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Home > Safety & Sustainable Development > Environmental management systems

ENVIRONMENTAL MANAGEMENT SYSTEMS

All operations in the Group have environmental management systems (EMS) that comply with the ISO 14001: 2004 standard. This is an international standard for environmental management systems and is based on three key principles, namely prevention of pollution, compliance with relevant environmental legislation and continual improvement in performance. Achieving and maintaining ISO 14001 certification of an EMS is a way to demonstrate a company's commitment to manage environmental risks and impacts. Certification does not mean that there will be no environmental risks or impacts: it means that all operations have appropriate management systems in place to ensure compliance with the standard requirements, other operational procedures and applicable legislation.

All mines, smelters and refineries in operation in 2004 achieved their initial ISO 14001 certification of their EMS during that year. All those operations have maintained their certifications to date. Most operations were reassessed by an independent service provider DQS German Association for Certification of Management Systems (Proprietary) Limited during 2008, against the ISO 14001: 2004 standard. Only Waterval Smelter was not reassessed in 2008 owing to the reorganisation of the smelter into two entities, namely the smelter and ACP. It was decided, in conjunction with DQS, to postpone the reassessment to 2009. No major non-conformances to system requirements were raised at any of the managed operations assessed by the certification body. Minor non-conformances and numerous observations were, however, raised. These are managed by each operation until resolution and close-out.

The Mototolo concentrator achieved certification for the first time in June 2008. Twickenham Platinum Mine has reverted to being a project and will consequently not be certified during 2009 as previously planned.

It must be noted that one of our non-managed operations, Modikwa Platinum Mine Joint Venture, received a major non-conformance in their previous reassessment. In addition, the mine has decided to postpone further ISO 14001 audits due to the economic downturn. It is not a specific requirement for our joint venture partners to implement and maintain ISO 14001. Legal compliance with environmental obligations is mandatory.

MATERIALS

Bulk materials used include rock mined in underground and open-pit operations, and milling of the mined rock, liquid fuels, coal, grease and lubricants. Bulk-material use over the years is increasing because operations are continually expanding production. Key bulk-material use is illustrated here. Other materials include wood, chemicals and packaging. The Group does not currently use waste, processed or unprocessed, from external sources in any material quantities. The rock broken and mined figure for managed operations was 10% higher in 2008 than in 2007, mostly as a result of the development at Mogalakwena Section. Tonnes milled from managed operations increased slightly over the previous year. Major commodities usage, such as coal and fuel (diesel, petrol and paraffin), has decreased slightly year on year. Use of lubricating and hydraulic oils increased during 2008.

ENERGY

Energy is one of our material issues and has therefore been included in the 'Our Materials Issues' section here.

WATER

Water is one of our material issues and has therefore been included in the 'Our Materials Issues' section here.

BIODIVERSITY

The Group holds mining, surface and freehold rights over large tracts of land. Land owned, leased or where surface rights exist and which is under the direct management and control of the Group, comprises 51,334 hectares. This excludes the total surface area of the mining right areas as the Group does not control or manage these areas. The land altered for mining and associated activities is 15,136 hectares or nearly 29% of all land managed.

The Group currently mines from mainly underground resources, except at Mogalakwena, which is an open-pit operation. It is thus not possible to report annually on newly rehabilitated land as would be the case for opencast mining, as the pit is not rehabilitated concurrently with mining. There are still mined-out opencast pits at BRPM and Rustenburg. The rehabilitation of the Union open pit was completed in 2007, but the rehabilitation of the BRPM pit has not yet begun. The Rustenburg pit will not be rehabilitated at present as it may be used as a regional landfill site for the Rustenburg municipality once specific legal requirements have been met.

The Group has no operations in protected areas, such as IUCN (World Conservation Union) protected-area categories I to III, world heritage sites and biosphere reserves. The Madeleine Robinson Reserve, established by Amandelbult for habitat and species protection, is shown in the UNEP-WCMC database of protected areas as an IUCN category IV area. The reserve has also been declared by Birdlife Africa as an important bird area owing to the presence of the yellow-throated sandgrouse, which is on the IUCN's red list of threatened species. There are no other category IV overlaps at any other operation. However, Union also manages part of its lease area as a game reserve for species and habitat protection. Other current and future operations are located in areas with high concentrations of endemic plant species. The Der Brochen project, Mototolo Joint Venture, Modikwa Joint Venture and Twickenham Mine are located in the Sekhukhuneland Centre of Plant Endemism, a region with a high concentration of endemic plant species. The Group is committed to minimising the footprint required for efficient mining in these areas, to ensure that fully representative and sustainable examples of these habitats remain for future generations.

The Group is also involved in a number of alien vegetation eradication projects, community cleanups and biodiversity awareness-raising and training initiatives within local communities. Examples include:

• celebrating Arbor Day at most operations, to raise awareness of the importance of nature and of trees specifically;
• facilitating a snake-handling course at Amandelbult as part of implementing its biodiversity action plan (BAP) commitments;
• facilitating SAQA-accredited alien and invasive species courses for 10 members of the Moruleng village near Union;
• planting of indigenous trees at most operations on a continual basis;
• continued management of the biodiversity offset areas at Mogalakwena;
• training of 10 members of local communities near Mogalakwena Mine to become effective game rangers. They are now employed in the biodiversity offset areas; and
• the Waterval Smelter greening project.

Summary of potential environmental risks and impacts

Category	Examples of potential risks and impacts
Air	Activities causing excessive dust, gas and particulate emissions. Activities causing odours and excessive noise levels.
Biodiversity	Illegal fishing and hunting; illegal removal of wood; setting of snares. Disturbance of protected plants and animals.
	Proliferation of exotic vegetation.
Energy	Energy wastage, inefficient use.
Hydrocarbons	Spillage of fuel, oil, grease and lubricants. Incorrect storage of fuel, oil, grease and lubricants.
Land	Erosion caused by water and process spills, the establishment of unauthorised activities, and uncontrolled driving off existing tracks and roads. Veld fires. Topsoil handling, stripping and storage. Excessive footprint.
Hazardous substances	Spillage of chemicals and other hazardous substances. Incorrect storage and use. Inadequate training in use and storage of chemicals and other hazardous substances.
Tailings	Spillage/uncontrolled discharge of tailings caused by pipe and other failures.
Waste	Illegal dumping of scrap, domestic or industrial waste. Illegal dumping of hazardous waste. Inappropriate handling of waste. Littering.
Water	Leakage or spillage of process water. Illegal/uncontrolled discharge of effluent or process or stormwater. Exceedance of water-quality standards. Water supply and demand.

Note: The data and narrative in this section only include managed operations, including managed joint ventures. Data and descriptions of non-managed joint ventures are not included.

Each operation has compiled and is implementing biodiversity action plans based on its biodiversity risk profile. All aspects of the plans must be implemented by the end of 2009. Biodiversity action plans describe the objectives, programmes and targets for protecting and restoring native ecosystems and species in degraded areas. They have been integrated with the on-site environmental management system (EMS) at each operation. In 2008, Anglo American plc conducted a biodiversity action-plan peer review at BRPM. A review was also planned at Mogalakwena Mine, but had to be postponed owing to personnel capacity constraints. The review will now be conducted in 2009.

BRPM scored 58% in the 2008 BAP peer review. The score highlights that the mine is aware of the need for managing biodiversity, and has integrated some aspects of biodiversity management into its EMS. There is clearly room for improvement. To improve its score, the operation will have to:

• clarify the responsibilities for the management of the lease area with the local communities;
• comprehensively identify and assess the risks posed and the opportunities offered to the business by the loss or enhancement of biodiversity;
• adequately evaluate the business case for managing biodiversity based on risk and opportunity; and
• link the business case for managing biodiversity to managerial decision-making.

EMISSIONS, EFFLUENTS AND WASTE

Greenhouse gas emissions and climate change

Energy and climate change is a material issue and has therefore been included in the 'Material Issues' section included here.

Ozone-depleting compounds

Ozone-depleting compounds have been phased out at all major installations, but there are some minor installations in which these compounds are still present. These include some fire-fighting systems and domestic appliances used at the operations.

Persistent organic pollutants

The key persistent organic pollutants for the Group are polychlorinated biphenyls (PCBs), dioxins and furans. The Stockholm Convention requires that equipment containing PCBs must be phased out by 2025. Any PCBs recovered in the interim from such equipment must be treated and eliminated by 2028. Current in situ equipment, such as transformers and capacitors, may remain in place and operational as long as all reasonable steps are taken to prevent leaks. Some of the Group's transformers still contain PCBs. These will be phased out to ensure compliance with the Stockholm Convention.

Dioxins and furans are principally emitted from PMR during the incineration of general and process wastes. The incineration is not a continuous process. The installation of a new high-grade incinerator and an activated carbon absorption system at the PMR has been completed. The principal motivation for this installation was to reduce dioxin and furan emissions from the incineration of general and process waste. After initial commissioning, the system was functioning satisfactorily. Before performance testing was done in late 2007, it was necessary to replace the activated carbon. The results from the 2007 tests did not indicate the direct source of the dioxins and a second sampling campaign was undertaken in 2008. The results showed dioxins concentration at stack 584 at PMR of 1.35 nanogram threshold equivalency dry standard per cubic metre (ng TEQ ds/m₃) which is higher than the European Union limit of 0.1 ng TEQ/m₃ but within South African standards. PMR is investigating a pollution control system, in addition to the dioxin trap to capture excess dioxins before exiting stack 584.

Sulphur dioxide and particulate emissions

Key emitters of sulphur dioxide (SO₂) within the Group are the Waterval, Mortimer and Polokwane smelters, with minor contributions from RBMR and PMR.

Total SO₂ emissions (stack and fugitives) decreased by 16%, to 15.5 kt in 2008.

Total SO₂ emissions from Waterval Smelter increased by 46%, to 8.3 kt in 2008.

In terms of emissions for Waterval Smelter in tonnes per day, the average (16 tonnes per day) for 2008 remained below 20 tonnes per day until the end of September. The average emissions for the last quarter were 41.7 tonnes per day due to a breakdown on the tower plant which has been repaired. As a result, emissions for the last quarter were more than the scheduled process registration certificate limit of an average of 20 tonnes per day. SO₂ emissions from Waterval Smelter accounted for 54% of Group emissions in 2008.

SO₂ emissions at Polokwane Smelter decreased by 24% in 2008, despite production nearly doubling. The principal reason is that most concentrate smelted was UG2, which has a lower sulphur content than Platreef from Mogalakwena North. On average, 13 tonnes per day were emitted against the scheduled process registration certificate limit of 25 tonnes per day.

SO₂ emissions at Mortimer Smelter decreased by 67% to 2.1 kt in 2008. This smelter was shut down for four months during 2008. On average, six tonnes per day were emitted against the scheduled process registration certificate limit of 24 tonnes per day. It must be noted that the above quoted averages do not take the shutdown periods into account; the actual on-line daily average emissions would thus be higher.

The SO₂ emissions per total refined ounce of precious metal from managed operations decreased by 18%, to 3.6 kg in 2008.

The Rustenburg ambient-air-quality monitoring network currently comprises eight stationary monitoring stations, including the recently installed station at the Western Limb Tailings Retreatment plant. All stations continually record SO₂, particulate matter with an aerodynamic diameter of less than 10 microns (PM10) and meteorological data from all sources in the region. The results of these measurements are used in dispersion models to predict air quality conditions under various production scenarios. The results for seven of the stations are given in the table below (because the

eighth station was recently installed, no consolidated data for this station is yet available). The SO₂

hourly averaged exceedances against the South African National Standards (SANS) targets have increased since 2007 owing to the shutdown of the tower plant at the ACP complex. The tower section of the ACP acid plant, which treats low sulphur content gas, was temporarily shut down in June 2008 owing to safety concerns after an equipment failure. The construction material of some sections of the tower plant was changed following a detailed investigation, after which the plant was restarted at the end of August. The new parts installed also showed signs of failure after a few days of operation, leading to a decision to stop the operation again. Development of a superior, alternative material and design are in progress. The new equipment is expected to be installed and commissioned in February 2009. The remainder of the acid plant, which treats high sulphur content gas, is in operation, with high efficiencies to manage sulphur containment off-site.

The PM10 exceedances have decreased since 2007. This can be attributed to the dust suppression systems that have been installed at the Paardekraal and Hoedspruit tailings dams. The main dust sources include tailings dams, unpaved roads, crushers and coal-burning activities in the Rustenburg area, especially during the winter periods.

Polokwane Smelter has six ambient-air-quality monitoring stations, with one station intermittently offline owing to electrical faults. There were no exceedances of SO₂ and PM10 guidelines recorded in 2008. Polokwane Smelter will be implementing an improved data-capturing and reporting system during 2009, following an external audit undertaken using South African National Accreditation System (SANAS) requirements.

Rustenburg ambient-air-quality monitoring statistics for 2008

Monitoring station name	SO2 data capture (%)	Number of exceedances of SANS 1929 SO2 hourly average guideline (>134 ppb)	Number of exceedances of daily DEAT SO2 average guideline (>48 ppb)	PM10 data capture (%)	Number of exceedances of SANS 1929 PM10 daily average guideline (>75 g/m3)	Number of exceedances of DEAT PM10 daily average guideline (>180 g/m3)
Bergsig	85.1	9	0	75.9	8	0
Brakspruit	81.5	21	0	47.7	41	0
Hex River	85.4	5	0	83.7	14	0
Klipfontein	67.7	6	0	84.6	6	0
Mfidike	82.2	40	1	78.1	75	7
Paardekraal	81.8	39	0	78.0	67	1
Waterval	64.5	31	4	55.2	15	0
Total		151	5		226	8

In the past a visible white plume consisting of NH₄Cl used to be emitted intermittently from stack 578 at PMR. To reduce this emission, PMR has installed a scrubber system to remove the NH₃ before it enters the stack. Removing NH₃ from the chlorine-bearing vapours prevents the formation of NH₄Cl, thereby eliminating the white plume from the stack.

Dust fallout

Total dust deposition is determined at all operations in accordance with the ASTM D1739 standard test method for the collection and measurement of dust fallout. Dust fallout buckets are used as a first-line monitoring system. They consist of a cylindrical container half-filled with de-ionised water exposed for one calendar month (giving or taking three days). Known quantities of copper sulphate are added to each sampling bucket to minimise algae formation, and distilled water is added to minimise sample loss, particularly during episodes of high wind velocity. The bucket stand also has a raised ring to prevent contamination from perching birds. Each series of samples is analysed by external laboratories. The gravimetric results are compared to proposed guidelines for dust deposition as described in the SANS 1929: 2005, Edition 1.1. The guidelines set four levels of dust-fall rates (measured in milligrams per cubic metre per day), namely: residential, industrial, action and alert rates.

Although most dust fallout may be associated with dust generated at tailings dams, other sources – such as crusher plants and gravel roads – are also key contributors. Post-control risk assessments, completed annually for tailings dams, indicate seven dams with a high potential to generate nuisance dust. Five dams are at Rustenburg Section and two at Lebowa.

During the year the following key dust-related issues were reported:

• At Twickenham, one of the communities near the mine complained about excessive dust caused by ore transportation on gravel roads. A water truck was subsequently bought and is now used to water the roads to prevent excessive dust formation.
• At Rustenburg, there were two campaigns during 2008 to analyse dust fallout to determine the source contribution. The results have not yet been finalised, but improved dust-suppression measures are nevertheless being implemented at the Paardekraal and Hoedspruit tailings dams. These measures include irrigation systems on the beach parameters of these tailings dams. The Waterval tailings dam access roads are being sprayed with dust suppressant owing to excessive dust formation caused by the contractor vehicles hauling tailings from this dam to the cementation batching plants. The Rustenburg Section water truck is used to ameliorate dust on various mine roads at the operation.
• At Lebowa, the dust-fall rates within the residential and industrial ranges generally do not result in complaints from the public. However, action and alert ranges generally do result in complaints from the public and are therefore considered to be levels at which sources of excessive dust are investigated (if not known) and suitable mitigation measures instituted. To ensure up-wind and down-wind profiles of all major sources, additional monitoring points were installed in 2008.
• At Mogalakwena, new and existing roads are continually treated with Dust-A-Side to minimise nuisance dust from hauling and other mine transport.
• At BRPM, excessive dust was generated in the concentrator plant and thickener area as a result of the excavation for the IsaMills. A water tanker was used to ameliorate the dust formation.

Waste

Non-mineral, non-hazardous waste sent to landfill

Even though waste separation, sorting, recycling and disposal procedures are in place at all operations, these are not uniformly implemented and managed. As a result, waste management remains a concern at some operations and should remain a top priority at these operations during the next few years. Just over 26.1 kt of non-mineral, non-hazardous waste were sent to landfill during 2008.

Non-mineral hazardous waste sent to landfill

Hazardous waste management improved in 2008, but there are still some areas that could be improved on in conjunction with third-party service providers. Hazardous wastes include oils, grease, fluorescent tubes, medical waste and chemical containers. Around 13.7 kt of non-mineral hazardous waste went to hazardous waste landfill during the year. Some 22.6 tonnes of medical waste were incinerated, while 32.4 tonnes of non-hazardous waste were incinerated during the year.

Anglo Platinum does not transport, import or export any waste deemed 'hazardous' under the terms of the Basel Convention annexes I, II, III and VIII.

Mineral waste

Mineral waste – accumulated tailings

The Group has 16 active tailings dams, six dormant dams, two dams where remining is taking place and two dams that were under construction in 2008 (excluding non-managed joint-venture tailings dams). Although the remining of Ivan Dam A at Union Mine was already completed in 2007, the rehabilitation of the footprint of the dam has not yet begun. Mineral waste accumulated in active and inactive tailings dams includes all accumulated tailings from the concentrator plants and the co-disposal of excess slag from the Waterval and Mortimer smelters. The Klipfontein tailings complex is currently being reprocessed through the Western Limb Tailings Retreatment plant. The tailings from this plant are sent to the new Hoedspruit tailings dam. Bi-annual aerial inspections of all tailings dams are conducted and each tailings dam is subjected to a third-party audit. Pre-control risk assessments indicate seven dams with a high risk of loss of life should they fail. However, post-control risk assessments indicate medium risks at only five dams. The identified risks at these dams are potential excessive dust fallout, not loss of life. All other dams are rated as having low post-control risks.

Mineral waste – accumulated waste rocks

Just under 93% of Anglo Platinum's accumulated waste rock is in dumps at Mogalakwena. Rock dumps are generally not revegetated, as this would require enormous quantities of topsoil, which is not readily available in the mining areas. The waste-rock dumps of the Richard and Spud shafts at Union are being remined and sent to the Mortimer concentrator for reprocessing. The rock dumps are also a resource in many areas, as they are used for road construction. Aggregate production and HDSA companies have been given the contracts to process this waste rock, creating local employment opportunities.

Some of the slag produced at Waterval Smelter is disposed of together with tailings on the Paardekraal tailings dam, while a portion is supplied to a third-party company for sandblasting purposes. There is a historical slag dump at Mortimer Smelter, and new slag dumps are being created at Polokwane Smelter. The rehabilitation of the Mortimer slag dump has not yet been completed. The slag pads at Polokwane Smelter are designed to take cognisance of the potential environmental impact of seepage and run-off from the slag residue stockpiles, even though the slag could be considered inert. Slag at Polokwane Smelter is currently stored on a 2-mm-thick HDPE-lined area, known as the environmentally compliant pad. A five-year slag stockpile area has been designed and will eventually consist of five pads built progressively, covering approximately 10.5 hectares in total.

Anglo Platinum has also been working with the Council for Scientific and Industrial Research on a project to find alternative commercial uses for the slag as long-term storage on site is not feasible owing to the large volumes being produced. This project initially focused on slag only but was expanded during the year to include an evaluation of the feasibility of also using tailings in building and mining products. The project continued successfully through the year and has resulted in a matrix of prioritised products, including the building of the prototype of a housing system using these materials. Applications for the use of these materials in selected building products have been submitted to the relevant regulatory authorities. Entrepreneurial opportunities have been identified and bankable business plans are in progress for selected products. (Refer to here).

ENVIRONMENTAL COMPLAINTS AND INCIDENTS

Complaints

Eight formal complaints were reported in 2008, against 18 in 2007. Most complaints are the result of visual emissions from the smelters and refineries, and of dust fallout from various tailings dams. At Twickenham, complaints were received because the spring dried up as a consequence of mining activities. All formal complaints are logged and followed up.

Incidents

Level 1 incidents

The number of level 1 incidents reported was 3,442 for 2008, which indicates a reduction of 38% from the number reported in 2007. This drop is attributed mainly to reorganisation and personnel turnover (and consequently to less vigilant reporting) rather than a significant improvement in site conditions. Nevertheless, the Group still encourages level 1 incident reporting as it enables operations to focus on pollution prevention. Of all level 1 environmental incidents reported, 85% were classified as insignificant and 15% as minor in terms of the environmental impact caused. 'Insignificant' incidents are non-harmful, are localised with no off-site impact, have no regulatory non-compliance implications and are not accompanied by public concern or awareness. 'Minor' incidents may be potentially harmful, may have localised off-site impact, may entail minor breaches of regulatory issues and may draw local public attention.

Most environmental incidents are still caused by inadequate management of hydrocarbons (diesel, oil, grease, etc), non-mineral waste (domestic and hazardous) and water (leaks, discharge,

Anglo Platinum level 1 environmental incidents*

Air (8.8%) Biodiversity (1%) Energy (0.9%) Hydrocarbons (37.9%) Land (1%)

Other hazardous substances (6.0%) Slimes/Tailings (0.9%) Socio-economic (0%) Systems (1.4%) Waste (19.9%) Water (22.2%)

contamination). The chart below provides a consolidated view of the various categories of level 1 environmental incidents for the Group for 2008.

The number of hydrocarbon-related incidents made up 38% of all incidents in 2008. Hydrocarbon-related incidents include minor spillage and incorrect storage of fuel, oil, grease and lubricants.

The number of waste-related incidents increased marginally, from 19% of all incidents reported in 2007 to 20% in 2008. Despite this marginal increase, waste separation, storage and disposal can still be significantly improved at most operations. Waste-related incidents include: illegal dumping of scrap or domestic and industrial waste, illegal dumping of hazardous substances, incorrect handling of waste and littering.

The number of water-related incidents reported remained constant, at 22% of all incidents reported. Water-related incidents include minor leakage, spillage or wastage of water, uncontrolled discharge of water, seepage, leakage or spillage of sewage, inefficient clean and dirty water separation, and the silting of drains.

Level 2 incidents

Despite the fact that there were numerous discharges and spillages at operations during the year, only one of these spills was significant enough to be classified as a level 2 environmental incident. This incident occurred at Twickenham Platinum Mine.

Description of incident 1: Raw sewage overflowed from the septic tank at the Capital yard into a stream that discharges into the Motse River.

Cause of incident: The sewage system became overloaded owing to the increased numbers of people using the system during the mine ramp-up.

Action taken: The frequency of monitoring the level and pumping of the septic tank has been increased.

Residual effect: Negligible.

Level 3 incidents

No level 3 incidents were reported.

PRODUCTS

During 2008, Anglo American and the Imperial College, London, collaborated on a research project studying the impact of PGMs on human health and the environment. A final internal report, 'Platinum-group elements in the environment with reference to mining operations' was completed in November 2008.

COMPLIANCE

Anglo Platinum is not aware of any pending environmental litigation against its managed operations. No fines or non-monetary sanctions were imposed in 2008 for non-compliance with environmental regulations and permits.

All operations have approved environmental management programmes (EMPs) in terms of applicable legislation.

During the year, the Department of Water Affairs and Forestry and various authorities approved water-use licences for Lebowa, Twickenham and Polokwane smelters. Mogolakwena Section received its water-use licence during 2007. All other operations have applied for their integrated water-use licences, but these have not yet been approved. Conditions attached to the water-use licences are being implemented by the operations in a phased manner. The Lebowa licence, for instance, requires, inter alia:

• compliance with the mining charter and submission of an approved Social and Labour Plan by October 2009;
• discharge of water to Rapholo River to cease by 24 April 2009;
• seepage from earth dams and sewerage plants to cease by April 2009; and
• stormwater measures to be implemented by 24 April 2009.

All operations have access to relevant environmental legislation and to an environmental legal register, specifically designed to address issues of importance to the Group. All operations are also kept informed of changes in environmental legislation. However, environmental legislation in South Africa remains complex and fragmented between various government departments.

Environmental performance through environmental management programmes, against system standards and procedures, policy objectives, operational targets and legal requirements is assessed, audited and monitored through a mix of in-house and external parties. All operations were covered by environmental audits and assessments in 2008. The findings and action plans of all audits and assessment are captured in the electronic environmental management tool, IsoMetrix, and managed until close-out.

The Group appointed legal specialists in 2008 to undertake environmental legal compliance evaluations at Amandelbult Section, Union Section, Polokwane Smelter, Mogalakwena Section and Waterval Smelter. The intention of these evaluations was to indicate the non-compliance and potential non-compliance areas and issues at these operations so that proactive management steps can be taken to address issues timeously. The following areas for improvement were identified:

• Amandelbult: Finding against the requirements of the Mineral and Petroleum Resources Development Act, 2002 (MPRDA), regarding the timing of EMP performance assessments.
• Union: Finding against meeting certain conditions of the waste permit issued in terms of section 20 of the Environment Conservation Act, 1989 (ECA); finding against meeting some requirements of Government Notice 704 of the National Water Act, 1998 (NWA).
• Waterval Smelter and ACP: Finding against certain conditions of the provisional registration certificate issued in terms of Atmospheric Pollution Prevention Act, 1965 (APPA); finding against some EMP commitments approved in terms of the MPRDA; finding against authorisation provisions of the NWA regarding the operation of the ACP pollution control dam; finding against conditions of Exemption 1865B issued in terms of the NWA; finding against certain requirements of GN 704 of the NWA.
• Mogalakwena: Findings against some EMP commitments approved in terms of the MPRDA; finding against the 'Directions in terms of section 20(5)(b) of the ECA – the control and management of general communal and general small waste disposal sites'; finding against conditions of Water Use Licence 27059655, and various unauthorised water uses, in terms of the NWA.
• Polokwane Smelter: Findings against conditions attached to the provisional registration certificate issued in terms of APPA; finding against authorisation requirements under the NWA; finding against Record of Decision conditions issued in terms of the ECA and the National Environmental Management Act, 1998.

These findings are proactively addressed by the Group as it continually takes corrective action as and when findings are raised. The Group views these findings as key risk areas and continually takes corrective action.

TRANSPORT

The transport of concentrates to the various smelters and of furnace matte from the Polokwane and Mortimer smelters to Waterval Smelter is by road by third-party contractors. Transportation of products, such as copper, nickel, sulphuric acid and sodium sulphate, is by road and rail. Precious metals are transported by road or air to customers. The energy used by contractors' transportation of intermediate materials and final products is currently excluded from Group energy totals. Any spillage from transport contractors is cleaned up by the relevant contractor to the satisfaction of the Group and local authorities.

Energy used for organisational travel (road and air) is currently also excluded from total energy-use calculations.

OVERALL

The Group is monitoring total environmental costs, including staffing costs, at a consolidated level. This includes expenditure on monitoring; impact assessments and reports; public consultation for environmental reports; waste-management contracts; certification; auditing; and licence fees for electronic environmental management systems.

PROVISION FOR REHABILITATION AT CLOSURE

Each mine and plant annually estimates its expected total expenditure for the final rehabilitation and remediation of it operations in terms of the requirements of the approved EMPs and closure objectives. All relevant rehabilitation liabilities based on current assets and impacts were updated in 2008. The total undiscounted rehabilitation liability for the Group as at the end of 2008 was estimated to be R2,205 million.

Various trusts have been created to fund this estimated environmental closure liability at the end of the lives of the Group's mines. Contributions are determined on the basis of the estimated environmental obligation over the life of a mine, to a maximum of 30 years. The total amount in all the environmental rehabilitation trusts at year end was R475 million. The shortfall between this total and the undiscounted environmental rehabilitation liability for premature mine closure is funded by way of bank guarantees in favour of the Department of Minerals and Energy.