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Submission to the Parliamentary Portfolio Committee on Water and Environmental Affairs

Submission to the Parliamentary Portfolio Committee on Water and Environmental Affairs. John Munro - CEO 28 th June 2011. Practical Steps being taken by Rand Uranium – 2008 to date. 1. AMD Treatment Plant Operations – Interim Measures

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Submission to the Parliamentary Portfolio Committee on Water and Environmental Affairs

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  1. Submission to the Parliamentary Portfolio Committee on Water and Environmental Affairs John Munro - CEO 28thJune 2011

  2. Practical Steps being taken by Rand Uranium – 2008 to date 1. AMD Treatment Plant Operations – Interim Measures • Partially treat an average of 12 ML/d of AMD from the Western Basin • Approximately 50% of the AMD discharge rate required to reduce to ECL • At maximum reliable capability of the AMD Plant • Maintained and optimised performance of this plant • Executed emergency measures on behalf of DWA March to June 2010. • Provided assistance to affected parties - alternative water sources, flood control • However RU is running out of capacity to continue even partially treating the AMD • Regular reporting and interaction with regulators on AMD and AMD Plant • Facilitated ongoing community awareness training and access to site by Civil Society , media and academia-total transparency Incurred costs in excess of R60m since December 2008

  3. Practical Steps being taken – 2008 to date 2. Secured the development of a Long Term Solution to the AMD • Supported WUC in development of a Long Term Solution • Supplied ongoing human capital into the solution • Championed the Implementation of a Long Term Solution and Action • September 2009 – Appeal to DWA regarding Long Term Solution - DDG level • December 2009 – Follow up appeal engagements - DDG level • March 2010– Hosted Minister Sonjica at AMD Site • March 2010 – Further DWA Workshop - DDG level and HoD’s of DWA and DMR • June 2010 – Presentation to Minister Sonjica re Long Term Solution • June 2010 - Long Term Solution tabled to new DDG • July 2010 –Presented and Hosted PPC on Water at AMD Site • July 2010 – Detailed Proposal Document presented to DWA on Long Term Solution • August 2010 - Hosted GDARD MEC for Environment • September 2010 – Presentation to IMC Team of Experts

  4. Practical Steps being taken 3. IMC Engagement • Presented position and proposals to IMC technical team in Sept 2010 • Prepared alternative short term treatment plan for Western Basin, in line with IMC recommendations released February 2011: • Expansion of RU AMD Treatment Plant Operations • Linkages to Mintails AMD Treatment Plant • Or Link to Central Basin • Presented ideas to DWEA, TCTA and National Treasury • Continued constructive engagement through various engagements, site visits and information provision • Continued operating the AMD Treatment Plant at R2.5 m/month

  5. Legal Position 1. Rand Uranium was formed in December 2008, • New company, which could not have undertaken the mining that caused the Western Basin AMD • RU does not operate UG mines in the Western Basin • RU’s operating mines are 20 kms away from the Western Basin and are not connected underground • RU acquired the property on which the AMD decants and on which the AMD Treatment Plant is located 2. Water Treatment Plant Governance 1. Directives • 2005 Directive – Expired in 2006, pre RU incorporation • 2009 Directive - RU appealed to Water Tribunal, DWA withdrew the Directive prior to the WT hearing • 2010 Revised Directive Issued • RU lodged an appeal with the Tribunal - November 2010 – Awaiting hearing date • Status in question (lapsed January 2011?) 2. Expended considerable financial and human resources on this matter • Ongoing engagement with DWA and local stakeholders regarding the AMD Treatment Plant pre and post IMC report • Rand Uranium continues ongoing partial treatment of AMD • THE AMD IS A LEGACY LIABILITY, WAS NOT CREATED BY RAND URANIUM

  6. Conclusion Rand Uranium : • Has and continues to undertake very costly partial AMD treatment operations • on a without prejudice basis, given RU did not create this problem • when few other parties were taking any action in the face of an ownerless crisis • Has undertaken extensive engagement with Government to argue for action • Has extensively supported the development and implementation of a SUSTAINABLE, EXTERNALLY FUNDABLE LONG TERM SOLUTION thus obviating long term liability disputes • Has proposed various short and long term measures to meet the needs identified in the IMC Report. • Has reached a critical decision point in the face of the rejection by DWA of the Long term WUC solution

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