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Workshop on Environmental Governance for mining

sector: Putting Policies into Practice.

15th May, 2018

National Environment Management Authority
Project Location:
▪ Kilimapesa Gold (Pty) Limited is a gold mining company registered in
Kenya and wholly owned by London based Goldplat Plc.
▪ The project is located in Lolgorien, Transmara Sub County of Narok County
in the southwestern part of Kenya.
▪ It is located about 360 km inland and the mining areas include MAINLY
Kilimapesa Hill around Lolgorian Township.
▪ The exact location is defined by coordinates 9865000 m N; 696000 m E.
Project Location:
It has two sites within Lolgorian area 7
kilometres apart. The original site has a
Carbon-in-Leach Gold processing capacity
of 25 tonnes/day and a tailings storage

The second site has a plant that processes

300 tons of ore per month with 6000 tons
Carbon-in –Leach Gold processing plant.

The ore body contains an average of 5 gm

per ton around Kilimapesa while the
remaining material will be rock

The gold resources are currently estimated

to be in excess of 650,000 ozs.

The Kilimapesa gold plant operations has

an EIA license issued by NEMA and have
submitted an EA for review.
The Project Activities:
• The project mining phase is restricted to only Kilimapesa Hill.
• It involves clearing of vegetation ahead of the area to be mined, stock
piling of top soil for further reuse in the revegetation of the adit and
road to the adit. Operations will be restricted to underground
operations including blasting and drilling.
• The ore from the underground mine will be transported through rail
wagons to the entrance of the adit and then loaded onto tractor trailers
which will ferry the bulk ore to the Kilimapesa plant where it will be
stockpiled awaiting processing.
• The next phase incorporates ore processing which will include the
crushing, grinding, and milling followed by gravity sedimentation,
cyanidization, carbon leaching and extraction of gold to a 85% purity.
• The slurry( might contain hazardous material such as cyanide,
peroxides, the fuels, oils and the tailings) will be conveyed to the tailings
dam that needs to be managed.
potential Impacts areas:
• Ground and Surface Water Impacts - Water sources and quality, Hydrology
and drainage
• Land use and Landscape Impacts - Soil and land
• Social and economic activities - Human settlements, Impacts of Mining on
• Biodiversity and Wildlife movement -
• Impacts on livelihoods – mining activities not adequately managed cause
degraded soils, water, biodiversity and forest resources;
• Impacts on Public health – hazardous substances and wastes in water, air
and soil can have serious impacts on public health;
• Impacts to cultural and aesthetic resources – mining projects can affect
sacred landscapes, historical infrastructures and natural landmarks
** Climate change considerations – large scale mining projects have the
potential to alter global carbon in at least the following ways – lost CO2 uptake,
CO2 emitted by machines and CO2 emitted by the processing of ore into metal;
• An incident was reported on the 27th January 2018 on an issue of contaminated
water discharge (liquid hazardous waste - a reddish liquid discharge substance
) from Kilimapesa pond that settled on some nearby open trenches.

mud tailings spilled across the wire mesh perimeter fence

Dam 2 is currently filled with mud Adits at Kilimapesa new site
sludge and part of the dam has been
damaged as shown below.
Closer scrutiny of the
dam shows poor
workmanship of the
tailings dam as well as
lack of de-sludging thus
overflow of the mud
sludge as shown.

Dam 3:
seepage of
mud sludge.
Identified Impact Proposed Mitigation Measure Ground Observation Compliance status
Water pollution from seepage Lining of the tailings dam The dams are not lined Low

Construction of seepage Trenches unprofessionally done

trenches No indication that the seepage water in the
trenches is collected
Collect and recycle water in No evidence that the water in the adjacent
seepage trenches lands is monitored

Monitor water in adjacent lands

Windblown dust and Not specifically addressed in the No mitigations measures prescribed or Nil
atmospheric pollution mitigation measure implemented
Water logging of adjacent land Employ sound engineering The dams construction do not conform to Low
design of TSF sound engineering design and their stability
Tailings erosion is not monitored
Continuous monitoring and
verification of dam stability

Tailing dam rupture

Poisoning of animals drinking Block access to tailings dam area The main dams have been fenced with a Low
water wire mesh but the trenches are accessible
Treatment of process water prior to open field.
to discharge There is also torn in some sections with
evidence of human pathways through the
visual effects interference. Re-vegetation and rehabilitation The soil from the dams is not spread out Low
in order to allow future use of but piled on the open field. There is visual
land effects

Landscaping and re-vegetation

The Authority's Rapid Response Unit (RERU) responded to the
incident on 28th January 2018 and after the ground inspection, the
team took the following action;
1. Issued a closure order for the Kilimapesa facility in the new plant
(the processing activity that generates the mud tailings) until the
proposed mitigation measures are put in place to the satisfaction of
the Authority,

The team also recommended that;

1. The dam construction designs to be submitted to NEMA for
verification and monitoring,
2. Immediate cleanup of the contaminated area outside the dammed
area be done, and
3. Closer monitoring of the Kilimapesa plants on quarterly basis where
full control audit is done to assess the integrity of pollution prevention
measures to avoid fatal incidents to human and animals
Mine Site Closure

▪ There is increasing need to provide for 'sustainability' of ecological and social

settings in which mines are developed, operated and closed.

▪ There is need to do more than 'Design for Closure', requiring that we also prepare
'Post Mining Sustainable Use Plans' for the mine site and affected area.

▪ This requires that all stakeholders be consulted in the preparation of mine

development, operations, closure and post closure sustainable use plans.
Mine closure considerations
In planning for closure, the following factors needs
to be considered:
(a) the public safety of the site;
(b) the stability of the site under a range of seasonal
conditions representative of that climate;
(c) the ecological system recovery at the site;
(d) Sampling and analysis of applicable parameters;
(e) the state of recovery in comparison to the
surrounding area;
(f) the aesthetic value of the site
Mine closure consideration cont..
(g) time scales to meet the required remediation level
will vary depending on the facility in question, the
magnitude of the operation, nature of the incident,
post remediation care and maintenance required;
(h) the compatible after-use plans of the site;
(i) involvement of stakeholders, project affected
populations and surrounding community
▪ Most of the existing mines (if not all) do not have closure
▪ Inadequate capacity for the preparation and monitoring of
closure plans;
▪ Some mines were closed without closure plan;
▪ There is limited Subject Matter Experts(SMEs) in the mining
• Community “gate-keepers” who influence and distort the
genuine public views and therefore the public consultation
• Political pressure/influence and associated investor rush
which might compromise technical inputs and the due
• Pressure on provision of Socially Uplifting Projects (SUPs)
Opportunities in mining operations
• Early Engagement with regulatory agencies
(NEMA/MoM/DOSHS etc) to understand the Statutory
timelines for issuance of Record of Decision (RoD).
• Adequate PAP and/or stakeholders
• Compliance with statutory requirements – RAP, Draft
Deposit Bonds Regulations - Closure Bonding
• Negotiate Compliance (Where applicable)
• Self- Regulation
• Development of mine closure plans as part of the initial
feasibility study of the project
▪ There is need to build adequate capacity among
the regulators in order to effectively regulate the
entire mining industry;
▪ All proposed mines should prepare closure
plans as part of the initial feasibility study of the
▪ There is urgent need to prepare closure plans
for the existing mines;
▪ The Government to provide restoration funds to
cater for restoration of abandoned mines where
the perpatrators are not known.
Recommendations cont..
▪ There is need for further training in the mining
industry in order to develop subject matter
experts (SMEs) within the various regulator
▪ Polluter pays principle to be applied in cases of
mine operations and closure
▪ Integration of the environmental assessment
tools into the mining cycle.
• NB: As regulators, we can NOT walk
away from a mine site