.
4 1.4.04.06 Project 6: Fine Processed Kimberlite Cell #1 and PFK Cell #2 – Site Preparation and Reclamation.
4 1.4.04.12 Airstrip.
4 1.4.04.15 Pit Slopes.
4 1.4.04.16 Main Haul Road.
4 1.4.04.17 Water Intake Road.
4 1.4.04.18 Water Intake.
4 1.4.04.19 End Pit Lake.
3 1.4.05.00 Planting.

Mine Closure – Work Breakdown Structure (WBS) (continued)

4 1.4.05.06 Project 6: FPK Cell #1 and Fine Processed Kimberlite Cell #2 – Site Preparation and Reclamation.
4 1.4.05.12 Airstrip.
4 1.4.05.15 Pit Slopes.
4 1.4.05.16 Main Haul Road..
4 1.4.05.17
Water
Intake
Road.
4 1.4.05.18
Water
Intake.
4 1.4.05.19
End Pit
Lake.
2 1.5.00.00 Post-Closure Monitoring Programme 2014-2024.
3 1.5.01.00 Post Closure Bio-physical Monitoring and Inspection Programme (2018-2024).
4 1.5.01.01 Geotechnical Inspections (Year 2019-2024).
3 1.5.02.00 Aquatics Programmes (2019-2022).
4 1.5.02.01 Attawapiskat River Well Field Discharge Receiving Water Study.
4 1.5.02.02 Fine Processed Kimberlite Discharge Receiving Water Study.
4 1.5.02.03 Adaptive Management Strategy Aquatic Biological Monitoring – Naysh.
4 1.5.02.04 Mercury Monitoring Programme – Small bodied Fish (assumes 2, 3-year cycles – 2019 and 2022).
4 1.5.02.05 Mercury Monitoring Programme – Large/Small Bodied Fish.
4 1.5.02.06 General Site Effects – SGC EEM.
4 1.5.02.07 Metals Bioaccumulation (Landfill) NGC.
3 1.5.03.00 Water Quality Monitoring (2019-2029).
4 1.5.03.01 LF-3, 4A, 5, 6, 7 and Demolition Landfill Discharge.
4 1.5.03.02 Central Quarry.
4 1.5.03.03 WWTP/WTP.
4 1.5.03.04 Confluence/Winter Road Crossing 04FC011/04FC010.
4 1.5.03.05 Phase 1 Ditch.
4 1.5.03.06 Monument Channel.
4 1.5.03.07 Attawapiskat River Samples.
4 1.5.03.08 Northeast Fen.
4 1.5.03.09 North Granny Creek.
4 1.5.03.10 South Granny Creek.
4 1.5.03.11 Main Rivers.
4 1.5.03.12 Summer Groundwater Programme.
4 1.5.03.13 Biosolids.
3 1.5.04.00 Laboratory Costs.
3 1.5.05.00 Wildlife Monitoring.
4 1.5.05.01 Monitoring – caribou @ year 10.
4 1.5.05.02 Monitoring – birds @ year 10.

4 1.5.05.03 Monitoring – small mammals @ year 10.
3 1.5.06.00 Noise Monitoring (2019 – 2021).
3 1.5.07.00 Air Quality Monitoring (2019-2022).
2 1.6.00.00 Operations and Maintenance – Post Closure 2019-2022.
3 1.6.01.00 Equipment mobilisation/demobilisation.
3 1.6.02.00 Construction of Reclamation Camp.
3 1.6.03.00 Maintenance of Reclamation Camp and associated facilities.
3 1.6.04.00 Winter Road Construction and Maintenance.
3 1.6.05.00 Operate flow supplementation for 2.5 year.
3 1.6.07.00 Reclamation Camp Dismantling and Disposal.
2 1.7.00.00 Non Distributable Overhead Costs.
3 1.7.01.00 Salaries and Benefits.
3 1.7.02.00 Accommodations and Travel.
3 1.7.03.00 External Consulting.
2 1.8.00.00 Owner’s Management Cost.
3 1.8.01.00 Owner’s Project Management.
3 1.8.02.00 Owner’s Support Centre.
3 1.8.03.00 Mine Closure General and Administration.
3 1.8.04.00 Owner Permitting.
2 1.9.00.00 Indirect Cost.
3 1.9.01.00 Draw Down of ARO Liability Account.
3 1.9.02.00 Re-trenching and re-training programme.
3 1.9.03.00 Social Investment.
3 1.9.04.00 Engineering and Consultants.
3 1.9.05.00 Temporary Facilities.
3 1.9.06.00 Power Supply.
3 1.9.07.00 Power Plant Operating.
3 1.9.08.00 Bulk Fuel.
4 1.9.08.01 Bulk Diesel.
4 1.9.08.02 Bulk Gas.
4 1.9.08.03 Northec Fuel Consumption.
3 1.9.09.00 Closure Mine Camp Catering.
3 1.9.10.00 General Contractor Expenses.
3 1.9.11.00 Shipping and Handling Indirect.
3 1.9.12.00 Spare Parts.
3 1.9.13.00 Freight.
4 1.9.13.01 Passenger Airfare.
4 1.9.13.02 Road Freight.
4 1.9.13.03 Helicopter Support.
3 1.9.14.00 Other Support Contracts.
3 1.9.98.00 Contingency.
3 1.9.99.00 Escalation.

EXAMPLE 18: DEMOLITION PLAN
Kolomela Mine, South Africa. Intern Robin Bhola and Izak Gous (Environmental Tech) check on the progress of a sap flow study on these sheperd trees
on the mine property. The study is being conducted to better understand the tree and how it will respond when used in rehabilitation of the mine.

INTRODUCTION
These two examples reflect a typical “Table of Contents” to give some indication as to the scope of a demolition plan
that is influenced by the size of the operations. Table 1 relates to a very small demolition project, that typically will take
place during the operational phase of a mine and be executed by the owner’s team with some specialist support from a
demolition contractor. Table 2 on the other hand is an example of a final demolition plan for a large mining operation that
typically will be executed and managed by an external contractor with sub contractors.
Table 1: Example of a simplified Table of Contents for a demolition plan.
TABLE OF CONTENTS
1 Project
1.1 Purpose of this document 1
1.1.1 Project background 1
1.2 Scope definition and management summary 2
1.2.1 Demolition strategies 2
1.2.2 Scope of work 2
1.2.3 Work, plant, equipment and services etc. excluded 3
1.2.4 Work, plant, equipment and services etc. included 3
1.3 Methodology 3
1.4 Stakeholders 4
1.5 High level overview of risk assessment 4
2 Organisation and Staffing 4
3 Health and Safety 4
3.1 Asbestos 5
3.2 Safety 7
4 Completion 7
5 Supporting Plans 7
5.1 Operational readiness plan 7

Table 2: Example of a detailed Table of Contents for a complex demolition project.
TABLE OF CONTENTS
Executive summary i
Document control ii
Abbreviations and acronyms iii
1. Introduction 1
1.1 Mine closure objectives 1
1.2 Scope of work for DEP 2
1.3 Integration with other closure work packages 3
2 Analysis of steady state closure and overall strategy for demolition execution 6
3 Demolition execution plan scope 8
3.1 Logistics management plan 9
3.2 Support management plan and contractor’s temporary facilities 11
3.3 Asset removals and salvage plan 13
3.4 Waste management plan 17
3.4.1 Off-site management of hazardous waste 17
3.4.2 On-site management of inert demolition waste and detritus 19
3.5 Demolition plan 21
3.5.1 Removal of major structures 21
3.5.2 Removal of minor structures 23
3.5.3 Removal of other items 24
3.6 Site restoration plan 25
3.6.1 Seal of mine openings 25
3.6.2 Soil cover and surface grading/scarification 26
3.6.3 Facilities for long term monitoring and revegetation maintenance 26
3.7 Engineering, procurement and construction management plan 27
3.7.1 Engineering 27
3.7.2 Procurement 28
3.7.3 Construction management 28
3.9 Excluded scope elements 32
4. Schedule management plan 33
4.1 Critical path construction schedule 33
4.2 Resource requirements 34
4.3 Dependencies related to excluded work areas and scope 35
5. Cost management plan 36
5.1 Basis of estimate 36
5.2 Cost estimate for DEP implementation 37
5.3 Risk management plan 38
5.3.1 Cost uncertainty 38
5.3.2 Allowances 41
5.3.3 Risk contingency 42
6. Stakeholder management plan 43
7. Environmental, health and safety stewardship monitoring plan 44
8. Conclusion 45

Kolomela Mine, South Africa.

EXAMPLE 19: CLOSURE MAINTENANCE AND

MANAGEMENT PLAN
INTRODUCTION issues are fire, weeds, feral animals, erosion, plant diseases,
overgrazing and nutrient cycling. It is important these are
A Closure Maintenance and Management Plan (CMMP) addressed to ensure the overall rehabilitation objectives of
is important to understand the management activities to safe, stable, non-polluting and self-sustaining rehabilitation
ensure the rehabilitation areas are sustainable into the are met.
future. They must be aligned to the recreated post-mining
land capabilities and identified land-uses. The will form Rehabilitation areas should be monitored at an early
an important part of the transfer agreement between stage and results compared to success criteria. Areas
the mine and the post-mining land-user facilitating lease that do not meet the defined success criteria should have
relinquishment. This will ensure the land is adequately maintenance activities completed to facilitate achievement
managed and reduces the risk of exposing the company to of the success criteria. Areas requiring maintenance should
long-term management costs. be addressed as soon as possible and re-monitored until
success criteria are met.
METHODOLOGY
A CMMP should clearly detail the known residual risks,
The objective of rehabilitation management is for the area limitations to land-use capability and the potential for
to be self-sustaining and resilient and to require no more latent environmental risks. The CMMP should explain
management effort than surrounding areas with the same the risk causes, already implemented actions, proposed
land-use. The most common rehabilitation management preventative actions as well as future corrective actions

Helena Tailings Dam facility in South Africa, showing reinforcement work being done.
should the residual risk event occur. The proposed • An indication of where infrastructure can and cannot be
methodology for developing a CMMP is outlined below and constructed (such as over unconsolidated spoils).
an example is provided. The CMMP should: • Alleviating compaction where vegetation establishment
• Highlight sensitive areas that require specific activities and growth is limited.
excluded (i.e. no grazing on tailings or waste dumps with • Identification of areas where groundwater
hostile materials encapsulated). contamination from the rehabilitated mine site may be
• Weed/invasive/alien species control programmes to be present as well as any modelling of plume movement
implemented along with a species map. and exclusion points for new groundwater abstraction
• Mitigating erosion and managing sedimentation of points.
waterways or drains. • Any specific and agreed commitments to other
• Introduction of stock (domestic or game) and stakeholders that the new land-user will need to maintain
stocking rates. (i.e. potable water supply, access to monitoring points).
• Fertiliser rates, type and timing to optimize pasture The approach should be to demonstrate, through identification
productivity. of success criteria and associated monitoring, that
• Fencing and stock water points maintenance requirements. rehabilitated areas with the desired composition and structure
• Re-seeding or re-planting. are self-sustaining non-polluting and resilient. Maintenance
• Feral animal control requirements. and management work must be budgeted and implemented
• Fire regimes (if appropriate) to be implemented to with planned versus actual works tracked and reported.
integrate into the surrounding landscape.

EXAMPLE 20: SUGGESTED STRUCTURE FOR

ANGLO AMERICAN CLOSURE PLANS
Kolomela Mine Process plant, South Africa.

INTRODUCTION
The ‘Table of Contents’ structure for closure plans is an

expansion from the structure proposed in the MCT (Version
2, 2013) to reflect the additional work that was undertaken
as part of the ICPS process as well as to accommodate
existing and anticipated future regulatory requirements.
PROPOSED STRUCTURE
The overall closure plan itself should be short and to the

point (Main report of between 50 and 80 pages) and only
contain the outcomes (summary) of the detailed closure
planning steps and deliverables. The rest of the supporting
documentation that were developed as part of the process,
should form part of an appendix.
The main closure plan report should contain the following:
EXECUTIVE SUMMARY
The executive summary must be short (< 5 pages) and

describe the closure plan by focusing on the following five
key topics namely the closure vision, final land-use plan
(map), summary of the closure liability, residual risk profile,
key gaps and associated action plan to close the gaps.
1.0 Introduction
Include a high-level description of the mine, current
situation and requirements linked to the development
of the closure plan.
2.0 Baseline:
2.1 Physical and biophysical context.
2.2 Social and economic context.
2.3 Closure conditions and commitments (including
legal and regulatory requirements).
3.0 Influencing Factors:
3.1 Benchmark and outline closure options (based
on residual risk).
3.2 Identification of the final land-use plan .
3.3 Closure vision, policies and KPI’s.
4.0 Closure Planning:
4.1 Overview of the LoAP.
4.2 Identified integrated planning opportunities.
4.3 Concurrent rehabilitation strategy and ongoing
implementation.
4.4 Closure objectives.
4.5 Closure criteria.
4.6 Success criteria.
4.7 Proposed monitoring programme.
5.0 Closure risk assessment (with and without closure
criteria).
Only include the profile of the “unacceptable” residual
risks (full risk assessment to be included as an
appendix).
6.0 Closure gap analysis:

Only include a summary of the key gaps (full gap 9.1 Closure cost estimate (drawings, assumptions – Basis
analysis will be included as an appendix). of Estimate).
7.0 MAP Only include the a description of the key assumptions,
Only include a summary of the key actions from the the main categories of the basis of estimate and
various sources (e.g. gap analysis, risk assessment, the summary sheets of the estimate (the full cost
opportunities), RACI and key milestones (full master estimate, with all the drawings and detailed basis of
action plan with RACI and schedule will be included estimate will be included as an appendix).
as an appendix). 9.2 Closure cash flow and schedule:
8.0 I&AP consultation (Closure Stakeholder Engagement Only include the high level cashflow and level 1
Plan). schedule with key milestones (the detailed cashflow
Only include the most significant stakeholder issues/ and level 3 schedule will be included as an appendix).
concerns and anticipated needs based on current and 10.0 Closure maintenance and management plans
historical engagements, including anticipated future Include the summary of the plan in this section with
needs based on social trending. the full plan as an appendix.
9.0 Closure Costs: 11.0 Proposed closure organisational structure
General view of the Barro Alto laboratory, Brasil.

Include the organisational structure in this section, 13.0 Review process:
describing the decision philosophy related to for Describe the ongoing review and continuous
example, owner execution vs. contractor execution of improvement process that will be followed as well as any
some or all of the closure plan activities. requirements for additional resources and or budget.
12.0 Audit and reporting:
Describe the process that will be followed to ensure APPENDICES
the identified gaps are closed and the closure plan is
improved to the required level of confidence. Also All the detailed reports and analysis that were used in
describe the governance and reporting process that developing the closure plan (e.g. detailed drawings and
will be followed. cost estimate, gap analysis spreadsheet, risk register, RACI,
MAP) should be included as appendices.

Kolomela Mine Leeufontein pit operations in South Africa.

ACRONYMS
AA Anglo American LED Local Economic Development
AMD Acid Mine Drainage LGA Land Grid Array
ARD Acid Residue Deposit LoA Life of Asset
BoE Basis of Estimate LoAP Life of Asset Planning
BU Business Unit MAP Master Action Plan
BU CEO Business Unit Chief Executive Officer MCP Mine Closure Planning
CBO Community Based Organisation MCT Mine Closure Toolbox
CEO Chief Executive Officer Met Coal Metallurgical Coal
CEP Community Engagement Plan MoA Memorandum of Agreement
CMMP Closure Maintenance and Management Plan MPRDA Mineral, Petroleum and Resources
COP Code of Practice Development Act
CRD Coard Residue Deposit MRA Mineral Resources Act
CSI Corporate Social Investment NEMA National Environmental Management
Act
DAFF Department of Agriculture, Forestry and
Fisheries NEMBA National Environmental Management
Biodiversity Act
DENC Department of Environment and Nature
Conservation NGO Non-Governmental Organisation
DWS Department of Water and Sanitation OEL Occupational Exposure Limit
DWS WUL DWS water use licence P&G Primary and General
EAP Employment Assessment Process PEF Public Engagement Forum
EIA Environmental Impact Assessment PEP Project Execution Plan
EMP Environmental Management Programme PFM Project Management Framework
EMPr Environmental Management Programme PFS Pre-Feasibility Study
Report PMF Project Management Framework
EMS Environmental Management System PMLs Post-mining Land-uses
ESHIA Environmental, Social and Health Impact QRA Quantitative Risk Assessment
ESHMP Environmental, Social and Health RACI Responsible, Accountable, Consulted and
Management Plan Informed
FIFO Fly In and Fly Out or First In is First Out SEAT Social Economic Assessment Toolbox
FOS Factor of Safety SED Socio-Economic Development
FRD Fine Residue Deposit SEP Stakeholder Engagement Plan
FS Feasibility Study SHE Safety Health and Environment
GIS Geographic Information System SHIRA Social and Human Rights Impact and Risk
GM General Manager Analysis
HIA Health Impact Assessment SHR Safety and Human Resources
HMP Health Management Plan SIA Social Impact Assessment
HRA Health Risk Assessment SIOM Sishen Iron Ore Mine
HR Human Resources SLP Social and Labour Plan
I&APs Interested and Affected Parties SMART Specific, Measurable, Attributable, Realistic and
Time-framed
ICMM International Council on Mining and Metals
SMP Social Management Plan
ICPS Integrated Closure Planning System
SPON COM Spontaneous Combustion
ID Investment Development or Identifications
SPV Special Purpose Vehicle
IDM Investment Development Model
SoW Scope of Work
IDP Individual Development Plan
SWOT Strengths, Weaknesses, Opportunities
IT Information Technology
and Threats
IUCN International Union for Conservation
TSF Tailing Storage Facility
of Nature
WBS Work Breakdown Schedule
KPI Key Performance Indicator
WRD Waste Rock Deposit
KT Kepner Tregoe
ZoI Zone of Influence

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Helena Tailings Dam facility, South Africa.

Anglo American
20 Carlton House Terrace,
London,
United Kingdom,
SW1Y 5AN
www.angloamerican.com

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MINE CLOSURE

ANGLO AMERICAN MINE CLOSURE TOOLBOX EXAMPLES VERSION 3 a

Mining plays a significant role in human and economic

The updated Mine Closure Toolbox (MCT) (v3) has

For more information contact: EXAMPLE 7: REHABILITATION STRATEGY

or EXAMPLE 11: KEPNER TREGOE

EXAMPLE 15: QUANTITATIVE RISK SIMULATION

Designed and produced by Creativity EXAMPLE 16: EXECUTION PLANNING AND

EXAMPLE 17: WORK BREAKDOWN STRUCTURE 126

EXAMPLE 18: DEMOLITION PLAN 136

EXAMPLE 19: CLOSURE MAINTENANCE AND

EXAMPLE 20: SUGGESTED STRUCTURE

ANGLO AMERICAN MINE CLOSURE TOOLBOX EXAMPLES VERSION 3 1

EXAMPLE 1: ESTABLISHING THE ZONE OF

The Navigation Plant at Landau Collieries, South Africa.

INTRODUCTION that are directly due to the development (e.g. loss of

2 ANGLO AMERICAN MINE CLOSURE TOOLBOX EXAMPLES VERSION 3

24°0'0"W 26°0'0"W 27°0'0"W 28°0'0"W 29°0'0"W

GAME RESERVE Letlhakane

Water Resources Fence Livestock Farm Wildlife Management Area

Figure 1: Typical example of a Zone of Influence

ANGLO AMERICAN MINE CLOSURE TOOLBOX EXAMPLES VERSION 3 3

EXAMPLE 2: SWOT ANALYSIS

Mogalakwena North Concentrator, South Africa.

4 ANGLO AMERICAN MINE CLOSURE TOOLBOX EXAMPLES VERSION 3

INTRODUCTION diversification, good soil conditions, availability of good

ANGLO AMERICAN MINE CLOSURE TOOLBOX EXAMPLES VERSION 3 5

EXAMPLE 3: CLOSURE RISK ASSESSMENT

6 ANGLO AMERICAN MINE CLOSURE TOOLBOX EXAMPLES VERSION 3

The purpose of this example is to illustrate and highlight

The following key actions must form part of developing

The example on the next page shows the change in

It is recommended that only the consequence type with the

ANGLO AMERICAN MINE CLOSURE TOOLBOX EXAMPLES VERSION 3 7

LEGAL & REPUTATION/

ii Exposed tailings lead to air pollution from dust. 2 4 12

iii Geotechnical failure of tailings dam post closure. 3 3 13

iv Erosion from the revegetated tailings surface leads to sedimentation of 4 4 21

2. Pollution Control and Dirty Water Dams

ii Dam overflow or failure leads to soil contamination. 2 3 8

8 ANGLO AMERICAN MINE CLOSURE TOOLBOX EXAMPLES VERSION 3

LEGAL & REPUTATION/

1. Groundwater monitors to detect liner 3 1 6

ANGLO AMERICAN MINE CLOSURE TOOLBOX EXAMPLES VERSION 3 9

ii Geotechnical failure of WRD. 4 3 18

iii Failure of rehabilitation leads to dust issues. 1 3 4

iv Death or injury resulting from accessing WRD’s. 4 3 18

v Design and operational implementation for water contol is inadequate. 3 3 13

vi Over-dumping on WRD leads to increased rehabilitation costs. 4 4 21

vii Erosion from the revegetated WRD surface leads to sedimentation of 3 4 17

2. Low Grade Stockpiles

ii Erosion from closed rehabilitated stockpiles surface leads to sedimentation 2 4 12

10 ANGLO AMERICAN MINE CLOSURE TOOLBOX EXAMPLES VERSION 3

1. Geochemistry evaluated. 3 1 6 1. Review report on geochemistry of

1. Monitoring of rehabilitation and 1 2 2

1. Security during mining operational phase. 2 2 5

1. Preparation of WRD dumping plans. 3 3 13 1. Establish in-field marking system

1. Groundwater monitoring during 1 2 2

1. Groundwater monitors to detect liner 3 1 6

1. Geochemistry evaluated. 3 1 6 1. Review report on geochemistry of

1. Monitoring of rehabilitation and 1 2 2

1. Preparation of WRD dumping plans. 3 3 13 1. Establish in-field marking system

1. Groundwater monitoring during 1 2 2

1. Groundwater monitoring. 3 4 17 1. Post closure water balance

1. Pit Wall control - controlled blasting and 3 3 13 1. Install signage.

1. Develop asset disposal strategy. 3 3 13 1. Spread sale of houses out

1. Identify which roads are to remain and 2 2 5

1. Reshaping of areas to blend in with 2 2 5 3 2 9

1. Install necessary monitoring. 2 3 8 1. Develop and run model to

1. Dolomite (subsidence) risk management 3 2 9

1. Temporary diversion structures are 3 2 9

1. Water rehabilitated areas. 2 3 8 1. Water retaining strategy to enhace