Environmental performance

Implats recognises that its mining, smelting and refining operations have an impact on the natural environment and the communities surrounding its operations. A comprehensive group management strategy is in place to minimise and mitigate these impacts and the risks associated with them.

Key features

• ISO 14001 certification in place at Impala Rustenburg and Springs, Mimosa and Zimplats
• Emission of sulphur dioxide (SO₂) per platinum ounce increased by 6%
• Direct and indirect greenhouse gas emissions considered and calculated
• Total water consumption increased by 11.7%; total consumption per platinum ounce was 1.8% up
• Total fresh water usage decreased by 12.3% while fresh water consumption per platinum ounce decreased by 20%
• 33.5% of water currently consumed is recycled internally; an additional 16.3% is treated effluent from external sources
• Total energy usage increased by 0.6%, but declined by 8.3% per platinum ounce produced
• Rehabilitation provision of R330.1 million

Policy and governance

At board level, the SHE Audit Committee oversees environmental issues, and environmental performance is reported to this committee on a quarterly basis. Measures to mitigate environmental impacts form a key component of the company’s mining licence applications and maintenance, with extensive permitting in place at all operations in line with relevant legislation. New legislative requirements are monitored on an ongoing basis to ensure that our activities are aligned and in compliance with these. No significant breaches of environmental laws, regulations or standards were reported within the group during FY2007, and no fines were imposed. Legal compliance audits were undertaken at Impala Rustenburg, Mimosa and Zimplats, and no major areas of non-compliance were recorded. A similar audit is planned for Marula in FY2008.

Furthermore, all the permits required for operations are in place or have been applied for. In particular, our Rustenburg operation submitted an Environmental Management Plan (EMP) and Environmental Impact Assessment (EIA) to the relevant authorities for the proposed 17 shaft and is finalising the EIA and EMP for the proposed smelter upgrade and expansion, while Marula has begun an EIA for the proposed Merensky project.

Our Precious Metals and Base Metals Refineries are currently concluding all the requirements necessary for the Phase II expansion, in line with the Record of Decision received from the local authorities in 2004. A scoping document for the next phase of expansion to produce 3.5Moz platinum has been submitted to the Gauteng Department of Agriculture, Conservation and Environmental Affairs as required by the EIA regulations.

Environmental management forms an integral part of site-based line management, with senior operational management aware of its responsibility for environmental matters. Environmental staff are employed at all operations to assist line management, and the environmental team based at Impala Rustenburg is available to provide assistance and guidance to the other operations within the group as required. Contractors to the group are expected to abide by our Safety, Health, Environmental and Quality (SHEQ) Policy and this forms part of the negotiated contracts with contractors.

Environmental management systems based on ISO 14001 (see box below) are in place, or are being implemented, at all operations. ISO 14001 certification was attained at our Rustenburg and Springs operations, at Mimosa and at Zimplats. Marula aims to start its external audit process in FY2009. Several standards and procedures were developed and definitions established at both a group and site level during the year in support of the environmental management system. In addition, closure plans have been developed for Impala Rustenburg and Zimplats.

Although the various operations may have site-specific policies in place, these are aligned with and guided by the group-level policy which is available on the company’s website. Impala Springs has also been audited by the International Responsible Care Initiative.

Incident reporting systems have been implemented at all operations although there are operational variations. As a rule, however, vigorous reporting is encouraged – even if there is minimal environmental impact – and a summary of incidents is provided to the SHE Audit Committee. At Impala and Marula, incidents are categorised into four levels depending on the nature of their impact, namely critical, high, moderate and low. The process followed at Rustenburg is outlined below.

ISO14001 certification

Operation		Date of ISO certification	Valid until	Certified by
Impala Platinum	Rustenburg	May 2003, recertified in June 2006	March 2009	DQS (South Africa)
	Springs	May 2000, recertified in August 2006	April 2009	Bureau Veritas, through UKAS
Marula		Marula is in the process of implementing an ISO14001 based EMS. The certification process is planned for FY2009.
Zimplats		SMC – October 2004
		Ngezi Mine – November 2005	November 2008	DQS (South Africa)
Mimosa		May 2007	April 2010	NQA Africa (SA)

Reporting incidents at Rustenburg operations

The Rustenburg Environmental Management System encourages the reporting of all incidents, even those resulting in minimal environmental damage.

A summary of the incidents recorded is submitted to the SHE Audit Committee on a quarterly basis.

The degree of severity of each incident is categorised according to one of four levels as outlined below:

Level of severity	Definition of levels
Critical	Severe or large extent of environmental damage High cost implications Major legal implications Significant implications for interested and affected parties (IAP)
High	Limited or localised environmental damage Cost implications Legal and IAP implications
Moderate	Environmental damage limited to mine site or adjacent land (provided this land is unoccupied) Cost implications Legal implications
Low	Environmental damage limited to immediate area Minor cost implications No legal and IAP implications

There are 24-hour hotlines in place at both our Rustenburg and Springs sites.

Rehabilitation liabilities and provisions (R million)

		Rehabilitation liability FY2007	Rehabilitation provisions FY2007
Impala*	Rustenburg	498.8	213.4
	Springs**
Marula*		63.1	21.1
Zimplats		102.2	87.3
Mimosa		11.6	8.3
Group		675.7	330.1

*	In accordance with accounting requirements.
**	There is no legislation in place to regulate rehabilitation liabilities for Impala Springs.

Performance during FY2007

While environmental priorities and the potential for environmental risk vary from site to site, broadly these can be categorised as:

• air and noise pollution;
• water discharge, and ground and surface water pollution;
• resource usage – water and energy;
• storage, handling and management of hazardous materials;
• waste management; and
• land management.

Air quality management

Air quality management is of particular importance in the areas surrounding our smelting and refining assets, located at Impala’s operations in Rustenburg and Springs in South Africa and at the smelter at Zimplats in Zimbabwe, and we have therefore intensified our efforts to reduce both dust and gaseous emissions.

The main gaseous emission from the smelting operation is sulphur dioxide (SO₂). Given our current expansion plans, limiting these emissions has been a significant area of focus at Impala and, during FY2007, an emission reduction strategy was embarked upon to ensure that requirements as specified by the National Environmental Management: Air Quality Act of 2004 are met, that visible emissions are minimised and that the occupational exposure of employees is limited.

Good progress has been achieved in recent years in reducing sulphur dioxide emissions at our Rustenburg operations, largely owing to the commissioning of the company’s sulfacid plant in 2003 and improvements in the availabilities and efficiencies of the acid and sulfacid plants. Total sulphur dioxide emissions per ounce of platinum produced declined again in FY2007, by 8.6% to 5.3kg per platinum ounce (FY2006: 5.8kg per platinum ounce).

At Impala Springs, the primary gaseous emission is also sulphur dioxide. Stack sampling has now been supplemented by the commissioning of two ambient monitoring stations which enables a better understanding and tracking of plant emissions. These stations continuously monitor PM10, SO₂, ammonia, NO₂, NO and meteorological conditions. The commissioning of the NO₂ scrubber and the upgrade of the ignition scrubber (which scrubs ammonia) were achievements during the year.

Delays have been experienced with the implementation of an air quality monitoring programme at Zimplats as a result of problems with the commissioning of equipment installed during the year.

At Impala Springs, ambient noise levels have been an area of concern and a comprehensive noise management plan is being developed. All major sources of noise were identified during the year and 71% of these have been brought into compliance with regulations.

Direct sulphur dioxide emissions in FY2006 and FY2007

		Total SO2 emitted (tonnes)		Total SO2 emitted per platinum ounce (kg)
		FY2006	FY2007	FY2006	FY2007
Impala	Rustenburg	10,863	10,990	5.79*	5.33*
	Springs	637.8	475.1	Not comparable with Rustenburg and Zimplats figures
Zimplats		4,587	7,820	50.7	81.8
Group		16,321	19,053	8.95	9.49

* Calculation included the Zimplats Pt ounces in matte; blended at the Rustenburg operations.

Rustenburg Smelter Expansion 2006-08 – treatment of smelter off-gases

A critical component of our Rustenburg smelter expansion programme is the treatment of smelter off-gases. As an expansion in smelter capacity will result in a greater volume of off-gases to be treated, gas treatment capacity has to be increased. It is also important to improve gas cleaning efficiencies in order to minimise air pollution and the occupational exposure of employees.

A number of off-gas cleaning processes were investigated, with a key requirement being a 65% reduction in sulphur dioxide per platinum ounce produced. The process selected involves an expansion of the existing gas-cleaning infrastructure, with the construction of two new lime-scrubbing plants for tail gases and fugitive gases. The project is currently under way at a cost of some R850 million and final commissioning is scheduled for December 2008. (The pollution abatement programme comprises around 50% of capital expenditure at R430 million.) More detail on the project follows.

Emission control strategy

Our smelter emission control strategy is based on three important aspects: ambient air quality standards, visual emissions and occupational exposures. It has to ensure that each of these aspects is catered for and managed. The process route selected for the treatment of off-gases had to ensure that:

• ambient air quality standards as specified by the National Environment Management: Air Quality Act will be met;
• visual emissions will be minimised as far as possible in order to improve and manage public perceptions of the smelter plant; and
• occupational exposure of employees will be minimised.

All of the above objectives had to be met at the increased smelter production rate. An important parameter which was used in the formulation of the emission control strategy is the amount of SO₂ emitted per ounce of platinum produced. This parameter is currently 5.8kg SO₂ per ounce of platinum, based on FY2006, but will reduce to approximately 2.1kg SO₂ per ounce of platinum after the implementation of the gas cleaning expansion. This represents a reduction of approximately 65%.

Lime processing option selected

A number of off-gas cleaning processes were thoroughly investigated and the lime processing option was selected. This entails an expansion of the existing gas cleaning infrastructure with two new lime scrubbing plants for the tail gases and fugitive gases.

Upgrading of sulphuric acid plant

The first stage of the project is the upgrading of the sulphuric acid plant capacity from the current 12Nm³/s to 15Nm³/s for the treatment of converter off-gas. This represents an improvement in converter primary suction of approximately 25%. No extra converters will be operated at any one time when the expansion is completed; this means that all the extra suction will translate into an improvement in suction on the converter primary hoods.

It is thus expected that primary suction will improve by at least 20% and that fugitive gas from the converters will be reduced.

New large dry electrostatic precipitator

The second stage of the project is the construction of a new large four-field dry electrostatic precipitator (ESP) for de-dusting of furnace off-gases. The new ESP replaces the three old small ESPs and will be large enough to treat the full off-gas volume from three operational furnaces running as high as 105MW, although the furnaces will typically run at a combined power of 90MW. More efficient and using the latest technology, the new ESP will be designed to reduce dust to levels lower than 30mg/Nm³.

Expanded Sulfacid™ Plant

The existing Sulfacid™ plant is to be upgraded from eight to twelve pots to allow for the treatment of off-gas from three operational furnaces as opposed to the current two. Several improvements will be incorporated into the expanded plant although overall efficiency of SO₂ removal will not be increased.

Tail Gas Cleaning

The next phase of the project will be the construction of a brand-new lime scrubbing plant for the treatment of tail gases from the expanded acid and Sulfacid™ plants. Instead of venting both tail gases as is the current practice, the tail gases will be combined and sent to a new Dynawave™ lime scrubbing plant for SO₂ removal. After this secondary cleaning step, clean tail gases will be vented to the atmosphere via the existing Sulfacid™ stack. The expected reduction in tails gas emissions will be in the order of 78%.

Fugitive gas scrubbing

The greatest problem in the smelter is that of fugitive gas emissions from the converters and furnaces. To address this, secondary fugitive gas capture hoods will be constructed around the three large Peirce-Smith converters in the aisle. The captured fugitive gas will be transported along a new fugitive ducting to a new Dynawave™ lime scrubbing plant for SO₂ removal. New secondary fugitive capture hoods will be constructed above all matte launders and above the ladles used for matte. The captured furnace fugitive gas will be transported along a new ducting to the same lime scrubber used for converter fugitives. It is conservatively expected that at least 50% of all fugitive SO₂ gases will be captured and fixated into gypsum. The effect of this can be seen in the accompanying diagram. The tail gas from this plant is vented to atmosphere via a new stack.

The advantages of the selected gas cleaning route include the following:

• this option is inexpensive compared with others;
• well-established, proven technology is utilised;
• the scrubbing system is simple and robust;
• excellent overall sulphur fixation efficiency (92%) will be achieved;
• there are potential markets for gypsum, the new end product;
• consumable consumption will be lower than it might have been so smaller storage and handling facilities will be required; and
• should it not be possible to sell the gypsum, it can relatively easily be stored or disposed of.

The diagram below is a basic flow sheet of the gas cleaning project.

The process route will address the three-pronged strategy with respect to SO₂ abatement (ambient conditions, visibility management and occupational exposure) at the lowest risk, optimal capital expenditure and operational expenditure, and will ensure stable operations. The table below lists the key indicators for this project.

Lime processing option

Sulphur feed into the smelter (tpd)	125
SO2 emissions from the smelter (tpd)	16-20
Sulphur fixation (%)	92
Capex	R348,633,797
Opex (R/month)	R933,261
NPV (total smelter expansion)	R159.6 million
IRR (total smelter expansion)	16.7%
Additional by-products
Sulphuric acid (tpd)	36
Sulfacid weak acid (m3/day)	90
Gypsum (tpd)	40

Accounting for greenhouse gas emissions

During FY2007, we undertook an internal evaluation of the risks and opportunities faced by the company in respect of climate change and conducted a preliminary greenhouse gas emissions audit.

While we do not foresee significant regulatory risks to our business in respect of emission limits or energy efficiency standards, we are committed to developing and implementing strategies that will see us become more efficient and conserve resources. A group policy is currently being developed and, once finalised, will be made available on our website.

The potential does exist for rising input costs, particularly given increases in water, electricity and fuel costs, and the risks to production caused by power and water shortages. However, these appear to be outweighed by the potential for increased demand for the group’s metals – platinum, palladium and rhodium – as a result of ever more stringent vehicle emissions legislation globally and as alternative fuel generation technology, such as hydrogen fuel cells, becomes a reality.

Climate change indicators

	FY2004#	FY2005#	FY2006	FY2007
Tonnes CO2 emitted
(direct CO2 emissions)*	411,026	411,641	405,430	396,252
Tonnes CO2 emitted
(indirect CO2 emissions)**	2,431,507	2,458,127	2,653,935	2,716,235
MWh of indirect energy
(electricity purchased)	2,486,203	2,513,422	2,713,635	2,777,336
GJ energy (direct)##	5,885,118	5,756,401	5,792,044	5,661,377
GJ energy (indirect)##	8,950,331	9,048,319	9,769,086	9,998,410

*	Refers to direct CO2 emissions as a result of fuel burning (coal, diesel, petrol)
**	Refers to CO2 emissions from electricity purchased
#	Excludes numbers from the Mimosa operations
##	Excludes Marula as comparable data for fuel consumption could not be provided

Water management

In line with its commitment to comply with standards and in recognition of water as a scarce resource, we are endeavouring to reduce water consumption, optimise the recycling of fresh water (which is dealt with below) and mitigate any negative impacts of its operations on local and regional water bodies.

The primary concern in respect of water pollution is the potential release of sulphates, chlorides and nitrates into receiving water bodies. Groundwater sampling is regularly undertaken at all operations, as well as sampling of surface water. A regional groundwater model developed in 2003 for our Rustenburg operations is updated annually.

Impala Springs is a zero effluent operation, but water had to be discharged to the local sewer during the year to maintain pond levels. A holistic water management plan is being implemented to maximise recycling and to control storm water in order to maintain its zero effluent status.

A project currently under way at Impala Rustenburg involves the conversion of the Rockwall dam (which is currently a return water dam that contains contaminated water from the tailings dam) into a clean water dam over the next few years by minimising discharges into this dam. Not only will this decision result in a reduction in the immediate environmental impact of the operation, but it will also reduce the environmental liability on closure. Capital expenditure of R50 million is planned for this project.

Total water consumption* (kl)

		FY2007	FY2006	% change
Impala	Rustenburg	24,608,446	23,402,953	5.2
	Springs	1,309,755	1,161,235	13.2
Marula		3,536,662	1,654,792	113.7
Zimplats		2,972,352	2,726,238	9.0
Mimosa		2,077,610	1,941,260	7.0
Group		34,504,825	30,886,478	11.7

* Total water consumed includes various sources of water (including fresh water and recycled water).

Internally recycled and externally treated effluent consumed (kl and % of total water consumption)

		kl recycled FY2007	% of total consumption	kl recycled FY2006*	% of total consumption
Impala	Rustenburg (internally recycled)	7,893,011	32.1	10,634,238	45.4
	Rustenburg (from externally treated effluent)	5,632,922	22.9	–	–
	Springs	456,792	35.1	305,895	26.3
Marula		1,227,010	34.7	886,012	53.5
Zimplats		1,147,584	38.6	725,301	26.6
Mimosa		834,062	40.1	–	–
Group		17,191,381	49.8	12,551,446	40.6

* Note that the water consumption data for FY2006 has been restated given the change in the definition of recycled water.

Minimising resources used – water and energy

The primary resources used (apart from rock mined) are energy and water, and programmes are under development to minimise the use of these scarce resources.

Water

In respect of optimising water usage, conservation programmes include the recycling of water within our own operations by drawing treated effluent into the processing facilities. Our Rustenburg operation has an agreement in place with the Rustenburg Water Services Trust for the usage of treated effluent. However, this facility was initially not able to deliver the planned 10 megalitres per day required, which has had an impact on the achievement of the reduced fresh water consumption targets. Rustenburg achieved a reduction of 5.2% in total water consumption and a 13.2% reduction in fresh water consumption despite this.

Total water consumption by the group in FY2007 increased by 11.7% and that of consumption per platinum ounce by 1.8%. However, fresh water consumption by the group decreased by 12.3%.

The effluent treatment plant at Impala Springs has reached full capacity and a capital project is currently under way to deal with bottlenecks at the plant.

Energy

Implats is a signatory to the DME’s Efficiency Accord in terms of which we have pledged a 15% decline in energy demand from 2000 to 2015.

At Impala Rustenburg during the year under review, a materials handling project which was commissioned in the drying section of the smelter resulted in a 10% reduction in coal consumption. It is our overall objective to improve energy efficiency year-on-year. All operations are expanding so a reduction in total energy consumption is not possible at this stage, however, improved energy efficiency remains a target.

Total energy consumption (which includes energy from all sources) rose by 0.6% to 15.7 million GJ in FY2007. Energy consumption per ounce of platinum produced decreased by 8.3% to 7.7GJ per platinum ounce produced.

Total energy consumed* (000GJ)

		FY2007	FY2006
Impala	Rustenburg	10,441	10,639
	Springs	2,789	2,569
Marula		472	419
Zimplats		1,468	1,456
Mimosa		491	480
Group		15,661	15,563

Waste management, and the management and rehabilitation of land disturbed by mining

We have a significant area of land under management – some 94,022ha in total as at the end of FY2007. None of our operations is located in protected areas or in areas of high biodiversity value, although red data species are located in the vicinity of the Marula operations and are catered for in Marula’s EMP. A biodiversity management plan is currently being developed for Impala Rustenburg.

Impala Springs is a corporate trustee of the Blesbokspruit Environmental Centre, just outside Springs. The centre, which provides environmental education to schools and communities, is located in a wetland site.

During the process of mining, significant amounts of ore (that is minerals-bearing material) and waste rock are brought to surface and processed to extract the precious metals. Waste rock and tailings (the slurry left behind when the minerals concentrate is sent on for further processing) are deposited on surface in waste rock dumps and tailings dams respectively. These dumps represent a potential source of ground and surface water contamination and we are currently investigating ways of minimising this impact. The rehabilitation process of the waste rock dumps will include landscaping and vegetation as appropriate to the area of operation and as appropriate to its designated land use.

Woodchips and sewage sludge from the Rustenburg operations continue to be collected for the manufacture of compost by Monontsha, a community-based business. This is then used in the rehabilitation of the tailings dam slopes. Impala Rustenburg is currently in the process of re-vegetating the existing two tailings dam complexes with some 34.3ha of 430ha.

Opencast mining areas at Impala Rustenburg and at Zimplats are also being rehabilitated as mining progresses. To date 108.2ha and 42.75ha have been rehabilitated respectively.

Waste management strategies have been implemented at all operations and a waste management module is being implemented as part of our SAP management programme which will assist in the improved management and minimisation of waste.

Closure plans have been compiled for our Rustenburg operations and for Zimplats. Mining at Zimplats’ Ngezi opencast operation will cease in April 2008.

The single largest waste stream generated by our Refineries in Springs is the salt generated by the Precious Metals Refinery crystalliser which came into full operation in February 2007. By the end of FY2007, a total of 2,656t had been disposed of. Test work is under way to determine an alternative to disposal.

In addition, a total of 726t of jarosite was disposed of at a permitted landfill site during the year. Jarosite is an iron-based waste product that remains after the PGMs and base metals have been leached out of the matter.

Objectives for FY2008

An overriding priority in respect of environmental performance is to achieve, maintain and where practicable, exceed compliance with all relevant laws, policies and guidelines.

An area of focus for FY2008 is the full implementation of an ISO 14001-based environmental management system across the group and the maintenance of external certification. In particular, certification of our Marula operations in line with ISO 14001 is planned for FY2009.

In line with the continuous improvement processes advocated by ISO 14001, specific targets for FY2008 include:

• improved energy efficiency across our group so as to meet the 2015 target of a 15% reduction in energy demand based on predicted energy consumption levels in 2000;
• a continued reduction in fresh water consumption by increased emphasis on recycling initiatives; and
• the continued reduction of sulphur dioxide and dust emissions from all group smelters and refineries.

It is also a key objective of ours to establish and maintain open and constructive relationships with all stakeholders in respect of environmental performance. The ongoing use of hotlines, open days and newsletters forms part of this, as does the rapid response to complaints by members of the public. An important part of this process is the training of management and employees, and indeed local communities, in respect of environmental awareness and their active engagement in any site developments; as well as the continued dialogue with and holding to account of contractors.