ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT OF

THE PROPOSED SMALL SCALE GOLD MINING AND

PROCESSING PLANT (HEAP LEACHING) AT IKUNGUMHULU
VILLAGE, SHILALO WARD, MISUNGWI DISTRICT IN
MWANZA REGION.
PREPARED FOR

DF METAL MINING LIMITED

P.O.BOX 112
KAHAMA-TANZANIA

SUBMITTED TO:
The National Environmental Management Council
Lake Victoria Zonal Office
PSSSF Front wing, 6th Floor, Plot No 17/1, 17/2 & 18, Kenyatta
Road
P. O. Box 11045,
Mwanza
Email: [email protected]

Website www.nemc.or.tz

PREPARED BY:
KELVIN THOMAS
REGISTERED ENVIRONMENTAL (EA/EIA) EXPERT
P.O.BOX6048, MWANZA–TANZANIA
TEL+255763985119
E-MAIL:[email protected]

April 8, 2025
 EXECUTIVE SUMMARY
DF METAL MINING LIMITED of P.O. Box112 Kahama –Tanzania is a private
company incorporated under companies Act, 2002 and given registration
number177686476. The company is also registered as a Taxpayer with TIN
(Tax identification number) 177-686-476 by Tanzania Revenue Authority. The
company is limited and a new venture intending to engage in mineral
processing activities. The company is proposing to establish the gold ore
mining and Heap leaching Plant which will process tailings as raw materials
from exiting small scale gold miners and from open cast mining at the site to
obtain gold. The company intends to establish gold mining and processing
plant project (Heap leaching) at Ikungumhulu Village, Shilalo Ward, Misungwi
District in Mwanza Region.

DF METAL MINING is expecting to conduct gold mining activities in 8 Primary

mining licenses namely PML0228MZA, PML0229MZA, PML0230MZA,
PML0231MZA, PML0232MZA, PML00822MZA, PML00823MZA and PML0317MZA
with total area of 72.28 hectares which were mined previously by small scale
miners. The 8 primary mining licenses are owned and licensed to JIKOMBOE
MINING IKUNGUMHULU of P.O. Box 112 Kahama-Shinyanga. The JIKOMBOE
MINING IKUNGUMHULU Company has entered a Mining Agreement with DF
METAL MINING LIMITED for technical support. The site for the proposed
development is legally owned by JIKOMBOE MINING IKUNGUMHULU Company.

The total investment cost for the proposed establishment of the

Project is about TZS 2,000,000,000 (Two billions Tanzania shillings)

The project will be implemented in three phases namely; construction,

operation and decommissioning. The construction phase has the following
components: Material mobilization, building and civil works, installation of
machinery, equipment and utilities, water and electricity. The operation phase
includes mining of Gold ore via open cut method and transportation of ore to
the plant area for processing activities. The decommission phase shall include
closure of the plant, dismantling of the equipment’s and rehabilitation of the
land to its original.

Currently, environmental legislations (section 81 of Environmental

Management Act, Cap. 191 and regulation 11 of The Environmental
Management (Environmental Impact Assessment and Audit)(Amendment)
Regulations, 2018, requires that, all proposed development initiatives, which in
i
one way or another may significantly affect the environment, be subjected to
Environmental and Social Impact Assessment (ESIA) study. It is from this
context, DF METAL MINING of P.O. Box 112 Kahama to carry out the ESIA
study, aiming at identifying, investigating and foreseeing the future negative
impacts emanating from the proposed project as well as providing mitigation
measures of those impacts. Besides legal requirements, TOR of this
assignment generally requires to undertake EIA study by following all relevant
procedures including undertaking scoping exercise.

This work examined potential impacts of the project on its immediate and
nearby surroundings in respect to all the phases of its construction, operation
and decommissioning. Likewise, aspects related to physical, ecological, socio-
cultural, health, safety conditions at the site and areas of its influences were
also examined by this study. The study applied combination of scientific and
qualitative procedures that currently dominate EIA studies and relevant
legislative framework governing the mining sector. Therefore, this report
presents results/outcomes of the EIA study of the proposed Gold ore mining
and processing plant.

METHODOLOGY OF THE STUDY

The methodology employed in conducting the ESIA study is in line with The
Environmental Management (Environmental Impact Assessment and Audit)
(Amendment) Regulations, 2018. The study was undertaken based on
checklists developed by consultants complimented by past experience of
similar EIA studies. The following methodology was adopted: Literature reviews
i.e. reviewing various reports, maps, documents and drawings of the proposed
project, consultation of stakeholders, Appraisal of physical and environmental
conditions of the project site and areas that might be impacted by the project
i.e. soils, hydrology, flora and fauna; Appraisal of land use and assessment of
other relevant socio-economic parameters.

POLICY, ADMINISTRATIVE AND LEGAL FRAMEWORK

In carrying out the Environmental Impact Assessment for the proposed Gold
ore mining and processing plant, various policies and Acts relevant to the
project were reviewed, namely; National Environmental Policy (1997);The
Mineral Policy (2009); Environment Management Act (2004); The
Environmental Management (Environmental Impact Assessment and Audit)
(Amendment) Regulations, 2018, Local Government (Urban Authorities) Act
( 1982), National Transport Policy (20030, National Water Policy (2002), The

ii
National Energy Policy, (2003), The National Policy on HIV / AIDS (2001), The
National Employment Policy (URT, 1997b), The National Land Policy (1995),
The National Investment Promotion Policy (1996), National Gender Policy,
(2000), Land Acquisition Act Cap 118 R:E 2002, The land (Forms) Regulation
2001, Urban Planning Act 2007, The Water Resources Management Act, The
Architects and Quantity Surveyor Act No. 16 of 1997, The Engineers
Registration Act, Cap 63, The Contractors Registration Act, Cap 235, The
Occupational Health and Safety Act No. 5 of 2003, The HIV and AIDS
(Prevention And Control) Act (2008), Land Act Cap 113, The Mining Act, Cap
123 and the Mining (mineral Rights) Regulations, GN. 01 of 2018 just to
mention a few.

RESULT OF STAKEHOLDER CONSULTATION

In this EIA study, the following stakeholders were identified and consulted
 Occupational Safety and Health Authority(OSHA Lake Zone -Mwanza
office);
 Lake Victoria Basin Water Board;
 Misungwi District Council;
 Fire and Rescue force;
 Government Chemist laboratory Authority;
 Residence Mines Office; and
 Village Executive Office.
During public consultation, major issues which were identified include: -Waste
generation, noise and air pollution, soil and ground water pollution, cases of
accidents, fire oubreaks and injuries, increased pressure on social services i.e
water and electricity, jobs creation, increase tax opportunities to both local
and central government and economic growth, development of mining sector
and business expansion.

DESCRIPTION OF THE MAJOR SIGNIFICANCE IMPACTS

The proposed project will generate a wide range of environmental and social
impacts from site preparation stages, construction phase to operation phases.
The impacts are of both positive and negative in nature. Most adverse impacts
will be of a temporary nature during the site prepartion and construction phase
and can be managed to acceptable levels with implementation of the
recommended mitigation measures for the Project. Ways of enhancing positive
impacts have been also suggested. Significant impacts are as shown below:

iii
Positive Impacts
 Enable the proponent to invest into the local economy of the region;
 Growth of local and national economy;
 Help to alleviate poverty as a spill over in supporting various other
investments within the project locality;
 Increased economic benefits to local communities to be obtained from
sale of goods and services;
 Revenue collection to local and national government;
 Increased business opportunities; and
 Improved security within the area.

Negative impacts
 Interference with the ground water system;
 Atmospheric release of gas and dust from the operating machines and
equipment’s;
 Alteration of the area’s potential resources;
 Ground vibration;
 Occupational health and safety of workers;
 Impacts due to Inadequacies in management of solid and liquid waste;
 Noise and Water pollution;
 Fire risks; and
 Spreading of HIV and other STIs in the region.

ALTERNATIVE CONSIDERED
The EIA procedure requires that an environmental investigation identify main
project alternatives for any proposed development during the EIA process a
number of alternatives were identified and analyzed in terms of their economic
and environmental cost and benefits. These are project sitting alternatives i.e.
best location for constructing the processing plant, alternative methodology
for the processing of Gold, whether to use Heap Leach, Carbon in Pulp Circuit
(CIP) or Carbon in Leach Circuit (CIL). The company has made decision to use
heap leaching method for gold recovery which is more effective and less cost
fully.

MITIGATION MEASURES AND ENVIRONMENTAL MANAGEMENT PLAN

The EIA identifies potential adverse environmental impacts and proposed
corresponding mitigation measures to minimize or prevent any adverse

iv
impacts. The environmental options to minimize or prevent the identified
adverse impacts suggested in this report are contained in the EMP. These are:

Noise and air pollution due to operating machines and equipments

 To mitigate this impact, the proponent shall ensure that proper
maintenance of machines is done as well as provision of mufflers and
ear plugs to workers.

Occupational health and safety of construction workers

 The following are the mitigation measures:
 Establish Workers Safety Management Systems;
 Formulate Occupational Health and Safety Policy;
 Use of water sprinklers to suppress dust during project implementation;
 Workers at the site will be provided with appropriate protective gears
such as boots, helmets, masks, etc;
 The contractor shall ensure that the Personal Protective Equipment are
used properly;
 Putting in place the First Aid Kit and there shall be a trained first aider on
site; and
 Proper storage and control of exprosives.

Occupational Health Hazards during operation phase

In order to offset occupational health risk to workers who will be working at the
mining and processing plant, protective gears such as masks, gloves and boots
will be provided and used appropriately.
Also the following measures will be taken:
 Establish Workers Safety Management Systems and formulate
Occupational Health and Safety Policy;
 Provide regular training to all staff on safety matters especially new
employees;
 Provide First Aid facilities and train some workforce on emergency
response measures;
 Provide regular medical check up for the workers;
 Draw up and establish health and safety regulations; and
 Formulating preventive measures for accidents and other human health
and safety hazards.

v
Impacts due to Inadequacies in management of solid and liquid waste
Inadequacies in collection and transferring of the solid wastes may lead to
littering and blockage of drainage system, consequently leading to
environmental pollution. To mitigate this impact the following measures shall
be taken:
 Avoid discharge of liquid and solid waste to the open environment;
 Proper handling, transportation and disposal of solid waste to designated
dumping site; and
 Proper design and management of tailings storage facility.

Degradation of environment due to alteration of the areas potential

resources
Implementation of the project will significantly change the landscape of the
project area, in order to minimize the impact, Proponent will make sure that
activities are confined to core areas where vegetation’s shall be cleared. Re-
contouring of land for landscape improvements shall be done at the site and
the top soil that will be stripped off as overburden will be kept aside and then
re used for restoration in already mined plots while the project is on progress.

Loss due to fire outbreak

Possibilities of accidents shall be minimised by observing operation procedures
(safety aspects) of the mining area and processing plant. All workers and new
recruits will undergo training on safety procedures to be observed in the
project area. The company will also install a full fire fighting system with fire
hydrants and portable fire extinguishers and alarm systems. Employees will be
trained on what to do in case of fire or other accidents. Also, the proponent will
ensure that regular testing of fire extinguishers and alarm system is done.

Spreading of HIV and other STIs in the city

Measures for mitigation of this impact include:
 Raising awareness of the dangers of the HIV/AIDS to workers and visitors
through seminars; and
 Rolling out voluntary HIV counselling and testing programs.

Pollution of the ground water

To minimize this impact measures such as confining activities to core areas,
planting grasses in open areas, scheduling and sequencing activities during
vi
run off rain season and proper handling of waste materials may reduce effect
of the proposed development to surface run off and improve ground water.

Environmental and Social Management Plan

This plan describes the mitigation measures, responsible agents, monitoring
parameters and frequency of their execution. The plan is proposed as one of
measures to help rectify the significant impacts as a result of the gold
processing project undertaking. This is therefore a working document, which
can be updated whenever new information is received or site conditions
change. Therefore, the environmental and social monitoring plans (ESMP) for
this project will be operationalized at a number of levels of the project phases.
It is based upon the anticipated impacts, required mitigation measures and
degree of follow-up (monitoring) required. It is also advisable that,
collaboration with different stakeholders at all levels in some aspects of the
project is very important. However, the main responsibilities lie in the hand of
the project proponent.

The proponent shall be responsible for overall implementation of the ESMP and
will establish an organizational structure with clearly defined lines of authority,
areas of responsibility and accountability. Assigned staff at the site shall be
responsible for day to day follow ups (supervision and liaising with key
stakeholders). The assigned staff’s primary responsibilities will be to ensure
that all project activities comply with applicable environmental and social
regulations and that ESMP commitments are honored. Also the proponent shall
ensure that qualified expertise is provided in a coordinated manner.

To a considerable degree, proponent will be responsible for implementing

mitigation measures but, in any case, the ultimate responsibility for ensuring
that environmental and social protection elements are being carried out
properly is of Ministry of Minerals, National Environment Management Council
and Misungwi District Council. Most of the predicted impacts can be reduced or
avoided through the application of sound mining and processing management
guidelines.

Environmental and Social Monitoring Plan

Monitoring is the long-term process that normally begins at the start of the
project and throughout the life of the project. Its purpose is to establish
benchmarks so that the nature and magnitude of anticipated environmental

vii
and social impacts are continually assessed. Therefore, monitoring will involve
the continuous or periodic review of mitigation activities to determine their
effectiveness. Consequently, trends in environmental degradation or recovery
can be established and previously unforeseen impacts can be identified and
dealt with during the project life. The monitoring plan in this report specifies
the type of monitoring; who will carry out monitoring and what other inputs
such as training are necessary.
The objectives of Environmental monitoring program are:
 To monitor the effective implementation during the implementation
phases of proposed mitigation measures;
 To confirm compliance with environmental, social and safety
legislation/regulations during construction;
 To control the risks and ecological/social impacts;
 To ensure best practices management as a commitment for continuous
improvement in environmental and social performance;
 To provide environmental information to community/stakeholders;
 To provide early warning signals on potential environmental degradation
for appropriate actions to be taken so as to prevent or minimize
environmental consequences;

COST BENEFIT ANALYSIS

The EIS presents an assessment of the project, in terms of negative impacts,
compared to the socioeconomic benefits that will not happen if the project is
not implemented. Environmental cost benefit analysis is assessed in terms of
the negative versus positive impacts. The potential benefits of the project, in
terms of financial and social benefit are substantial. Similarly, the
environmental impacts can be reasonably mitigated and the financial
resources needed to mitigate negative impacts, when compared to the
required investment, are relatively small.

DECOMMISSION (MINING AND PLANT CLOSURE) PLAN

The closure plan will be approached systematically, disturbed areas will be
restored to pre-operation conditions to the best extent possible, and
consideration will be given to desired end land uses throughout the closure
process. The objective of the closure process includes;
 To protect people from potential health and safety risks when accessing
the site after the plant closure;
 To protect the surrounding environment from the long term effects
resulting from plant activities and infrastructures; and

viii
  To return the project site and other affected areas to its natural condition
to the best extent possible.
 To properly remove and dispose all equipment’s and plant
infrastructures not needed beyond the end of the life of the plant
operation;
 To ensure long term chemical and physical stability of disturbed and
eroded areas and engineered plant components
 To ensure the effectiveness of closure activities through monitoring; and
 To implement both short term and long term erosion control and slope
stabilization on applicable disturbances.
Achieving all the above mentioned objectives needs that the closure plan be
sufficiently flexible to incorporate changes and alterations associated with the
plant operation plan. The plan proposed in this document is preliminary and
likely to be amended during the life of the plant.

CONCLUSION
The ESIA has been completed by describing the project characteristics and
identifying impacts and proposing corresponding mitigation measures. The
project proponent and other beneficiaries are eagerly waiting for a decision
from the council. If the council is satisfied that the proposed project shall not
have significant negative impacts on the environment and the community, or
that the information provided in this report discloses sufficient mitigation
measures, it may approve the project to continue. Most of the project negative
impacts can be mitigated to the acceptable level using the proposed
mitigation measures. Constant (s) involvement of all parties including the
proponent, government officials as well as local communities in the project will
be required to implement and monitor the mitigation measures.

In addition the company will hire a qualified Environmental Officer to monitor

the application and performance of the EMP as well as dealing with all other
environmental related issues which shall emerge during the project
implementation. Therefore based on these fact the company wishes to assure
the government and all relevant stakeholders that the proposed environmental
management and monitoring plan if appropriately implemented will safeguard
the integrity of the environment.

ix
 ESIA TEAM OF CONSULTANTS
Name of Position Profession Signature
Consultant
1 KELVIN THOMAS Bio-processing EA specialist
Engineer(Register
(Team Leader)
ed Environmental
Expert)

ESIA Experts Trainees

NON- Registered Experts

NAME Qualification Involvemen Signature
t

VIOLETH G BACHELOR OF ARTS IN TRAINEE

PALLANGYO GEOGRAPHY AND
ENVIRONMENTAL STUDIES
JUDITH INNOCENT BACHELOR OF ARTS IN TRAINEE
MAJURA GEOGRAPHY AND
ENVIRONMENTAL STUDIES
HALIMA ALLY BACHELOR OF SCIENCE IN TRAINEE
ABUBAKAR ENVIRONMENTAL
ENGINEERING
NEEMA DAMSON BACHELOR OF SCIENCE IN TRAINEE
MACHELE ENVIRONMENTAL
ENGINEERING
RAMADHAN SHABAN BACHELOR OF ARTS IN TRAINEE
MGALULA GEOGRAPHY AND
ENVIRONMENTAL STUDIES

x
 ACKNOWLEDGEMENT
The DF METAL MINING wishes to convey sincere appreciation to all key players
who in one way or another supported the completion of this work. Special
thanks should go to all the people who provided prompt assistance during the
whole period of consultancy. The Proponent specifically acknowledges all those
who consistently worked very closely with the consultancy team up to the
successful completion of the assignment.

xi
 TABLE OF CONTENTS
EXECUTIVE SUMMARY...........................................................................................i
LIST OF FIGURES...............................................................................................xix
LIST OF TABLES..................................................................................................xx
ABBREVIATIONS................................................................................................xxi
CHAPTER ONE......................................................................................................1
1.0 INTRODUCTION.......................................................................................1
1.1 GENERAL BACKGROUND........................................................................1
1.2 PROJECT OBJECTIVE AND RATIONALE..................................................2
1.3 OBJECTIVE OF THE ENVIRONMENTAL IMPACT STUDY......................3
1.3.1 Main objectives.....................................................................................3
1.3.2 Specific Objectives...............................................................................3
1.4 APPROACH AND METHODOLOGY OF THE STUDY........................................4
1.4.1 Communication with Stakeholders.......................................................5
1.4.2 Baseline Data and Information.............................................................5
1.4.3 Physical Environment...........................................................................5
1.4.4 Biological Environment.........................................................................6
1.4.5 Socio-economic Environment...............................................................6
1.4.6 Policy, Legal and Institutional Arrangement.........................................6
1.4.7 Impact Assessment...............................................................................7
1.5 REPORT STRUCTURE..................................................................................7
CHAPTER TWO.....................................................................................................9
2.0 PROJECT BACKGROUND AND DESCRIPTION...............................................9
2.1 Location and Accessiblity...........................................................................9
2.2 Project Site Description............................................................................10
2.3 Adjacent Land Uses..................................................................................11
2.4 LAND OWNERSHIP.................................................................................11
2.5 Geology and Topography.........................................................................11
2.5.1 Regional Geology................................................................................11
2.5.2 Local geology and mineralization of the Area.....................................13
2.6 RESOURCES ESTIMATION.........................................................................13
2.6.1 PRODUCTION PROJECTION..................................................................14
2.7 PROJECT ACTIVITIES DESCRIPTION...........................................................14

xii
 2.7.1 Mobilization Phase..............................................................................15
2.7.2 Construction phase.............................................................................15
2.7.3 Operation Phase.................................................................................17
2.7.3.1 MINING METHOD..............................................................................18
2.7.4 Decommissioning phase.....................................................................29
2.8 Utility requirements..................................................................................30
2.8.1 Water system.....................................................................................30
2.8.2 Power Supply......................................................................................30
2.9 WASTE MANAGEMENT..............................................................................31
2.9.1 Construction Phase.............................................................................31
2.9.2 Operation phase.................................................................................32
2.9.2.4 Management of Hazardous wastes..................................................32
2.10 Storm water Management......................................................................34
2.11 Waste rock dump......................................................................................34
2.12 CLOSURE PLAN.......................................................................................34
2.12.1 Process Plant..........................................................................................34
2.12.2 Open Pit..................................................................................................35
2.12.4 Waste Rock Dump..................................................................................35
CHAPTER THREE:...............................................................................................37
3.0 POLICY, LEGAL AND INSTITUTIONAL FRAMEWORK......................................37
3.1 INTRODUCTION.........................................................................................37
3.2 NEED FOR ENVIRONMENTAL IMPACT ASSESSMENT..................................37
3.3 RELEVANT POLICIES..................................................................................37
3.3.1 The National Environmental Policy (NEP), 2021....................................37
3.3.2 The Mineral Policy of Tanzania, 2009....................................................38
3.3.3 The National Land Policy (1997)............................................................39
3.3.4 The National Energy Policy (2003)........................................................40
3.3.5 The National Investment Policy (1997)..................................................40
3.3.6The National Employment Policy (1997).................................................41
3.3.7 The National Policy on HIV/AIDS (2001)..............................................41
3.3.8The National Transportation Policy (2003)..........................................41
3.3.9 The National Water Policy, 2002.........................................................42
3.3.10 The National Health Policy (2007)....................................................43
3.4 RELEVANT LEGISLATION AND REGULATIONS...........................................43
xiii
 3.4.1The Environmental Management Act, Cap 191...................................43
3.4.2The Land Act, Cap.113........................................................................44
3.4.3 The Land Use Planning Act, No. 6 of 2007..........................................44
3.4.4 The Occupational Health and Safety Act, No.3, 2003.........................45
3.4.5 The Water Resources Management Act No 11 of 2009 and its
amendment No.8 of 2022............................................................................45
3.4.6 The Tanzania Investment Act, Cap.38................................................47
3.4.7 The Employment and Labour Relations Act, Cap. 366........................48
3.4.8 The Public Health Act, No. 01 of 2008................................................48
3.4.9 The Mining Act, Cap 123.....................................................................48
3.4.10 The Fire and Rescue Force Act, Cap. 427.........................................49
3.4.11The Prevention and Control of HIV/AIDS Act No.28 of 2008..............49
3.4.12 The Village Land Act, Cap.114..........................................................49
3.4.13 The Workers Compensation Act, Cap.263........................................50
3.4.13The Standards Act, Cap 130..............................................................50
3.4.14The Local Government (District Authorities) Act, Cap.287................51
3.4.15The Contractors Registration Act, Cap. 235.......................................51
3.4.16 The Employment and Labour Relations Act, Cap 366.......................52
3.4.17 The Industrial and Consumer Chemicals (Management and Control)
Act, No.3 of 2003.........................................................................................52
3.5 THE REGULATIONS.................................................................................52
3.5.1TheEnvironmental Management (Environmental Impact Assessment
and Audit)(Amendment) Regulations, 2018................................................52
3.5.2 The Environmental Management (Air Quality Standards)
Regulations, 2007........................................................................................53
3.5.3 The Environmental Management (Soil Quality Standards)
Regulations, 2007........................................................................................54
3.5.4 The Environmental Management (Water Quality Standards)
Regulations, 2007........................................................................................54
3.5.7 The Environmental Management (Hazardous Waste Management and
Control) Regulations, 2021..........................................................................55
3.5.8 The Environmental Management (Solid Waste Management)
Regulations, 2009........................................................................................57
3.5 INTERNATIONAL AGREEMENTS, CONVENTIONS AND TREATIES................61
3.5.1 Africa Convention on the Conservation and Natural Resource (1968)
....................................................................................................................61

xiv
 3.5.2 Other Relevant convention to the proposed project...........................61
3.5.3 UNITED NATION CONVERSION TO COMBAT DESERTIFICATION (UNCCD)
62
3.6 INSTITUTIONAL FRAMEWORK...................................................................63
CHAPTER FOUR:.................................................................................................69
4.0 BASELINE CONDITIONS................................................................................69
4.1 INTRODUCTION......................................................................................69
4.2 METHODOLOGY OF CONDUCTING BASELINE STUDY.............................69
4.2.1 CRITERIA FOR BASELINE ENVIRONMENT STUDY.................................70
4.2.2 COMPONENTS AND PARAMETERS.......................................................70
4.3 PHYSICAL ENVIRONMENT..........................................................................71
4.3.1 Geographical and Administrative Location.........................................71
4.3.2 Climate...............................................................................................71
4.3.2.1 Climate............................................................................................71
4.3.3.2 Rainfall.............................................................................................71
4.3.2.2 Wind characteristics........................................................................71
4.3.3 Geology, hydrogeology, Topography and Soil....................................71
4.3.3.1 Topography and Geology................................................................71
4.3.4 Air Quality Measurements..................................................................77
4.4 BIOLOGICAL ENVIRONMENTAL OF THE PROJECT SITE..............................79
4.5 DEMOGRAPHIC CHARACTERISTICS...........................................................79
4.6 SOCIAL ECONOMIC ENVIRONMENT...........................................................79
4.6.1 Main economic activities....................................................................79
4.6.2. Road network....................................................................................80
4.6.3 Trade and commerce..........................................................................80
4.6.3 Mining.................................................................................................80
4.6.4 Energy................................................................................................81
4.4.5 Communication..................................................................................81
4.4.6 Water supply......................................................................................81
4.4.7 Sanitation services.............................................................................81
4.4.8 Solid wastes management..................................................................81
4.4.8 Health, education and other systems.................................................81
4.5 Waste management.................................................................................82
4.5.1 Solid Waste Management:..................................................................82
xv
 4.5.2 Existing Liquid Waste Management and Sanitation Situation.............82
4.9 Community Safety and Security............................................................82
CHAPTER 5........................................................................................................83
5.0 STAKEHOLDER CONSULTATION AND PUBLIC CONSULTATION.....................83
5.1 STAKEHOLDERS PARTICIPATION IN THE EIA PROCESS.............................83
5.2 STAKEHOLDERS IDENTIFICATION.............................................................83
5.3 PUBLIC PARTICIPATION PROCESS.............................................................83
5.4 IDENTIFICATION OF STAKEHOLDERS’ CONCERNS....................................84
5.5 STAKEHOLDERS AWARENESS...................................................................90
5.6 PROJECT RECEPTION AND ACCEPTANCE...................................................90
CHAPTER SIX:....................................................................................................91
6.0 ASSESSMENT OF IMPACTS AND IDENTIFICATION OF ALTERNATIVES...........91
6.1 INTRODUCTION.........................................................................................91
6.1 Approach for assessment of significance.................................................91
6.1.1 Classification of Environmental Impacts................................................91
6.1.2 Methodology used to assess the significance of impacts......................92
6.1.3 Direct and Indirect Impact..................................................................92
6.1.4 Magnitude of Impact...........................................................................92
6.1.5 Duration and Frequency.....................................................................92
6.1.6 Temporary or Permanent....................................................................92
6.1.7 Sensitivity...........................................................................................92
6.1.8 Probability...........................................................................................93
6.1.9 Potential for Mitigation..........................................................................93
6.1.10 Impact Significance.............................................................................93
6.2 MOBILIZATION/ PREPARATION/ CONSTRUCTION PHASE...........................96
6.2.1 Noise pollution due to movement of construction equipment..................97
6.2.2 Occupational health and safety of construction workers....................97
6.2.3Loss/disturbance of biodiversity due to vegetation clearance..................97
6.2.5 Increase pressure on environmental resources........................................97
6.2.6 Water (surface and ground) Contamination.............................................98
6.3 OPERATION PHASE...................................................................................98
6.3.1 Impairment of local air quality from dust and fumes..........................98
6.3.2 Losses and misuse of toxic chemicals due to theft of chemicals and
other inputs.................................................................................................98
xvi
 6.3.4 Potential for pollution of soils, surface and underground water from
chemical spills.............................................................................................99
6.3.5 Air pollution from release of noxious gases in case of fire.................99
6.3.6 Poisoning by hydrogen cyanide gas built-up in the store...................99
6.3.7 Health impacts from accidental spillage of cyanide from storage
facilities.......................................................................................................99
6.3.8 Health impacts to workers from acute exposure to cyanide............100
6.3.9 Potential impacts to wildlife from spillages......................................100
6.3.10 Potential for contamination of surface and groundwater from
spillage and seepage.................................................................................100
6.3.11 Contamination of sediments and down-gradient soils through
cyanide seepage........................................................................................100
6.3.12 Potential for surface and groundwater pollution from acid drainage
from processed tailings.............................................................................101
6.3.20 Contribution to government revenues............................................102
6.3.21 Support to local social services......................................................102
6.3.22 Employment and training...............................................................103
6.3.24 Economic development........................................................................103
6.3.25 Infrastructure development..................................................................104
6.3.26 Social conflict.......................................................................................104
6.3.27 Population movement..........................................................................104
6.3.28 Social welfare.......................................................................................105
6.4 DECOMMISSIONING PHASE.....................................................................106
6.4.1 Pollution of surface and groundwater (cyanide spills)......................106
6.4.2 Healthy hazards to workers from demolishing work.........................106
6.4.4 Increased sediments load from erosion............................................106
6.4.6 Loss of employment opportunity......................................................106
6.4.2 Socio-economic impacts related to decommissioning......................107
6.5 PROJECT ALTERNATIVE...........................................................................107
6.5.1 No Project Alternative.......................................................................108
6.5.2 Alternative site.................................................................................108
6.5.3 Alternative Design and technology...................................................109
6.7.3.3 Alternative Power Supply...............................................................109
6.7.3.3.1 National grid power....................................................................110
6.7.3.3.2 Solar Power.................................................................................110
xvii
 6.7.3.3.3 Generator...................................................................................111
6.7.3.4 Alternative Water source...............................................................112
6.7.3.4.1 Alternative 1: Tap water from RUWASA......................................112
6.7.3.4.2 Alternative 2: Rain Water Harvesting.........................................112
6.7.3.4.3 Alternative 3: Groundwater abstraction.....................................112
6.7.3.5 Waste Water Management Alternatives........................................113
6.7.3.5 Solid Waste Management Alternatives.............................................113
CHAPTER SEVEN:.............................................................................................115
7.0 MITIGATION MEASURES.............................................................................115
7.1 MOBILIZATION/ CONSTRUCTION PHASE.................................................115
7.1.1 Noise pollution due to movement of construction equipment................115
7.1.4 Potential for surface and groundwater pollution....................................116
7.1.5 Potential for health and safety impacts to workers..........................116
7.1.6 Loss of lives and property as a result of Fire break out..........................116
7.2 OPERATION PHASE.................................................................................116
7.2.1 Impairment of local air quality from dust and fumes........................116
7.2.2 Losses and misuse of toxic chemicals due to theft of chemicals and
other inputs...............................................................................................116
7.2.4 Air pollution from release of noxious gases in case of fire...............117
7.2.5 Poisoning by hydrogen cyanide gas built-up in the store.................117
7.2.6 Health impacts from accidental spillage of cyanide from storage
facilities.....................................................................................................117
7.2.7 Potential impacts to wildlife from spillages......................................118
7.2.8 Potential for contamination of surface and groundwater from spillage
and seepage..............................................................................................118
7.2.10 Impacts from explosives uses.........................................................119
7.2.11 Contamination of sediments and down-gradient soils through
cyanide seepage........................................................................................120
7.2.12 Health and safety hazards to workers............................................120
7.2.13 Increase of vehicular traffic............................................................120
7.2.14 Loss of lives and property as a result of Fire break out..................120
7.2.15 Impacts from acidic forming rocks.................................................121
7.3 ENHANCEMENT OF POSITIVE SOCIO-ECONOMIC IMPACTS......................121
7.3.1 Contribution to government revenues..............................................121
7.3.2 Corporate Responsibility...................................................................121
xviii
 7.3.3 Employment opportunity..................................................................121
7.3.4 Increased income by utilization of local resources...........................122
7.4 DECOMMISSIONING PHASE.....................................................................122
7.4.1 Health hazards to workers from demolishing work..........................122
7.4.2 Pollution of surface and groundwater...............................................122
7.4.3 Increased sediment load from erosion.............................................123
7.4.4 Loss of employment opportunities...................................................123
7.4.5 Contamination and impaired Environment.......................................123
7.5 ENHANCEMENT MEASURES OF POSITIVE IMPACTS.................................123
7.5.1 Income, skills and knowledge increase to local labourers................123
7.5.2 Enhanced income, employment opportunities and local business...124
CHAPTER EIGHT:..............................................................................................125
8.0 ENVIRONMENTAL AND SOCIAL MANAGEMENT PLAN.................................125
8.2 PERSONNEL RESPONSIBLE FOR THE IMPLEMENTATION OFTHE ESMP....125
8.3 ENVIRONMENTAL AUDIT PROCEDURES..................................................125
CHAPTER NINE:................................................................................................138
9.0 ENVIRONMENTAL AND SOCIAL MONITOING PLAN.....................................138
9.1 Baseline monitoring................................................................................138
9.2 Impact / effect monitoring......................................................................138
9.3 Compliance monitoring..........................................................................138
9.4 Mitigation monitoring.............................................................................139
CHAPTER TEN:.................................................................................................156
10. COST BENEFIT ANALYSIS...........................................................................156
10.1 FINANCIAL COST BENEFIT ANALYSIS....................................................156
10.2 COST STRUCTURE.................................................................................156
10.3 FINANCIAL EVALUATION.......................................................................157
Project’s Economic Valuation.....................................................................157
10.3.1 Cash Flow Analysis..........................................................................158
10.4 EFFECT ON THE LOCAL COMMUNITY....................................................158
10.5 INFRASTRUCTURE DEVELOPMENT........................................................159
10.6 ADVANTAGES FOR THE BROADER COMMUNITY AND COUNTRY...........159
10.7 ENVIRONMENTAL COST AND BENEFIT ANALYSIS..................................159
CHAPTER 11....................................................................................................160
11.0 PRELIMINARY DECOMMISSIONING PLAN..................................................160
xix
 11.1: INTRODUCTION....................................................................................160
11.2 PURPOSE AND CONTENT......................................................................160
11.2.1 Plan Purpose...................................................................................160
11.2.2 Plan Content...................................................................................160
11.3 PRELIMINARY PLAN...............................................................................161
CHAPTER TWELVE:........................................................................................165
12.0 SUMMARY AND CONCLUSION...............................................................165
APPENDICES....................................................................................................168

LIST OF FIGURES
Figure 2. 1 Topographical map of Shilalo ward scaled down from the national
level to ward level (Source: Arch Map, 2025)...................................................21
Figure 2. 2: Geology of Lake Victoria Gold Field (source: GEOSPHERE PRO
LIMITED, 2024).................................................................................................25
Figure 2. 3: Pit Optimization and Pit Design (source: Datamine)......................31
Figure 2. 4: Overall Slope Angle (source: Datamine)........................................32
Figure 2. 5: Overall Slope Angle (source: Datamine)........................................33
Figure 2. 6: Elution column and elector winning machine................................39

xx
 LIST OF TABLES
Table 4. 1: Water quality tests results.............................................................85
Table 4. 2: Average values of Particulate Matter (PM10) around the proposed
project site.......................................................................................................78
Table 4. 3: Average noise levels recorded at the proposed project site..........78
Table 5. 1: Principle stakeholders identified....................................................84
Table 5. 2: Stakeholder consulted, their views and responses........................85
Table 6. 1: Assessment of significance............................................................94
Table 6. 2: Assessment of significance in terms of exposure and Likelihood...95
Table6.3: Consequence Assessment according to score /
scale………………………………….96
Table 8. 1: Environmental and Social Management Plan for the proposed
mining project………132
Table 9. 1: Environmental and Social Monitoring Plan for the proposed mining
project............................................................................................................145

xxi
 ABBREVIATIONS
Ag Silver
AIDS Acquired Immune Deficiency Syndrome
ANFO Ammonium Nitrate Fuel Oil
APHA American Public Health Association
As Arsenic
ASM Artisanal and Small-scale Mining
Au Gold
BOD Biochemical oxygen demand
BoQ Bill of Quantities
CAP Chapter
CBO Community Based Organization
CCTV Closed Circuit Television
Cd Cadmium

xxii
CFC Chlorofluorocarbon
CIL Carbon in Leach
CIP Carbon in Pulp
Cl- Chloride
CO Carbon monoxide
CO2 Carbon dioxide
Cu Copper
Dbc Decibels
DFO District Fire Officer
DO Dissolved Oxygen
DOE Director of Environment
EA Environmental Audit
EATV East African Television
EC Electrical Conductivity
EIA Environment Impact Assessment
EM Electro magnetics
EMA Environment Management Act
EMO Environmental Management Officer
EMP Environment Management Plan
ESIA Environmental and Social Impact Assessment
ESMaP Environment and Social Management Plan
ESMoP Environment and Social Monitoring Plan

EU European Union
F- Fluoride
FM Frequency Media
GCLA Government Chemist Laboratory Agency
GN Guidance Note
GTA Greater Toronto Area
H2S Hydrogensulphide
HCFC Hydrochloro flourocarbon
HDPE High Density Polyethylene
HFC Hydroflourocarbons
HIV Human Immune Virus
HIV/AIDS Human Immune Virus/Acquired Immune Deficiency Syndrome
IDFC Intensity Duration Frequency Curve
IEC International Electro technical Commission
IRR Internal Rate of Return
ITV Independent Television
Kg Kilogram

xxiii
KVA Kilo Volt Amperes
KW Kilo Watts
LGAs Local Government Authorities
LOM Life Of Mine
LSM Large-Scale Mining
LVG Lake Victoria Goldfield
MEO Mtaa Executive Officer
MMS Maintenance Management System
MS Monitoring Station
N/A Not Applicable
NaCN Sodium Cyanide
NAFPA National Fire Protection Association
NaOH Sodium Hydroxide
NAWAPO National Water Policy
NE North East
NEMC National Environment Management Council
NEP National Environment Policy
NES National Environmental Standards
NESC National Environmental Standards Compendium
NGO Non-Governmental Organization

NH3 Ammonia
NHSDP National House and Settlement Development Policy
NLP National Land Policy
NLUPC National Land Use Commission
NO Nitrogen monoxide
NO2 Nitrogen dioxide
NO3 Nitrate
NPV Net Present Value
NTU Nephelometric Turbidity Units
ºC Degrees Celsius
OCN2 Cyanate
OHS Occupational Health and Safety
OPEX Operating Expenditure
OSHA Occupational Health and Safety Authority
Oz Ounce
PACD Plan of Action to Combat Desertification
pH Potential of Hydrogen
PM Particle Matter
PMC Project Management Consultancy

xxiv
PML Primary Mining Licence
PMP Probable Maximum Precipitation
PO4 Phosphate
PPE Personal Protective Equipment

PPM Parts Per million

PVC Poly Vinyl Chloride
ROM Run Of Mine
SCADA Supervision Control and Data Acquisition
SGS Societe Generale de Surveillance
SHE Safety Health and Environmental
SO2 Sulfurdioxide
SQM Square Meters
STIs Sexual Transmitted Infections
SW South West
TANESCO Tanzania Electric Supply Company Limited
TBC Tanzania Broadcasting Corporation
TBS Tanzania bureau of standards

TDS Total Dissolved Solids

TMA Tanzania Meterological Authority
ToR Terms of Reference
TSF Tailings Storage Facility
Tshs Tanzanian Shillings
TTCL Tanzania Telecommunication Company Limited
TZS Tanzania Standards
UNCCD United Nation Conversion to Combat Desertification
UNCED Nations Conference on Environment and Development
UNCOD United Nations Conference on Desertification
URT United Republic of Tanzania
US EPA United States Environmental Protection Agency
VEO Village Executive Officer
VPO Vice president Office
WB World Bank
WEO Ward Executive Officer
WHO World Health Organization
WSS Water Supply and Sanitation
Zn Zinc

xxv
xxvi
 CHAPTER ONE
1.0 INTRODUCTION
1.1 GENERAL BACKGROUND
DF METAL MINING LIMITED of Po Box112 Kahama –Tanzania is a private
company incorporated under companies Act, 2002 and given registration
number177686476. The company is also registered as a Taxpayer with TIN
(Tax identification number) 177-686-476 by Tanzania Revenue Authority. The
company is limited and a new venture intending to engage in mineral
processing activities. The company is proposing to establish the gold ore
mining and Heap leaching Plant which will process tailings as raw materials
from exiting small scale gold miners and from open cast mining at the site to
obtain gold. The company intends to establish gold mining and processing
plant project (Heap leaching) at Ikungumhulu Village, Shilalo Ward, Misungwi
District in Mwanza Region.

DF METAL MINING is expecting to conduct gold mining activities in 8 Primary

mining licenses namely PML0228MZA, PML0229MZA, PML0230MZA,
PML0231MZA, PML0232MZA, PML00822MZA, PML00823MZA and
PML0317MZA with total area of 72.28 hectares which were mined previously
by small scale miner hectares which were mined previously by small scale
miners. The 6 primary mining licenses are owned and licensed to M/S
JIKOMBOE MINING IKUNGUMHULU of P.O. Box 112 Kahama-Shinyanga. The
JIKOMBOE MINING IKUNGUMHULU Company has entered a Mining Agreement
with DF METAL MINING LIMITED for technical support. The site for the
proposed development is legally owned by M/S JIKOMBOE MINING
IKUNGUMHULU Company.

In line with the EMA of 2004, all projects, undertakings and activities that
may potentially have adverse impacts on the surrounding environment are
regulated by The Environmental Management (Environmental Impact
Assessment and Audit)(Amendment) Regulations, 2018, which were made
under sections 82(1) and 230(2)(h) and (q) of the Environmental
Management Act, Cap 191. The Regulations require that all projects,
undertakings and activities that may have potential adverse impacts to the
environment to be subjected to the EIA study before their commencement.
Therefore, the Company to comply with the above legal instruments
commissioned KELVIN THOMAS of P.O. Box 6840 Mwanza to provide
technical advice through undertaking Environmental and Social Impact
Assessment of their proposed Gold ore mining and processing project.

1
The study has been conducted as per section 81(1) and third schedule to
Environmental Management Act, Cap 191 and first schedule of the
Environmental Management (Environmental Impact Assessment and Audit)
(Amendment) Regulations, 2018.

The Consultants undertook scoping exercise to identify key stakeholders,

environmental issues and concerns requiring special attention during the
fully fledged environmental impact assessment study. The scoping was
conducted in from February to March, 2025 and involved both the field visits
and consultations with stakeholders as well as analysis of issues through
desk studies.

The scoping study culminated into Terms of Reference which were approved
by the National Environment Management Council (NEMC) (see TOR
Appendix 1).These ToR provided guidance under which the EIA assessments
were done. The ESIA study was conducted from January to March, 2025. The
Environmental Management Act, cap 191 and the The Environmental
Management (Environmental Impact Assessment and Audit) (Amendment)
Regulations, 2018, were observed in the ESIA study.

After screening, the project proponent was required to undertake a full EIA
study. As per The Environmental Management (Environmental Impact
Assessment and Audit) (Amendment) Regulations, 2018, scoping was done in
order to develop the Terms of Reference (ToR) for the EIA study.

1.2 PROJECT OBJECTIVE AND RATIONALE

The demands for commercial Gold around the globe are eminent. Gold
extraction methods are wide with advantages and disadvantages of each
specific technology.
The purpose of this project is to process 9.8 million tonnes of low grade ore
through heap leaching method and produce 42,532 kg of gold. Accordingly,
the process known as Heap leaching is a process commonly used in mining
to extract valuable metals such as gold, copper, and uranium from their ores.
It is a low-cost method that involves piling crushed ore onto a lined pad (the
heap) and then applying a leaching solution, usually a diluted cyanide or
sulfuric acid solution, to dissolve the desired metals from the ore. The
solution percolates through the heap, leaching out the metals, and then
collects at the bottom of the pad.

2
From there, the metal-laden solution is pumped to a processing plant where
the metals are recovered through further chemical or electrochemical
processes. Heap leaching offers several advantages which includes;
 Heap leaching requires less upfront capital investment compared to
conventional mining methods since it doesn't involve the
construction of extensive underground mines or complex
infrastructure;
 It often produces less waste and has a smaller environmental
footprint compared to traditional mining methods, as it typically
involves fewer disturbances to the surrounding ecosystem;
 Heap leaching is particularly effective for extracting metals from
low-grade ores that would not be economically viable to mine using
traditional methods.
The availability of ore from open mining which dominates the area has
become the major drive as significant percentage of gold remains within. The
proposed project is therefore, in line with the national development agenda
as it will create employment opportunities, enhance living standard of people
and generate revenue to the country.

The main objective of the proposed project is mining and processing of Gold
ore. Hence due to high investment cost JIKOMBOE MINING IKUNGUMHULU
has entered to a contract with DF METAL MINING for technical support.
Therefore, the project will be source of income to the proponent as well as
development catalyst to the country.

1.3 OBJECTIVE OF THE ENVIRONMENTAL IMPACT STUDY

1.3.1 Main objectives
The main objective of carrying out Environmental Impact Assessment is to
ensure that the potential impacts related to the ecological, social, cultural,
health and economic as well as physical environment are foreseen and
addressed during the projects planning, designing and implementation as
well as decommissioning stages. This further identifies measures to mitigate
or minimize the negative impacts, enhance positive impacts and propose
ways to improve the project sustainability. The findings of the study were
assessed by all stakeholders involved in the assessment. It is expected that
the ESIA will help to the decision making about the project and shape it so
that its benefits can be achieved and sustained without degrading the
environment and human health.

1.3.2 Specific Objectives

3
Part IV of The Environmental Management (Environmental Impact
Assessment and Audit) (Amendment) Regulations, 2018provides the general
objectives for carrying EIA, among others a list comprise the following:
 To identify environmental, social and economic impacts that will be
associated proposed gold project;
 To provide baseline information for subsequent environmental control
and future monitoring purposes;
 To assess the project alternatives;
 To assess the compatibility of the project with national and sectoral
policies and legislation potential impacts of the project on the cultural
and social economic environment surrounding communities;
 To provide mechanism, design and implementation procedures of a
project or undertaking so as to mitigate adverse environmental
impacts;
 Identifying pertinent policies and legislations relevant to the operation
of project and assess compliance status;
 To identify and propose mitigation measures that the project
proponent has to implement in order to improve her Environmental
Performance; and
 To prepare Environmental and Social Management Plan for the
proposed project in order to ensure compliance with applicable
national environmental laws, policies and regulations as well as
international management policies and practices.
1.4 APPROACH AND METHODOLOGY OF THE STUDY
The methodology used is in line with the Environmental Impact Assessment
and Audit Regulations, G.N. No. 349 of 2005. The study was undertaken
based on checklists complimented by past experience of the Consultants.

EIA study is an open participatory process and various methodologies were

used in undertaking this Environmental Impact Assessment based on what is
provided in The Environmental Management (Environmental Impact
Assessment and Audit)(Amendment) Regulations, 2018.This study followed
some procedures stipulated in the aforementioned regulation. The study
adopted the following approach: (i) review of secondary data on baseline
information (ii) review of policies and regulations, (iii) review of previous
meetings consultations with stakeholders, (iv) interviews with key
stakeholders, and (v) site visits at the project site to gather information and
data on various aspects of the project site. The methodology is detailed
below:

i. Site visit-Observation: this tool was very significant getting eye-

4
 contact information from the project characteristics; Site visit was
carried out in order to identifying key issues, assessing
environmental status and propose the level of compliance;

ii. Questionnaires and Checklist: this was used when approaching

different project stakeholders and key informants with intention of
obtaining their various views, concerns and suggestions with
reference to the proposed project in the areas of environment,
safety, health issues and social-economic matters;

iii. Literature Review: internet and physical library visit on relevant

National and International Standards, laws, policies and regulations
as well as baseline information was conducted; the aim being to get
self-satisfaction on the level of environmental performance of the
proposed project;

iv. Interview: this was done with street members and other key
informants living nearby the proposed project, but also to those
stakeholders who was not ready to present their concerns using
questionnaires and checklist;

v. Impact Assessment: Impact assessments were determined by

superimposing project facilities on to the existing environmental
conditions of the project site. This involved analysis of data for
identification, prediction and evaluation of foreseeable impacts, both
beneficial and adverse, of the proposed using checklists, simple
matrices and expert judgment; and reference to standards and
guidelines. The impact assessment includes three principle
components or steps, the identification of impacts, the evaluation of
significance, and suggestion of mitigation measures with preparation
of Environmental Management and Monitoring Plans and
consolidation of the findings in the Environmental Impact Statement.

The study adopted the following approach:

1.4.1 Communication with Stakeholders
Identification of stakeholders
The identification was based on the role and relevance of an organization,
group or individual to the proposed project. Some of the stakeholders such
as national authorities e.g. relevant Ministries/Departments/Agencies within
Ministry Minerals, Local Government Authorities (Misungwi District Council),
etc. were pre-determined based on the nature of the project, while others
and affected groups at the proposed project site and area of influence

5
unfolded as consultations went along. List of stakeholders is found in
Appendix 3.

Involvement of Stakeholders
The consultant ensured that all the concerned parties were given adequate
opportunity to participate in the scoping exercise. Different participatory
methods were used to involve the stakeholders. These included one to one
discussions and focus group discussions with individual stakeholder or
representative of an organization, and project affected people. In
establishing the views of the public concerning the project, notices were sent
to the local authorities of the area mainly Ward Office, and Village office.

Consultations with stakeholders revolved around the following issues: (i) land
issues, (ii) uses of the project area, (iii) stakeholders view on suitability of
project in relation to the existing situation,(iv) potential conflicts and
alternative scenario; (v) permit procedures; and available data and baseline
information.

Identification of stakeholders’ concerns

Through interviews, discussions and other communication channels the
stakeholders pointed out issues and concerns to be addressed during the
EIA. An issue rose by one individual or a group of people were cross-checked
by discussing it over with other groups (triangulation). Stakeholders’ views
were also sought on their acceptance or supportiveness of the project.

1.4.2 Baseline Data and Information

Environmental Consultants identified information that will be required for the
environmental impact assessment. The Information on the bio-physical,
socio-economic environment, institutional and legal regimes were collected
from a variety of sources, namely project documents and general literature
review, visual and inspection, expert opinion, consultations with selected
stakeholders and discussions with the company management.

1.4.3 Physical Environment

Information was gathered on the existing physical environment, particularly
as related to geology, topography, soils, drainage, water quality, air quality
and noise.

Geology, Topography and Soils

6
Information on the geology, topography, soils, was obtained by compiling
data from existing reports, and source agencies. Aerial photos, satellite
imagery and other published maps were also examined. Field work was
carried out to augment and verify existing information relating to geology
and soils and to obtain first-hand knowledge of the topography

Hydrology and Drainage

Surface and ground water characteristics were assessed using field
investigation as well as maps and data from previous reports.

1.4.4 Biological Environment

The status of the flora and fauna of the study area was determined by a
review of literature relevant to the area and field investigations.
Flora
The vegetative communities were identified and classified into community
types. Identification was carried out of dominant tree species. The vegetation
was identified and described for the property.
Fauna
Information on fauna was gathered from existing literature on reported
species as well as observations in the field. Observations were made
particularly to assess the presence of birds in the general area. Information
was obtained from locals in the area about the presence of any significant
specie.

1.4.5 Socio-economic Environment

Rapid field appraisal techniques in conjunction with desk research were
employed to investigations of the socio economic considerations within the
project area:
 Population and settlement characteristics
 Land uses and livelihoods
 Developments underway
 Infrastructures in place
 Water supply and other utilities
 Waste management practices
 Recreational activities .


1.4.6 Policy, Legal and Institutional Arrangement

Policy, legal and institutional arrangement were compiled from review of
documents: policies, legislation, guidelines and standards. Information and
data on local by-laws, institutional structures and mandates/authority were
7
obtained from Misungwi District Council and local government Council and
relevant committees.

1.4.7 Impact Assessment

This was done by superimposing project elements onto the existing natural
conditions of the project site. Environmental impacts were then identified,
their significance assessed and mitigation/enhancement measures proposed.
The consultants, used the below general criteria to evaluate significance of
the identified impacts. Criteria for significance include but not limited to the
following:
 Magnitude and likelihood of impact;
 Spatial and temporal extent;
 Potential to implement mitigation measures and controls;
 Likelihood and degree/timescale of environmental recovery;
 Value of the affected environment/social component;
 Level of public concerns; and
 Political repercussions of the project.

The scales of those negative and positive impacts that are likely to occur
were determined using a range of low, medium and high:
 Low positive;
 Medium/moderate positive;
 High positive;
 Low negative;
 Medium/moderate negative;
 High negative; and
 No apparent impact.
As the proposed activities will be within occupied village forest reserve area,
cumulative effects are likely to occur and have been given consideration in
the impact assessment as well as residual impacts that cannot be mitigated
against. The assessment considers contribution to local and national
environmental and socio-economic issues as well as global environmental
issues of air quality.

1.5 REPORT STRUCTURE

This report is organized in twelve chapters.
 Chapter one is on the introduction;
 Chapter two entails the project background and its description;
 Chapter three is on the policy, administrative and legal framework
within which the project will operate;

8
 Chapter four presents the baseline or existing conditions of the project
site, surrounding areas and area of influence;
 Chapter five entails Stakeholders’ consultations and public
participation;
 Chapter six deals with assessment of impacts and identification of
alternatives;
 Chapter seven deals with mitigation measures;
 Chapter eight present the environmental and social management plan;
 Environmental and social monitoring plan is presented in Chapter nine;
 Chapter ten is on resource evaluation or cost benefit analysis;
 Chapter eleven is on decommissioning: and
 The last chapter is twelve which gives the summary and conclusions of
the report.

9
 CHAPTER TWO
2.0 PROJECT BACKGROUND AND DESCRIPTION

2.1 Location and Accessiblity

The project is located about 30 Km from the Misungwi Distict Council. The
project can be easily accessible through Misasi-Kahama Earth road on the
left side, about 5 km from Shilalo centre.
Table 2.1: Co-ordinates points:
S/N LATITUDE LONGITUDE
0 -3.1482770 33.0804740
1 -3.1483400 33.0736930
2 -3.1556820 33.0735080
3 -3.1608720 33.0772300
4 -3.1575030 33.0806870

Figure 2. 1 Topographical map of Shilalo ward scaled down from the

national level to ward level (Source: Arch Map, 2025)

10
Plate 2. 1: Satellite image showing location of proposed project site
(Source: internet accessed - Google Earth, 2025).

2.2 Project Site Description

The proposed site was previously used by small scale artisanal miners
(JIKOMBOE MINING IKUNGUMHULU) who stopped their activities when the
proponent entered in to a contract with the PML owner. The site has natural
short and long grasses, sisal plant, small bushes and shrubs but currently,
there is ongoing clearance of site area. The area is not fenced and there are
temporary structures made of corrugated iron sheets (residential houses and
toilets). There are tailings ready for processing that were mined with the
previous user of the site, the tailings are to be processed by the proponent.

The site is characterized by different species both natural vegetation with

predominance of trees especially shrubs, sisal, short grasses, minyaa and
various indigenous vegetation. The soils of proposed site can be classified
into three major groups: (a) sandy soils derived from granite at northern
side; (b) red loams derived from limestone; and (c) black clay soils at
southern. At the site there are no traces of species that are rare and
protected. The zone adjacent to the location where the proposed project will
be located is used for agricultural, residential and undeveloped lands. The
site has plot area about 72.28 hectare.

11
 Plate 2. 2: The existing situation at the proposed mine and
processing plant site (Source: Consultant site visit: March, 2025)

2.3 Adjacent Land Uses

The project site is adjacent to undeveloped lands and farmlands on the
northern and eastern sides, and residential settings and small scale miners
on the southern and western sides.

Plate 2. 3: Adjacent land uses at proposed site for (Source:

Consultant: January, 2025)

2.4 LAND OWNERSHIP

The project is to be established and conducted in an area with 6 Primary
mining licenses namely PML0228MZA, PML0229MZA, PML0230MZA,
PML0231MZA, PML0232MZA and PML0317MZA with total area of 54.85
hectares which were mined previously by small scale mining company
(JIKOMBOE MINING IKUNGUMHLU). JIKOMBOE MINING IKUNGUMHLU of P.O.
Box 112 KAHAMA (who are the legal holder of the PML) has entered into
venture of technical support with DF METAL MINING LIMITED (refer in
appendices).
2.5 Geology and Topography
2.5.1 Regional Geology
The Lake Victoria Goldfield (LVG) of northern Tanzania consists of a
number of east-west trending linear, greenstone belts. The greenstone
belts of the LVG are separated by granite-gneiss terrains. The LVG is
considered the third largest gold producing area of Africa, surpassed only by
the Witwatersrand in South Africa and the Tarkwa region of Ghana.

12
Numerous gold occurrences have been identified in the LVG, and new
discoveries continue to be made. Since 1998, when the first mine (Golden
Pride) was commissioned, five additional large scale mines (Bulyanhulu,
North Mara, Buzwagi and Tuluwaka) have begun production and
Bulyanhulu are considered world-class deposits, together comprising in
excess of 35Moz of gold resources.
The greenstone belts comprise mafic volcanic rocks, pyritic sediments,
tuffs, banded iron formation (BIF) and iron formation, chert, and felsic
volcanics (in sequence). Collectively these rocks are known as the
Nyanzian Group. A metamorphism of Nyanzian group of rocks is generally
of lower to middle greenschist facies, and two major deformational episodes
have been interpreted. Amphibolite facies metamorphic rocks are
exposed in the western portions of the belt near Tulawaka Mine, but in
general higher grade metamorphic complexes are rare.
The greenstone rocks are considered to be of Archaean age having
geological and structural similarities to major gold districts in the
Canadian Shield and the Yilgarn Craton in Western Australia.
Gold mineralisation within the LVG occurs in a number of geological
environments, including: -
 Quartz veins within minor brittle lineaments, most commonly worked
on a small scale by artisanal workers due to their limited extent and
erratic gold distribution;
 Major ductile shear zones, such as at Bulyanhulu;
 Replacement of BIF and ferruginous sediments, such as at Golden
Pride and Golden Ridge; and
 Felsic (porphyry) hosted mineralisation, such as within the Rwamgaza
Greenstone Belt.
Regardless of the geological environment, it is accepted that structural
control on the emplacement of the mineralisation is critical. The following
structural features have proven to be important targets for gold
mineralisation:-
 Structural lineaments trending at 120º
 Flexures and splays to the 120º trend (such as at Golden Pride)
 Structural lineaments at 70º (such as at Golden Ridge) and
 Granite-greenstone contacts (such as at the Ushirombo and
Rwamagaza Greenstone belts) It follows that key aspects to any
exploration programme within the LVG, are identifying high potential
geological and structural environments consistent with the above.

13
 Figure 2. 2: Geology of Lake Victoria Gold Field (source: GEOSPHERE PRO
LIMITED, 2024)

2.5.2 Local geology and mineralization of the Area

DF METAL MINING Mining Project area dominated by sedimentary package
composed mainly of highly weathered Banded Iron Formation (BIF) which
cover central to NW part of the area striking in NW to SE direction, area also
covered with weathered cherts mostly around mineralized area specifically
on upper part of the mountain and reddish soil in lower elevated part of the
project area as shown in appendix 1. This reddish soil is typical weathered
product of BIF since it has magnetic nature and reddish colour due to
oxidation of iron present in BIF, the package is cut by NW-SE trending
sedimentary body which mainly dip in SW direction. Sedimentary packages
are complexly deformed (folded) as well as metamorphosed.

DF METAL MINING Mining Project noted to have mineralization associated

with BIF and silicified BIF. Cherts found between BIF and soil cover on the
project area. Also it is reflected to have mineralization controlled by
contact/shear zones structures between BIF and Chert.

14
2.6 RESOURCES ESTIMATION
Referring to the Geological report of the Geologist, the present Geologic
Resources at the area with Banded Iron Formation (BIF) as the primary ore

estimated resource of 𝟖𝟗𝟖, 𝟒𝟎𝟐.𝟏𝟗Ounces. The area presents significant

deposit has revealed promising indications of gold mineralization. With an

potential for economic extraction and contributes to the region's mineral

wealth.

The presence of BIF as the host rock for gold mineralization signifies
favorable geological conditions for the formation and concentration of gold
deposits. The distribution and characteristics of the ore indicate the
feasibility of extraction through appropriate mining methods.

Considering the nature of the deposit and the scale of the resource, an open-
pit mining method is recommended as the most suitable approach for
extraction. Open-pit mining offers several advantages including cost-
effectiveness, accessibility, and the ability to extract large volumes of ore
efficiently.

2.6.1 PRODUCTION PROJECTION

The average total material moved (ore and waste) is planned at
approximately 75,000 t/m of Run of Mine (ROM) ore, for the extraction and
production of gold bullion. it is expected that CAT 5130 class excavators, or
equivalent, will be used both for ore and waste production, though the actual
units may be different depending upon the final choice of management, it is
planned that waste will be mined on 10 - m high benches with the excavator
rigged as a face or backhoe shovel with a bucket capacity of 10.5m 3 whereas
in ore the benches will be sub divided into 5 m or exceptionally, 2.5m high.
Mining is planned to take place on two 12 - hours shift per day. Two run - or -
mine stockpiles, located close to the primary crusher, will be used for
blending and intermediate storage. Based on the average grade of 6.95g/t

4𝟗𝟖, 𝟒𝟎𝟐. 𝟏𝟗 Ounces of gold (Au) per year.

and working a maximum of 24 hours a day, it is expected to produce up to

Table 2. 2: Production Profile for the first 3 years: (Max.= 500,000tpawith

LOM=10Years)
Period(Year) 1 2 3
Waste(t) 300,000 300,000 300,000
Ore(t) 200,000 200,000 200,000
Average Grade(g/t) 6.95 6.95 6.95
TOTAL material 500,000 500,000 500,000
mined(t)
Stripping ratio 1:3 1:3 1:3
Mined Ounces (OzAu) 134,083.6 134,083.6 134,083.6

Note: Mining schedule (Max.=500,000 tpa and LOM=10Years)

15
2.7 PROJECT ACTIVITIES DESCRIPTION
The project will have several stages of development with different activities.
These stages will commence with mobilization, construction, operation of the
mine and processing plant and end with a mine closure (decommissioning)
phase, all of which will impact the adjacent environment. Activities that
impact the surrounding environment and social conditions are those that
affect the physical conditions (air, water and soils), biological conditions
(flora and fauna) and socio-economic and cultural conditions (employment,
infrastructure, community support, security, traditions, morality, economic,
etc.). Development of the proposed project will commence and continue with
the following detailed main stages.

2.7.1 Mobilization Phase

Mobilization of various construction materials will need to be undertaken
prior to commencement of construction. The major activities during the
mobilization phase shall include transportation of construction materials and
machinery from Dar – es – Salaam, clearing of the construction sites,
recruitment of labors and erection of temporary accommodation and stores
infrastructure.

2.7.2 Construction phase

This construction phase will entail carrying out development activities that
will facilitate a proposed mine and processing plant to operate. The
construction of the project infrastructure will entail clearing of vegetation
and removal of rubble (where surface mining is applied), drilling, blasting,
and further activities will include loading and hauling of blasted rock to the
stockpile or dumping on waste rock dumps. In order for the mine to operate,
the construction of support facilities will be required. These will include:

 Administration and staff Block

The mine accommodation camp is designed as a modular system which
allows configuration in the most appropriate format for use. If required, the
camp could provide additional office space.
There is constructed two building to save for staff accommodation and
administrative purposes. The firs block consists of 10 rooms, six toilets and
one kitchen. One room is a master bedroom consisting of a sitting room,
toilet and sleeping quarters, while the remaining rooms only consists of
sleeping quarters.
The second block consists of 21 rooms, 3 storage rooms, 3 bathrooms, 5
toilets, 1 kitchen, 1 S.R and 1 laboratory unit. Two rooms are master

16
bedrooms consisting of toilets and sleeping quarters while the 19 rooms are
for sleeping quarters only and will use the available 3 public toilets
The camp suitable for housing up to 50 persons during both the construction
phase, after construction phase be scaled back to be able to house
approximately 100individuals for the production phase.
 Security Office and Change House
The Security office and gatehouse will be located at the main site entrance.
The gatehouse consists of the following:
o Protection services office;
o Protection services search area;
o One Unisex Toilet; and
o One Turnstile.
This gatehouse will control all vehicles in and out of the plant.

 Plant Control Room

A dedicated plant control room will be located in a double container
arrangement. The top container will house the control room and the bottom
container will house one of the MCC units. The control room will house the
SCADA system and provide operators with an elevated view of the entire
plant.
 Heap Leach pad
The leach pad occupies approximately 150 x 150m. Maximum capacity of
the pad is 13162.5 m3 tons of ore. Capacity of stockpile was estimated by
average density of stacked ore to be 2t/m3 and stockpile height from the
pad liner to be 60m high. The leach pad shall consists of 300 mm compacted
clay base, 1.5 mm thick linear low density polyethylene synthetic liner
(LLDPE) and 600 mm layer of crushed rock cover.
 The Barren Solution Tank
This is where fresh solution is prepared i.e. quantities of water vs. cyanide to
require strength is done. The dimension of this tank is 6m by 5m. An
overhead supply pump will be installed to supply cyanide solutions in leach
tanks for the process and the cycle repeats itself.
 Carbon columns/Extractors
These are carbon columns with conical shape and will be made by steel. The
carbon sits above a sieve of stainless steel. The pregnant solution is
introduced from the tap and flow downwards through the carbon. The outlet
of the 1st column comes off the top edge height above the carbon fill to the
bottom of the next column.

17
  Smelting room
This is an operation unit that will be used to make a gold bar from the gold
sludge to obtain the final product (gold bullion). It will involve the use of
domestic gas and the addition of borax chemicals. It will be well designed to
allow natural air circulation and will be equipped with a fire extinguisher, an
extractor fan, and a fume pipe to collect all the fumes generated during
operation.
 Blasting room
This is the area where the process of adding sulphuric and nitric acid to the
gold concentrate will be done. The room will be well designed to allow air
circulation, an extractor fan will be installed to extract fumes from the acids,
and a fume pipe will be installed to collect all the fumes that will be
generated during the operation process. The pipe will be packed with
absorbent materials to absorb the fumes and it will be connected to a waste
water tank for collecting water drops from vapor.
 Gas storage room
This is a room that will be used for keeping gases that are to be used in the
operation process, and about 336 kg/month will be consumed.

 Access Roads within Processing Plant

The roads within the plant area will be stripped of organic material and
compacted, which will facilitate access to the requisite areas within the
plant. Drainage ditches and culverts will be created in accordance with the
requirements for site drainage.

 Mine Workshop
A suitable workshop will be established adjacent to the process plant to
enable repair of plant equipment. The workshop will be a steel frame
building equipped with overhead crane and will have bays for servicing light
vehicles. The workshop will have separate areas for mechanical and
electrical repairs. Provision will be made for oil separation of any water
leaving the facility. Offices for supervisory, workshop store, maintenance and
planning personnel will be provided in the form of a modular building
situated next to the workshop.

 Laboratory
The company will manage the laboratory form gold testing and plant
operation. The lab shall be set up in the administration buildings once the
new administrations facilities and camp are complete. This laboratory will

18
conduct all of the onsite test work for the processing plant and the grade
control.
 Security
The plant site will be enclosed within a security fence. Access to the plant
area will be via gates located on access roads to the site. Additional fencing
will be provided for further safety and security within process plant areas,
such as power plant, fuel storage, gold room area, transformers and
substations, as required. CCTV cameras will be installed at strategic locations
in the plant for surveillance purposes. The cameras will be integrated with
the plant’s overall network, which will be the responsibility of the security
manager.

 Magazine
The site will also consist of magazine for storage of Ammonium nitrate in a
large ANFO shed in 25 kg bags. The facility will be able to store up to 1
year’s supply of Ammonium Nitrate (maximum 250t).Detonators and
detonating cord will be stored in separate magazines on the surface in
accordance with Tanzanian explosive storage regulations.

2.7.3 Operation Phase

The gold ore mining and processing will be of medium scale project. The
operation shall consist of three main sections which are grinding/ size
reduction, mineral leaching and gold extraction (elution process).

The operational phase will commence after development has been

completed and infrastructure to support the production operations is
commissioned. Production operations will include routine unit operations,
which are similar in nature for open pit mining method. These include:
2.7.3.1 MINING METHOD
The deposit from these prospects will be mined by open pit method,
stockpiled to be processed in the property area. Based on the infrastructure,
and depending on the outcome of the resource upgrade drilling program,
one open pit will be developed at Jikomboe before embarking on
underground mining. In future Geotechnical boreholes will be drilled to
further investigate ground conditions, prior to switching from open pit to
underground mining method.

Initially mineral exploitation of this deposit will initially be by open cut

methods using conventional shovel and truck method firstly as a pilot pit
operation expanding into a full scale open cut mining operation based on the
findings of the Definitive Feasibility Study. Drilling and blasting will be
19
performed on 10m high benches, with blasted material excavated in four
discrete flitches, each nominally of 2.5m height. The mining equipment
chosen to fulfill this schedule is a fleet of 3 Dump trucks of 20 tons each,
1Excavators of 3m3, 2 Bull Dozers and 2 Wheel Loaders. The sizes of
equipment proposed were chosen based on their flexibility around the site as
well as ease of their maintenance.

The use of RC drilling, assays every 2.5m sample and interpretation of the
results by mine geologists is the primary method of grade control envisaged
for the project. Further investigation is warranted with regards to optimizing
sample length and sample pattern to insure appropriate statistical
methodologies can be utilized to minimize dilution and maximize ore
extraction. A notional drilling pattern of 10m x 5m will be adopted for the
project during the production phase, with 115% of the expected ore zones
assumed to be grade control drilled, to ensure sufficient overlap into
adjacent low grade or waste such that is not missed.

The proponent will undertake and manage all mine planning technical
aspects, including geology, grade control, mine planning, drill-and-blast
planning, operational scheduling and performance management. The mining
operations are based on conventional drill-and-blast, load and haul mining
techniques. Loading of the ore and waste rock following drill-and-blast is
envisaged to be by hydraulic excavators in backhoe configuration into
nominal tonne haul trucks with 50% of the ore reporting directly to the
crusher tip and 50% to the ROM ore pad, and waste to the designated waste
dump areas. It has been assumed that the weathered portion of the ore and
waste will be free dig or require light blasting as it transitions to fresh rock
which will require blasting.

Overall Pit Design View

20
 Topograph
y (top of Pit Ramp
Main entrance ramp
Ramp Switchbacks

Pit Benches
Ore Body

Topography
(down of the
hill)

Figure 2. 3: Pit Optimization and Pit Design (source: Datamine)

Pit access roads will be designed and constructed to a nominal width of 10 m

with inclusive of safety berms and water drainage controls. A ROM pad
stockpile area will be constructed adjacent to the process plant crusher
station/tipping point and all ore stockpiled will be sorted under a stockpile
grade control management scheme. Stockpile reclaim will be undertaken by
a front end loader and fed to the crusher as required. All waste material will
be deposited either to the surface waste dump facility adjacent to the
boundary of the open pit or be backfilled in the mined-out pit areas,
depending on which facility is closest and available at the time of mining any
particular area and to suit the efficient scheduling of the mining fleet.

Bench width

21
Figure 2. 7: Pit benches designs (width and height (source: Datamine).
 Switchback/Curve Width and Gradient
Switchbacks is designed with an inside ramp string radius of 12.5mwith
width of 12m to give a minimum inside tire path radius of at least 150% of
the minimum turning circle inner clearance radius of the truck being used in
the pit. Flat switchbacks are recommended. Flat switchbacks provide the
least load on the trucks drive train, and in a mechanical drive truck will likely
still cause a gear change but this is at least fairly non aggressive. The overall
gradient of switchback designed to be 100.Gradient on the inside windrow
curve radius set to be flatter than the ramp grade by 20to compensate for
increased curve rolling resistance.

In our design there was no switchback from top to down of the pit due to
nature of ore and ramp designed.
The angle made with the horizontal of the line connecting the lowest toe to
the uppermost crest. In design the overall slope angle was 65°.

Slope angle

Figure 2. 4: Overall Slope Angle (source: Datamine).

Bench slope angle

This is the angle between the toe of a slope where a ramp segment passes
and the toe of a bench located immediately upwards. In this design the
bench slope angle used was 55° .

22
 Bench slope
angle

Figure 2. 5: Overall Slope Angle (source: Datamine).

 Open Pit Dewatering

It is assumed that no significant ground water will be encountered during
mining operations at the mine site due to high-elevation sitting of deposit.

Mine Scheduling
The mining schedule targeted of at least 1,080,000 tpa tonnes per year (tpa)
will go for at most 3 years (LOM = 3Years). This schedule (Table 2.6)
constitutes lowest risk factors that would facilitate establishment of a mine
producing at least 90,000 tonnes of ore for processing every month.

Table 2. 3: Proposed mine scheduling (Max.= 500,000tpawith LOM=3Years)

Period(Year) 1 2 3
Waste(t) 300,000 300,000 300,000
Ore(t) 200,000 200,000 200,000
Average Grade(g/t) 6.95 6.95 6.95
TOTALmaterialmine 500,000 500,000 500,000
d(t)
Stripping ratio 1:3 1:3 1:3
MinedOunces(OzAu) 134,083.6 134,083.6 134,083.6

Note: Mining schedule (Max. =500,000 tpa and LOM=3Years)

23
  Mine Manpower
It is anticipated that during the initial phase of the mining production the
proponent will provide its own experienced operatives who will also operate
as one-on-one operator/trainers for local employees from within the country.
Over time it is envisaged that local Tanzanian operatives will predominate
within the labor force.

Table 2. 4: Summary of employment program

Employee’s profile Details
Sub- Male Female Total
profiles
Total number of employees Permanent 120 30 150
Temporary 30 20 50
Local 110 28 138
Foreigners 10 2 12
Employees from local communities 80 10 90
Disabled employees 0 0 0
Employment projections at full production - - 300
Degree 15 4 19
Education level of employees Diploma 65 6 71
High school 20 10 30
Secondary 20 10 30
Primary 30 20 50
No school 0 0 0
Number of hours an employee is supposed to work per day (2 12
Number of employees with Pension Scheme - National Social 150
Tanzanian 138

 Explosive Storage and Handling

The main blasting agent for the open cut mine and the open pit will be ANFO.
The ANFO for proposed project will be stored in magazine at site. The
Ammonium nitrate will be stored in a large ANFO shed in 25 kg bags. The
shed should be able to store up to 1 year’s supply of Ammonium Nitrate
(maximum 250t). The fuel oil will be ordinary diesel stored on site near the
ANFO Plant.
Detonators and detonating cord will be stored in separate magazines on the
surface in accordance with Tanzanian explosive storage regulations. The
detonator magazines will be re-supplied by road freight.

 Fuel Storage and Distribution

Diesel fuel will be delivered to the mine site by road tankers. The diesel will
be kept in purpose built storage tanks in accordance with Tanzanian
24
regulations appertaining. The tanks will be in an elevated position so that
gravity can be utilized for distribution to the filling station. The filling station
tank should also be elevated above the level of the vehicles also to utilize
gravity for fuelling the vehicles.

 Mine Equipment Maintenance

A Maintenance Management System (MMS) will be set up early in the Project
to optimize equipment availability and utilization. All major repairs and
planned service maintenance will be carried out in the Heavy Mobile
Equipment Workshop. This workshop will be fully equipped and capable of
machine repair and full of basic spare parts.

 Health and Safety

A fully equipped medical center staffed by qualified medical personnel will be
available on site to treat minor injuries and ailments. The seriously injured
and sick will be taken by car to a hospital in Misungwi District. First Aid
stations will be established close to the working areas equipped with First Aid
boxes and stretchers.

 Manpower Requirements
The mine site will operate on a 10 hours per day (h/d), 7 days per week
(d/wk) operating for 350 d/a. The initial anticipated workers number in this
design for the mine site and processing plant and related activities is 75 for
both permanent and casual labors, the number of main production workers
in the plant is 24 and the number of administration and service is 20. The
mining personnel numbers are modeled at 41 with additional workers
provided based on demand. It is assumed that catering, cleaning, laundry
personnel etc. will be supplied by an outside contractor.

2.7.3.2 PROCESSING METHOD

The company shall construct a heap leaching Plant which shall consists of
crushing unit, heap leaching pad for crushed ore with dilute cyanide
solutions with precious metals production in carbon adsorption-desorption
recovery (ADR) and elution plants to produce gold bars. The project will use
“gold cyanidation” throughout its entire operations. This is a metallurgical
technique for extracting gold from low-grade ore by converting the gold to a
water soluble coordination complex. The whole process shall involve;

2.7.3.2.1 Ore Receipt and Crushing (Primary Crushing)

This will involve crushing ore materials maximum 250mm to less than 2mm size
using a high impact jaw crusher which will produce direct feed to the ball mill.
25
The jaw crusher is installed with a capacity of 10-15 tph and will consume about
5kWh.

On an operating basis of more crushing and less grinding, crushing adopts two
stages and close circuit crushing process, final particle size is≤ 10mm. Run-Of-
Mine (ROM) opencast ore received from trucks will be treated in a primary
crushing circuit comprising of a ROM bin fitted with a static grizzly, rock
breaker, apron feeder, vibrating grizzly feeder and primary jaw crusher by plate
feeder, crushing product is transported to self-cent ring vibrating screen by belt
conveyer to screen. Product over size return to cone crusher, product from cone
crusher is transported to self-cent ring vibrating screen to screen. Product
undersize is transported to fine ore bin by belt conveyer. An electric magnetic
iron remover and a dust suppression system will be installed.

The primary crushed product, apron feeder spillage and grizzly feeder undersize
material will gravitate onto the jaw crusher conveyor. A tip area spillage pump
is provided in order to pump excess water from the crushing circuit to the mill
discharge sump. Secondary crusher product is combined with primary crusher
product on the circuit screen conveyor which feeds the crushing circuit sizing
screen.

Circuit screen oversize is conveyed to the secondary crushing circuit comprising

of a split bin, a vibrating feeder and a cone crusher, operating in parallel and in
closed circuit to produce a crushed product stream of 10mm. A dust
suppression system will be installed.

2.7.3.2 Proposed Processing Path (Leaching)

Crushed ore coming from the crushing unit will be transported to the heap
leach pad. In order to gain the valuable mineral from the ore laid down the
leach pad, for 30-60 days leach processing operation will be subjected to the
heap where ore laid process is completed, by using diluted cyanide solution.
This method involves piling crushed ore onto a lined pad (the heap) and then
applying a leaching solution, usually a diluted cyanide solution, to dissolve
the desired metals from the ore. The solution percolates through the heap,
leaching out the metals, and then collects at the bottom of the pad.

The layout of a heap leach typically involves several key components

designed to facilitate the efficient leaching of metals from the ore as
described bellows.
 Ore Preparation

26
This is where the mined ore will be crushed and sometimes ground to a
suitable size for heap leaching. The crushed ore is typically transported to
the leach pad via conveyor belts or trucks.
 Leach Pad
The leach pad is a large, flat area where the crushed ore is stacked in heaps
or lifts. The pad will be lined with an impermeable membrane to prevent the
leach solution from leaking into the surrounding environment.
Then the ore is stacked in lifts, with each lift consisting of a layer of crushed
ore topped with a layer of impermeable material (such as clay or
geomembrane) to prevent channelling of the leach solution.
 Leach Solution Distribution System
Pipes or drip emitters will be used to distribute the leach solution evenly across
the surface of the heap. This will ensure uniform contact between the solution
and the ore, maximizing metal recovery. The solution onto the floor will be
applied by means of a system of drippers and wobblers at a rate of 10
liters/hour/m2. Dilute cyanide solution while filtering down through the stack,
there will be pregnant solution resulted from the passing through inside the
solution of gold and silver metals. This pregnant solution will be accumulated by
catching on via the geomembrane liner system located under the heap leach
pad and collected via drainage pipes and then transported to the pregnant
solution pond. Cyanide will be added to the solution collected in the barren
solution tank (after the ADR process) and then this solution will be pumped
again on to the ore laid on the leach pad.

 Ponds or Tanks for Leach Solution

One ponds or tank will contain monitoring systems to track solution levels,
pH, and other parameters. Leach solution, which typically contains a
dissolved reagent (such as cyanide or sulfuric acid) to facilitate metal
extraction, will be stored in ponds or tanks near the leach pad in the mining
site.

 Heap Irrigation and Collection System

A system of pipes and channels will collect the leach solution as it percolates
through the heap.
Solution collection systems will include drainage pipes, sumps, and pumps to
collect the metal-laden solution and transport it to a processing facility for
metal recovery.

 Gold adsorption(Carbon Column Chambers)

Metal recovery facilities, such as a carbon column or solvent extraction-
electrowinning (SX-EW) plant, will be located near the leach pad. The carbon
27
shall adsorb the gold into the pregnant solution; Barren solution will then
flow out of the column and into the barren of 3m3 tank. After adsorption
process complete pregnant carbon will be removed from the chamber for
elusion/electro winning process.

 Solution Recycling and Reagent Regeneration:

The operations shall employ recycling systems to recover and reuse the
leach solution, reducing water consumption and operating costs.

28
 Ore Leach solution
Ore
Source distribution
preparation
center

Leach pad

Heap irrigation
and collection Recycling
system center and
reagent
regeneration

Gold Metal
recovery Barren
adsorption
plant pond
H2O, CN
and pH
Figure 2.1: Heap leaching process description

2.7.3.3 Gold Elution and Refining (Cathode reaction-gold deposition)

This process involves an elution column for desorption of gold from carbon
into the solution. Desorption process is favored by high temperature, high
pressure as well as the addition of chemicals. Chemicals that are used
include sodium cyanide, caustic soda, conc. nitric acid andconc. Sulfuric acid.
Gold from solution is recovered by electrolysis, a process that is known inthe
extractive metallurgy industry as electro winning.

The Principle of electro winning is metal sedimentation from pregnant

solution by electrolysis. A current is passed from an inert anode through a
liquid leach solution containing gold so that gold is extracted as it is
deposited in an electroplating process onto the cathode. Finally, gold is
refined by oxidation (using concentrated acids) and smelting processes.
29
Gold is electrolytic ally displaced from the alkaline cyanide solution
(pregnant elute) and deposited on the cathode surface according to the
reaction below:
Au (CN) ₂⁻+℮⁻=Au+2CN⁻
Gold cyanide Ion + electron=solid gold + cyanide Ion Calcining
Prior to smelting the cathodes are firstly calcined in an oven at 750˚C.The
purpose of calcining is to oxide the steel wool and base metal impurities are
then removed into slag during the subsequent smelting process. Without
first calcining the cathodes, smelting would require large quantities of flux, a
large furnace heat input and would take a lot longer. This is followed by
smelting to produce gold bullion.

Cell anodes
The anodes, or positive electrodes, made of stainless steel mesh. The anode
does not collect gold but is necessary for the current to flow, completing the
electrical circuit within the cell.
It is important that the eluate has a high Ph, as the anodes will corrode at pH
less than 12.5. Oxygen gas produced by the oxidation of water is the main
reaction occurring at the anode
2H₂O=O₂+4H⁺+4 e⁻
Water=oxygen hydroxyl ions + Electrons

Figure 2. 6: Elution column and elector winning machine

Gold Smelting
Smelting is the final stage in the production of tile gold. The purpose of
smelting is to remove the metallic and other impurities into slag phase, and
produce a gold-silver bullion containing typically >95% precious metals.
Smelting is done in a firebrick lined furnace that is fixed with LPG at the
base. It is achieved by heating gold (with impurities) in the presence of borax

30
(slag-forming fluxes1). This smelt temperature is maintained for a period
45minites to ensure complete separation of the impurities into the slag. The
molten gold and silver form an alloy that is heavier than the Slag and hence
sinks to the bottom of the smelting crucible. The gold-silver alloy is then cast
into bars by pouring the molten gold out into moulds. It is finally cleaned by
soapy water to remove the external impurities. At this stage, the gold bar is
ready for selling.
This process is associated with the following environmental, OS&H issues:

(i) Combustion emissions

(ii) Metal residues and releases SO₂
1
Fluxes are materials that are added to the calcine material to complete the
oxidization of the impurities and remove them from the gold

2.7.3.3 Reagents to be used in the plant

Chemicals are the major input in the gold recovery process. The plant will
use caustic soda, sodium cyanide, activated carbon, concentrated sulfuric
acid, concentrated nitric acid, Hydrogen peroxide, Hydrochloric acid, Nitric
acid, Silver Nitrate, Tin Metal, Zinc fillings Acetone and Rhodanine. All of
chemicals that are proposed to be used at the plant will be sourced from the
authorized dealers in MWANZA Region and transported from the suppliers to
the plant by the suppliers according to the Government Chemist Laboratory
Agency (GCLA) guidelines. Chemicals will be carefully handled in a special
room by using Personal Protective Equipment that are present at the plant, a
special room designated for storing chemicals used at the plant which has
the temperature that is not above 24oC, the room will be always locked up,
it’s in cool condition, dry and well-ventilated area and chemicals are kept
away from incompatible materials.

 Caustic Soda Make-up and Storage

Caustic soda (NaOH) will be delivered to the plant in 2000 kg bulk bags in
“pearl” form where it is diluted with reagent water to solution strength of
20% by volume. The caustic soda solution will be pumped into the caustic
soda storage tank. The solution will be pumped to required points of use
(intensive leach reactor, strip solution make-up tank and electro winning)
using fixed speed helical screw pumps (operating and standby) as required.
Sodium hydroxide and sodium cyanide make-up share a common, discrete,
concrete bund. Spillages gravitate to a dedicated sump, and are pumped to
the detoxification circuit.

31
  Sodium Cyanide Make-up and Storage
Sodium cyanide (NaCN) will be delivered to the plant in 1,000 kg bulk bags.
The bags will be fed into the cyanide mixing tank feed hopper bag-splitter,
and the contents discharge through a 100 mm screen basket into the mixing
tank, where it is diluted with reagent water to solution strength of 20% by
volume. The cyanide solution will be pumped into the cyanide storage tank,
from where it will be pumped to required points of use. The safety shower in
this area will be equipped with a high-flow switch which will alarm when said
shower is in use and alert the control room operator to investigate in the
cause of activation.

 Flocculent Make-up and Dosing

Flocculent will be delivered to the plant in 25 kg bulk bags and manually
loaded into the flocculent powder loss-in-weight hopper. It will be fed by the
flocculent screw feeder into a floc. Wetting tank and mixed with water to
achieve 0.5% solution strength. The hydrated flocculent will be pumped into
the mechanically agitated flocculent transfer tanks and further diluted to
0.05%. From here it will be pumped to the pre-leach thickener.

 Hydrated Lime Make-up and Distribution

Hydrated lime will be delivered in 1,200 kg bulk bags which are transported
to the plant by road in containers. The lime will be added to the milk of lime
bag cabin as required, with the contents discharging into the feed hopper.
The feed hopper is equipped with a vibrating system and variable speed
rotary feeder.
The rotary feeder meters the hydrated lime into the agitated milk of lime
mixing tank where it is diluted to 20% w/w slurry. The lime slurry is pumped
to the mill feed and the detoxification circuit. A facility is installed to allow for
the addition of lime to the pre-leach thickener and Heap leaching pad No. 1.

At the mill feed, the rate of primary dosage of lime into the Heap leaching is
controlled by a pH sensor/integrated-timer interface which operates a
solenoid-controlled valve on the lime ring-main off-take. Lime make-up area
spillage is pumped to the detoxification circuit feed tank. A safety shower
provided with potable water is strategically located within the Lime make-up
area

Table 2. 9: The list of chemicals to be used in the whole processes, sources

and quantities consumptions is summarized in the table below

Table 2. 5: Chemicals to be used, sources and quantities

32
 Yearly usage Monthly usage
Activated Carbon 10-20 tons 1000 kgs
Sodium cyanide 10- 20 tons 8000 kgs
Caustic Soda 500- 1000kg 72kg
Ferro Sulphate 500- 1000 kgs Emergencies only
Borax, silica 300- 400 kg 12kg
Hydrochloric Acid 100 - 200 kgs 150 kgs
Sulphuric Acid 780kg 780kg
Nitric Acid 780kg 780kg
Hydrogen peroxide, 50kg 50kg
,
Silver Nitrate, 50kg 50kg
Tin Metal, 50kg 50kg
Zinc fillings 50kg 50kg
Acetone
Rhodanine 50kg 50kg
2.7.4 Decommissioning phase
The decommissioning phase will entail dismantling of some of the facilities in
line with the closure plan that will be prepared and approved by Government
and the surround stakeholders. As part of the proposed Environmental
Impact Assessment study, a preliminary mine closure plan will be prepared.
The plan will then be tabled to closure committees that will be formed at the
local, district and national levels. Following the discussions, the closure plan
will be detailed accordingly and updated from time to time as the project
develops and stakeholders give their views. As such, during
decommissioning, facilities that will be identified by local stakeholders for
continual usage will be left on site and those that are not needed will be
demolished and rehabilitated accordingly.

After closure monitoring will be facilities do not period of up to three years in

order to ensure that all rehabilitated waste containment facilities do not
contribute to pollution of the surrounding environs. In accordance the
regulations, a Government clearance will be sought after inspection prior to
final closure of the project site.

2.8 Utility requirements

2.8.1 Water system
 Water Supply
A water balance will be developed and will be used as the basis for sizing the
water storage tank and the raw water requirements. Raw water stored in the

33
water supply tanks will be pumped to the process plant for make-up
operations during the plant start-up and during periods where the return
water from the tailings storage facility is insufficient to meet the
requirements of the plant. Groundwater that is pumped out of the open pits
will be discharged into a settling sump in order to settle out any solids after
which it will be pumped to the water reserves tanks. Water for domestic uses
will be sourced from RUWASA.
Table 2. 6: Estimated water usage
Description: Water Requirement
( At full production) Cubic meters per month
Leach tank water 15,500
Elution Section 5
Domestic 500
Sub Total 16,000
Recycled water 13,700 – 15,000
Total Needed 17,000

2.8.2 Power Supply

The proposed project is set to obtain its electricity from a National Grid line
with TANESCO as it expects to own a transformer power supply of 620kVA.
There is an onsite diesel generator of 100 kVA as an alternative source of
power. Project power Supply is estimated to be 300kwh per week for
production and lighting.

The supply of diesel to the power plant shall be via the bulk diesel storage
facility located adjacent to the power plant fence line. The bulk diesel
storage facility shall be built and operated by the diesel supply contractor,
with diesel fuel being free-issued to the power plant contractor. A diesel day
tank has been allowed for within the power plant area.

2.9 WASTE MANAGEMENT

2.9.1 Construction Phase
During construction stage of the project waste materials to be generated will
include among others:
 Solid wastes such as landscape and land clearing debris, gravel and
aggregate products, concrete, masonry scrap and rubble(brick,
concrete masonry, stone),and plastics and paper from cement bags;
 Gaseous emissions. The majority of the air pollution will be in the form
of dust, being generated during construction;

34
  Liquid wastes from toilets and washrooms;
 Sufficient waste management on a construction site is crucial to
ensure sustained building. Such wastes as rubbles and other debris
will be used for landscaping purposes onsite.
Types and amounts of wastes to be generated during this phase are shown
in Table 2.6.
Table 2.7: Waste Generated During Construction Phase
Waste Type Amount Treatment/Disposal
Solid waste Rubbles (mainly 20,000m3 -Salvaged materials will be sold to recyclers.
(degradable) blocks) -other wastes will be collected within the site
before being deposited to the authorized
dumpsites.
-other wastes will be re-used during
foundation making.
Food remains, 0.3kg/ Collected in the waste bins at site ready to
cardboards and day/ be disposed at government nearby
papers person designated dumpsite.
Demolition waste 270m3 To be sold to recyclers
Solid waste Spoil soil 1500m 3
This soil shall be stock pilled along the
(non- foundation trenches. The soil shall be used
degradable ) to reinstatement site at the end of the
project.
Drums 50 to 80 To be sold to recyclers
Kgs
Tins and glasses 20 to 50 To be sold to recyclers other shall be used
Kgs for different uses within the site.
Liquid waste Domestic waste 200 There will be a temporal toilets on site to be
water which will be litres/wee used only during the construction period
generated by the k
workers who will
be present at the
site
Source: Bill of Quantity from Contractor, 2025

2.9.2 Operation phase

The operation works are expected to generate three types of wastes. These
include solid waste, liquid waste, hazardous waste and emission of gases and
dusts.

35
2.9.2.1 Liquid waste (Sanitary effluents)
During operations wastewater shall result from washrooms/toilets as well as
processing plant. The waste water from toilets and washroom will be carried
out through soak away pits and septic tanks for the sanitary waste water.
Sewerage from the plant will be gravity fed to a sewage septic tank with the
capacity of 100,000 litres. The sewage plant has been sized based on
potable water requirements during the construction phase.

2.9.2.2 Processing water

The processing water shall be reused in the leaching plant

2.9.2.3 Solid Waste

During the operational phase, solid wastes will be both biodegradable (food
remains, papers, tissue papers, etc.) and non- biodegradable materials
(plastic materials―plastic bottles, bags etc.).
Solid wastes that will be generated during production will include pieces of
paper results from sample storages, plastic drums with different capacities
from chemical. Yard wastes will be handled through existing site disposal
system.

2.9.2.4 Management of Hazardous wastes

Hazardous waste from operation activities will includes plastic drums with
different capacities from chemical storages, groves, bottles from chemical
titration, respiratory masks, tailing and waste oil. This hazardous waste will
be managed differently like the bottles will be given to the registered
recyclers within MWANZA region. Other Plant wastes like gloves and
respiratory will be handled through collection in waste bin at before taken to
dumping site for final disposal. While empty chemical plastic drums shall be
returned to chemical dealers. The amount of waste that will be generated at
the site is about 100kg/month.

2.9.2.5 Processed Tailings Management

The company has completed a study of tailings disposal options, with
specific attention given to the identification of suitable tailings disposal sites
and to make recommendations of a site for the safe deposition of process
tailings throughout the project life. The scope of work included the following:
 Hydrological evaluation;
 Water management plan;
 Preliminary closure plan;
 It has the storage capacity for the current tailings volume;
 It is the nearest site to the mill;
36
  The non-contact water diversion requirement of the site is one of the
smallest; and
 It is located outside the buffer zone for the open pit operation

During operational phase after processing of crushed ore mine, an area will
be designed and compacted for the management of fresh tailings after
processing. Compaction method for the area to be used for the storage of
ore mine will be based on the following stages;

 Site selection: an area for trailing storage will be selected which will
be geologically stable based on the geology, hydrogeology and
hydrological studies conducted at the proposed site, which should be
impermeable bedrock to prevent seepage of contaminants into
groundwater. The area should be free from flooding or erosion
tendencies; Estimated compacted area for tailing storage will be
50,000 m2, height of 5m and maximum tailing volume of 250,000m3
after three years;
 Preparation: Clearance of the area will be done at the proposed site
by removing all vegetation cover and topsoil. Then this will be followed
by grading the area to ensure uniformity and proper drainage, sloping
away to prevent surface runoff contamination;
 Lining: liners with 1.5 mm thick linear low density polyethylene
synthetic liner (LLDPE) will be used for management of processed
tailing will be installed at the proposed site in order to prevent seepage
into groundwater. This will be done by installing clay liners, synthetic
liners or barriers to prevent contamination to both surface and
groundwater;
 Compaction: at the proposed site compaction will be done using
mechanical equipment i.e. heavy machinery such as compactors or
bulldozers to compact the tailing materials at the storage area, the
advantage of using compaction method it will increase the density of
the tailing material, reducing its volume, and minimizing the risks of
liquefaction and slope instability;
 Layering: after compaction exercise to complete the tailing materials
will be placed in layers, then compacting each layers before adding the
next tailing materials. This method will aid to ensure uniform
compaction and prevent formation voids between the compacted
tailing materials within the disposal area;
Cover once the disposal area for tailings if filled to its maximum capacity,
then the surface will be covered with a layer of soil or other suitable

37
material to prevent erosion and promote vegetation growth. This will work
more during decommission phase.

Proper management will be done by establishing water quality monitoring

points around the compacted area and regularly taking water samples for
checking and monitoring water quality for water sources nearby the
proposed site specially downstream the area which have been compacted.

 Detox and Residue Disposal

After the spraying, there is a certain amount of cyanide ions and leached
free gold in the stockyard. Direct unloading will cause the loss of gold and
affect the environment, so it is necessary to wash the pile. When washing
the pile, generally use industrial water with a pH value of about 8-10 for
continuous spraying to detect the cyanide ion and gold grade in the site.
Generally, the spraying time is controlled at 2-3 hours. Heap washing can be
stopped when the root ion is less than 0.2 x 10-4 and the gold grade is less
than 0.1g/m3. After the washing liquid is exhausted, the pile can be
unloaded. When unloading, leave a layer of waste slag 2m thick at the
bottom of the yard to avoid damage to the bottom pad.

Cyanide detoxification will be achieved by an SO 2/air process. Each detox

tank will be fitted with spargers for the introduction of air, with an allowance
for copper sulphate. PH control will be achieved by the addition of Lime to
each detox tanks as required. The Detox circuit will be operated to achieve a
cyanide concentration in the final tailings stream of less than 50 ppm WAD.
Detox circuit tailings gravitates to the final tailings disposal tank via a
primary cross-cut/secondary Vezin sampler system. Plant tailings will be
comprised of the following streams; detoxification circuit tails, carbon fines,
spent acid and acid spillage.
Detox and residual disposal; detoxification shall consider reducing of Weak
Acid Dissociable Cyanide (WAD), Laboratory analysis to check soil and water
quality standard conformity before disposal;
A spillage pump and safety shower will be installed in the detox/tailings
disposal area. Return water will be pumped back to the process water pond
via a silt trap.

2.10 Storm water Management

Most of the surface runoff will be diverted from the project area by way of a
drainage system which will prevent its contact with process related
38
products, raw materials and waste. The Pit will collect seepage and runoff
from the surrounding area and pump the water to an open process water
tank.

Two collection (drainage) ponds will collect surface runoff around the
processing area, water release from the operation area. The seepage from
the processed tailings will be collected to runoff storage pond with a
capacity of 200000 litres.

2.11 Waste rock dump

The Project has been designed to utilize in-pit waste dumping. Once the pit is
completed it will be utilized to backfill waste material. There is area selected
for waste rock dump area.

2.12 CLOSURE PLAN

2.12.1 Process Plant
The closure objectives for the Process Plant site are as follows:
 Decommission unnecessary materials, equipment and infrastructures;
 Remove and remediate soil and restore original land use to the extent
feasible;
 Handover some infrastructures for local use, if appropriate; and
 Encourage re-vegetation.
 The closure measures are:
 Conduct environmental site assessment/risk analysis to determine
clean-up requirements;
 Drain and store all valuable reagents for resale;
 Flush and clean all equipment to ensure that no residual toxic
materials are left;
 Dismantle equipment and sell for re-use if possible or sell as scrap.
Non-saleable material will be disposed at the waste dump;
 Dismantle unnecessary buildings and resell. Non saleable material will
be disposed of at the waste dump;
 Remove impacted/contaminated soils and dispose at the TSF. Treat or
cover the area to limit exposure;
 Re-grade reclaimed surfaces. Avoid steep slopes to reduce erosion;
 Where feasible, promote re-vegetation of the footprint area of the
demolished facilities;
 Scarify non-essential internal roads and other surface areas to
encourage infiltration and natural re-vegetation;
 Culverts will be removed where necessary and the disturbed areas re-
graded to allow for unobstructed drainage; and
39
  Where appropriate, construct diversion ditches/channels to route run-
off to the open pit.
2.12.2 Open Pit
The closure measures for the open pit are:
 Decommission pipelines, pumps, and electrical lines;
 Stop open pit dewatering;
 Block access ramps;
 Evaluate the stability of the pit slopes and where required, re-shape or
stabilize pit slops;
 Remove water diversion ditches to facilitate flooding of the open pit;
 Construct high safety berms around open pit with warning signs; and
 Continuously assess the water quality in the open pit and if required,
provide water treatment system (e.g. pit lake treatment, constructed
wetland, water treatment plant, etc.).
2.12.4 Waste Rock Dump
The management of rock dump is very essential during operation and
decommission, hence the management will require considering the following;
 Site Selection and Design
The proponent will be required choosing the location basing on the
geological study, the area should be suitable to minimize environmental
impact, avoid water bodies and geological stability. The design of the area
should consider slope stability, drainage, and potential for acid rock drainage
(ARD). Design should ensure stability over the long term. The developer
should also establish buffer zones around the dump to protect surrounding
ecosystems and prevent contamination.
 Geotechnical Considerations
Waste rock dump during mining activities will also consider geotechnical
issues such as slope stability by analyzing and designing slopes to prevent
landslide and erosion and also use a proper benching technique. Other
geotechnical issues to be considered are the stability of the foundation and
measures to control and manage seepage using liners and drainage system.

 Acid Rock Drainage (ARD) Management

Waste rock testing is potential for determining acid generating rock and non-
acid generating rock, after the determination separation should be done so
as to implement measures to treat ARD, such as neutralization, constructed
wetlands, or passive treatment systems.
 Water Management
Water management is essential during rock management hence surface
water control should be considered by designing diversion channel, berms
and retention ponds to manage surface water and prevent erosion. For the
40
case of underground water regular monitoring should be done, also
collection and treatment of the leachate from the waste rock dump.
 Rehabilitation and Closure Planning
Rehabilitation is required as part of the closure plan so as to retune the area
to its original appearance, hence rehabilitation has to be a progressive
process were part of the rock dump has to be rehabilitate during the life of
the mine. During rehabilitation native species should be used to promote the
ecological restoration, also a comprehensive closure plan will be developed
as it will include slope stabilization, water management, and long-term
monitoring.
 Risk Management
The developer has to ensure that risk assessment is conducted regularly so
as to identify and mitigate potential hazards which may result from the rock
dump site. Also emergency response plan should be implemented to avoid
potential incidents like landslides or spills

CHAPTER THREE:
3.0 POLICY, LEGAL AND INSTITUTIONAL FRAMEWORK
3.1 INTRODUCTION
Policy, legal and administrative frameworks are the basis of Environmental
Impact Assessment (EIA). A policy framework is required to provide broad
guidelines on areas of focus in undertaking environmental management
activities in the sector. A legal and regulatory framework is essential for
providing mandate, allocating specific responsibility and accountability to
key actors and stakeholders, and also prescribes and enforces specific
operating environmental procedures and standards. Finally an institutional
framework is required to develop policies, guidelines and plans; to ensure
compliance with laws and regulations; and to monitor, review and adapt
policies, plans and regulations in the light of experience.

41
3.2 NEED FOR ENVIRONMENTAL IMPACT ASSESSMENT
Environmental Impact Assessment is one of the planning tools which are
used to facilitate and promote sustainable development by integrating
environmental consideration in the decision making process to ensure that
unnecessary damage to the environment is avoided. EIA also seeks to
optimise resources which are used and management opportunities. Due to
the importance of EIA, most sector policies and legislation have incorporated
the requirement of undertaking EIA prior to the implementation of the
development projects.

3.3 RELEVANT POLICIES

The following are relevant Sectoral and cross–Sectoral policies which provide
directives on how projects should be implemented in relation to the
concerned environmental and socio-economic settings. The project
proponent shall consult these policies in the course of designing and
implementing the proposed project activities.

3.3.1 The National Environmental Policy (NEP), 2021

Tanzania aims to achieve sustainable development through rational use of
natural resources and incorporating measures in development activities to
safeguard the environment. The NEP seeks to provide the framework for
making fundamental changes that are needed to bring environmental
considerations into the mainstream of decision- making in the country.

The NEP outlines six major environmental problems for urgent attention
including land degradation, loss of wildlife habitats and biodiversity,
environmental pollution, deterioration of aquatic systems and lack of
accessible, good quality water for both urban and rural inhabitants, and
deforestation.

The policy provides the framework for the formulation of plans, programmes
and guidelines for the achievement of sustainable development. Chapter 4 of
the NEP elaborates clearly the importance of EIA in the implementation of
the National Environmental Action Plan (NEAP). Paragraph 65 states that “It
is in the context of an EIA regime that policy guidance on choices to
maximize long-term benefits of development and environmental objectives
can be revealed and decided upon. EIA as a planning tool shall be used to
integrate environmental considerations in the decision – making process in
order to ensure un-necessary damage to the environment is avoided”.

42
This EIA responds to National Environmental Policy and addresses all issues
that need the attention of the Proponent and other affected and interested
stakeholders in ensuring environmental concerns are taken on board during
the mobilization, construction, operation and decommissioning phase.

The policy stipulates that an EIA shall be mandatory for all major projects
and those in ecologically sensitive areas to ensure that environmental
concerns receive due and balanced consideration in reconciling urgent
development needs and long-term environmental sustainability.
The NEP emphasizes the fact that environmental considerations should not
become an afterthought in planning and decision making; rather, it should be
part of a conscious awareness of Tanzania’s development realities. The NEP
places emphasis on public consultation as an effective tool in the EIA
process.
The policy proposes the following measures as means for minimization of
pollution likely to emanate from the mining sector:
 Overall project cycle of mining (including reclamation and restoration
of land after use) shall be adequately managed to minimize adverse
environmental impacts.
 Mining discharge to grounds and water shall be controlled.
 Preventive and clean up measures for accidents shall be formulated
and implemented.
 Air pollution from mining areas shall be controlled.
 Strict regulations shall be put in place to control the use of mercury in
mining activities, use of retorts will be promoted.
 Regular and periodic environmental audits shall be maintained to
ensure the adoption of environmentally sound practices in mining
operations

Commitments: This EIA responds to National Environmental Policy and

addresses all issues that need the attention of the developer and other
affected and interested stakeholders in ensuring environmental concerns are
taken on board during the mobilization, construction, operation and
decommissioning phase for the proposed Mineral processing project at
Ikungumhulu Village, Shilalo ward, Misungwi District in Mwanza Region.

3.3.2 The Mineral Policy of Tanzania, 2009

The Mineral Policy of Tanzania recognizes the importance of integrating
environmental and social concerns into mineral development programmes as
a way of ensuring sustainability. To achieve sustainable mining development,
the policy underscores the need to balance the protection of flora and fauna

43
and the natural environment with the need for social and economic
development.
The policy has put forward strategies aimed at reducing/eliminating adverse
environmental effects of mining; improving health and safety conditions in
mining areas; and addressing social issues affecting women, children and the
local communities.
The Mineral Policy of Tanzania deals with the environmental and social
sustainability of mining developments and provides a framework of
strategies for protecting the environment as well as ensuring human health
and safety during mining. These specific strategies for protecting the
environment include:
 Establishing environmental management programmes.
 Complying with regulations and monitoring required by the
government.
 Carrying out baseline environmental studies and environmental impact
assessments for new projects.
 Completing the required environmental audits.
 Determining the environmental liability of mining projects.
 Complying with guidelines restricting mining in certain areas (including
forests, national parks and bodies of water).
 Preventing the use of toxic chemicals and associated pollution.
 Complying with any health and safety regulations.
 Preventing accidents and hazards to the health and safety of humans.
 Investing in health care facilities.
 Incorporating provision for hygiene enhancing facilities including water
supply and sewerage facilities.

Commitments: The project shall comply with the objectives of the mineral
policy as a catalyst in government revenues, employment to the people,
hence contribute to poverty eradication.

3.3.3 The National Land Policy (1997)

The National Land Policy recognises the importance of EIA in management of
land and land resources. It advocates the protection of land resources from
degradation for sustainable development and addresses several
environmental issues such as land use planning, land capability, effective
management of coastal, urban and rural land resources. Resource sharing
and multiple land use techniques in areas of conflicting land use is promoted
by this policy.
The National Land Policy recognises the need for investors to acquire land for
investment and allows for the following:

44
  Special areas for various investments will be identified and set aside
for allocation to investors by the government;
 Land will be allocated to investors according to their ability to develop
and that interests of citizens over their land shall be safeguarded;
 Land ceilings will be determined by the government on the basis of
use, location, feasibility study and proven ability of the applicant to
develop the said parcels of land; and
 Land hoarding will be discouraged by strict enforcement of
development conditions and by the use of local by-laws, planning and
land use regulations.
 The policy makes the following statements regarding land acquisition:
 All land in Tanzania is public land and vested in the President as
trustee on behalf of all citizens;
 Land has value;
 The rights and interests in land of citizens shall not be taken without
due process of law;
 Full, fair and prompt compensation shall be paid when land is acquired;
and
 Village Councils will administer village land and their powers will be
subject to limitations embedded in laws and procedures; and

Commitments: The site for the proposed development is legally owned by

JIKOMBOE MINING IKUNGUMHULU who has entered contract with DF METAL
MINING COMPANY (The Proponent) for technical support. The proponent shall
observe all provisions intended to protect land resource for sustainable use.
Consultation and consent of the Village Council will be required whenever
alienation of village land is necessary

3.3.4 The National Energy Policy (2003)

The policy outlines measures to adopt clean technology and minimize energy
losses. The policy states that energy is a prerequisite for the proper
functioning of nearly all sub sectors of the economy. It is an essential service
whose availability and quality can determine the success or failure of the
development endeavours. In the industry sector, a major policy objective on
energy and uses is the progressive reduction of dependence on imported
energy through the use of demand management to reduce the negative
effects of continued dependence on imported petroleum products.
Furthermore, the policy calls for efforts to promote switching from petroleum
to other environmentally friendly or alternative sources such as natural gas.

45
Commitments: The project proponent shall abide to the policy by ensuring
that clean technology of minimum energy loss is used.

3.3.5 The National Investment Policy (1997)

National Investment Promotion Policy seeks to promote the growth of
investments by strategically utilizing the scarce natural, social and capital
resources to accomplish it. One of the key policy objectives is maximum
promotion of high quality domestic goods and services to enhance the
development of a dynamic and competitive mining sector. The policy insists
that promotion of the investment must be accompanied by strategies that
aim at increasing high quality domestic goods so as to reap the benefits of
the local investment.

Commitments: The proponent is committed to adhering to the policy.

3.3.6The National Employment Policy (1997)

The major aim of this policy is to promote employment, mainly for Tanzania
citizens. Relevant sections of this policy are (i) Section 10, which lays down
strategies for promoting employment and section 10.1 is particularly
focusing on industry and trade sectors (ii) Section 10.6 which deals with
employment of special groups i.e. women, youth, persons with disabilities
and (iii) Section 10.8 which deals with the tendencies of private industries to
employ expatriates even where there are equally competent nationals.

Commitments: The proponent shall abide by this policy by employing local

people, about 40 during operation phase.

3.3.7 The National Policy on HIV/AIDS (2001)

The policy provides a framework for leadership and coordination of the
National multi-sectoral response to the HIV/AIDS epidemic. One of the major
objectives of the policy is to strengthen the role of all the sectors, public,
private, NGOs, faith groups, CBOs and other specific groups to ensure that all
stake holders are actively involved in HIV/AIDS work and to provide a
framework for coordination and collaboration. The policy recognizes that HIV
infection shall not be grounds for discrimination in relation to education,
employment, health and any other social services. Pre-employment HIV
screening shall not be required. For persons already employed, HIV/AIDS
screening, whether direct or indirect, shall not be required. HIV infection
alone does not limit fitness to work or provide grounds for termination.
HIV/AIDS patients shall be entitled to the social welfare benefits like other
patients among the employees. HIV/AIDS information and education
46
targeting the behavior and attitudes of employees and employers alike shall
be part of HIV/AIDS intervention in the workplace.

Commitments: The project proponent shall observe this policy by

introducing awareness creation programme and sensitization to protect
workers and communities around the project area against HIV/AIDS both
during the project construction and operation phases.

3.3.8The National Transportation Policy (2003)

The policy aims at guiding the development of an efficient, well integrated
and coordinated transport infrastructure and operations, which are
economically, financially, socially and environmentally sustainable.
Relevant section of the policy is:
 4.1.1 (vi) on the intention of the policy to facilitate sustainable
development by ensuring all aspects of environmental protection and
management are given sufficient emphasis at the design and
development stages of the transport infrastructure and when providing
services
 Given the fact that there will be transportation of various materials and
goods to the plant and other associated materials, the proponent is
directly linked to the policy in its activities.
Commitments: Since the proponent has direct link to the policy hence
they will adhere to the requirement of the policy.

3.3.9 The National Water Policy, 2002

The main objective of the NAWAPO is to develop a comprehensive framework
for sustainable development and management of the nation’s water
resources, and establishing an effective legal and institutional framework for
its implementation. The policy aims to ensure that beneficiaries participate
fully in all stages of water resource developments.
The NAWAPO recognises the fundamental but intricate linkages between
water and socio-economic development, including environmental
requirements. The policy expounds on the importance of water for domestic
use, agriculture, livestock keeping, mining, energy, fisheries, environment,
wildlife and tourism, forestry, navigation and trans-boundary requirements.
It calls for integrated water resource management in Tanzania to ensure
“there is equitable and sustainable use and management of water resources
for socio-economic development, and for maintenance of the environment”
(URT, 2002).
The following NAWAPO principles are applicable to the Project:

47
  All the water resources in the country are vested in the United
Republic of Tanzania and every citizen has an equal right to access
and use of the nation’s water resource;
 Water use for basic human needs has the highest priority. Water to
sustain the environment and other uses are subject to social and
economic criteria, which shall be reviewed from time to time;
 Developments in water basins and water abstraction shall be
subjected to permits and mandatory legal requirement for an EIA;
 The “Polluter Pays Principle” shall apply in conjunction with other
legal and administrative actions;
 Standards for in-stream flows, industrial effluents and other waste
discharges to be developed will be enforced;
 Water related activities should aim to enhance or to cause least
detrimental effects on the natural environment;
 The allocation and consumption of water for environmental purposes
is to be given appropriate considerations;
 Water for environmental purposes shall be determined on the best
scientific information available, considering both the temporal and
spatial water requirements, to maintain the health and viability of
riverine and estuary ecosystem;
 A sound information and knowledge base, including data on surface
and groundwater (quantity and quality), socio and economic data
shall be established; and
 Status of surface and groundwater resources, in terms of quantity,
quality and its use shall regularly be determined and information
made easily accessible to stakeholders and decision makers.
Commitments: Water needs for the proposed project shall be met by
receiving of water from RUWASA. Wastewater will not be discharged into the
open environment without prior treatment. If discharge of effluents to the
environment will be necessary, the proponent will apply for discharge permit
and ensuring environmental standard are adhered to.

3.3.10 The National Health Policy (2007)

One of the main objective of this policy is to ensure that health services are
available and accessible to all people wherever they are in the country,
whether in urban orrural areas. The policy encourages safe and basic
hygienic practices in workplaces, to promote sound use of water, to promote
construction of latrines and their use, to encourage maintenance of clean
environment and working environment which are conducive and satisfactory
for work performance. The policy puts more emphasis on ensuring workers’
protection against all occupational hazards, which may occur in their work
48
places such as industries, estates, plantations and other high-risk
institutions. It is the responsibility of the management at work places to offer
health information and services to their employees according to guidelines
which are given by the Ministry of Health.

Commitments: The proponent will be responsible for the coordination and

guidance in the provision of health services to employees of these
institutions with technical support from the Regional Secretariat and the
Ministry of Health.

3.4 RELEVANT LEGISLATION AND REGULATIONS

This section addresses the legal and regulatory conditions which are relevant
to the proposed project. This EIA has been conducted in general compliance
with the following legislations.

3.4.1The Environmental Management Act, Cap 191

The Environmental Management Act, Cap 191 seeks to provide legal and
institutional framework for sustainable management of the environment in
the implementation of the National Environmental Policy.
The Environmental Management Act provides for continued existence of the
National Environmental Management Council (NEMC). Under this Act, NEMC
is mandated to undertake enforcement, compliance, review and monitoring
of environmental impact assessment and has a role of facilitating public
participation in environmental decision making, exercise general supervision
and coordinating over all matters relating to the environment. The Act also
requires the Council to determine whether the proposed project should be
subjected to an EIA, approves consultants to undertake the EIA study, invites
public comments and also has the statutory authority to review EIS and
recommend to the Minister for approval and issuance of EIA certificate. This
new Act imposes an obligation on Proponents to conduct an EIA prior to the
commencement of the project to determine whether the project may/or is
likely to have, or will have a significant impact on the environment. Article 82
makes EIA mandatory to all projects that fall under the EIA mandatory list
(Schedule 2). The proponent has complied with relevant provisions of the Act
in carrying out this EIA.

Other caps where proponent should be aware on them are: Environment

Management Act, Cap 191 under section 72 which emphasize on land users
and occupiers shall be responsible for the protection, improvement and
nourishment of the land and for using it in an environmentally sustainable
manner as may be prescribed by the minister.
49
Environment Management Act, Cap 191 section 110 (1) say; No person shall
discharge any hazardous substance, chemical, oil or mixture containing oil in
any water or any other segment of the environment except in accordance
with guidelines prescribed under this Act.
Environment Management Act, Cap 191 section 141, provides on every
person undertaking any activity shall be required to comply with
environment quality standards and criteria and
Environment Management Act, Cap 191 section 116(1) Local government
authorities shall ensure that industries located within their geographical
respective areas of jurisdiction provide adequate space and facilities for
managing all solid waste generated from such industries before they are
collected for disposal at designated place.

Commitments: This EIA is responding to the requirement of the

Environmental Management Act (Act No 20 of 2004) and particularly Part VI
and Second schedule of the act and addresses significant impacts associated
with the proposed development.

3.4.2The Land Act, Cap.113

The purpose of this law is to make sure that the general idea and aim of the
National Land Policy are acted on. The Act seeks to control the land use and
clarify issues pertaining to ownership of land and land-based resources,
transactions on land and land administration.
The Land Act introduces into the body of the law for the first time,
fundamental principles of land policy including the principle of ensuring that
“land is used productively and that any such use complies with the principles
of sustainable development”. This principle is introduced in a way that is
enforceable in court of law. Therefore, during project implementation,

Commitments: The Act will be observed by the proponent. The project

activities will be conducted in consent with this principle in order to preserve
the environmental integrity of the area. This will be ensured by
implementing the Environmental Management Plan and No land use plans
has been contravened by this project and there is no issue of conflicts.

3.4.3 The Land Use Planning Act, No. 6 of 2007

The National Land Use Commission (NLUPC) was established under this Act
as the principal advisory organ of the Government on all matters related to
land use. Among other things, the Act recommends measures to ensure that
Government policies, including those for development and conservation of
land are in harmony. It also takes adequate account of their effects on land
50
use and seeks the advancement of scientific knowledge of changes in land
use. It encourages development of technology to prevent, or minimize
adverse effects that endanger man’s health and his/her welfare. It also
specifies standards, norms and criteria for beneficial uses and maintenance
of the quality of land.

In accordance with the functions mentioned in the Act, the commission can
indirectly help to prevent or minimize environmental and socio-economic
impacts through advising on proper location of economic activities.

Commitments: The proposed project is planned in accordance with the

requirement of the Act and future developments shall also adhere to it.

3.4.4 The Occupational Health and Safety Act, No.3, 2003

This Act deals with the protection of human health from occupational
hazards. It specifically requires the employer to ensure the safety of workers
by providing safety gears at the work place. Relevant sections of the
ordinance to the project activities include part IV which deals with general
health provision, such as provision of regular medical examination of
employees, safe means of access, safe working place, prevention of fire etc.;
and Part V on health and welfare provisions which includes provision of
supply of clean and safe water to workers, sanitary convenience, washing
facilities and first aid facility. Section 50 deals with fire prevention issues.

Section 15 gives powers to the Registrar of factories and workplace to enter

any factory or workplace to perform his/her duties as provided by the Act.
Section 16 requires that factories and workplace be registered with the
Registrar of factories and workplaces before commencing operations.

Commitments: The proponent shall observe the provision of this Act during
all stages of the project development and operation. The project will be
registered to OSHA zonal office.

3.4.5 The Water Resources Management Act No 11 of 2009 and its

amendment No.8 of 2022
The Water Resources Management Act No 11 of 2009 and its amendment
No.8 of 2022is a new principal legislation dealing with the protection of water
resources and control of water extraction for different uses. According to
section 39 (1) of this act, owner or occupier of land on which any activity or
process is or was performed or undertaken, or any other situation exists
which causes has caused or is likely to cause pollution of a water source,
51
shall take all reasonable measures to prevent any such pollution from
occurring, continuing or recurring. It is stated under section 39 (2) that a
Basin Water Board may direct any person who fails to take the measures
required under subsection (1) to;-

a.
commence taking measures before a given date;
b.
diligently continue with those measures; and
c.
Complete the measures before a given date.
Section 40 (1) states that where a person fail to comply or comply
inadequately with a directive given under Section 39 (2), the Basin Water
Board may take measures as it considers necessary to remedy the
situation. Section 40 (2) provide more that the responsible person, any
other person involved in the incident or any person with knowledge of the
incident must, as soon as is practicable after obtaining knowledge of the
incident, report the incident to the Basin Water Board or any public officer
and the a responsible person shall:-

(a) take all reasonable measures to contain and minimize the effects
of the incident;
(b) undertake clean-up procedures; and
(c) Take such measures as the Basin Water Board may verbally or in
writing direct, and any verbal directions shall be confirmed in writing
within fourteen days to have effect under this subsection.

The Act underscores the institutional and legal framework for sustainable
management and development of water resources. Key sections outlines:
 Principles for water resources management.
 Principles for prevention and control of water pollution.
 Provides for participation of stakeholders and the general public in
implementation of the National Water Policy, and plans and processes
for the management of the environment.
The main objectives are to ensure that the national water resources are
protected, used, developed, conserved, managed and controlled in a way
that meets the basic human needs of present and future generations,
prevent and control pollution of water resources and protects biological
diversity in aquatic ecosystem.

In accordance with this law, all water resources in mainland Tanzania shall
continue to be public water and vested in the President as the trustee for
52
and on behalf of the citizens. The power to confer a right to the use of water
from any water resources is vested in the Minister responsible for water.
Section 9 of this Act, requires carrying out an EIA for any development in
water resource areas or watershed.

Section 43, stipulates the application for a water use permit in accordance
with the Act to divert, dam, store, abstract and use water from surface
and/or ground water sources. The holder of a water use permit shall not
cause or allow any water to be polluted, prevent damage to the source,
ensure sustainable use of water and submit any data on request from the
Basin Water Board.

According to section 63(1) “a person who wishes to discharge effluents from

any commercial, industrial, or agricultural source or from any sewage works
or trade waste systems or from any other source into the surface water or to
underground strata shall apply to the Basin Water Board for a Discharge
Permit in accordance to this Act; (2) The application for Discharge Permit
shall be made in accordance with section 75 of this Act”.
Furthermore, sections 64(1-2) and 64(1-6) details the issue of ‘‘discharge
permits’’ which should be followed accordingly.

Section 87(1) stipulates that no person shall engage in any construction

activity that blocks or otherwise impedes the flow of water in watercourse
unless a permit authorizing the activity has been obtained in accordance
with the provision of Part VII of the Act.

In terms of the Act, any persons who pollute water in any water body and
cause any impact to the environment shall be liable for conviction of a fine
of not less than one million shillings, and not more than ten million shillings,
or to imprisonment for a term of not less than six months, but not more than
two years, or to both. In the case of subsequent conviction, a fine exceeding
five million shillings or to imprisonment for term not exceeding two years or
to both will be applied. In the case of continuation of the offence, an
additional fine not exceeding fifty thousand shillings in respect of every day
during the offence continues will be applied.

The proposed project will require water during the construction and
operation phase; therefore, the provisions of this Act will be taken into
account in order to safeguard this scarce resource.

53
The Water needs for the proposed project shall be met by receiving of water
from the drilled borehole, and will apply for a permit from Ministry of water
for drilled boreholes

Commitments: Wastewater will not be discharged into the open

environment without prior treatment. If discharge of effluents to the
environment will be necessary, the proponent will apply for discharge permit
and ensuring environmental standard are adhered to.

3.4.6 The Tanzania Investment Act, Cap.38

The act provides for legal mandates of Tanzania Investment Centre which
shall assist all investors to obtain necessary permits, authorizations,
approvals, registrations, consents, licences and any other matter required by
the law for a person to set up and operate investment in Tanzania.

Commitments: The proponent has complied with the relevant provision of

the act by applying for the certificates of investment which was granted
accordingly.

3.4.7 The Employment and Labour Relations Act, Cap. 366

This Act guarantees fundamental Labour rights and establishes basic
employment standards. The Act provides broad protection against
discrimination. Specifically, the Act mandates that employers "promote equal
opportunity in employment and strive to eliminate discrimination in any
employment policy or practice." It prohibits direct or indirect discrimination
by employers, trade unions and employers' associations on a number of
grounds, including gender, pregnancy, marital status or family responsibility,
disability, HIV/AIDS and age. Harassment of an employee on any of these
grounds is equally prohibited.
The Act also requires employers to take "positive steps" to guarantee women
and men the right to a safe and healthy environment.

Commitments: The proponent will observe the Act by making sure that
harassment of an employee on any of these grounds is equally prohibited.

3.4.8 The Public Health Act, No. 01 of 2008

The Act provide for the promotion, preservation and maintenance of public
health with a view to ensuring the provisions of comprehensive, functional
and sustainable public health services to the general public. The proponent
shall observe Part IV of the Act which relates to sanitation, housing and
54
hygiene. The Part also makes provisions for matters relating to nuisance,
housing and human settlement, waste management, sewerage and
drainage.
Commitments: The proponent will observe all the requirement as provided
by the act.

3.4.9 The Mining Act, Cap 123

An Act to re-enact with substantial amendments the provisions that regulate
the law relating to prospecting for minerals, mining, processing and dealing
in minerals, to granting, renewal and termination of mineral rights, payment
of royalties, fees and other charges and any other relevant matters. The Act
require the Proponent will have to take proper account of the environmental
impacts assessment commissioned in accordance therewith or otherwise
fails to conform to regulations, or reasonable standards established by the
government of Tanzania for management of mining operations .The Act
require that where the mining operations intended to be carried out under a
mining license or a gemstone mining license fall within a scale of mining
operations set out in the regulations, the applicant for the Mining license
shall commission and produce an EIA on the proposed mining operations
from an independent consultant. Other environmental management
provisions provided under the Mining Act, 2010 and its associated
regulations include:
 Procedures for amending and updating EMPs;
 Environmental obligations for someone surrendering a mineral right;
 Environmental standards and monitoring requirements;
 Monitoring, auditing and reporting procedures;
 Reclamation requirements;
 Rehabilitation bonds and financial guarantees; and
 Action against breach of regulations.
Commitments: The proponent will adhere with the Mining Act 2010
requirement.

3.4.10 The Fire and Rescue Force Act, Cap. 427

The act empowers the commissioner general of the force or his agent to
enter premises to ascertain any contravention of provisions of the Act and
obtain information required for firefighting purposes. A court may issue an
order for a closure or prohibit the use of any premises for human habitation
or storage in case there is failure to comply with fire prevention regulations.

Commitments: The proponent shall abide by the relevant provisions of the

Act to ensure safety and security of its work force and the general public.

55
3.4.11The Prevention and Control of HIV/AIDS Act No.28 of 2008
The Act focus basically on the provision of the prevention, treat, care support
and control of HIV and AIDS, for provision of the public health in relation to
HIV and AIDS, to provide for an appropriate treatment, care and support
using available resources to people living with or at risk of HIV and AIDS and
to provide for related matters under this Act.

Further, the Act stipulates the following: Section 4(1) gives details of
promotion of public awareness on cause, mode of transmission,
consequences, prevention and controls of HIV and AIDS. Also, it describes
mode of reduction in spreading, prevalence of STI’s in the population and
adverse impacts resulting from HIV and AIDS as well as protection right of
orphans.

Commitments: The proponent shall operate within the requirements of this

legislation in addition to those of the HIV policy.

3.4.12 The Village Land Act, Cap.114

The Village Land Act was enacted specifically for the administration and
management of land in villages. Under the provisions of this Act, the village
council is responsible for the management of the village land and is
empowered to do so in accordance with the principles of a trustee managing
property on behalf of a beneficiary. As provided under Section 8 of the Act,
the village council is required to manage land by upholding the principles of
sustainable development, and the relationship between land use, other
natural resources and the environment in and contiguous to the village and
village land. In so doing, the council exercises any of the functions of the
management of the village land. A district council, as provided under Section
9 of the Act, may provide advice and guidance concerning the administration
of the village land. In the case of a conflict over village land boundaries
between a village and another person or body, the Minister responsible may
appoint a mediator or appoint an inquiry as provided under Section 18 of the
Land Act, Cap 113.

Under the Act, the village council may grant derivative rights where an
application has been made to the village council accompanied by a plan of
location, boundaries and fees. For application of not more than 5 ha and for
five years or less, known as Class A, it is determined by the council. For land
of more than 5 ha, but less than 30 ha (Class B), it is determined by the
council with the approval given by the village assembly. For land of more
than 30 ha and for more than 10 years (Class C land), it is determined by the
56
council subject to approval by the village assembly and the advice of the
Commissioner.

Commitment; the proponent has collaborated with the Village Council in

the acquisition of land for the project and will be using it according to the
intended use.

3.4.13 The Workers Compensation Act, Cap.263

The Act focuses mainly on:
 Provision for adequate and equitable compensation for employees who
suffer occupational injuries or contract occupational diseases arising
out of, and in the course of their employment, and in the case of death
to their dependents.
 Provision for the rehabilitation of employee who have suffered
occupational injuries or contacted occupational diseases to assist in
restoring their health.
 Provision for a framework for the effective, prompt and empathetic
consideration, settlement and payment of compensation benefits to
employees and their dependants.
 Provide for the establishment, control and administration of workers to
compensation fund, and the legal framework for the contribution to,
and payment from, the fund.
 Give effect to international obligations with respect to compensation.
 Promote prevention of accidents and occupational diseases.
 This Act provides the right for compensation to workers for
occupational injury in section 19(1) - (5) or accident in sections 20 and
21. Also in sections 22(1) - (5), an employee has the right to
compensation for occupational diseases.

Commitments: The proponent shall adhere to the requirements of the Act.

3.4.13The Standards Act, Cap 130

This Act aims at the promotion of specifications of commodities and services,
re-establish the Tanzania Bureau of Standards (TBS), the designated national
standards authority established under the TBS Act 1975 and repealed by this
Act. TBS is responsible for developing national standards, including
environmental standards.
The Standards Act has established the National Environmental Standards
Compendium (NESC) which is a collection of various standards prepared at
different times and recognized by the EMA 2004. The NESC is divided into
three parts:
57
  Part 1 comprises of standards that require compulsory compliance.
Compulsory standards are categorized as generic or specific. Specific
standards cover those industries with peculiar effects to the
environment. Other industries are without a specific standard for
Tolerance Limits of Emissions discharge including water quality,
discharge of effluent into water, air quality, control of noise and
vibration pollution, sub-sonic vibrations, soil quality, control of noxious
smells, light pollution, and electromagnetic waves and microwaves.
 Part 2 contains those standards that may be implemented on voluntary
basis. These include guideline standards, codes of practice, and other
such standards that may not necessarily be directly enforced, but
whose results are implied in some legal requirements.
 Part 3 has the requisite test methods that should be followed when
testing for compliance. Although it is not stated in the Act, in the
absence of national standards, project proponents are encouraged to
use international standards such as those of the World Health
Organization (WHO), World Bank, British Standards (BS), European
Union (EU), American Public Health Association (APHA), United States
Environmental Protection Agency (US EPA) etc. Relevant national
environmental standards include:
 TZS 860:2005 Municipal and Industrial Wastewaters – General
Tolerance Limits for Municipal and Industrial Wastewaters
 TZS 845:2005 Air Quality – Specification
 TZS 983:2007 Air Quality – Vehicular Exhaust Emissions Limits
 TZS 932:2006 Acoustics – General Tolerance Limits for Environmental
Noise.
 TZS 789:2003 Drinking (potable) water – Specification
 TZS 931:2006 Protection against ionizing radiation - Limits for
occupational exposure

Commitments: The proponent will adhere to the required standards as

highlighted in the Act.

3.4.14The Local Government (District Authorities) Act, Cap.287

This Act outlines and describes the nature of local government, from the
district to the lowest levels of government (e.g. mtaa/ hamlet). The objective
of the Act is to promote local government in mainland Tanzania; ensure
creation of local government institutions geared and devoted to the
meaningful involvement of and participation by the people in the making of
decisions on matters affecting or connected with their livelihood and well-

58
being; and secure the effective execution by local government authorities, of
the national policy on local government.

Commitments: The proponent will ensure all the decision from the local
government are adhered and respected.

3.4.15The Contractors Registration Act, Cap. 235

The Act provides for the requirements for someone to be termed as a
contractor. Any person who for himself as a developer or investor,
undertakes construction works of any structure for public or private use,
should be authorized to supply the labour necessary for the works or to
employ or select for employment workmen to assist him in the execution of
the work. Section 10 of the Act restrict any person/firm to undertake or
cause to carry out and complete any construction works unless such person
or firm is registered by the Board, and holds a valid certificate of registration.
Commitments: The proponent will ensure that all the hired contractors are
registered with the authority.
3.4.16 The Employment and Labour Relations Act, Cap 366
The Employment and Labour Relations Act provides for workers’ rights, basic
employment standards, a framework for collective bargaining, and dispute
resolution.
Section 5 states that a child under the age 14 years may not be employed
without prejudicing his/her health, attendance at school or participation in
vocational training programmes. A child under the age of 18 years old may
not be employed in a mine where work conditions may be considered
hazardous by the Minister.
Section 7(1) provides for equal employment opportunities in the workplace.
Furthermore, Part III stipulates employment standards, including wage
determination and minimum terms and conditions of employment.
Commitments: The proponent will make sure that all the works employed
are having qualification and providing equal employment opportunities in the
workplace.

3.4.17 The Industrial and Consumer Chemicals (Management and

Control) Act, No.3 of 2003
The Act requires users, producers and marketers of industrial and consumer
chemicals to register all chemicals imported, exported or produced in
Tanzania with the Chief Government Chemist. An application for registration
of the chemical shall be submitted to the Chief Government Chemist in the
prescribed manner and form.

59
The Act further prescribes procedures for obtaining approval for importation,
registration, and general requirements for handling, storing, and
warehousing chemicals. It also provides some restrictions on use, disposal of,
importation and handling of certain types of chemicals. The Act defines and
lists chemicals which are highly hazardous and precursor chemicals.
Provision should be made during decommissioning to ensure that harm to
human health and the environment is prevented.

These steps and precautions must be addressed as part of an EIA to ensure

that all remaining stocks of chemicals are disposed of soundly.

Commitments: The proponent shall keep abreast all requirements of the

Act and conditions given under the license issued to deal (use) with mining
chemicals.

3.5 THE REGULATIONS

3.5.1TheEnvironmental Management (Environmental Impact
Assessment and Audit)(Amendment) Regulations, 2018
The regulations as amended by Government Notice No. 474 published on 31-
8-2018 The Environmental Management (Environmental Impact Assessment
and Audit) (Amendment) Regulations, 2018, it consists of 12 parts, and three
schedules. Section 4(1) states that no developer or proponent shall
implement a project:
 That is likely to have a negative environmental impact; or
 For which an EIA is required under the Act, the regulations or any other
written law, unless an EIA has been concluded and approved in
accordance with these regulations.
 The Project was registered in accordance with the regulations
contained in Part III and a screening letter obtained from NEMC which
is attached as Appendix A of this report.

Part IV of the regulations details the requirements for the EIA, and stipulates
the general objectives of the EIA and the procedures required to be followed.
Part VIII provides for the right of access to environmental information
presented to NEMC by the public. Section 39(1) states that any project brief,
EIS, terms of reference, public comments, report of a person presiding at a
public hearing, decision letter or any other information submitted to the
Council under these regulations, shall be public documents.

60
Part IX stipulates that if an EIA certificate has been issued, but no
development has started within three years, the developer or proponent
shall re-register with the Council any intention to develop.

Part X of the regulations details audit requirements and procedures. An

environmental audit study shall be undertaken on an annual basis and
submit an environmental audit report to NEMC.
Commitment: The proponent has abide with the regulation by making sure
EIA is conducted before starting the project.

3.5.2
The Environmental Management (Air Quality Standards)
Regulations, 2007
Part III 7(1) of these regulations requires every person to comply with the
minimum air quality standards approved and published pursuant to these
regulations. Thus no person shall emit, or release any hazardous substance,
chemical, gas or mixture containing gaseous and hazardous substance into
the environment unless such emission or release is permitted under these
regulations or any other written law. The limit for fugitive dust emissions are
stipulated in the Second Schedule to the Regulations.
Furthermore section 23 (1) mandates NEMC, a city Environmental
Management Officer, Municipal Environmental Management Officer, a District
Environmental Management Officer and a Town Environmental Management
Officer to ensure a protection order against activities likely to result in
adverse effects on air quality or to the environment or public health.

Commitments: In its mining operations, the proponent shall abide by these

regulations including adhering to permissible weight concentration (Emission
limits) from the atmosphere to a receptor as set out in the first schedule of
the regulations.

3.5.3
The Environmental Management (Soil Quality Standards)
Regulations, 2007
Soil in terms of these regulations is defined as “…earth, sand, rock, shell,
mineral, vegetation and the flora and fauna in the soil and derivatives
thereof such as dust...”. The objectives of these Regulations relevant to the
Project are to:
 Set limits for soil contaminants in agriculture and habitat.
 Enforce minimum soil quality standards prescribed by the National
Environmental Standards Committee.
61
  Prescribe measures designed to maintain, restore and enhance the
sustainable productivity of the soil.
 Prescribe minimum soil quality standards to maintain restore and
enhance the inherent productivity of the soil in the long term.
 Ensure implementation of criteria and procedures prescribed by the
National Environmental Standards Committee for the measurement
and determination of soil quality.
 Prescribe measures and guidelines for soil management.

Commitment: The proponent shall make every effort to adhere to these

regulations in its processing operations.

3.5.4
The Environmental Management (Water Quality Standards)
Regulations, 2007
Water in terms of these regulations is defined as “drinking water, river,
stream, water-course, reservoir, well, dam, canal, channel, lake, swamp,
open drain, or ground water”.
The regulations require any person to protect water sources and
groundwater. Section 6(1) prohibits any person to discharge any hazardous
substance, chemical, oil or mixture containing oil in any waters, except in
accordance with what is prescribed under these regulations or any other
written law. Regulation 7(1) requires every applicant for a water right or
permit under relevant laws that govern management of water resources,
abstraction and use of water, within twenty one days of lodging their
application, to file through the Basin Water Officer a statement to the Council
indicating the likely impacts on the environment if the water right or permit
is granted.
Section 8(1) requires a holder of a water right or permit to comply with
effluent or receiving water standards prescribed by any other written law
provided that they are not below the standards prescribed under these
regulations.

Commitment: The proponent shall abide by the regulations by ensuring

that waste water is not discharged into the open environment to avoid
pollution of water bodies.

3.5.6 Environmental Management (Fees and Charges) (Amendment)

Regulations, 2024
62
These Regulations may be cited as the Environmental Management (Fee and
Charges) (Amendment) Regulations, 2024 and shall be read as one with the
Environmental Management (Fees and Charges) Regulations, 2021
hereinafter referred to as the “principal Regulations” These regulations were
made under section 230 (2) (b) of the Environmental Management Act, Cap.
No. 191 of 2004. The regulations apply in relation to an act or omission to
which fees and charges are payable under the Act. It requires that any
person who wishes to perform any function related to the prevention,
protection, promotion or conservation of environment or to carry on business
related to –
a) Environmental impact assessment, environmental audit or
environmental monitoring;
b) Registration as environmental expert;
c) Environmental quality standards; or
d) Ozone depleting substances,
Hence shall be required to pay the fees prescribed in the Schedule to these
Regulations.

Commitment; The fees of which will be collected by the council shall

neither be refundable nor transferable. DF METAL MINING is aware of the
regulations and will be answerable for the charges prescribed in these
regulations in case it is proved guilt.

3.5.7 The Environmental Management (Hazardous Waste

Management and Control) Regulations, 2021
The regulations were made under sections 110, 128, 133, 135 and 230 of
EMA to control all categories of hazardous wastes and to the generation,
storage, transportation, treatment and disposal and their movement into and
out of Mainland Tanzania. Focus areas of the Regulations include:
i. Hazardous and toxic wastes (in general):
 Principles of environmental and sustainable development i.e.
precautionary principle, polluter pays principle and producer
extended responsibility guide any person generating, handling or
transporting or exercising jurisdiction on hazardous wastes.
 Duty to every person living in Tanzania to safeguard the environment
and to inform relevant authority on any activity and phenomenon
resulting from hazardous wastes that is likely to adversely affect the
environment and human health.
 Owner or controller of a facility or premises which generates
hazardous and toxic wastes adopt cleaners production principles
i.e. improvement of production process through conserving raw
63
 materials and energy, and monitoring the product cycle from
beginning to end to minimize the wastes generation.
 Occupier or operator of a hazardous waste management facility
should ensure hazardous wastes are handled and stored in a suitable
manner that ensures safety to the environment and human health
 Packaging of hazardous wastes should be in United Nations approved
containers or packages that is capable of containing or storing the
wastes, and container labelled in English or Kiswahili language affixed
onto it specifying identity of the waste, name and address of the
generator etc.
 Import into the United Republic of any hazardous wastes is not
allowed - a transit cargo of hazardous waste passing through the
United Republic for purpose of export or import shall not be unloaded
for repackaging.
 License to export hazardous wastes, approval of insurance for export
of hazardous wastes, issue of Prior Informed Consent document for
movement of hazardous wastes issued by Director of Environment. A
valid export permit issued by the Minister and a valid Prior informed
document issued by the designated authority of the receiving
country.
 Environmental inspector empowered to stop and inspect any vehicle
used for transportation of hazardous wastes; enter upon any
premises where hazardous wastes is stored, processed or disposed
of; ensure premises producing hazardous wastes are adequately
ventilated and fitted with air polluting control facilities.
 License for treatment or disposal of hazardous wastes application
accompanied by Environmental Impact Assessment Certificate and an
Emergency Response Plan.
 Establishment of a hazardous waste treatment plant or disposal
facility subject to EIA and renewal of a license subject to
Environmental Audit.
 Six month records and bi-annual reports of the licensed activity and
all related transactions kept by license holder and submitted to the
Director of Environment.
 Health care wastes: segregated at their point of generation; packed
in containers approved by ministry for health; transportation under a
permit issued by the ministry for health; and operator of a healthcare
waste treatment facility conduct an environmental Audit annually and
submit the audit report to the council.
ii. Electrical and electronic wastes separated from other type of wastes;
disposed separately into receptacles prescribed by the council or local
64
 government; person handlers of the wastes are supplied with appropriate
protective gears, trained in safe handling and equipped with waste
handling equipment.
iii. Pesticides management conducted in accordance with the Plant Protection
Act, Tanzania Pesticides Research Institute Act, Veterinary Act and Public
Health Act.
iv. Radioactive wastes managed in a designated sites or facilities in manner
approved by the Tanzania Atomic Energy Agency.
v. Industrial and consumer and chemical wastes managed in accordance with
the Industrial and Consumer Chemicals (Management and Control) Act.

Commitment: The proponent is aware of the importance of handling

hazardous wastes appropriately and includes such practices in its waste
management processes for both chemicals and other key pollutants
encountered in the mining site.

3.5.8 The Environmental Management (Solid Waste Management)

Regulations, 2009
The solid waste management regulations 2009 as amended by Government
Notice No. 190 published on 03/06/2016 The Environmental Management
(Solid Waste Management) (Amendment), 2016 were made under section
114, 115, 116, 117, 118, 119,120,121,122, 230 of the Environmental
Management Act, 2004. The regulations outline the requirements,
responsibilities and administrative mandates in management of various Solid
Wastes. Section 6 states that every person living in Tanzania shall have a
stake and a duty to safeguard the environment from the adverse effects of
solid wastes and to inform the relevant authority on any activity and
phenomenon resulting from solid waste that is likely to adversely affect the
public health and environment.
The second schedule to these regulations provides the details required for
any person who wishes to apply the licence for waste disposal while the first
schedule list all types of solid wastes, their treatment/recycling methods and
their anticipated final disposal methods.

Commitment: The execution of DF METAL MINING project will result to

production of various solid wastes which their management should adhere to
the requirements of these regulations and any other associated legislation to
ensure the environmental quality is maintained.

3.5.9 The Mining (Safety, Occupational Health and Environment

Protection) Regulations of 2010
65
These regulations set out procedures on safety, occupational health and
environmental protection to all mines and quarries during exploration,
evaluation, development, construction, production, closure, reclamation and
abandonment.
General Safety Procedures are described in Part III 20 (1)(3), including safety
precautions to be observed, while emergency preparedness as described in
Part IV, including industrial first aid and rescue.
More specifically, in terms of the regulations, the following are directly
applicable to construction, management and closure of a mine site:
 The Manager shall make an application for approval to construct
major impoundment, dam, or waste dump, complete all necessary
supporting documents, to the Chief Inspector and copies of the
complete application shall be sent to other relevant regulatory
agencies specified by the Chief Inspector.
 The Manager must ensure that no work is commenced on a major
waste dump, dam or impoundment without the written acceptance of
the design by the Chief Inspector and possession of all other
applicable permits and licenses.
 The Manager shall implement and maintain a monitoring program in
the design accepted by the Chief Inspector.
 Major waste emplacements and major impoundment or dams shall:
 Be designed by a qualified professional engineer registered according
to the Engineers Registration Act.
 Comply with the specifications established by the Chief Inspector.
 Prior to the abandonment of any impoundment, dam or waste dump,
the long-term stability of exposed slopes shall be assured to the
satisfaction on the Chief Inspector.
 The level of land productivity to be achieved on reclaimed areas shall
not be less than existed prior to mining on an average property basis
unless the owner, agent or Manager can provide evidence which
demonstrates to the satisfaction of the Chief Inspector the
impracticality of doing so.
 Waste dumps shall be reclaimed to ensure:
 Long-term stability.
 Water quality released from waste rock dumps to the receiving
environment is of a standard specified in to these Regulations.
 Land use and productivity objectives are achieved.

Commitment: With regard to closure of the mine: “all potential acid

generating material shall be placed in a manner which minimizes the

66
production and release of acids to a level that assures protection of
environmental quality.”

3.5.10The Mining (Mineral Beneficiation) Regulations, 2018

These regulations as amended by Government Notice No. 136, The Mining
(Mineral Beneficiation) (Amendments) Regulations, 2019 provide the detailed
regulatory requirements for the holders of a processing, smelting or refining
licence. According to Regulation 6, the holders of these licenses are entitled
to “carry on processing, smelting or refining operations in the specified area
of the licence. The Regulation also allows the holder, his servants and agents
to:
(a) Buy or otherwise acquire or to sell or otherwise dispose of minerals as
specified in the licence, and, for the purpose of carrying on business as
a dealer, to have possession thereof;
(b)Export minerals specified in the licence;
(c) Erect the necessary equipment, plant and infrastructure for the
purposes of his operations, transporting, dressing or treating the
mineral in his possession.
In addition to the obligations provided by Section 61(2) of the Mining
Act, 2019, Regulation 7(c) requires the holder to “stack or dump any
mineral or waste products in a manner provided by Environmental
Regulations under Environmental Management Act, 2004”. Further,
Regulation 8(1) requires the holder of processing, smelting or refining
licence to keep at the place of business a register in respect of each
variety of mineral and mineral products at such place of business or
otherwise in his custody. Copies of the true and accurate records must
be submitted in duplicate to the Commissioner on quarterly basis,
(8(3)). Regulation 9 gives the licensing authority the powers to
suspend the licence where the holder has been found in default,
served with a default notice and failed to respond within thirty days.

Commitment; The proponent will remain committed to the conditions given

in the processing license and all other directives issued by TMC.

3.5.11 The Mining (Mineral Trading) (Amendment) Regulations, 2012

These amendments were made to replace the first schedule of the Mining
(Mineral Trading) Regulations, 2010 on the various fees for dealing in
minerals. According to the regulations, applicants for dealer licence have to
pay $200 as application fees and $1000 for a licence to deal in gold, metallic
and colored gemstones. On the other hand, brokers pay an application fee of
TShs. 50,000/= ($31) and TShs. 200,000/= ($125) for the broker licence.
67
Both licences are renewable with a $100 charged for application for renewal
of dealer licence and TShs. 50,000/= ($31) for application for renewal of
broker licence. The fees for renewal of dealer licence is charged at $800 and
TShs. 160,000/= ($100) for the broker licence. Those wishing to export
minerals need to pay an application fee of $100 and $300 for those wishing
to import minerals into the country.

Commitment; There are other fees payable for those seeking special export
permits and for taking minerals out of the country.

3.5.14 The Environmental Management (Prohibition of Plastic

Carrier bags) Regulation, 2019
These Regulations shall apply to the import, export, manufacturing, sale,
supply, storage and use of plastic carrier bags within Mainland Tanzania. All
plastic carrier bags, regardless of their thickness are prohibited from being
imported, exported, manufactured, sold, stored, supplied and used in
Mainland Tanzania. Without prejudice to the provision of regulation 5, no
person shall sell or offer for sale beverages or other commodities wrapped in
plastics unless the nature of such commodities require wrappings by plastics.
No licensing authority shall, after coming into force of these Regulations,
register or issue a license or permit to any person intending to import,
export, manufacture or sell plastic carrier bags that have been prohibited by
these Regulations. butes, supplies, possesses and uses plastic bags and
plastic wrappings in contravention of this Part commits an offence and shall,
upon conviction be liable, in case of-
a) manufacturing or importation, to a fine of not less than twenty million
shillings but not exceeding one billion or to both
b) exportation, to a fine of not less than five million shillings but not
exceeding twenty million or to imprisonment for a term not exceeding
two years or to both
c) Storing, supplying and distributing to a fine of not less than five million
shillings but not exceeding fifty million or to imprisonment for a term not
exceeding two years or to both.
d) Selling, to a fine of not less than one hundred thousand shillings but not
exceeding five hundred thousand shillings or to imprisonment for a term
not exceeding three months or to both.
e) possessing and using to a fine of not less than thirty thousand shillings
but not exceeding two hundred thousand shillings or to imprisonment for
a term not exceeding seven days or to both.

68
Commitment: The execution of DF METAL MINING will adhere to the
requirements of these regulations and any other associated legislation to
ensure the environmental quality is maintained and does not use prohibited
plastic bags.

3.5.14
The Environmental management (quality standards for control of
noise and vibrations pollution) regulations (2015)
The regulation is formulated under sections 140, 141 and 230 of EMA for the
control of noise (loud, unreasonable, unnecessary on unusual) and vibration
pollution that annoys, disturbs, injuries or endangers the comfort, repose,
health or safety of others and of the environment. Focus areas include:
 Noise management by owner of machinery or occupier of facility or
premises to control noise and to install sound level meters for the
measurements and monitoring sound.
 Noise emission license issued by NEMC director general to owner or
occupier of premises whose work or activity is likely to emit noise in
excess of the permissible noise levels.
 Compliance order, protection order or stop order issued by NEMC or
any other empowered authority when any condition of any license or
permit has been breached or prevention orders and improvements
notice issued by environmental inspector to prevent noise and
vibration pollution in an amount ,concentration or manner that
constitute a risk to human health or environment.
 The minister may provide a reward to any person who will report an
incident of incidental, concealment or inadvertent emissions or noise
pollution or excessive vibration.

Table 2. 8: Maximum Permissible Noise Levels for Mines and Quarries

Column 1 Column 2

Facility Limit Value in dBC

1. For any building used as a hospital, 109dBC
school, convalescent home, old age home
or residential building.

2. For any building in an area used for 114dBC

residential and one or more of the
following purposes: Commerce, small-
scaled production, entertainment, or any
residential apartment in an area that is
used for purposes of industry, commerce
69
Commitment: From the reading in chapter four, the noise parameters were
within TBS maximum limits. Therefore the proponent shall ensure to regulate
the noise emission to be within the stipulated standards in mining area.

3.5.15
The Environmental Management and Pollution Control (Waste
Management) Regulation of 2010
Formulated under Sections Made under section 114, 115, 116, 117, 118,
119,120,121,122, 230 of EMA for the control of solid wastes management.
The regulation focus areas include: Use of approved receptacles.- (1) The
occupier of any premises shall be obliged to use approved receptacles by
Council or local government authority; (2) without prejudice to sub-regulation
(1), approved receptacles shall include standard metal dustbin, plastic
standard dustbin, plastic bags, papers bags, standard litter bins, standard
containers or skips and any other recommended receptacles ideal for the
locality.

The occupier who fails to-

Use approved receptacles for holding waste prior to disposal;
Ensure that reusable receptacle is kept clean and maintained in good
repair; or
Ensure that each waste receptacle is used in a way which protects the
contents from spillage, storm water, birds, flies or other pests and
vermin, commits an offence.

Commitment: the operation shall comply with this regulation for proper
environmental management i.e. Proper Solid waste management including
segregation, sorting and storage at site.

3.5 INTERNATIONAL AGREEMENTS, CONVENTIONS AND TREATIES

3.5.1 Africa Convention on the Conservation and Natural Resource
(1968)
This convention intends to promote conservation efforts by requiring
contracting States to adopt the measures necessary to ensure conservation,
utilization and development of soil, water, flora and fauna resources in
accordance with scientific principles and with due regard to the best
interests of the people. The proponent will support Tanzania’s commitment
by promoting conservation efforts in all of its operations.

3.5.2 Other Relevant convention to the proposed project

70
In the course of its operations, the proponent will ensure that the project
operation abides by other relevant International Conventions Ratified by
Tanzania include:
 ILO Convention: C138 Minimum Age Convention, 1973 (Ratified by
Tanzania (United Republic of) on 16:12:1998) which prohibits child labour.
The proponent shall ensure no child is employed to do any of its activities.
 ILO Convention: C148 Working Environment (Air Pollution, Noise and
Vibration) Convention, 1977 (Ratified by Tanzania (United Republic of) on
30:05:1983) which protects Workers against Occupational Hazards in the
Working Environment Due to Air Pollution and heat. The proponent shall
ensure workers are protected against occupational hazards.
 ILO Convention: C182 Worst Forms of Child Labour Convention, 1999
(Ratified by Tanzania (United Republic of) on 12:09:2001). The proponent
shall ensure no child is employed in its activities.

At international level EIA has been proposed as a tool for environmental

planning to ensure sustainable development. Tanzania has ratified or
acceded to a large number of international treaties and conventions.

3.5.3 UNITED NATION CONVERSION TO COMBAT DESERTIFICATION

(UNCCD)
This international community has long recognized that land
degradation/desertification is a major economic, social and environmental
problem of concern to many countries in all regions of the world. In 1977, the
United Nations Conference on Desertification (UNCOD) adopted a Plan of
Action to Combat Desertification (PACD). Despite this and other efforts, the
United Nations Environment Programme (UNEP) concluded in 1991 that the
problem of land degradation in arid, semi-arid and dry sub-humid areas had
intensified, although there were “local examples of success”. As a result, the
question of how to tackle desertification was still a major concern for the
United Nations Conference on Environment and Development (UNCED),
which was held in Rio de Janeiro in 1992.

The Conference supported a new, integrated approach to the problem,

emphasizing action to promote sustainable development at the community
level. At the Eighth Conference of the Parties in Madrid in September 2007,
the UNCCD entered a new phase with the adoption of the 10-year strategic
plan and framework to enhance the implementation of the Convention (The
Strategy). This new development has taken the Convention to new ground.
Most importantly, Parties have laid out a clear vision for a period of ten years
in The Strategy, which is to forge global partnerships to reverse and prevent
71
desertification and land degradation. These partnerships are also meant to
mitigate the effects of drought in affected areas. Coupled with the vision is a
Strategy mission: To provide a global framework to support the development
and implementation of national and regional policies that are to contribute to
the reduction of poverty.

The proponent is aware with the UNCCD mission to combat land degradation
and climate change issues around the world. The proponent intends to re-
vegetate the project area with native grasses and shallow-rooted shrubs that
will stabilise the surface against erosion and reduce water stored within the
cover. Water management systems will be reassessed following the
establishment of vegetation. The vegetation to be established across the
capped surface of the area will comprise a mixture of native and shallow-
rooted grass, shrub and tree species such as suitable Acacias. The exotic
grasses will be used to quickly establish a vegetation cover while the slower
growing native species become established.

3.6 INSTITUTIONAL FRAMEWORK

The Environmental Management Act (EMA, 2004) gives mandate to NEMC to
enforce compliance process. It empowers NEMC to determine whether a
proposed project should be subjected to an EIA, approves consultants to
undertake the EIA study, invites public comments etc. In carrying EIA review
NEMC carries site visits, convenes the Technical Advisory Committee (TAC)
meeting and advises the responsible Minister on issuing Environmental
Certificate. Continuously, NEMC is responsible for carrying out monitoring
and auditing of environmental performance of the project.

Currently the proponent has no clear identified institutional framework for

environmental management; however the proponent intends to establish the
environment unit that will be responsible for the coordination of
environmental issues and programmes at the project area. The unit will be
responsible for monitoring development activities of the mining site for
ensuring that implementation of the project is compatible with the principle
of sustainable development. The unit will ensure good cooperation of
individuals, communities, government agencies and non-governmental
organization concerned with the protection of the environment. Furthermore
the unit will be responsible to ensure that environmental concerns are
integrated in all aspects of company development projects and compliance
matters are well addressed. Lastly the unit will be responsible to develop
mechanism to enable the focal points to identify the key environmental

72
issues to be reported in a regular basis. This focal point will in future act as a
major source of information for the state of environmental report

Table 3.1 provides key institutions that have a role to play in as far gold ore
mining and processing is concerned.
Level Instituti Role and Responsibility Remark
on s
Nation Vice  Overall responsibility for planning and Environm
al President’ implementation on all environmental ental
s Office matters. Manage
(Division  Responsible for articulation of policy ment
of guidelines necessary for promotion and Act, 2004
Environm protection.
ent)  Issue general guidelines to sector
Ministries and coordinate all agencies
public/private institutions related to
environmental management.
 Facilitate civil society involvement.
 Advice the Government on legislative
measures related to management of
environment and on international
agreements in the field of environment.
 Monitor and assess activities being carried
out by relevant agencies to ensure that
the environment is not degraded.
 Prepare and issue a report on the state of
the environment.
 Coordinate issues relating to articulation
and implementation of environmental
management aspects of other sector
policies.

Director  Examine any matter, which may be Environm

of referred to it by the Minister or any sector ental
Environm Ministry relating to the protection and Manage
ent (DOE) management of the environment. ment
And  Advise the minister on any matter in Act, 2004
National connection with restocking and the
Environm limitation of stock numbers.
ental  Advise the Minister on matters relating to
Advisory watering, grazing and moving stock.
73
Level Instituti Role and Responsibility Remark
on s
Committe  Make recommendations to the Minister
e where there is degradation of the
environment.
 Receive and deliberate on reports from
sector ministries on the protection and
management of the environment.
 Review and advice on any environmental
standards, guidelines and regulations that
are to be made pursuant to the provisions
of the Act.
National In collaboration with other Ministries, the Environm
Environm Council has jurisdiction to: ental
ent  Carry on environmental audit as provided Manage
Managem under the EMA. ment
ent  Carry out surveys which will assist in the Act, 2004
Council proper management and conservation of
(NEMC) the environment.
 Undertake and co-ordinate research,
investigation and surveys in the field of
environment and collect, and disseminate
information about the findings of such
research, investigation or survey.
 Review and recommend for approval of
environment impact statements.
 Identify projects and programmes or types
of projects and programmes, for which
environmental audit or environmental
monitoring must be conducted under EMA.
 Enforce and ensure compliance of the
national environmental quality standards.
 Initiate and evolve procedures and
safeguards for the prevention of accidents
which may cause environmental
degradation and evolve remedial
measures where accidents occur.
 Undertake, in co-operation with relevant
sector Ministries programmes intended to
enhance environmental education and
public awareness about the need for
74
Level Instituti Role and Responsibility Remark
on s
sound environmental management as well
as for enlisting public support and
encouraging the effort made by other
entities in that regard.
 Publish and disseminate manuals, codes
or guidelines relating to environmental
management and prevention or
abatement of environmental degradation.
 Render advice and technical support,
where possible, to entities engaged in
natural resources and environmental
management so as to enable them to
carry out their responsibilities.
 Perform such other function as the
Minister may assign to it or as are
incidental or conducive to the exercise by
it of any or all of the functions provided
under this Act.
Ministry  Issue licenses (prospecting, Mining
of mining/quarrying, etc.). Act, 2010
Minerals  Oversee implementation of the Mining
Policy.
 Enforcement of laws and regulations for
mining/quarrying and protection of
environment.
 Environmental monitoring and auditing.
 Mining projects EIS and EMP approvals
(through a multi-sectoral committee).
 Mining/quarrying conflict resolutions.
Ministry  Enforce laws and regulations for water Water
of Water quality and utilization. Resource
 Issuance and regulation of water rights. s
 Enforce water and effluent discharge laws Manage
(standards, monitoring and regulation). ment
Act, 2009
Ministry  Issuing of Right of Occupancy. Land Act,
of Lands, Land use planning. 1999
housing  Valuation and compensation.
and
75
Level Instituti Role and Responsibility Remark
on s
human
settlemen
ts
Developm
ent
Ministry  Implementation of the Forestry Policy. In
of Natural Enforcement of laws and regulations for accordan
Resources forestry resources management. ce to the
and  Issuance of permits for exploitation of Forest
Tourism forest resources. Act, 2002
(Forestry  Issuance of permits to conduct activities in
Division) the forest reserve areas.
NGOs  National Environmental watchdog. Accordin
 Initiating dialogue on national g to civil
environmental concerns among society
stakeholders. rights
and
responsi
bilities
Region Regional  Responsible for coordination of all advice Environm
al- Secretaria on environmental management in their ental
Mwanz t respective regions and liaison. Manage
a  Regional Environmental Management ment
Region Expert. Act, 2004
 Responsible for advising the local
authorities on matters relating to
implementation and enforcement of the
Act.
 Link between the Region and Director of
Environment as well as Director General.
District Environm  Initiate inquiries and investigations about Environm
, Ward ental any allegation related to the environment ental
and Managem and the implementation or violation of the Manage
Village ent provisions of this Act. ment
Committe  Require any person to provide information Act, 2004
es or explanation about any matter related to
the environment.
 Resolve conflict among individual persons,
companies, agencies, non-governmental
76
Level Instituti Role and Responsibility Remark
on s
organizations, government departments or
institutions about their respective
functions, duties mandates, obligations or
activities under this Act.
 Inspect and examine any premises, street,
vehicle, aircraft or any other place or
article which it believes or have
reasonable cause to believe that pollutant
or other articles or substances believed to
be pollutants are kept or transported.
 Require any person to remove at own cost
any article or substance from any place
which it believes such article or substance
may be safely kept or destroyed without
causing harm to health.
 Initiate proceedings of civil or criminal
nature against any person, company,
agency, department or institution that fails
or refuses to comply with any directive
issued by any of such Committees.
NGOs/  Regional environmental watchdog. Accordin
CBOs  Education and awareness rising on g to civil
environmental management. society
 Stakeholders’ platform to be heard. rights
and
responsi
bilities
District Land  Land allocation and approvals Village
/ Local Allocation Land Act,
Committe 1999
e
District/  Extension Services. Environm
Ward  Advise committees and departments on ental
Functiona environmental matters. Manage
l  Promote environmental awareness. ment
Departme Gather and manage information on Act, 2004
nts – environment and the utilization of
Planning, resources.
Water,  Prepare periodic reports on the state of
77
Level Instituti Role and Responsibility Remark
on s
Health, the environment.
Communi  Monitor the preparation, review, and
ty approval of EIA of local investments.
Developm Review by-laws on environmental
ent, management and on sector specific
Natural activities related to the environment.
Resources
, etc.
Environm  Coordinating and advising on Environm
ental environmental policies and ental
Committe implementation obstacles. Manage
es  Promoting environmental awareness. ment
(District,  Information generation, assembly and Act, 2004
Ward & dissemination from any person.
Village)  Initiate inquiries and investigation on any
environmental disputes or violation of the
Act.
 Resolve conflicts among individual
persons, companies, agencies, NGOs,
Government Departments.
 Inspect any source of pollution in the area.
 Initiate proceedings of civil nature against
any person, company, and agency for
failing or refusing action under the Act.
Local  Local environmental watchdog.
Stakehold
ers
Councils  To oversee performance of the
(District, Environmental Committees (within their
Ward and jurisdictions).
Village)
NGOs/CBOs  Local environmental watchdog. Accordin
 Education and awareness raising gonto civil
local
environmental issues. society
 Local stakeholders’ platform for voice. rights
and
responsib
ilities
PROPO DF METAL EIA Study undertaking
78
Level Instituti Role and Responsibility Remark
on s
NENT MINING Project implementation
 Project monitoring and internal Auditing

CHAPTER FOUR:
4.0 BASELINE CONDITIONS
4.1 INTRODUCTION
This section describes the baseline conditions as they are related to the
physical, environmental, bio-environmental and social economic -
environment within core project area and the marginal zones. This sub-
section of physical, economic and social characteristics, infrastructures and

79
demographic characteristics are based on secondary data observation, while
the last sub-section including bio -environmental is based on the primary
survey data obtained during field work.
The level of details in the various sections depends on the interactions
between the project activities and the particular environmental aspect.
Information provided in this chapter will be superimposed onto the project
concept and components for impact identification, evaluation and
development of mitigation measures.

The major purposes of describing the environmental settings of the study

area are:

 To assess the existing environmental quality, as well as the

environmental impacts of the future developments being
studied;
 To identify environmentally significant factors or geographical
areas that could preclude any future development; and
 Additional purposes of the baseline studies are to provide
sufficient information so that decision makers unfamiliar with
the general location can develop an understanding of the
project need.
The environmental impacts are assessed for a project at a specific location to
establish baseline status and monitor the environmental quality prevailing in
the study area prior to implementation of the project. The environmental
status within the study area could be used for identification of significant
environmental issues to be addressed for assessment of the project impacts
(positive and negative) and suggest remedial measures thereof.

4.2 METHODOLOGY OF CONDUCTING BASELINE STUDY

The guiding factors of the present baseline study are the requirements laid
down by the National Environment Management Council (NEMC) and
guidelines as per the Environmental Impact Assessment and Audit
Regulation of 2005 as well as it amendment Regulation of 2018. The baseline
environmental monitoring has been carried for the period of three month
(January 2025 to March 2025). For the purpose of the EIA study, the general
impact zone for the proposed implementation shall confine within a radius of
10 km from the center of the project site and specific impact within the
project area.
 The Meteorological Data for this project has been collected from
secondary source;
 water quality samples were collected from the Lake;

80
  The land use pattern of the study area was assessed through Misungwi
District land office;
 Socio-economic data was collected from primary source through
Village -level surveys. Data was also taken from secondary sources like
Census of Tanzania 2022 and other demographical surveys; and
 Inventory of flora and fauna species present in the area was made
through field visits and surveys by ecologists and secondary data.

4.2.1 CRITERIA FOR BASELINE ENVIRONMENT STUDY

General study area and core study area has been classified within the IEA
study. The location of the baseline monitoring has been selected with
respect to established land use and environmental susceptibility of the
critical areas. The sampling locations have been selected on the basis of the
following factors:
 Predominant wind directions;
 Existing topography;
 Drainage pattern and location of existing surface water bodies like
rivers and streams; and
 Location of sensitive areas.

4.2.2 COMPONENTS AND PARAMETERS

Various components need to be studied during the baseline environmental
study. These components and parameters are used as the baseline
information and will be compared after the operation of an industry to see
the contribution of an industry to these parameters. The following are the
components and parameters that will be discussed further in this chapter;
 Physical Environment;
 Biological Environment; and
 Socio-Economic Environment.

Table 4.1 gives various environmental attributes considered for formulating

environmental baseline and gives frequency and monitoring methodologies
for various environmental attributes.
Table 4.1 Various environmental attributes
SN Attribute Parameter Source of Data
1. Land Use Trend of land use change Latest Satellite Imagery
for different categories and Top of sheet
2. Geology Geological history Secondary sources.
3. Soil Quality Physical and chemical Data collected from
parameters secondary sources and soil
sampling at one location.
4. Socioecono Socio-economic Based on field survey and
mic aspects characteristics data collected from

81
 of the study area secondary sources.

4.3 PHYSICAL ENVIRONMENT

4.3.1 Geographical and Administrative Location
Misungwi District is one of the five districts of Mwanza Region of Tanzania. Its
administrative center is the town of Misungwi. It is bordered to the north
by Nyamagana District and Magu District, to the east by Kwimba District, to
the south by Shinyanga Rural District, and to the west by Nyang’hwale
District and Lake Victoria.
4.3.2 Climate
4.3.2.1 Climate
The region experiences moderate temperatures between 22 oC and 30oC with
an average rainfall of 900mm- 1200mm per annum. Rainfall is fairly evenly
distributed with short rains from September to December, followed by a dry
spell from January-February before long and heavy rains set in between
March to the end of May.
4.3.3.2 Rainfall
The Region gets an average of 811 mm of rainfall per annum, which normally
rains from late September to January and between March and mid of May.
4.3.2.2 Wind characteristics
Wind speed is variable parameter but the site does experience winds
exceeding 20km/h which might affect any aspects of the project. The
dominant wind is in the northeastern direction. Presence of the conducive
climatic condition in the region, offers the production plant with the ability to
work in atmospheric friendly condition that can sustain the construction and
operation phases within the Plant. This wind system is coupled with an
almost complete clockwise current system that changes character with the
changing wind (TMA, 2024).
4.3.3 Geology, hydrogeology, Topography and Soil
4.3.3.1 Topography and Geology
Misungwi district comprises of land comprised of gentle sloping and its
topsoil is that of sandy. This favors the growth of varieties of crops such as
cassava, bananas, sweet potatoes, beans, groundnuts, paddy, maize, cotton,
coffee, millet, wheat, fruits, sisal, sunflower etc.
The Sailats Investment Mining Site is located on hills with elevations ranging
from 1232 to 1303 meters above mean sea level, with an average elevation
of 1268 meters. This is higher than the dominant terrain of the sub-
watershed (41 km²), which has an average elevation of 1175 meters, and the
larger watershed (720 km²), which averages 1194 meters above mean sea
level. The higher elevations predominantly cover the western part of the
watershed, ranging from 1177 to 1303 meters.
82
Soil
In Misungwi district the top soils are comprised of sandy soil throughout the
district. The soils in MWANZA region comprise those made of black cotton
soil, loam, sandy, sandy loam, and clay loam soil.
At site the soil is silt sand with brownish color.

Groundwater Character
In general, MWANZA Region falls in Lake Victoria Basin. Detailed studies
conducted on hydrology and geology of the area revealed that there are
several surface water bodies as well as groundwater bodies or surface-
groundwater interactions that might be impacted or influenced by the
project. However, no water table was encountered during the hydro
geophysical survey at the project area.

Large, near-surface ore bodies are excavated by forming an open pit. The
ore and non-ore materials (which include topsoil, overburden and rock) are
excavated using surface mining equipment, generally trucks and shovels.
The dimensions and size of each open pit are unique and depend upon the
ore grade and geometry, geologic structures, rock strength and topography.
The pit slopes are commonly designed in a system of steep slopes, typically
up to 30 meters high, between horizontal benches. The height of each
individual slope is principally dependent upon the size of excavation
equipment, geologic structures, and rock strength.

Currently at site there is a borehole indicating the availability of underground

water sources at site and as per hydro geological report for proposed site,
groundwater flow was primarily from northeast to southwest.

Water Management
The basis of the water management is in the design of a robust system, in a
manner that should allow for massive interruptions to the process and still
not affect the water management (Table 36). To ensure that water is
continuously managed, to a better than legally acceptable level,
management shall be constantly patrolling the site inspecting for leaks and
any early warning signs of leaks. Monitoring of the chemical contents of the
leach tanks will also be done.

Table 4. 2: Estimated water usage

Description: Water Requirement
( At full production) Cubic meters per month
83
 Leach tank water 15,500
Elution Section TBA
Domestic 500
Sub Total 16,000
Recycled water 13,700 – 15,000
Total Needed 1,300

 Groundwater Quality
For monitoring purposes, present groundwater quality of the sites must be
known. Usually, water quality/quality of water is perceived differently
depending on purpose of user. Water quality for industrial production may
not be suitable for domestic use. In this study, water from existing borehole
was tested to analyze its suitability for domestic use.
Water samples were collected on boreholes within the sites; Analyses were
carried out and Samples were measured against:
o Physical parameters such as Alkalinity (pH), Temperature, Dissolved Oxygen
(DO), Total Dissolved Solids (TDS) and Electrical Conductivity (EC). These
were measured on site;
o Bacteriology parameters such as Total coliform and Feacal coliform; and
o Chemical parameters such as Sulphide ( S2-), Iron (Fe2+), Manganese (Mn),
Sulphate (So42-), Ammonia (NH3), Fluoride(F-), Chloride (Cl-), Chromium
(Cr6+), Zinc (Zn), Copper (Cu), Nitrate (NO3), Phosphate (PO4), Calcium,
Magnesium and Total Hardness
o The standards to which the water samples were compared to are that of
Tanzania Bureau of Standards (TBS) and Tanzanian Temporary Water Quality
Standard. Result shows quality of the sites’ groundwater is acceptable for
domestic use

84
 Table 4. 3: Water quality tests results
Parameters Units Standard Sample 1 Sample 2
Results Remarks Results Remarks
Physical Analysis
pH - 6.5-8.5 7.31 Acceptable 7.42 Acceptable
Temperature ºC 20-35 25.8 Acceptable 23.5 Acceptable
Conductivity µS/cm - 122.4 Acceptable 123.4 Acceptable
Total Dissolved mg/l 1000 54.9 Acceptable 49.4 Acceptable
Solids
Turbidity NTU 15 0.48 Acceptable 0.46 Acceptable
Bacteriology Analysis
Total Coliforms count/100 0 0 Acceptable 0 Acceptable
ml
Feacal Coliforms count/ 0 0 Acceptable 0 Acceptable
100ml
Chemical Analysis
Sulphide (S2-) mg/l 0.50 0.041 Acceptable 0.055 Acceptable
Iron (Fe )
2+
mg/l 0.30 0.07 Acceptable 0.09 Acceptable
Manganese (Mn) mg/l 0.50 0.09 Acceptable 0.04 Acceptable
Sulphate SO4 2-)
mg/l 400 4.93 Acceptable 5.27 Acceptable
Ammonia (NH3) mg/l 0.5 0.08 Acceptable 0.02 Acceptable
Fluoride (F )
-
mg/l 1.5 0.97 Acceptable 0.98 Acceptable
Chromium (Cr ) 6+
mg/l 250 11.9 Acceptable 7.8 Acceptable
Zinc (Zn) mg/l 0.05 0.01 Acceptable 0.00 Acceptable
Copper (Cu) mg/l 0.50 0.03 Acceptable 0.01 Acceptable
Nitrate (NO3) mg/l 1.5 0.01 Acceptable 0.05 Acceptable
Phosphate (PO4) mg/l 30 12.5 Acceptable 9.3 Acceptable
Calcium mg/l 6.0 4.13 Acceptable 0.39 Acceptable
Magnesium mg/l 200 91.3 Acceptable 89.2 Acceptable

85
Total Hardness mg/l 150 37.6 Acceptable 36.1 Acceptable

86
4.3.4 Air Quality Measurements
Air Quality and Noise Levels Measurements:

Air quality measurement locations were selected across the proposed

project area to measure gaseous pollutants, particulate matters and noise
levels at the proposed area. Also the selection criteria for sampling
stations targeted the ambient air points such as working environment
around the proposed project site and the surrounding environment likely
to be affected.

Study Methodology
Ambient Pollutant gases and dusts Concentrations:
Levels of ambient gases from different points at site were measured using
GX 2003(Type B) Serial No. 166010241RN, Portable Multi Gas Detector-
71-0028RK, dust levels (Suspended Particulate Matter less than 10
micron, PM10) were measured using Dust Track II, Model 8530, With
Calibration Standard GB40493-2009, JJG 693-2004, Date 02-Dec-2014
based on equipment’s manufactures procedures and with reference to ISO
11041-1: 1996. At each point of measurement, multiple measurement of
Carbon dioxide(CO2) in % Carbon monoxide(CO) in mg/Nm 3,Oxygen(O2) in
%,Hydrogen sulphide(H2S) , Oxide of nitrogen(NO and NOX) in
mg/m3,Sulfur dioxide(SO2) in mg/m3 and PM10 in mg/m3 . In order to get
actual composition of ambient air in particular point, several readings
were recorded while the device valves pointing to all directions (north,
west, south and east) to obtain its average value,
The implementation of the project is likely to affect the ambient air of the
proposed site due to the activities going to be conducted during the
project phases from mobilization phase to construction phase.

Noise Levels and Vibration:

Noise and vibration levels were both measured by using CEMDT-8852, IEC
61672-1 Class 2 Data logger. On noise level Meter range; 30dB – 180dB
(A).On taking measurements, the device-meter scale was set to the ‘A’
weighed measurement scale, which enables the device to respond in the
same manner as human ear.
During measurement ,the device were fixed/and or held approximately
1.5m above the ground and at least 3m away from hard reflecting surface
or objects. Noise levels were recorded at each identified station mean
values were calculated and then compared with local standards and
international guidelines. The study took place on 17 January 2025
between 09:30am to 05:00 pm
The level of the noise is likely to be affected by the project activities such
as the movement of vehicles and other operating machines. Hence the
EIA report has provided guideline on how to deal with the noise at the
project site.
Atmospheric Conditions:
During sampling of data the sky was partly cloudy, temperature was 21 oC,
Wind speed was 15km/h and direction was ESE, while chance of rain was
0%, and humidity was 74%.

Results:
Air quality survey was conducted at different stations at the site as
indicated in tables below for ambient air quality and noise levels.
A general picture of the project area air quality can be drawn from the
results of the particulate matters, ambient gases and noise levels
measured from different location within and outside the site. All results
were compared with Tanzanian guidelines on ambient air quality
standards which indicate that all measurements sampled during the study
(ambient gases and Particulate matters and noise levels) were below
prescribed TBS/WHO limits levels
Table 4. 4: Average values of Particulate Matter (PM10) around
the proposed project site
CO
CO AMBIEN SO2 NO NOx
MEASURE O2 2
[mg/m T TEMP. [mg/m [mg/m [mg/m3
D POINT [%] [%
3
] [°C] 3
] 3
] ]
]
20.9
Point 1 - - 20.30 - 0.01 0.03
0
20.9 0.03
Point 2 - - 20.25 - 0.02
0
20.9 0.03
Point 3 - - 20.20 - 0.02
0
20.9
Point 4 - - 20.60 - 0.01 0.03
0
20.9 0.02 0.03
Point 5 - - 20.60 -
0
20.9 0.02 0.03
Point 6 - - 20.20 -
0
20.9 0.02 0.03
Point 7 - - 20.20 -
0
20.9
Point 8 - - 20.10 - 0.01 0.03
0
20.9 - - 20.06 - 0.01 0.01
MEAN
0
HIGHEST LIMIT
(TANZANIA 10.00 0.12
STANDARD)*

Table 4. 5: Average noise levels recorded at the proposed project

site
POINT NOISE LEVEL, dB(A)

78
 OVER
Reading Reading Reading Reading OVER 90
NO. MEAN 85
1 2 3 4 dB(A)
dB(A
48.3
1 48.40 48.50 47.90 48.40 NO NO
0
46.0
2 46.20 47.80 43.60 46.60 NO NO
5
51.8
3 51.50 51.60 52.80 51.40 NO NO
3
55.1
4 55.50 55.40 55.80 53.70 NO NO
0
47.7
5 48.20 47.70 48.10 46.90 NO NO
3
57.6
6 59.80 56.80 56.30 57.80 NO NO
8
69.8
7 69.70 74.70 68.90 66.00 NO NO
3
54.7
8 55.80 53.90 56.00 53.20 NO NO
3
63.1
9 64.30 65.70 65.30 57.30 NO NO
5
61.1
10 56.80 61.80 57.80 68.20 NO NO
5
55.5
MEAN NOISE LEVEL NO NO
5

79
4.4 BIOLOGICAL ENVIRONMENTAL OF THE PROJECT SITE
The rationale of management of biodiversity is to enhance
maintenance of ecosystem functioning. Animals and plants provide
the biological mechanism for the filtration of dirty water, or
reconditioning of polluted soil. Biodiversity conservation and
management therefore is the crucial aspect of maintenance of the
ecosystem services that are essential for the life support of plants,
human and other animals. All components of the ecosystems (physical
environments, flora and fauna) of a site are related and interdependent.

The recent activities by artisanal miners in the nearby area have greatly
reduced local fauna and flora. Widespread tree felling (for shaft building,
building poles and fuel wood), digging of pits, noise, etc. substantially
reduced the suitability of the area for wildlife by substantially degrading
the original Combretaceous woodland habitat. As a result, only those
species which were able to survive in edge situations, or in close proximity
to humans, have persisted

The project area lies within a thicket and savannah area that is relatively
flat and lightly treed relative to other parts of the country. Current
vegetation types include dwarf Acacia wooded grassland; Combretum
coppicing open bushland (recovering from extensive clearing activities);
disturbed Combretum open shrubland, heavily disturbed areas covered in
fast colonising weeds; riparian vegetation and cultivation / settlement
areas. The only mammalian species identified within the project area of
management concern was the vervet monkey (Cercopithecusaethiops),
which is a widespread species in Tanzania. Likewise only one reptile, the
Nile monitor lizard (Varanusniloticus), was identified which is of
management concern, whilst no amphibians of such a nature were
identified.

The project activities are likely to affect the species available at the site
during mobilization phase, hence the report has guided the proponent on
environmental management during operation phase and decommission
phase.

4.5 DEMOGRAPHIC CHARACTERISTICS

As of 2022, the population of Misungwi was 467,867. The customs and
norms of indigenous tribes found in the district do resemble and have the
same originality though the existing differences are due to subjection of
economical and developmental changes. Shilalo ward had a population of
17,606 people in 2022 (NBS, 2022)

80
Presence of high population offers the project with man power especially
the unskilled labors who will be sourced from the community in vicinity to
the site.

4.6 SOCIAL ECONOMIC ENVIRONMENT

4.6.1 Main economic activities
Most people in Misungwi District are employed in the private sector, then
followed by self-employed while the rest are employed in the public
sector. The majority of the residents are street vendors, service and shop
sales workers, craftsmen, fisheries, livestock keepers and farmers.There
are 2 irrigation schemes and small plots for agricultural purposes
occupying 22% of the District total area. Others have small gardens
around their houses in which various vegetables and root crops are grown
for family food and the surplus for income generating.

Ikungumhulu Village has different economic structure and activities. The

main economic activities practiced in area mainly mineral processing
with few people engaging in agriculture and livestock keeping. Agricultural
activities which mostly of maize , cassava and sweet potatoes are
practiced in areas close to water sources and area where mineral
processing activities have not yet been established. (Misungwi DC Profile;
2013-2020)

The company shall employ about 40 workers; hence they shall

contribute employment opportunities within the district.

4.6.2. Road network

There is a paved road trunk T8 from Shinyanga to Mwanza which passes
through Misungwi district from south to north. The Central line railway
from Tabora to Mwanza passes through the district from east to west and
there is one train station within the district’s boundaries at Fella village.

About 58.1 percent of road network in the region is passable throughout

the year. The road network measures 8,019.57 kilometers, and is graded
into four categories, namely trunk roads (7.3%); regional roads (5.8%);
District roads (45.1%); and feeder roads (41.8%). The road surface type in
the region shows that 4.7 percent is tarmac, 25 percent gravel, and 70.3
percent is earth (Misungwi DC Profile; 2013-2020).

The establishment of the project emphasis on the development of

infrastructures such as roads.

4.6.3 Trade and commerce

81
The villagers engage with trade and commerce whereby mostly human
needs are found. Different trade and commerce are observed through
the amount of buying and selling of different categories of
commodities ranging from shops and kiosk, which are scattered all
over the area. Since the area is close to Kahama town about 22 km,
other needs of large demands are obtained there. The trade and
commerce play crucial role in employment creation and income
generation in the area especially for the minority who does not engage
directly into mineral processing practices but indirectly through supportive
services to miners. (Misungwi DC Profile; 2013-2020)

4.6.3 Mining
The district is potentially rich in mineral resources as it possess
substantial deposits of gold. At present, only small scale artisanal mining
is carried out at villages in Misungwi with potential (Misungwi DC Profile;
2013-2020).
The propose project will be dealing with mining activities hence it has
direct impact to mining activities of the district.
4.6.4 Energy
The district is connected to national electricity grid. The distribution lines
are passing along the proposed site. (Misungwi DC Profile; 2013-2020).
Although people utilize solar energy and diesel generators in case of
power outage.

The proposed project shall use TANESCO power and alternative generator
for power supply to run the mining site operations.

4.4.5 Communication
The Council is also accessible through various communication network
such as Vodacom, YAS, Airtel, TTCL, Halotel, Zantel and Airtel.

4.4.6 Water supply

There is the existing distribution metered water network that covers most
parts of Misungwi District. Current metered customer connections serve
about 50% of the population of Misungwi. The connections are reported
to be in good condition.

Most parts of Misungwi District have water supply systems, with domestic
points available in the majority of villages. Approximately 50% of the
population benefits from tapped water provided by RUWASA (Rural Water
Supply Authority). While funding for further expansion is limited, the
existing infrastructure demonstrates progress in water accessibility. The
expressed desire for more widespread water services, as noted in the
Consensus Workshop of May 2022, highlights the need to build on these

82
achievements and explore opportunities for further investment in water
supply systems across the district.
Source: (Misungwi District strategic plan 2015/16-2020-2022)

The water will be sourced from RUWASA distribution line system to be

used during construction and operation phase.

4.4.7 Sanitation services

Most of ward residents; means of sanitation is use of pit latrines. This is
due to lack of sewerage system. There are no waste water services which
are supposed to be. Also there are less use of septic facilities which would
have been supported.
The project will use simple squatting toilets, hand wash basins and shower
heads for sanitation

4.4.8 Solid wastes management

Most of solid wastes being produced are organic wastes from domestic
and other small business centers. There is no proper recording
ascertaining data to verify amount of the wastes from these sources due
to nature of settlement and activities which depending on natural
processes like biodegradable process of wastes.

4.4.8 Health, education and other systems

Misungwi has one district hospital, one health centre and a dispensary
within the ward and there are a total of 611 primary schools in Mwanza
region, out of which 576 are public schools and 35 are private schools.
There are 3 vocational training centres, two of these VCTs are government
owned and one is privately owned. (Misungwi DC Profile; 2013-2020)
The company shall use the available health services for workers’ health
care or during accidents and sickness.

4.5 Waste management

4.5.1 Solid Waste Management:
The area where the proposed project is to be set, use informal practise of
solid waste management by dumping pit. Solid wastes which will be
generated from the Mining shall be collected in located waste bin and
shall be disposed to approve dumping place by the district.

4.5.2 Existing Liquid Waste Management and Sanitation Situation

The District Council is also responsible for liquid wastes collection and
disposal. The district does not have a waterborne sewerage system
and disposal of wastewater and excreta is based on onsite sanitation
method.

83
Extensive use is made of cesspits, soakage pits, septic tanks and pit
latrines. The underlying soil is mainly pervious, but there are certain areas
where the water table is high or rocks occurs and thus there are problems
associated with using such a system. The district Health Office reported
that the residents of the district use traditional pit latrines, and
septic tanks with soak away pits although no data exists in to show
the distribution in numbers (or percentages) of these facilities.

The proposed project will use toilets constructed septic tanks and soak
away pit for sanitary effluents

4.9 Community Safety and Security

The implementation of the project may positively/negatively impact the
community. Positively includes the community HIV/AIDs training, safety
and environmental conservations trainings, improved health services at
the dispensaries and health centers in the vicinity of the project.
Negatively the host community is likely to be affected directly/indirectly
with the dust from the operations, noise and vibrations. The project
construction contractors may come into contact with the nearby villages
where by social sexual relations may arise. It should be bared in mind that
individual characteristic differ from one person to another and may be
affected by the existing environmental conditions and community around.
It should be bared in mind that Mwanza Region is associated with
immigrants from neighboring countries of Rwanda and Burundi hence
HIV/AIDs spread is inevitable. Awareness to both workers and the hosting
community is essential to avoid unsafe sexual intercourses.
Furthermore the public is likely to be involved in hazards associated with
mineral processing Project. Sources of hazards include road accidents,
public-company conflicts, bribes, and sabotages, movements of vehicles,
transportation of materials, and transportation of workers to and from the
project site. The potential hazards include vehicular-vehicular conflicts,
vehicular-pedestrian conflicts, over speeding on the public roads, dust,
noise and vibrations, community exposure to gas and fumes from vehicles
and water pollution.

CHAPTER 5
5.0 STAKEHOLDER CONSULTATION AND PUBLIC
CONSULTATION
5.1 STAKEHOLDERS PARTICIPATION IN THE EIA PROCESS
Stakeholder consultation is necessary to be conducted during scoping
study because the impacts of the proposed development may influence
the surrounding in one way or another. It is therefore, compulsory to seek

84
the opinions of the neighbors, in relation to the development of the
proposed project. Section 89 of the Environmental Management Act (EMA,
2004) provides directives on public participation and its importance in the
EIA. Regulation 17 of the EIA Regulations (URT, 2005) provides further
details and procedures for public participation in the EIA process.

5.2 STAKEHOLDERS IDENTIFICATION

Stakeholders include individuals, groups or organizations that might be
affected by or might affect in one way or another (positively or negatively)
the proposed project. They are found both at National, regional and local
levels and range from government authorities, private to local
communities. The main objective of stakeholder identification process was
to establish responsible decision making authority or authority with
delegated responsibilities. The project proponent is required by the law to
consult with stakeholders on the preparation the EIA and to disclose to the
public the results of the EIA process.

Continued consultation is also required during construction and operation

phases of the project. The responsible decision making authority, as well
as other relevant authorities with responsibilities, interests or special
expertise relevant to the proposal have been directly contacted, in order
to exchange and collect information and comments. This exercise enables
to identify policies, legal or administrative constraints that may exist, as
well as determining the major concerns of these various authorities whose
interests may be affected by the proposed project.

5.3 PUBLIC PARTICIPATION PROCESS

Several methodologies were used during the stakeholder consultation
process. First, the fieldwork which is necessary to formalize and record
public opinion about the potential impacts of the project was undertaken
by EIA team of experts. Key informant interviews and issuance of
questionnaires were conducted to seek the public opinion. The EIA experts
explained the structure of the proposed development to the identified
stakeholders and responded to their questions as appropriate. At the
same time, the EIA experts also inquired of the local environmental
history of the site and adjacent areas in order to identify potential
environmental impacts. The exercise was conducted through interviews
with key informants, field surveys and discussions. A questionnaire was
developed to capture the concerns, comments and issues that the
neighbors and major stakeholders have regarding to the proposed mining
and processing plant project. A list of participants during public
participation exercise was prepared and signed by the participants and
has been attached as part of this chapter on the report.

85
Table 5. 1: Principle stakeholders identified
Stakeholder Potential institution / group / Consult
category individual ed
Institutional Mwanza Regional Mines Office √
arrangement Misungwi District Council √
according to EMA Lake Victoria Basin Water Board √
Cap 191. OSHA Lake Zone (Mwanza Office) √
Affected Area: √
Ward and Village officials and
residents

5.4 IDENTIFICATION OF STAKEHOLDERS’ CONCERNS

Stakeholders pointed out a number of issues and concerns. Raised issues
were cross checked through discussions with involved individuals or
groups. Details of stakeholders concerns recorded during consultation are
as pointed out in the table below,

86
Table 5. 2: Stakeholder consulted, their views and responses
Name: RICHARD CHARLES
Institution: MISUNGWI DISTRICT
Position: DEMO
Issue Concern Raised/Remarks EIA RESPONCES
 Ensure proper management of waste (solid and  The proponent will follow all procedures
liquid) that are provided so as to conserve the
 Ensure proper management of storm water-runoff environment before and during the project
 Establish strong cooperate social responsibility CSR implementation.
every year.
 Ensure proper management of chemical and
hazardous waste
 Establish environmental restoration program e.g.
tree planting
Name: SALVIO MAIGE
Institution: MISUNGWI DC
Position: LAND OFFICER
Issue Concern Raised/Remarks
 Local small scale miners will benefit from this project  The proponent will follow all the land rules,
as it will improve production of gold and hence the regulations and procedures during
Government will also benefit from more revenues development activities before
generated. The local citizens around the area will commencement of project activities
benefit from improved economic activities in the area
surrounding the project. The licences involved in the
project are free from any disputes. The project is
recommended to proceed while adhering to all
environmental laws and procedures.

87
Name: PROCHECE MAGAYANE
Institution: OSHA - LZ
Position: OHI
Issue Concern Raised/Remarks
 Construction phase  The proponent will register the project to
I. The proposed project must be registered to OSHA OSHA and attain a certificate of registration
and ensure it attains the certificate of registration  The proponent will ensure proper
i.e. the contractor must be registered conduction of the baseline risk assessment
II. Conduct the OHS baseline risk assessment and and ensure that it covers both phases of
ensures it covers both phases of the project, the project
prepare and communicate the OHS policy to  The proponent will ensure provision of
workers welfare facilities, working tools and
III. Ensure the provision of welfare facilities, washing appropriate PPE’s to all workers and
facilities, first aid facilities, working tools (proper) enforce their proper usage
and appropriate PPE’s to all workers and enforce  The proponent will submit architectural
its proper usage drawings to OSHA office for rectification of
IV. Submit (contractor) the architectural drawings / safety inputs before the project
planning of the project to OSHA office for construction begins
rectification of safety inputs before the project  The proponent will ensure proper medical
construction begins examination check-ups to all workers is
V. Ensure medical examination / check-ups to done
workers is done (OHS medical examination pre  The proponent will ensure there is a
entry) prepared working procedure which will
VI. Ensure there is prepared working procedures ensure the reduction of risks of the
which will ensure the reduction of risks at the proposed project site
proposed project site
VII. Appoint the OHS representatives and first aiders
and establish the OHS committee which is

88
 required to document the minutes properly

Name: JUDITH SWAI

Institution: GCLA – LAKE ZONE
Position: CHEMIST
Issue Concern Raised/Remarks
 The proponent should be registered as user of  The proponent will register the premises
chemicals as per [ industrial and consumer prior to commencement of operations
chemical Act 2003] requirement by register of  The proponent will ensure that the
chemicals before commencing the production chemical storage facility complies
 There should be chemical store for chemicals according to the stipulated regulations
according to the compatibility  The proponent will ensure proper
 The proponent should have qualified chemical management of chemicals, obsolete /
supervisor for managing all activities involving expired chemicals and waste water
chemicals resulting from processing area as well
 There should be a well-constructed drawing as empty chemical containers
system for collecting chemical contaminated  The proponent will adhere to the industrial
water around the premises to prevent and consumer chemicals (management and
environmental contamination control) Act no. 3 of 2003 and its
 The proponent must ensure proper regulations of 2020
management of chemicals, obsolete / expired
chemicals and waste water resulting from
processing area as well as empty chemical
containers

Name: JEREMIAH S. HANGO

Institution: MBOGWE MINING COMMISSION
Position: RMO

89
Issue Concern Raised/Remarks
 Local small scale miners will benefit from this project  The proponent will adhere to all
as it will improve production of gold and hence the environmental laws and procedures during
Government will also benefit from more revenues project implementation and operation
generated. The local citizens around the area will
benefit from improved economic activities in the
area surrounding the project. The licences involved
in the project are free from any disputes. The project
is recommended o proceed while adhering to all
environmental laws and procedures.
Name: Dr. RENATUS SHINHU
Institution: LVBWB
Position: BASIN WATER DIRECTOR
 Concern Raised/Remarks
 The proponent should apply for Ground water permit  Proponent will comply to the Water
from LVBWB for the drilled borehole to be drilling Resources Management Act No.11 of
according to Section 54 of the water Resources 2009 and its amendment No. 8 of 2022.
Management Act No. 11 of 2009  The proponent will provide baseline
 The proponent should ensure that project activities data for water quality before
will not cause any pollution to the water resources commencement of the project
both surface and ground water according to section
39 of the Water Resources management Act No. 11
of 2009 and its amendment No. 8 of 2022
 The proponent should apply for a discharge permit if
discharge of waste water to the environment will be
necessary in according to section 63 of the water
resources management act No.11 of 2009
 The proponent should engage approved professional

90
 person (APP) to the construction of the leach pad
according to section 86 of The Water resources
management Act No. 11 of 2009
 The proponent should submit leach pad designs
(drawings, designs assumptions, calculations, test
results and specifications) for approval in ministry of
water before the construction begins according to
section 88 of the water resources management Act
No. 11 of 2009
 The proponent should ensure proper management of
storm water by constructing a drainage system at
the project area and make sure contaminated waste
water is separated from storm water
 Waste tailings storage areas should be lined to avoid
ground water and surface water pollution
 Proponent should provide baseline data for water
quality before commencement of the project
 Proponent should make sure solid waste, liquid
waste, hazardous waste, hydrocarbons and other
waste rocks are managed properly throughout the
project lifespan
 The proponent should comply with the water
resources, management act No. 11 of 2009 and its
Amendments No. 8 of 2022
Name: ASF VERONICA J. AGRICOLA
Institution: FIRE AND RESCUE FORCE
Position: DFO
Concern Raised/Remarks
 Construction drawings should be submitted the  The proponent will submit construction
91
 Fire and Rescue Service office in order to be drawings at the fire and rescue force
given advice on prevention and precautions offices to be given advice on prevention
against fire disasters and safety in general at the and precautions against fire disasters and
workplace. safety in general.
Name: LAULENSIA C. LUKANYA
Institution: IKUNGUMHULU VILLAGE
Position: VEO
Concern Raised/Remarks
 Should continue with project implementation.  The proponent will consider the
 The proponent has no conflicts with the procedures for the environment and the
community. health of the relevant community
 The proponent should engaged in village  The proponent will provide employment
development for purpose of maintain good opportunities to the residents of
relationship. Ikungumhulu Village
 The investor will consider mining
procedures for the development of the
village by participating in development
activities

92
5.5 STAKEHOLDERS AWARENESS
The Stakeholders consultation process revealed that most of stakeholders
consulted from the national to the local level were aware of the proposed
mining development. Generally, they anticipate the proposed project to
improve the economic growth through tax/revenue collection, enhance
improvement of social services as well employment opportunities to the
people.

5.6 PROJECT RECEPTION AND ACCEPTANCE

There were no major issues raised by the respondents in line with the
proposed mining development, most of stakeholders consulted had no
objection provided the project proponent complies with the available rules
and regulations. However, the issues highlighted as being the key
potential negative impacts have been highlighted noted and their relevant
mitigation measures have been provided. The names of involved
stakeholders and their signatures are attached at the end of this report.

93
 CHAPTER SIX:
6.0 ASSESSMENT OF IMPACTS AND IDENTIFICATION OF
ALTERNATIVES
6.1 INTRODUCTION
The assessment of the socio-economic environment of the proposed
mining project has been to investigate potential issues concerning
implementation of the proposed mine and processing plant, particularly in
relation to local, national economic development and impact on the
environment. These issues were mainly raised in the course of, walk
through assessment, discussions with a wide variety of interested and
affected parties, at local, district, regional and national levels. These
issues may be clearly definable potential impacts, less clearly definable
primary or secondary impacts in other cases, or even generally expressed,
poorly defined concerns of interested parties. Some of these issues and
possible impacts may be minimal or even insignificant.

Concerns are sometimes based on inaccurate perceptions, particularly

where detailed information is not available, easily accessible or
understandable to interested parties. Perceptions are, however,
extremely important and need to be addressed whether they are accurate
or not, since it is on this basis that interested and affected parties will
make value judgements and decisions concerning the proposed project
and its potential impacts. The identified impacts are also based on project
phases namely: -mobilization, operation as well as decommissioning
phase.

6.1 Approach for assessment of significance

This section of the report assesses the significance of the environmental
impacts that have been identified by the study team which conducted the
environmental and social impact assessment process. The team members
conducted literature reviews of available information related to the site
conditions and with respect to similar project operations prior to visiting
the site. Most of the members of the team visited the specific project site
Ikungumhulu Village, Shilalo Ward, Misungwi District in Mwanza Region.
The team spent the time on site gathering information through field
studies. The combined site visit by all specialists assisted in integration of
ideas and findings between the specialists. The role of each specialist was
to collect sufficient data to assess the environmental and social impacts.
In order to achieve this, the EIA team assessed the environment as it
existed and secondary data from published and unpublished sources.

6.1.1 Classification of Environmental Impacts

An environmental impact is any change to the existing condition of the
94
environment caused by human or external influence. Impacts may be
positive (beneficial) or negative (adverse). They may also be direct or
indirect, long-term or short-term in duration, and wide-spread or local in
the extent of their effect. Impacts are termed cumulative when they add
incrementally to existing impacts. For the proposed development, it is
expected that, most of potential environmental impacts associated by the
project will arise in the operations phases. Thus the stage has positive
and negative impacts.
6.1.2 Methodology used to assess the significance of impacts
The approach used to assess the significance of the potential impact and
later assess the effectiveness of the mitigation or enhancement measures
is implying the application of significance rating to each impact based on
objective criteria, such as magnitude, extent and duration of such impact.
This assisted to yield a final evaluation of the significance of impacts
before and after mitigation. The technique of impact rating reduces the
number of variables which need to be considered by the decision maker,
when providing pertinent information about the implications of the
proposed project.

6.1.3 Direct and Indirect Impact

Impacts can be classified as being either direct or indirect.
 Direct impacts are those occurring at the time when the project activity
takes place, an example of direct impact would be noise pollution at
the work site resulting from the Machines operation;
 Indirect impacts are those that might be occurring in future and / or at
a considerable distance apart from the project site i.e. climate change.

6.1.4 Magnitude of Impact

The magnitude of an impact takes into consideration of the extent as well
as the anticipated size, or scale, of the impact. The magnitude can be
further classified as low, medium and high.
 Low– Means localized and relatively small scale impacts;
 Medium –Means moderate impacts, for this project, the one that can go
beyond the site and
 High – Means large scale coverage for example beyond the entire Town
and the region.

6.1.5 Duration and Frequency

The duration and frequency of an impact considers both the length of time
the impact is expected to prevail, as well as the likely frequency that the
impact is expected to occur. Under this category, the impacts can be
classified as low, medium and high. The impact is said to be low under this
classification system when takes relatively short term/ duration and has
low frequency events; medium, when is considered to be of moderate
95
term and has also moderate frequency event and high, when takes
relatively long terms and high frequency events.

6.1.6 Temporary or Permanent

In this sub category, the impact can be classified as temporary – when
takes shorter term and generally reversible (here short term may include
the period of construction phase may be a period of 1 – 2 years) and
permanent, when takes longer terms, and may be reversible or
irreversible.

6.1.7 Sensitivity
The sensitivity of an impact reflects the fragility and adaptability of the
receptor. The degree of sensitivity is usually classified also as Low,
medium and high. Under this classification category, the impact is said to
be low when the impact is easily adaptable, affects non-fragile systems
and has minor effects; and medium, when is adaptable, has predictable
outcome and modest effects; and high, when is characterized with low
adaptability, and affects fragile systems and has unknown effects.

6.1.8 Probability
The probability of the impact reflects the likelihood of the impact to occur.
For example, the probability of localized noise occurring due to operation
of the project is high, i.e. it will almost certainly happen. Here, a simple
classification considers impacts that might have low, medium and high
probability. Low – means unlikely chance of occurrence; Medium – means
there is a chance of occurrence; and High – means it’s probable chance of
occurrence.
6.1.9 Potential for Mitigation
The potential for applying mitigating measures to an impact reflect the
likely level of effort required and the availability of appropriate measures
that can be adopted. This can be, low (or zero) when there are no
mitigation measures available, and/or typically involve high cost
measures; medium – when there is moderate potentials for mitigation and
generally involves moderate effort; and high, when high potential and
generally involves relatively minor or low cost effort. In addition, other
criteria considered to evaluate whether its adverse or not adverse impacts
are significant that may also include environmental loss and deterioration
such as:
 Social impact resulted directly or indirectly from environmental
change
 Non-conformity with environmental standards, objectives and
guidelines
 Likelihood and acceptability of risk

96
 6.1.10 Impact Significance
The purpose of this EIA study is to identify the significant impacts related
to the project or activity under consideration and then to determine the
appropriate means to mitigate those which are negative and enhance
positive impacts resulting from the project. Thus significant impacts can
be determined, not necessarily in order of importance but as being those
which:-
 Are subject to legislative control;
 Related to protected areas or to historically and culturally
important areas;
 Are of public concerns;
 Are determined as such by specialists;
 Trigger subsequent secondary impacts;
 Elevate the risk to life threatening circumstances; and
 After sensitive environmental factors and parameters
Significance ratings based on synthesis of the above criteria (only for
negative impacts):
 Not significant: Impact not of significance hence no mitigation
action, should not influence the decision to approve the proposed
development.
 Low: No mitigation action required. Impact should not influence the
authorization decision. However monitoring of such impacts may be
necessary to make sure they remain low over the lifetime of the
project.
 Medium: Mitigation action is required. Impact should influence the
decision to authorize the development.
 High: Mitigation action is required. Impact should influence the
decision for authorization. Authorization granted only when
effectively mitigated

Table 6. 1: Assessment of significance

Criterion Descriptio Possible Results
n Term Description Score

Magnitude An Very High Extreme effect – Where 5

of the indication natural, social functions
Impact of the or processes
severity of permanently cease.
the impact, High Severe effect – where 4
either natural, cultural or
positive or social functions are
negative altered to the extent
that they temporarily
cease.
Moderate Moderate effect – the 3
97
 affected environment is
altered but natural,
cultural or social
functions and processes
are not affected.
Very Low Minimal or negligible 2
effect.
Unknown Magnitude of the impact 5
unknown.
Scale of An National Affects the resources of 5
the Impact indication the country
of the Regional Affects the resources of 5
geographic the region
al extent of District Affects the resources of 4
the impact the district
Local Affects the project area 3
and surrounding villages
Site Localized, confined 2
specific within the license area.
Unknown Extent of the impact 5
unknown
Duration of An Permanent Will remain 5
the Impact indication permanently
of the Long tern Extends into the post- 4
duration or closure phase, but not
time over permanently.
which the Medium During the operation life 3
impact will term of the project
be Short term Shorter than the 2
experience operational life of the
d. project
Transient Very short duration 1
Unknown Duration of the impact 5
is unknown

Table 6. 2: Assessment of significance in terms of exposure and

Likelihood
Criterion Descriptio Possible Results
n Term Description Score
Discrete Prolonged
Event exposure
from a
single
activity or
event.

98
Exposure to An Very High Daily or Exposure in 5
Impact indication continuous perpetuity
of the High Weekly/ Continuous 4
activity that once per exposure
may cause week into closure
the impact, or post-
or the closure
continuity phases
of the Moderate Monthly/ Continuous 3
exposure once per exposure
month during
constructio
n and
operation
phase.
Low Bi-annually Continuous 2
exposure
throughout
one phase.
Very low Annually or Prolonged 1
less exposure
frequently yet finishes
before end
of a phase
Unknown Frequently Continuity 5
activity exposure
unknown unknown
Probability An Highly Very likely or certain 5
the assessment likely
Occurrence of the possible Likely to occur 4
degree of Unlikely May possibly occur 3
certainty Highly Unlikely to occur 2
associated unlikely
with Unknown Very unlikely to occur, or 1
potential almost impossible
impact Probability of the 5
occurrence unknown

The consequence of the impact was then determined by adding the scores
for magnitude, scale and duration of a particular impact. The addition of
the scores for exposure and probability of occurrence or an impact was
used to determine the impact’s likelihood of occurrence. The description
for the Consequence and Likelihood of the impact are then expressed,
99
based on the obtained score as either very low, low, moderate, high, very
high.

Table 6. 3: Consequence Assessment according to score / scale

Consequenc Magnitude + 3-4 5-7 8-11 12- 15
e Scale Duration 14
Very Low Modera High Very
Low te High
Likelihood Exposure + 2-3 4-5 6-7 8-9 10
Probability Very Low Modera High Very
Low te High

Table 6.4: Matrix of Potential Interactions of the Project with the

Environment
Activities Associated

Water and
Atmospher

Environme

Environme
Terrestrial

ent on the
Resources

Groundwa

Environm
with the Project

Land Use
(Surface

Project
Effects
Health
Water

and

of
ic

Construction
Site Preparation 1 0 1 1 0 1
Physical Construction and
Equipment Installation 1 1 1 0 1
Commissioning 1 1 0 1 0 0
Operation
Operation of Facilities 2 1 0 1 0 0
Maintenance 1 0 0 1 0 1
Project-Related Emissions
and
2 1 0 2 0 0
Decommissioning and Abandonment
Decommissioning of 1 0 0 1 0 0
facilities
Accidents, Malfunctions, and Unplanned Events
Process Upsets 1 0 0 0 0 0
Fires 1 1 0 2 0 1
Vehicle Accidents 1 0 0 2 0 0
All other Accidents,
Malfunctions, and
1 0 0 1 0 0
Unplanned Events

6.2 MOBILIZATION/ PREPARATION/ CONSTRUCTION PHASE

Assessment of the impacts during mobilization and construction phase has
been based on transportation of construction equipment’s to the site,

100
construction of mine site, camp and other associated structures. In the
course of construction the following impact is anticipated:

6.2.1 Noise pollution due to movement of construction equipment

Movement of trucks loaded with construction materials such as sand and
aggregates, cement, stones etc. will cause noise, generation of dust and
emission of noxious gases mainly from exhausts of engines. These
pollutants may degrade local air quality, cause disturbance to workers
within the factory and road users along the route used by heavy
machines.

6.2.2 Occupational health and safety of construction workers

During construction, workers will be subjected to situations that could be
detrimental to their health and safety. A few examples include:
 Injuries caused by handling of construction equipment;
 Emissions of dust from clearing and excavation works and fumes
from vehicles and other machinery; and
 Noise and vibrations from construction equipment

6.2.3Loss/disturbance of biodiversity due to vegetation clearance

This might result to the changes in species and habitat diversity due to
removal of vegetation for site clearance and construction of associated
facilities such as workers camps, fence and access roads. This activity will
limit growth of vegetation cover that are living organisms necessities and
cause migration to other areas.

6.2.4 Soil Erosion and Land Degradation

Due to working activities soil in the area where the project will take place
will be affected mainly due to excavations. In this case the soil with
extracts of humus shall be removed. Also equipment to be engaged in
activities might cause light contaminations of soil. This is due to leakage
of fuels and other liquid form equipment. In addition, improper location of
construction materials might be associated with land degradation and
other soil quality impairment problems.

6.2.5 Increase pressure on environmental resources

Loss of woody vegetation and loss of species diversity is of global
environmental concern. The very large number of artisanal miners,
entrepreneurs supplying a wide variety of services to miners, and
associated family members that inhabited the area in the vicinity of the
Ikungumhulu Village, had a very marked impact on local vegetation
resources.

101
The area originally consisted of woodland savannah with many large trees.
Today the area largely consists of scrubland, although there has been a
substantial increase in the growth of woody vegetation since the
departure of the artisanal miners in 1996. The influx of newcomers
associated with the commercial mining operation will again place
increased pressure on the local environment.

The laying down of the mining, processing site and other supporting
facilities in the area will cause reduction in the number of species. This
project will take about 2-3acres of the area, if not observed it may have
impacts to the surrounding environment.

6.2.6 Water (surface and ground) Contamination

The water resources of the area will be susceptible to contamination. If
that happens then it will affect the ecological processes of the area.
Despites its seasonal flowage, the seasonal streams found nearby the site
about 1km at the project area is dependent on supply of water for local
communities living nearby the project area. Also water might be
contaminated due to oil spills.

6.3 OPERATION PHASE

6.3.1 Impairment of local air quality from dust and fumes
The atmospheric pollution created as a result of mining, crushing and
grinding of ore in the plant and the surrounding area as a fugitive dust.
It is generated at virtually every phase of the operation if weather
conditions are not conducive. Assessing the impact of fugitive dust from
tailings is essential in the design and planning stages in order to obtain
a balance between development and the environment.

In the project area tailing operations there will be numerous sources of

fugitive dust: dozers, graders, loading shovels, haul trucks, dumping
operations, exposed areas and light or medium duty vehicles
amongst others. The extent of air pollution will depend on the effects of
climatic conditions such as rain, wind and drying capacity of the air.

The dust could be hazardous to the workers, and villagers (depending on

the wind regime) and also on vegetation and surface water in the general
area. Much of the vegetation cover in the area will be caked with dust;
this may effectively kill the plants since it stops photosynthesis.
However the project is of small scale and the impacts related to
dust pollution is expected to be of minimum impact. The impact is
considered to be negative of long-term duration and moderate
significance.

102
6.3.2 Losses and misuse of toxic chemicals due to theft of
chemicals and other inputs
Due to the current growing need of cyanide unless security measures are
put in place, there is always a risk for theft. Theft of cyanide and the
associated chemicals and inputs for the heap leaching Plant will not only
present a loss to the company, but also potential dangers associated with
misuse of the toxic chemicals. Misuse may lead to deaths as
simultaneous ingestion, contact or inhalation of cyanide may easily
reach acute poisoning levels. Theft incidents may contribute strongly
to the commonly negative opinions about mining companies held by
local communities. However, the company is aware of the high risk
of theft and security measures to protect the company property from
theft will be developed and implemented on site and thus reducing the
potential for this impact. This impact is considered direct, long-term,
adverse, irreversible and of high significance.

6.3.4 Potential for pollution of soils, surface and underground

water from chemical spills
Cyanide releases during transportation are infrequent, but continue to
occur in the world. Such releases may lead to contamination of soils,
surface and underground water. The exposure of humans to cyanide
spilled during transportation is one of the major risk scenarios with respect
to cyanide use in mining or other related activities. Contamination of
surface water may lead to destruction of aquatic life, birds and animals. In
underground water, cyanide may lead to increased soluble heavy metals.
This impact is considered direct, long-term, adverse, irreversible and of
moderate significance.

6.3.5 Air pollution from release of noxious gases in case of fire

Fire is a potentially very serious problem to the safety of
transported cyanide, personnel and the surrounding environment as it
produces noxious gases. However, the measures highlighted above that
will be taken during transportation of cyanide will minimize the
likelihood of the occurrence of this impact. This impact is considered
direct, long-term, adverse, irreversible and of moderate significance.

6.3.6 Poisoning by hydrogen cyanide gas built-up in the store

Contacting cyanide with corrosive, acidic or explosive materials as well as
water can accelerate the generation of hydrogen cyanide gas. For a
cyanide storage facility that is not adequately ventilated to disperse any

103
built up of hydrogen cyanide gas, the produced gas can accumulate to
dangerously high levels. This presents a potential risk to personnel.
However, Project owners i.e. the company will employ experienced
personnel for handling and application of cyanide at the plant site. In
addition, ,the company is aware with the “The "International Cyanide
Management Code for the Manufacture, Transport and Use of Cyanide in
the Production of Gold" (Cyanide Code)” and hence will abides by the
principle of the code in terms of storage. As such, the construction of the
cyanide storage facilities will be carried out in accordance to
standards and hence minimize the potential for poisoning from cyanide.
This impact is considered direct, long-term, adverse, irreversible and of
moderate significance.

6.3.7 Health impacts from accidental spillage of cyanide from

storage facilities
Accidental spillage is an emergency incident that may occur at the
Processing Plant site and that may lead to operators being exposed to
cyanide as well as environmental pollution through seepage and drainage.
Cyanide spillage as an emergency will require the mobilization of
personnel and resources for cleaning-up. This is one of the most
hazardous operations in the handling of cyanide that can cause serious
cyanide contamination risks to workers.

Therefore, workers and emergency services should respond effectively

and efficiently. However, the project proponent will prepare emergency
preparedness procedures for handling various incidents e.g., spillage of
chemicals and hydrocarbons, floods, fire, drought and others. These
procedures will be updated to take into consideration the special needs of
cyanide handling and in line with the “International Cyanide Code”. This
impact is considered direct, short-term, adverse, irreversible and of
moderate significance.
6.3.8 Health impacts to workers from acute exposure to cyanide
Cyanide poisoning through inhalation of cyanide gas, dust or mist,
accidental ingestion or consuming materials containing cyanide or
absorption through skin following skin contact can cause several health
effects including death. The poisoning action of cyanide is the similar
regardless of the route of exposure. Cyanide has been used for more
than 100 year for the extraction of gold. Although it is a highly toxic and
that must be used with great care, it is rarely a cause of accidental
deaths. Enforcing strict usage of personal protective equipment (inclusive
of special suits, head gear, etc.), automation of most handling activities
and restriction of entry in cyanide handling area, will ensure minimization
of this impact. This impact is considered direct, long-term, adverse,

104
irreversible and of moderate significance.

6.3.9 Potential impacts to wildlife from spillages

Exposure of cyanide in solution through consumption of surface water is
the main exposure route for most animals affected by cyanide
poisoning, but concurrent exposure through inhalation and skin
absorption may also occur. Cyanide spillages may end up in the drainage
system and to surface water bodies and streams. Furthermore, animals
may consume cyanide inadvertently in tailings slurry or sediments.
Cyanide poisonings most frequently affects birds and fish as they
are the most sensitive aquatic organisms to cyanide. However, it is
planned that the cyanide containing tailings leaving the plant will have
cyanide concentration of not more than 0.2mg/l. This is well below the
Tanzanian standards of 0.5mg/l (Maximum Permissible Concentrations for
receiving water) for WAD Cyanide. It has been established worldwide
that cyanide concentration of up to 0.5mg/l have no impact on
fauna and especially on birds. Internationally, up to 1mg/l concentration
of total cyanide in water is allowed (see the World Bank Standards, 1998).
This impact is considered indirect, long-term, adverse, irreversible and of
moderate significance.

6.3.10 Potential for contamination of surface and groundwater

from spillage and seepage
Any spillages of cyanide may be washed down by storm water to end
up in surface water sources. However, handling of cyanide with the
processing plant will be carried out in bunded areas where all the spills
can be contained within the plant area. Potential areas for spillage would
include the bursting of the tailings transportation to the stockpile area.
This impact is considered indirect, long-term, adverse, irreversible and of
moderate significance.

6.3.11 Contamination of sediments and down-gradient soils

through cyanide seepage
Cyanide seepage through sediments and down-gradient soils will cause
the contamination of the two media. Since down-gradient soils and
underground sediments are not exposed to the atmosphere and therefore
do not provide conducive environment for natural degradation of
cyanide, they can act as reservoirs of cyanide and the dissolved metals
and continuously continue to contaminate underground water. However,
as indicated above, the concentrations of cyanide in the material delivered
from the processing plant would be very low and unlikely to cause any
contaminations. This impact is considered indirect, long-term, adverse,
irreversible and of moderate significance.

105
6.3.12 Potential for surface and groundwater pollution from acid
drainage from processed tailings
The deposition of tailings in the tailings dumping area will be permanent
because the area will be impermeable to water and air and there appears
to be no risk of solution migrating into sub-dam soils. Therefore, the
tailings present a potential problem for acid drainage and seepage. Once
the tailings deposited they are exposed to the elements as they are not
covered with water. Hence, there is no barrier to prevent rapid oxidation
of the tailings and the generation of ARD. If subsequent disposal layering
is not managed correctly then ARD can be a serious problem.
The company will conduct trial tests on different rock materials and sizes
with potential for acid generation in order to develop strategies for the
management of the ARD. This impact is considered direct, long-term,
adverse, irreversible and of moderate significance.

6.2.13. Health related hazards due poor management of waste

water from latrine
Waste water to be generated includes grey and black water (toilets) and
cleaning which will be collected in septic tanks on-site and soak away pit,
alternatively it can be collected by cesspit emptier to District waste water
stabilization pond for final disposal. Wastewater if not managed and
disposed properly, waste water would pollute the environment especially
ground water resources at the site. This impact is considered direct, long-
term, adverse, irreversible and of moderate significance

6.3.14. Health hazards and nuisance due to poor solid wastes

management
During operation phase, potential impacts on the environment may
be associated with the handling, storage and disposal of waste material
due to human consumption. Most of waste materials will be in the form
of solid wastes which will include garbage (from onsite food serving)
and rubbish (i.e. bottles, plastic materials, drums, containers,
polyethylene bags, packaging materials etc.), If not managed and
disposed properly, solid wastes would pollute the environment especially
ground water resources at the site. This impact is considered direct, long-
term, adverse, irreversible and of moderate significance

6.3.15 Impacts of Acid forming rocks

The potential for acid mine drainage is a key question. When mined
materials (such as the walls of open pits, tailings, waste rock, and heap
and dump leach materials) are excavated and exposed to oxygen and
water, acid can form if iron sulfide minerals (especially ‘fool’s gold’) are
abundant and there is an insufficient amount of neutralizing material to

106
counteract the acid formation. The acid will, in turn, leach or dissolve
metals and other contaminants from mined materials and form a solution
that is acidic, high in sulfate, and metal-rich (including elevated
concentrations of cadmium, copper, lead, zinc, arsenic, etc.) Leaching of
toxic constituents, such as arsenic, selenium, and metals, can occur even
if acidic conditions are not present. Elevated levels of cyanide and
nitrogen compounds (ammonia, nitrate, and nitrite) can also be found in
waters at mine site, from heap leaching and blasting. Acid drainage and
contaminant leaching is the most important source of water quality
impacts related to metallic ore mining.
6.3.16 Ergonomic hazard
At workplaces, it usually happens that workers suffer stress injuries from
working too long without proper rest or it may occur due to postures in
which their bodies are oriented or from positions from which they work.
Known problems due to unhealthy ergonomics include backache, neck
ache, finger numbness for both feet and hands, and with prolonged
situations, repetitive strain injuries (RSI).
These impacts cause inefficiency at work, muscular problems and even
permanent body damage. This impact is considered localized, medium
term and of medium significance.

6.3.17 Lighting and air stress hazards - dust allergy

Exposure to environments with limited light conditions for prolonged
durations and under inadequate ventilation may cause serious eye
damage or blindness, brain stress, accumulation of particulate matter in
the respiratory pathways, and even allergies in individuals who are
hereditary allergic to very fine dust with certain chemicals or metals. This
impact is considered localized, medium term and of medium significance.

6.3.18 HIV/AIDS and STDs

It is not very common in small workplaces, but chances may still exist that
the people coming from different backgrounds will find their way into this
area as jobseekers. Promiscuous behaviours and alcoholism may also
dominate especially due to raised incomes and therefore speed up the
spread of sexually transmitted diseases including HIV/ AIDS and syphilis.
This impact is considered localized, medium term and of medium
significance

6.3.19 Electric s
Electric equipment’s need proper management otherwise may cause
electric shock due to improper management. Hence maintenance has to
be done frequently to avoid electric shock. Poor ventilation within the
building can also led to heat stress and cause uncomfortably during the
107
work. This impact is considered localized, medium term and of medium
significance

SOCIO–ECONOMIC ASPECTS
6.3.20Contribution to government revenues
The project is expecting income tax. This will be achieved at a full
operation capacity of the plant. Also the project is expecting to pay
loyalties when exporting the gold at the estimated rate of 7% of the
value of exported gold. All these will increase direct foreign
exchange earnings on gold sales and through leverage the increase
contributes to other potential financial structures. The overall taxes
accompanying the project are estimated at 30% of the profit and this will
enhance government revenue collection. Therefore this impact is
considered positive, long term and of high significance.

6.3.21 Support to local social services

Mineral Processing project will create basic infrastructure facilities like
road, water supply and communication network during implementation of
the project. This is in response to the company policy and programmes to
assist social and economic development for local communities. The
project proponent also will consider as a priority provision of contribution
in improving social, health and sanitation facilities like schools,
dispensaries, water wells and toilets. These infrastructure facilities would
help in overall development of the area. This impact is considered
positive, long term and of moderate significance.

6.3.22 Employment and training

The development of the mining industry is often credited for generating
new employment in the area. The project will employ Tanzanian
professionals, technical and labour force for its work programme. It is
estimated 50 local people will be employed on full time basis. The project
also will conduct in house training whereby the employees will be
trained for the processing and recovery method. This impact of
employment and training is considered positive, long term and of
moderate significance.

6.3.23 Improve gold processing best practices

The proposed mining and processing plant will accomplish this impact by
benefit to more than many people who will be employed and use the
facility on best practices and the same number of people will benefit from
increased production, as well as enable individuals to start another
business there by contributing significantly to the national income. People

108
will also be able to sell their dormant heaps of tailings from their small ball
milling sites. The impact is positive, long term, high significance.

6.3.24 Economic development

Newcomers attracted to the area by the mining development have and
will contribute to a consumer market, stimulating economic activity and
accelerating economic growth in the area.

The injection of wages into the local economy by those who will be
employed in constructing the mine and those employees who will run the
mine in future, will promote trade in consumer goods and the
establishment of entrepreneurs.

Low levels of skills and literacy possessed by the local population will
restrict their ability to realise employment opportunities offered by the
mining development and will also reduce their ability to seize
entrepreneurial opportunities. The implementation of appropriate training
and capacity building programmes could be used to ameliorate this
problem. Economic activities associated with the mining development will
promote increased monetization of the local economy.

Mining development in Misungwi District provides a unique window of

opportunity for economic development on a district and regional level. For
an area such as Ikungumhulu Village, where economic development has
been limited, the successful establishment of commercial mining
operations has the potential to have a substantial beneficial long term
impact through:
 Direct employment opportunities, to the people;
 Indirect opportunities, for example, the greatly increased demand
for goods and services by paid employees of the mine and its
contractors; and

6.3.25 Infrastructure development

Infrastructure improvements associated with the mining development,
such as roads, are likely to significantly influence future settlement
patterns in the area, affecting the course of local and district
development. In the case of the recently upgraded Village road, a strip
development settlement pattern is likely to emerge.

Population influx to the vicinity of the mine and social change effected by
the mining development could necessitate the establishment of currently
absent law and order facilities, such as police posts.

109
Housing mine employees in existing nearby villages could be an important
means for the mining operation to contribute to local economic
development, particularly if local households and CBO’s are directly
involved in the planning and construction of housing.

Sitting and development of infrastructure can be used as a useful tool to

influence settlement patterns (e.g. provision of roads, water, schools,
etc.). These “pull factors” could be used to encourage settlement of
newcomers at Shilalo Ward (the central Ward village) rather than at
Ikungumhulu Village, which is immediately adjacent to the mine.
Encouraging settlement away from the mine boundaries will reduce
potential conflicts between the mine and local households, and will
stimulate development of other nearby communities, thus contributing to
a distribution of benefits.

The sitting of any new infrastructure and services will have a direct effect
on neighbouring communities and may encourage other activities to take
place.

6.3.26 Social conflict

Indefinite or “grey” land use boundaries (between villages, between
households, and between villages and the mine) and issues concerning
use of land may provide potential cause for social conflict. Competition for
economic resources such as arable and grazing land has and will be
affected by the resettlement of households as dynamics change between
different households.

Availability of mine employment opportunities is presently one of the most

frequently stated issues in local villages. Any perceptions that jobs have
not been allocated fairly may lead to conflict. Population influx to the area
could cause an increase in crime, violence and social conflict.

6.3.27 Population movement

The creation of economic opportunities and welfare services associated
with the mining development will result in an imbalance in the regional
context. The mining operation is likely to provide a more attractive
economic and social environment than surrounding areas, resulting in
population movement to the vicinity.

At present it is likely that most settlement of newcomers will be in or near

Ikungumhulu, adjacent to the mine. The development of a large
settlement immediately adjacent to the mine could result in a number of
problems (control of land use, development of informal settlement,
increased local pressure on natural resources, etc.). At present there is
110
difficulty in controlling the establishment of households near to the
airstrip. It may be preferable to encourage settlement at Ikungumhulu,
200m from the mine. Siting and provision of infrastructure and services,
or the upgrading of existing facilities, could be effectively used as “pull
factors” to influence settlement in this area.

6.3.28 Social welfare

The construction of the mine at the project area will generate greater
household incomes, directly through the provision of jobs and
entrepreneurial opportunities and indirectly through multiplier effects,
thus promoting welfare in the local area. Newcomers attracted to the area
by the mining development will exacerbate the level of social ills in the
area including sexually transmitted diseases, crime, teenage pregnancy,
etc.

An increase in road accidents on the access road is likely to occur as a

result of an increased number of vehicles and high speed traffic. There
are currently no speed control measures and very few road signs on the
upgraded road to Ikungumhulu. The improved road from Ikungumhulu to
Misungwi centre has already stimulated trade and provided access for
rural communities to facilities available in Misungwi area.

The employment of local workers in a large commercial operation will

improve the local skills base and will help develop a local vision for
entrepreneurial and other development opportunities.

Heightened commercial activity in the area will result in a steady increase

in the availability of non-biodegradable consumer goods. The welfare
impact of this increased availability will be positive in terms of addressing
local needs, but negative in terms of waste material created by disposal of
these products.

Local economic development associated with the operation of the mine

site could provide opportunities for individual development,
entrepreneurial activity and improvement in household incomes. An
important issue is that there is presently no district or regional
development plan for the area and without funding and an agency for its
implementation, the opportunities for such integrated development may
be missed. A structure plan has to be prepared for future development of
the village area. Aspects of this structure plan has to be realistic and
attention has not been given to linkages within the District

111
6.4 DECOMMISSIONING PHASE
The project might remain in operation for not less than 11years .However,
there will come a time when the mineral deposit be diminished and
deemed unsuitable for the mining activities to continue. This is what is
meant by decommissioning phase. Cessation of operations of the
proposed project may also set in anytime due to financial challenges, high
operating costs, decision of the investor to change the line of business etc.
If this happens environmental as well as socio-economic impacts may
occur.

6.4.1 Pollution of surface and groundwater (cyanide spills)

Demolition activities of the mineral Processing Plant may result in spills of
cyanide solutions from the various storage and processing utilities within
the plant. The spilled cyanide may be washed down by rains to
contaminate the downstream water sources. Similarly, the spilled cyanide
may seep through the soils and lead to contamination of the groundwater
sources. However, the plant infrastructure will be located in a bounded
area where all the spillages can be contained and collected for
controlled disposal. The entire floor within the plant will be cemented
to minimize the potential for soil contamination and seepage into
groundwater. This impact is considered direct, short-term, adverse,
reversible and of moderate significance.

6.4.2 Healthy hazards to workers from demolishing work

Demolishing works will involve activities that may generate substantial
amounts of dust and may also pose workers to risks of accidents. Pulling
down of plant structures, storage tanks for various chemicals,
engineered trenches, the floor, sumps and other structures will all lead to
generation of dust, noise and may cause accidents to operators. Fumes
that might have accumulated in tanks and pipes may be released and
thus cause harm to workers. This impact is considered direct, short-term,
adverse, reversible and of moderate significance.

6.4.4 Increased sediments load from erosion

Sedimentation problems can result from erosion of the processed tailings,
access roads and from the tailings sediments within the site. The
rehabilitation at site will involve planting of vertiva grass and allowing
other indigenous grass to grow between the vertiva rows. It is planned
that the top of the tailings will be covered with topsoil and planted with
trees and grass. However, Misungwi District in general weather does not
hinder the fast growth of the planted vegetation. This may result in
erosion during the wet seasons from the uncovered patches. However, it is
planned that the planted vegetation will be watered by using a bowser

112
truck to support growth of the vegetation. This will provide quick soil cover
and thus minimize the potential for erosion. This impact is considered
direct, short-term, adverse, reversible and of low significance.

6.4.6 Loss of employment opportunity

The proponent will prepare workers to be employed anywhere else in the
Heap leaching Plant through provision of extensive training in modern
exploration and mining techniques. Proponent will ensure that all
employees are members of the Pension Fund and the employees should
ensure that the developer’s contributions are made. In time of
decommission of this project, the company may consider its employees in
development of new projects as well as for those skilled Tanzanian miners
and minerals processors.

6.4.2 Socio-economic impacts related to decommissioning

6.4.2.1 Loss of employment to workers
If for whatever reason the project is closed down, the people employed by
the project will lose their jobs. This will have significant adverse impacts to
these people and their dependants.

6.5 PROJECT ALTERNATIVE

In EIA process, consideration of project alternatives is critical in ensuring
that the Proponent and decision-makers have a wider base from which
they can choose the most appropriate option. To be able to make better
and informed decision, it’s important to consider alternatives that can
enable achievements with no or less negative effects, these alternatives
will be discussed from environmental and socio-economic perspectives.
Based on identified project issues and foreseen impacts, the following
alternatives have been provided for consideration

The AfDB EIA Guidelines states that project `options` should be provided,
within the constraints of the aim and broad economic, technical and
environmental factors. The available options should be considered in
terms of size, technology, layout, raw materials, energy sources or
products. Alternatives (the term for project options used by the World
Bank) should include a:

“Systematic comparison of the proposed investment design, site

technology, and operational alternatives in terms of their potential
environmental impacts: capital and recurrent costs, suitability under local
conditions and institutional training and monitoring requirements. For
each of the alternatives the environmental costs should be quantified to
the extent possible and economic values should be attached where

113
feasible. The basis of the selection of the alternative proposed for the
project must be stated.”

Since the proposed activities are being conceived near the site of other
similar operations, the choice of alternatives is limited. For each
alternative presented it is indicated whether the alternative can be
considered most feasible in environmental, economic and socio-economic
terms.

The few available alternatives were then systematically evaluated against

each other in terms of their environmental impacts, mitigation measures
and residual impacts. The alternatives were also compared in terms of
the most pertinent environmental factors: impacts on land, construction
and operation impacts and economic characteristics. As a result of this,
the preferred alternatives were selected.

6.5.1 No Project Alternative

The No Action Alternative in respect to the proposed project implies that
the status quo is maintained. This option is most suitable alternative from
an extreme environmental perspective as it ensures non-interference with
the existing conditions. However, the need for such development is high
and the anticipated insignificance environmental impacts resulting from
construction have already been experienced. This option will however,
involve several losses both to the project proponent, the community at
large and Government. The property will remain under-utilized or
neglected. The No Project Option is the least preferred from the socio-
economic and partly environmental perspective due to the following
factors:
 The economic status of the Tanzanians especially local people would
remain unchanged;
 The local skills would remain under-utilized;
 Reduced interaction both at local, national and international levels.
 No employment opportunities will be created for hundreds of people
who will work in the motor vehicle service project area; and
 Increased poverty and crime in Misungwi district due to unemployment.

From the analysis above, it becomes apparent that the No Project

Alternative is not the appropriate alternative to the local people, and the
Government of Tanzania. This alternative describes a situation where the
proposed development fails to be implemented .In case this happens,
positive impacts associated with the proposed development will not

114
accrue to the stakeholders, the development consultants, contractors and
suppliers of materials. However, from an environmental conservation
perspective, this alternative will be beneficial in the sense that any
potential negative impacts associated with the project will be avoided. The
“No Action Alternative” should not be adopted, as we need to encourage
development so long as it is undertaken on a sustainable basis as per the
environmental management plan developed in this report. In addition,
adopting the no action alternative will mean that the existing shortfall in
health facilities’ needs will continue to prevail unabated.

6.5.2 Alternative site

Relocation option to a different site is an option available for the project
implementation. At the moment, there are no alternative sites for the
proposed development (i.e. the project proponent doesn’t have an
alternative PL). This means that the proponent has to look for the PL if
relocation is proposed. Looking for the land to accommodate the scale and
size of the project and completing official transaction on it may take a long
period.

In addition, it is not a guarantee that such site with gold deposits would be
available. It’s also worth noting that the said project is already underway
in terms of seeking development approvals in various government
departments. The project proponent would spend another long period of
time on design and approvals of the plans by the relevant government
departments. The project design and planning before the stage of
implementation would call for cost; already incurred in the proposed
development i.e. whatever has been done and paid to date would be
counted as a loss to the proponent. The other consequence of this is that
it would discourage both foreign and local investors especially in the
mining sector. In consideration of the above concerns and assessment of
the current proposed site, relocation is not a viable option.

6.5.3 Alternative Design and technology

The design and technology of open pit mining as opposed to underground
mining that was selected proved to be the most feasible. It provides
sufficient space requirements and facilities to meet the objectives of the
project. The proponent settled on this design and technology of open pit
mining as a unique that best meets the objectives. However the
proponent has not ruled out employing underground mining method as
well.
 Open Pit Mining- this is the type of mining in which the ore deposits
extends very deep in the ground, necessitating the removal of layer
upon layer of overburden and ore. The use of heavy machinery, usually

115
 bulldozers and dump trucks, shall be used as a means of removing over
burdens. Open pit mining shall involve the removal of natively
vegetated areas and will therefore impact negatively the environment.
 Underground Mining- in underground mining, a minimal amount of
overburden is removed to get access to the ore deposit through tunnels
or shafts gain access to this ore deposits. Tunnels or shafts lead to a
more horizontal network of underground tunnels that direct access the
ore. Although underground mining is a less environmentally-destructive
means of gaining access to ore deposits, it is often more costly and
entails greater safety risks than open pit mining.
 Use of Carbon in Pulp (CIP) process as an alternative of Carbon
in Leach (CIL) process- the proponent has indicated that, the gold
ore processing methods will be Heap leaching recovery. That
withstanding has not ruled out employing other gold ore processing
methods such as carbon in Leach method (CIL). The most common gold
extraction process, however, is agitation leaching and the method
varies based on the economic constraints as well as mining operation
and ore characteristics such as grade. Heap is the most attractive
alternative for treating precious metal ores because of its low capital
cost relative to other methods. Heap leaching is designed to treat low
grade gold ores containing 1.5 to 0.5 g Au/t and even lower
concentrations.
 Gravity Separation Circuit -The mill undersize discharged material is
taken straight to the gravity separation circuit using a set of jig plants
and classifying cyclones. The final separation of the concentrate is
done using a set of centrifugal gold concentrators (Figure 24). Power
consumption is estimated at 75kW mainly because of the centrifugal
water pump. It is expected that 90% recovery of the gold in the ore will
be attained by gravity only. No chemical processing will be undertaken.
However, the results of detailed metallurgical testing works will be
instrumental in determining the final process and whether chemical
leaching or other method will be necessary.

6.7.3.3 Alternative Power Supply

The proposed project site is connected to the National grid, proponent
intends to use TANESCO power for running the production plant and other
associated activities. The number of power alternatives such as the use of
generator and solar shall be put in place as an alternative in case of
TANESCO power uncertainties. Proponent will arrange periodic auditing of
power consumption as the production plant will be running in one shift for
8 hours. Unnecessary operation of machines will be controlled to avoid
excessive consumption of electricity. Natural ventilation in production
premise will be available to avoid use of electrical power during day hours.

116
6.7.3.3.1 National grid power
The primary source of energy is sought to be supplied from the National
Grid by the Tanzania Electrical Supply Company (TANESCO). It is the case
in most of developing countries; that supply of electricity from national
grids is not reliable as it mostly originates from hydroelectric power
generators, which depend on seasonal rainfall. However; the reliable
power from the National Grid will enable the project to run under 24 hours
shift and in turn increase production. On the other hand, the presence of
electricity to the project area will assists socio-economic activities to the
surrounding nearby communities.

The impacts associated with this alternative include;

 Comparatively clean source of power with less potential for air

quality deterioration;
 Unreliability of the electrical supply from the National grid and;
 Potential development of socio-economic activities in the
surrounding villages;
 Relatively lower operation cost.

6.7.3.3.2 Solar Power

Solar Power is the best and clean energy source. Solar energy is
considered as the best alternative for the Project but for the initial stage of
the project this cannot be sought of due to high initial investment cost
hence can delay the project development. Solar panels may be used to
power the factory operation. However, the panels needed to generate the
expected power output are many and require a large area which is not
readily available at the moment.

There are many benefits of using solar energy. These include:

 It’s a renewable energy source, meaning it can last forever (as long
as we have the sun).
 Reduce your carbon emission, It’s clean and pollution free: no
carbon emissions and no greenhouse gases.
 It can reduce your energy bills. Solar energy is free and can be
stored in a battery to maximise use;
 Solar panels require little to no maintenance, saving you time and
money.
Disadvantages of Solar Energy
 Cost
 weather dependent
 solar energy storage is expensive
 Uses a lot of space
 Associated with Pollution

117
6.7.3.3.3 Generator
The alternative for the TANESCO Power Supply is the use of onsite diesel
powered generator. The company is planning to have a stand by low
carbon fuel generator to backup for the power from TANESCO. However,
he could have opt to use the generator for the entire life of the project but
diesel generators, which are mainly used during power crisis, emit a lot of
greenhouse gases especially when they run for a long time.

The impacts associated with this alternative include;

 High capital and operational cost;

 Potential air quality deterioration(noise, dust and fumes);
 Potential for land and water pollution from hydrocarbon spills;
 Reliable source of power supply and
 Potential attraction of intruders, searching for diesel.

Advantages of Diesel Generators:

- Low Maintenance: Because the generator’s engine has fewer parts
to start, you won’t have to change spark plugs or replace
carburettors as frequently as you would with a gas engine.
- Durability: Diesel engines are built to withstand a lot of abuse in the
industry; thus, they can withstand a lot of abuse in a range of
environments.
- Safer storage: While still combustible, diesel has a far lower danger
of igniting than other forms of fuel, such as gasoline.
- Output of power: Diesel generators can handle higher power loads
and can run for longer periods of time than some other types of
generators.
- Durability: More durable and sturdy.
- In addition, the generator is equipped with voltage sensors that
detect power fluctuations and automatically switch on or of within
seconds of power interruptions.

Disadvantages of Diesel Generators:

- Due to laws, the price of fuel will continue to grow;
- To maintain the generators functional, frequent maintenance is
required.
- The fuel injector and other components are more prone to failure,
resulting in a lack of dependability and expensive spare part prices.
Diesel generators are made up of large, heavy components that
might be costly to fix;
- Even though the installation cost is lower, it may take longer and be
more expensive.

118
 - Noise pollution is a serious problem. Because diesel engines may be
somewhat noisy, they’re frequently located away from work areas;
- Diesel generators are simply too big and heavy to be termed
portable or tiny.
- They must always be kept dry or they will corrode quickly.

With the three alternatives discussed above therefore the client is advised
to opt for TANESCO as the best alternative or relaying on generators.

Given the fact that diesel generators are associated with high running
costs, and solar power are weather dependent, the option of using
electricity from TANESCO has been selected as first option for the mining
operation.

6.7.3.4 Alternative Water source

The supply of water for both process requirements and for water use will
depend on further investigations to be carried out on site. However, based
on the preliminary findings from the scoping study, the most feasible
options include abstraction from the underground water sources.

6.7.3.4.1 Alternative 1: Tap water from RUWASA

The project site is not connected with pipe line water from RUWASA which
result as a disadvantage

The potential impacts associated with this alternative include:

 Increase demand of the available water supply;

 Lowering cost from bore hole drilling;
 Less cost from connecting to the source.

6.7.3.4.2 Alternative 2: Rain Water Harvesting

Given the series of seasonal rains proponent will set infrastructure such as
gutter to tap all rainwater to the collection tanks;

As such, the potential impacts associated with this alternative include:

 Low operating costs through reduction of pumping costs from the

rivers;
 Minimization of pressure on the water sources from the surrounding
rivers;
 Potential for loss of life and damage to properties in case of
structural (impoundment) failure; and
 Increased processing cost due to poor water quality.
The proponent will employ best option, which will favor operational costs
reduction of the mentioned alternatives.
119
6.7.3.4.3 Alternative 3: Groundwater abstraction
The project intends to use existing borehole within the project site to
abstract water for the operation.

The potential impacts associated with this alternative include:

 Lowering of the water table in the area;
 Limited loss of biodiversity related to clearing of vegetation for
drilling activities;
 Localized contamination from hydrocarbons spillage which might
ingress in the water table following the process of drilling;
 Noise nuisance during borehole drilling; and
 Comparatively higher initial capital costs.

Therefore, the proponent plans to use water from borehole to be drilled at

site and also connection to water supply scheme from RUWASA. The
company shall put in place water storage tanks for reliable supply.

6.7.3.5 Waste Water Management Alternatives

Alternative one: Use of stabilization ponds/lagoons

This refers to the use of a series of ponds/lagoons which allow several

biological processes to take place, before the water is released back to the
water body. Speaking of space this method requires a large field for
natural treatment to take place which is not available at the proposed
project site. Furthermore; lagoons will present vulnerable situations due to
tress passers. They are usually a nuisance to the public because of smell
from the lagoons/ponds. However, with strict and professional
management, they are the most economical and environmentally sound in
the long term.

Alternative two: Constructed wetland

Constructed wetlands are engineered system designed and constructed to

copy natural processes taking place in the natural wetlands. Constructed
wetlands remove pollutants in wastewater through the combination of
physical, biological and chemical processes. They are either subsurface
flow where the flow is below the surface of soil or surface flow where the
flow of wastewater is above the soil.

Conclusion; Due to space available, cost for constructing and operating,

easiness in designing, good odor management and flies control; septic
tank and soak away pit have been considered as technology which will be
used for wastewater management at the site.

120
6.7.3.5 Solid Waste Management Alternatives
The proposed project will generate some quantities of solid waste from
plant production section and domestic waste. An integrated solid waste
management system is recommendable
Alternative one: Source reduction
Proponent will give priority to reduction at source of the materials. This
option will demand solid waste management awareness program through
reduction the amount to buy/use is the most significant of all the options
to manage waste. The key is to only purchase goods that needed and in
the right amount to be utilized in the factory.

Alternative two: Recycling

Recycling is the most obvious alternative to sending waste to a landfill. A
wide range of materials can be recycled at least to some degree, and
recycling can even yield potential financial benefits. Materials such as
wood products, metals such as steel and aluminum, plastics, and
particularly glasses can all be recycled in order to regain some utility from
the used product.

Recycling, Reuse and Composting of the waste will be the second

alternative in priority. This will call for a source separation program to be
put in place. The recyclables will be solid to waste buyers within the
surrounding areas. Hazardous waste such as scrap metal from machines
repair, chemical containers, oil filter packaging process in the form of
discarded packaging offcuts and waste oils from generator will be
collected by authorized collectors/dealers for recycling and final disposal.

Alternative three: Transportation of waste

o Transfer the collected amount of waste from the special designated
equipment’s and machines into lager skip-type containers. The contain-
ers have to be placed at well-accessible, strategically chosen sites.
o Transport of the loaded containers to the dumpsite and exchange of
containers, so as to guarantee permanent disposal capacity at the con-
tainer sites. The containers are exchanged and the transport vehicles
operate continuously between different sites and the dumpsite.

121
 CHAPTER SEVEN:
7.0 MITIGATION MEASURES
Chapter six has identified the potential impacts and their significance.
Based on the analysis and hence classification of the potential impacts
that may result from the proposed mining and processing activities in the
area. This chapter describes the mitigation measures for those impacts
considered to be of moderate to high significance. The standards upon
which the mitigation measures are targeted, the responsible entity and
the associated mitigation costs are presented as part of the Environmental
management plan. In mitigating against the impacts, the proposed
measures also take into consideration the impacts that are not a result of
the mining and processing operations but of historical nature.

7.1 MOBILIZATION/ CONSTRUCTION PHASE

7.1.1 Noise pollution due to movement of construction equipment
 To mitigate this impact, during construction, the contractor and
proponent shall ensure that proper maintenance of machines is
done as well as fixing mufflers of equipment; and
 Also water sprinklers shall be used to spray water during clearing of
land so as to suppress dust.
7.1.2 Loss/disturbance of biodiversity due to vegetation clearance
 Ensure minimum vegetation clearance by clearing only those areas
that are utilized for the project activities only;
 All topsoil within areas will be stripped and stockpiled for future use
during rehabilitation;
122
  Carry out detailed soil analysis in order to establish zones of
different soil fertility so that soil stockpiles can be labelled and used
for appropriate vegetation species;
 Ensure restoration of disturbed areas as early as is practicable and
indigenous vegetation species should be used;
 Movement of equipment, site personnel and workers should be
closely monitored so as to minimize unauthorized activities within
the project area; and
 Rock waste dumps will be progressively rehabilitated where
practicable and in keeping with sound management practice.
Basically, all disturbed land surfaces that can be reasonably should
will be managed;

7.1.3 Surface water pollution

 Conduct survey of the project areas and identify all catchment areas
that are a source of groundwater discharges to surface;
 Conduct sampling of the water discharges and that downstream and
establish the levels of the associated heavy metals;
 Cover and restore the open excavations, plug open drill holes and
ensure stability of the restored excavations;
 Conduct regular monitoring of the water bodies downstream; and
 Use of compacted clay or lining of the waste rock dump floor and
TSF to prevent seepage to groundwater resources.

7.1.4 Potential for surface and groundwater pollution

 Conduct surveys and identify all open excavations and associated
activities that may provide of pollutants into groundwater;
 Ensure that all open excavations are covered and areas are restored
and re-vegetated accordingly;
 Design waste rock dump and TSF in a manner that will hinder
pollutant seepage to groundwater resources; and
 Use of comprehensive compacted clay or carpet lining of waste
storage facility floor, the will prevent percolation of pollution plume
into the ground.

7.1.5 Potential for health and safety impacts to workers

 Establish Workers Safety Management Systems;
 Formulate Occupational Health and Safety Policy;
 Use of water sprinklers to suppress excessive dust during
construction;
 Workers at the site will be provided with appropriate protective
gears such as boots, helmets, masks, etc.;

123
  The contractor shall insist on their workers to use the Personal
Protective Equipment properly; and
 Putting in place the First Aid Kit with in-charge trained in First Aid
delivery.

7.1.6 Loss of lives and property as a result of Fire break out

 Mining projects and such like projects are projects which need
precautions so as to avoid fire break out. However, fire accidents do
not frequent happen, thus causing huge financial losses and even
human lives

7.2 OPERATION PHASE

7.2.1 Impairment of local air quality from dust and fumes
 Regular maintenance of all equipment on site shall be conducted as
a way or reducing emissions of noxious gases and improve working
mechanisms and thus reduce noise of the moving parts;
 The developer will use a generator of low or minimum emissions of
noxious gases;
 The air quality measurements monitoring shall be established
annually
 The proponent will conduct adequate training and use of personal
protective equipment (PPE) in order to reduce risks associated with
dust and noise;

7.2.2 Losses and misuse of toxic chemicals due to theft of

chemicals and other inputs
 All toxic chemical especially cyanide will be stored in secure
facilities;
 Security personnel will guard the facilities and remotely
monitored cameras shall be installed in cyanide storage
facilities;
 Alarm systems will be installed to signal the entrance of
any intruder into the cyanide storage facilities;
 All cyanide storage facilities shall be locked and fenced with
barbered wires to restrict access to unauthorized personnel;
 Proper store management procedures and audits will be
used in controlling the movement of cyanide to and from the
storage facilities;
 Spent cyanide packaging materials will be properly disposed
or returned to the supplier for appropriate disposal or reuse

7.2.4 Air pollution from release of noxious gases in case of fire

124
  The cyanide storage facilities will be located and built taking
into account the potential for fire problems. Vegetation, debris
and combustible materials from around the storage facilities will be
regularly removed.
 Effective fire protection systems will be provided; smoke
detectors, fire alarms and sprinkler systems shall be installed in
all cyanide storage facilities;
 Warning signs shall be posted to prevent personnel from smoking
and engaging in other potential fire causing activities in and around
the storage and compressed air facilities;
 Housekeeping measures shall be instituted and enforced in and
around the storage facilities;
 Personnel in the cyanide storage facility shall be trained on fire
prevention measures as part of the implementation of the mine’s
emergency preparedness programme.

7.2.5 Poisoning by hydrogen cyanide gas built-up in the store

 Adequate ventilation will be provided to disperse any build-up of
hydrogen cyanide in the storage facilities and compound;
 Cyanide will be stored in a properly roofed facility with adequate
drainage, above ground level or on an impervious surface to
minimize the possibility of contact with water from storm run-off or
flooding and the generation of hydrogen cyanide gas;
 Cyanide will be stored separately from corrosive, acidic and
explosive materials to minimize the potential for hydrogen gas
production;
 Hydrogen cyanide electronic detection equipment will be installed in
all potential hydrogen cyanide producing facilities such as storage
facilities and leaching tanks, and be used for faster response;
 Airborne contaminants including hydrogen cyanide will be
continuously monitored and sampled to protect workers from
exposure;
 Operators undertaking potentially hazardous procedures such as
opening storage containers, dissolving sodium cyanide pellets
and cleaning up cyanide spillages will be required to wear
appropriate personal protective equipment;
 Staff will be trained and competency tested in the handling of
cyanide and potential emergencies.

7.2.6 Health impacts from accidental spillage of cyanide from

storage facilities
In order to mitigate the health impacts from accidental spillage of cyanide
from storage facilities the project proponents will ensure that:

125
  Operators undertaking potentially hazardous procedures such as
cleaning up cyanide spillages should be required to wear
appropriate personal protective equipment;
 Staff will be trained and competency tested in the handling of
cyanide and potential emergencies including offering fist aid
treatment immediately following cyanide exposure;
 Adequate containment facilities and binding should be provided
to lessen the impact of accidental spillage of cyanide from
storage facilities;
 Workers will be instilled to adopt a culture of cleanliness including
the hand washing before eating, drinking or smoking;
 Adequate supply of neutralizing agent on site will be maintained;
 Adequate measures for dealing with victims of cyanide
exposure will be developed and implemented include provision
of first aid kits with cyanide antidotes in case of ingestion,
water sprays, specialized PPEs (gloves, suits, etc.), and others in
accordance to the requirements of the ”International Cyanide Code”.
 Contaminated protective gear and clothing should be securely
discarded or washed before being stored and reused.

7.2.7 Potential impacts to wildlife from spillages

In order to mitigate the potential impacts that may arise as a result of
spillages of cyanide the following measure are proposed:
 The heap leaching Plant will be designed with the objective of
having a zero discharge of cyanide to the surrounding environment
through balanced water and cyanide management system;
 Adequate containment facilities and binding should be provided to
ensure that cyanide is contained within the site and to prevent the
drainage of accidentally spilled cyanide to the environment from
processing and cyanide storage facilities;
 Procedures for continuous monitoring to ensure that the cyanide
concentration of the processed tailings does not exceed 0.5 ppm
cyanide (total) on a daily average basis will be implemented

7.2.8 Potential for contamination of surface and groundwater

from spillage and seepage
In order to mitigate the potential impacts that may arise as a result of
spillage and seepage of cyanide the following measure are proposed:
 Adequate containment facilities and binding should be provided to
ensure that cyanide is contained within the site and prevent the
drainage of accidental spilled cyanide to the environment from

126
 leaching processing and cyanide storage facilities
 Procedures for continuous monitoring to ensure that the cyanide
concentration of the processed tailings does not exceed 20ppm
cyanide (total) on a daily average basis should be implemented;
 Monitoring of seepage of cyanide and associated compounds
from the leach pad system will be established using the drilled
boreholes. Where the potential for seepage is detected
appropriate remedial measures such as relocation and collection
of seepage and recycling should be taken in order to stop the
continuation of such seepage.
 Analysis of the water sample results will be carried out
continuously in order to establish any changes in the cyanide and
heavy metal concentrations and hence establish potential for
seepage;
 Remedial measures where the potential for seepage has been
detected will be taken in order to stop continuation of such seepage.
Remedial measures will include treatment of the strata, e.g.,
through grouting, relocation of the facility, construction of a
lined storage facility, e.g., with geo-membrane, treatment of the
floor with a clay later and other means. Any such detected
seepage will be reported to the regulatory authorities;
 Continuous monitoring and testing of water samples downstream
from the tailings storage area and the all water storage ponds
will be undertaken as a way of controlling any potential for
seepage; and
 All equipment and facilities with potential for cyanide spillage
will be bunded and provided with containment.

7.2.9 Environmental pollution from poor waste management

The Company shall follow the normal and standard operational procedures
to address the impacts of wastes. The procedure shall involve segregation
of waste streams generated, recycling and reuse of waste products where
possible and carry out appropriate disposal of waste. Developer have
already identified all possible waste streams and proposed the
various management measures. The various disposal methods will be
undertaken in accordance with laws and standards and Local Government
Authority by-laws. The sections below highlight some management
measures for management of domestic and solid wastes:
 Domestic solid wastes i.e. glass, paper, cans will be segregated
using clearly marked ins and disposed of appropriately;
 Maintenance wastes (i.e. Paint sweepings, oil soaks, machinery
deposits etc.) and packaging wastes (pallets, cardboard boxes,
drums) shall be collected, compacted (if possible), segregated

127
 using clearly marked skips, labelled, stored in designated areas prior
to disposal or recycling; and
 Combustible solid wastes may be burnt and the ashes
collected and disposed in accordance with legal requirements.

7.2.10 Impacts from explosives uses

 Employ soft and controlled blasting techniques as practicable as
possible;
 Initiate a programme on vibration monitoring which will cover all
mining operations.
 Provide appropriate PPE’s to the workers including ear muff type
protectors and ear plug.

7.2.11 Contamination of sediments and down-gradient soils

through cyanide seepage
In order to mitigate the potential impacts that may arise as a result of
spillage and seepage of cyanide the following measure are proposed:
 Adequate containment facilities and binding will be provided to
ensure that cyanide is contained within the site and prevent the
drainage of accidental spilled cyanide to the environment from
processing and cyanide storage facilities
 Procedures for continuous monitoring to ensure that the cyanide
concentration of the processed tailings does not exceed 20ppm
cyanide (total) on a daily average basis will be implemented;
 Monitoring of seepage of cyanide and associated compounds
from the tailing storage area will be established using the drilled
boreholes. Where the potential for seepage is detected
appropriate remedial measures such as relocation and collection
of seepage and recycling will be taken in order to stop the
continuation of such seepage.

7.2.12 Health and safety hazards to workers

 Provide and enforce the use of personal protective equipment (PPE)
e.g. helmets, boots, goggles, earplugs, gloves and others;
 Ensure regular training programmes on health and safety matters to
all cadres;
 Maintain and enforce hygienic conditions at work place, e.g.,
washrooms, change-rooms, dining and cooking areas, etc.;
 Provide regular medical check-ups for the workers on HIV/AIDS and
malaria control; and
 Ensure that the health and safety regulations that comply with the
“Mining (Safety, Occupational Health and environmental protection)
Regulations, 2010” are instituted and enforced on site.

128
7.2.13 Increase of vehicular traffic
 Hours of working will be restricted to day light;
 Maintenance of vehicles to avoid noise;
 Speed limit restricted to avoid accidents;
 Avoid overfilling of haulage trucks; and
 Covering of trucks especially during transportation of dust type ore.

7.2.14 Loss of lives and property as a result of Fire break out

 Fire breaks out at the project area shall be avoided by observing
operation procedures on safety aspects of the mine and processing
site. All workers and new recruits will undergo training on safety
procedures and drills. Any new employee will not be allowed into the
facility before receiving this training; and
 The firefighting equipment such as fire extinguishers shall be placed
in all strategic areas of the site. Also related safety gears especially
fire rescue coats, protective jumpsuits and safety boots should be in
place. An emergency assembly point shall be designated at the
mine site. Employees will be trained on what to do in case of fire or
other emergencies
7.2.15 Impacts from acidic forming rocks
The nature of the bedrock of the proposed is non-Acidic forming, but the
company will ensure the following in case it happen during mining
 Surface water diversion-This technique will help to reduce the water
supply to those potentially acid-generating materials, by using
safeguarding channels, pipes, or slope changes around the material
area, etc. The application of this technique should be preceded by
accurate hydrological and hydrogeological studies, however the lack of
these information may sometimes causes the unsuccessful application
of this method
 Materials handling-Poor handling of materials has a fundamental
influence on the generating acidity, this being maximal when sulphides
are situated on the top and minimum if a layer of neutralizing
materials, such as carbonates, is placed on top above the pyrite.
Sometimes there are some materials with a particularly high potential
to generate acidity, so if they can be stored in a waterproof trap, the
amount of drained acidic water will be considerably reduced. To
properly isolate the materials with higher acid generation rates, they
should be located well below the surface but always above the water
table in the area. They must also have a sufficiently compacted
waterproof coverage (usually clay or plastic) that must be umbrella
shaped to prevent water from coming in contact with the mined rocks.

129
7.3 ENHANCEMENT OF POSITIVE SOCIO-ECONOMIC IMPACTS
7.3.1 Contribution to government revenues
 The company is expected to enhance government revenue
collection at Regional and National level. This will be enhanced by
timely submission of all revenue to respective departments. The
revenue collected will contribute towards economic development
within the region and the country at large.
7.3.2 Corporate Responsibility
 The project has a potential of enhancing development of the area
through increased business activities and direct employment. As a
corporate citizen, developer will continue to work all along with the
Government to achieve the millennium development goals
mainly in the area of poverty reduction. This will be done
through a non-partisan scheme set by the Company, tailored
towards extending support to disadvantaged sections of various
communities in the area to enable them access education, health
care and clean safe water.

7.3.3 Employment opportunity

 To minimize population influx in the area, company shall give
preference to employing the local population. Only after
exhausting the human resources available in the area shall the
company resort to hiring people from outside the immediate project
area. This measure will easily be achieved by adopting the census
results as a guide in establishing the local skills available. This
strategy will also prevent conflict between the local people and
outsiders who may feel that their opportunities are being taken
up outsiders.
 The company shall employment hierarchy strategy that gives
preference to the people of the local village and the most vulnerable
group from the project impacts, and then move to the Town level,
then to the regional level and eventually to the national level. In
positions that require specialized training, the company shall design
a phased training program that will enable community members to
inherit those positions. Employment opportunities created by the
Heap Leaching Processing Plant project will increase income and
therefore improve the overall standards of living in the area. The
communities that will feel this impact immediately will be the
residents of Ikungumhulu Village, Shilalo Ward, Misungwi District
and Mwanza region at large.

7.3.4 Increased income by utilization of local resources

 Where ever possible the project will procure materials from
local sources as this will benefit local producers and suppliers.
130
 Some of the project services have been already contracted to
Tanzanian suppliers and contractors e.g. EIA study.

7.4 DECOMMISSIONING PHASE

7.4.1 Health hazards to workers from demolishing work
 Personal protective equipment (PPE), e.g., helmets ,boots, goggles,
earplugs, gloves and others will be provided and their use enforced
to all workers involved in demolishing of structures during closure;
 All workers involved in the demolishing work will be provided
with training on health and safety matters;
 Hygienic conditions within the working areas will be maintained and
enforced;
 Use of water spraying on dusty surfaces to suppress dust.

7.4.2 Pollution of surface and groundwater

 The top surface will be covered with top soil layer (not less than
30cm) and planted with indigenous grasses and trees. In order to
establish the suitable type of vegetation, tests of various species
and soil types and conditions will be carried out. The soil types and
condition will be created by utilizing the tailings materials with
varying water contents in simulation of the possible scenarios. The
top soil cover will be obtained from stockpiles created from stripping
operations in various parts of the project site;
 Continuous monitoring of the vegetation for metal uptake will be
undertaken. If harmful levels of metals are detected, rehabilitation
procedures will be reviewed in order to address and mitigate the
situation and ensure levels that are safe for animals and plant life;

7.4.3 Increased sediment load from erosion

 Rainfall will not be allowed to accumulate on the upper surface of
the tailings. All drains will be diverted away from the course of
the water bodies downstream to prevent suspended materials
entering down-slope streams directly;
 All suitable discharge points for storm water drainage from
surrounding areas will be identified and used to control pollution of
downstream water sources;
 Plant trees and grass on the tailings (use of native grass shall be
considered).

7.4.4 Loss of employment opportunities

131
  Preparing the workers to be employed anywhere else in the mine
and Processing Plant through provision of extensive training in
modern exploration and mining techniques.
 Preparing the workers for forced retirement by providing skills
for self-employment, wise investment.
 Ensuring that all employees are members of the Pension Fund and
the employees should ensure that the developer’s contributions are
made.
 In time of decommission of this project the company may consider
its employees in development of new projects as well as for
those skilled Tanzanian miners and minerals processors.

7.4.5 Contamination and impaired Environment

 To mitigate the impact during demolition, the contractor and the
proponent shall ensure that proper decommissioning procedures are
followed.

7.5 ENHANCEMENT MEASURES OF POSITIVE IMPACTS

7.5.1 Income, skills and knowledge increase to local labourers
 In order to enhance this positive impact, the proponent shall take
deliberate measures to employ human labour in carrying out all
activities during operation that may be done without machines while
maintaining high level of efficiency and necessary safety. This is
meant to increase the number of people that will benefit through
wages, skills and knowledge transfer during the project life span;
 Low levels of skills and literacy possessed by the local population
will restrict their ability to realize employment opportunities offered
by the mining development and will also reduce their ability to seize
entrepreneurial opportunities. The implementation of appropriate
training and capacity building programmes could be used to
ameliorate this problem;
 Increased income earning capacity will result in individual and
community empowerment, which in turn could result in greater
opportunities for political activity at the local and regional level; and
 Greater political participation could promote increased government
attention and possibly greater expenditure in the region. However,
it could also result in rejection should local or regional politics
conflict with regional or national politics respectively.

7.5.2 Enhanced income, employment opportunities and local

business
 To enhance this positive impact, the proponent shall make
deliberate effort to employ Tanzanians to work at the mine and

132
 processing site. Also, efforts shall be made to pay workers
handsomely so as to improve their livelihood. Outsourcing of
services needed at the mining shall be procured locally to benefit
the local community around the project area;
 Developing and implementing the social development plan with
attention needs to be given to an equitable distribution of
opportunities and benefits (e.g. employment opportunities,
economic development projects, etc.). Failure to do this or to
conduct the process in a transparent manner could result in tension,
conflict and antagonism with the mine bearing the brunt of local
frustration; and
 The need for representative community organizations to participate
in the implementation of a local economic development plan will be
critical to the success of the project. There will be a need for
considerable input with regard to local capacity building and
empowerment.

133
 CHAPTER EIGHT:
8.0 ENVIRONMENTAL AND SOCIAL MANAGEMENT PLAN
8.1 INTRODUCTION
The environmental and Social Management Plan (ESMP) for the
proposed establishment of gold mining and processing project at
Ikungumhulu Village, Shilalo Ward, Misungwi District in MWANZA Region
has been compiled in line with the requirements of the Mining (Safety
Occupational Health and Environmental Protection) Regulations, G.N No.
408, 2010. However, since the information regarding the scope of the
project, surrounding environment, impact analysis and the mitigation
measures have already been presented as part of the Environmental
Impact Statement, the ESMP is presented as part of the EIA report. The
project is a new project planned to be undertaken in an area that has been
well conserved and hence needs extra care during operation of the
project.

8.2 PERSONNEL RESPONSIBLE FOR THE IMPLEMENTATION OFTHE

ESMP
The Project Manager (PM) of the company will be responsible for ensuring
implementation of the ESMP. The PM will also ensure that a procedure is
developed such that all senior positions on site have their environmental
responsibilities and accountabilities clearly outlined. These descriptions
will form part of the contractual obligations upon which individual
employees are engaged. Specific accountabilities and responsibilities
outlined in the procedures will be communicated through the Heads of
Departments.

Although the project is small in nature, the management of

environment will require a to employ an environmental and safety
officer who will provide technical support and coordinate
environmental management initiatives. Typical duties and responsibilities
for the HSE staffs will include, inter alia to:
 ensure that environmental monitoring programs are carried out on
schedule and correctly;
 review environmental data and recommend appropriate actions;
 monitor environmental compliance of all mine operations;
 train others in the team and general personnel on mine
environmental issues;
 design and implement restoration of disturbed areas and re-
vegetation studies;
 establish, train and ensure readiness of the emergency response
teams;
 report on environmental data and incidents of significance as per
regulations;
134
  liaise with the appropriate regulatory authorities on incidences with
environmental risks;
 provide technical and environmental support to mining operations;
and,
 Ensure commitments listed in the EIS are met.
 Review (periodically) the existing monitoring system and design
updated system

8.3 ENVIRONMENTAL AUDIT PROCEDURES

In complying with the requirements of the Environmental
Management Act Cap 191, Gold Mineral Processing Plant project will
conduct independent audits biannually and submit on annual basis,
an environmental monitoring report. The annual report will review the
performance of various environmental parameters. The company will also
ensure compliance with the audit requirements. Environmental auditing
will seek to undertake the following, as its minimum requirements:
 Review all monitoring data and, if deemed warranted by the
independent third-party auditor, undertaking an independent
round of monitoring;
 Review various environmental reports compiled throughout the
year.
 Review operations, inspect facilities and observe monitoring
activities for purpose of assessing effectiveness of the
Company’s environmental management procedures,
implementation and identifying potential improvements if
deemed appropriate.
 Prepare an audit report complete with photographic record and
recommendations.
 The final audit report, together with monitoring data for the
previous year, will be distributed to the Ministry of Energy
and Minerals, Division of Environment, the National
Environmental Management Council and the Misungwi District
council through the Town Environmental Management Officer
for review, guidance and comments.

The summary of the key issues of the proposed Gold mining and heap
leaching Plant project at Ikungumhulu Village and their management are
shown in Table 8.1 below (ESMP).

135
 Table 8. 1: Environmental and Social Management Plan for the proposed mining project
Potential Management/Mitigation Measures Responsibility Estimated
Impacts Costs [TZS]
Disruption of  Land issues shall be settled in good time before construction work Proponent 5,000,000
various current of the Gold Mineral Processing Plant begins. People shall be given
land users of the ample time to find alternative land for settlement and to harvest
project sites their crops (whether compensated or not).Misungwi District council
and Village leadership all allocate alternative new plots for the
affected people. Compensation shall be settled according to the law
guiding compensation (Land Act, 1999).
Damage/  Loss of the vegetation cannot be avoided but the loss can be 4,000,000
disturbance to compensated through progressively rehabilitation of the project
protected area.
habitats and  PMC will rehabilitate and restore all the land that will be cleared
species of the vegetation for various project activities, through re-
vegetation of the ground by planting native species of tree and
grass planting.
 Before clearance the vegetated areas shall be properly assessed
for baseline conditions and existing biodiversity (flora and fauna)
documented. Indigenous tree seeds will be collected and
geminated in order to obtain seedlings for rehabilitation.
 The target for rehabilitation will be the utilization of indigenous
trees where possible. The project proponent shall consult GDC
Natural Resource Officer for advice and for potential flora stocks
for regeneration of disturbed vegetation in the project areas.
Loss/  Clearance of part of the vegetation at the project site to pave 6,000,000
disturbance of way for construction will be inevitable.
biodiversity  However, the proponent will ensure proper demarcation of the
due to project area to be affected by the construction works. This will be
127
Potential Management/Mitigation Measures Responsibility Estimated
Impacts Costs [TZS]
vegetation aimed at ensuring that any disturbance to flora and fauna is
clearance restricted to the actual project area and avoid spillover effects on
the neighboring areas.
 In the same vein, there will be strict control of construction
vehicles to ensure that they operate only within the area to be
disturbed by access routes and other works. Another important
measure aimed at reducing disturbance of vegetation in the
project area will be preservation of individual trees within the
site.
 In addition, the proponent has committed itself to re-vegetation
of some of the disturbed areas through implementation of a well-
designed landscaping programme. Part of the topsoil excavated
from the construction site will be re-spread in areas to be
landscaped to enhance plant health.
Potential for  Only the designated roads will be used during the project. 5,000,000
increased road  Traffic sign warning drivers of road humps, pedestrian crossings,
accidents animal crossings, sharp bends and other accident-prone areas
will be posted along the road stretch;
 All company vehicles will be installed with speed control devices,
e.g., speed governors as a way of limiting drivers from over-
speeding;
 Road safety education programmes will be established for the
communities living along the road; such as right of the road,
precautions necessary when crossing the road, etc.
 Only frequently inspected road-worthy vehicles and well-trained
drivers will be used for transportation of goods to and from the
project site;
 All drivers to undergo driving and vision tests prior to
128
Potential Management/Mitigation Measures Responsibility Estimated
Impacts Costs [TZS]
recruitment;
 All drivers to receive training on the operation of their specific
vehicle, and in awareness of pedestrians and cyclists.
Air pollution  Equipment shall be properly tuned and maintained 1,000,000
from  Maintain equipment in good running condition - no vehicles to be
emissions used that generate excessive black smoke. Construction
generating activities that will generate disturbing conditions will be
equipment’s restricted to normal working hours. Enforce vehicle load
restrictions to avoid excess emissions from engine overloading.
 Where practical, switch off engines when not in use.
Visual  Cover all trucks hauling soil, sand and other loose materials or 4,000,000
intrusion, dirt require all trucks to maintain at least two feet of freeboard.
on amenities  Pave, apply water when necessary, or apply (non-toxic) soil
and plants stabilizers on all unpaved access roads, parking areas and
along the road staging areas at construction sites.
 Transportation of good from the site will be carried out in small
convoys so as to limit visual intrusions and minimize other
disturbances to surrounding communities;
 The reduction of the number of trips will be encouraged and
facilitated by using high tonnage vehicles and truck deliveries
will be restricted to daytime to reduce illumination and noise
impacts.
Noise pollution  The mobilization vehicles will incorporate all standard sound 6,000,000
attenuation equipment, such that there would be no significant
increase in noise levels within the area,
 Low noise construction equipment shall be used. Furthermore,
insulation and sound enclosures around machinery will be done
 Most direct routes shall be used to minimize amount of fossil fuel
129
Potential Management/Mitigation Measures Responsibility Estimated
Impacts Costs [TZS]
used and hence reduce noxious gases emissions
 Drivers shall be sensitized on proper driving practices to
minimize fossil fuel use
 Periodic maintenance of vehicles shall be done to ensure they
are in good working conditions and hence reduction minimize
fuel use.
Loss of  All tailings disposal operations will be undertaken with extra care 4,000,000
aesthetics in order to minimize unnecessary aesthetic impacts. All
excavations (trenches, pits, burrow pits) will be backfilled,
resurfaced and lightly compacted;
 Grass and trees will be planted in areas being rehabilitated by
using the indigenous specious as already practiced in the on-
going rehabilitation programme;
 Disturbed soil surfaces will be protected from erosion by a mulch
of natural or manufactured material before adequate cover of
vegetation has been established;
 In order to prevent siltation of down-slope streams, run-off
control systems will be constructed around all material stockpile
areas and tailings storage facilities. The run-off control systems
will include a 2% fall across the waste dumps, silt traps and side
drains to direct run-off to settlement ponds downstream
Potential for  Several measures shall be put in place to mitigate the impacts 6,000,000
surface and that are likely to lead to water quality degradation.
groundwater  The proponent will control the dangers of oil, grease and fuel
pollution spills during construction by maintaining the machinery in
specific areas designed for this purpose.
 Machinery site repair will be discouraged and repair work
restricted to only approve garages to avoid pollution from oil,
130
Potential Management/Mitigation Measures Responsibility Estimated
Impacts Costs [TZS]
grease and fuel.
Potential for  The contractor shall provide a small section of the construction
health and site with a shed and a water stand where the food can be served
safety impacts to the construction workers to promote hygiene and health of the
to workers employees.
 A fully equipped first aid kit shall be provided at the site.
 The contractor must have workmen’s compensation cover as
required by law (The Workmen’s Compensation Act, 2008).
 The workers, immediate neighbor and other stakeholders shall
be sensitized on the dangers and risk associated with the
construction works for enhanced self-responsibility on personal
safety.
 The proponent shall ensure that the completed buildings are
fitted with safety facilities including fire detectors, firefighting
equipment’s, fire exits, adequate access and buffer between the
residential premises.
 Appropriate sanitation conveniences shall be provided at the site
as required in the OSHA, 2003 and echoed in the Public Health
Act, of 2008.

OPERATION PHASE
Impairment of  Regular maintenance of all equipment on site will be conducted 4,000,000
local air as a way or reducing emissions of noxious gases and improve
quality from working mechanisms and thus reduce noise of the moving parts;
dust, fumes  Research will be conducted in order to identify and adopt usage

131
Potential Management/Mitigation Measures Responsibility Estimated
Impacts Costs [TZS]
and noise of fuels that have minimum emissions of noxious gases; The air
quality monitoring stations will be established
 The proponent will conduct adequate training and use of
personal protective equipment (PPE) in order to reduce risks
associated
 with dust and noise
Losses and  All toxic chemical especially cyanide will be stored in secure 6,000,000
misuse of facilities;
toxic  Security personnel will guard the facilities and remotely
chemicals due monitored cameras will be installed in cyanide storage facilities;
to theft of Alarm systems will be installed to signal the entrance of any
chemicals and intruder into the cyanide storage facilities;
other inputs  All cyanide storage facilities will be locked and fenced with
barbered wires to restrict access to unauthorized personnel;
 Proper store management procedures and audits will be used in
controlling the movement of cyanide to and from the storage
facilities;
 Spent cyanide packaging materials will be properly disposed or
returned to the supplier for appropriate disposal or reuse.
Potential for ● Procedures for continuous monitoring to ensure that the cyanide 10,000,000
pollution of concentration of the processed tailings does not exceed 20ppm
soils, surface cyanide (total) on a daily average basis should be implemented;
and  Analysis of the water sample results will be carried out
underground continuously in order to establish any changes in the cyanide
water from and heavy metal concentrations and hence establish potential
spills for seepage;
 Remedial measures where the potential for seepage has been
detected will be taken in order to stop continuation of such
132
Potential Management/Mitigation Measures Responsibility Estimated
Impacts Costs [TZS]
seepage. Remedial measures will include treatment of the strata,
e.g., through grouting, relocation of the facility, construction of a
lined storage facility, e.g., with geo-membrane, treatment of the
floor with a clay later and other means. Any such detected
seepage will be reported to the regulatory authorities;
 Continuous monitoring and testing of water samples downstream
from the tailings storage facility and the all water storage ponds
will be undertaken as a way of controlling any potential for
seepage;
 All equipment and facilities with potential for cyanide spillage will
be bunded and provided with containment;
Air pollution  The cyanide storage facilities will be located and built taking into 6,000,000
from release account the potential for fire problems. Vegetation, debris and
of noxious combustible materials from around the storage facilities will be
gases in case regularly removed.
of fire  Effective fire protection systems will be provided; smoke
detectors, fire alarms and sprinkler systems shall be installed in
all cyanide storage facilities;
 Warning signs will be posted to prevent personnel from smoking
and engaging in other potential fire causing activities in and
around the storage and compressed air facilities;
 Housekeeping measures will be instituted and enforced in and
around the storage facilities;
 Personnel in the cyanide storage facility will be trained on fire
prevention measures as part of the implementation of the mine’s
emergency preparedness programme.
Poisoning by  Adequate ventilation will be provided to disperse any build-up of 5,000,000
hydrogen hydrogen cyanide in the storage facilities and compound;
133
Potential Management/Mitigation Measures Responsibility Estimated
Impacts Costs [TZS]
cyanide gas  Cyanide will be stored in a properly roofed facility with adequate
built-up in the drainage, above ground level or on an impervious surface to
store minimize the possibility of contact with water from storm run-off
or flooding and the generation of hydrogen cyanide gas;
 Cyanide will be stored separately from corrosive, acidic and
explosive materials to minimize the potential for hydrogen
gas production;
 Hydrogen cyanide electronic detection equipment will be
installed in all potential hydrogen cyanide producing facilities
such as storage facilities and leaching tanks, and be used for
faster response;
 Airborne contaminants including hydrogen cyanide will be
continuously monitored and sampled to protect workers from
exposure; Operators undertaking potentially hazardous
procedures such as opening storage containers, dissolving
sodium cyanide pellets and cleaning up cyanide spillages will be
required to wear appropriate personal protective equipment;
 Staff will be trained and competency tested in the handling of
cyanide and potential emergencies.
Health  Operators undertaking potentially hazardous procedures such 5,000,000
impacts from as cleaning up cyanide spillages will be required to wear
accidental appropriate personal protective equipment;
spillage of  Staff will be trained and competency tested in the handling of
cyanide from cyanide and potential emergencies including offering fist aid
storage treatment immediately following cyanide exposure;
facilities  Adequate containment facilities and binding will be provided to
lessen the impact of accidental spillage of cyanide from storage
facilities;
134
Potential Management/Mitigation Measures Responsibility Estimated
Impacts Costs [TZS]
 Workers will be instilled to adopt a culture of cleanliness
including the hand washing before eating, drinking or smoking;
Adequate supply of neutralizing agent on site will be maintained;
 Adequate measures for dealing with victims of cyanide exposure
will be developed and implemented include provision of first aid
kits with cyanide antidotes in case of ingestion, water sprays,
specialized PPEs (gloves, suits, etc.), and others in accordance to
the requirements of the ”International Cyanide Code”.
 Contaminated protective gear and clothing will be securely
discarded or washed before being stored and reused.
Potential  The Gold Mineral Processing Plant will be designed with the 4,000,000
impacts to objective of having a zero discharge of cyanide to the
wildlife from surrounding environment through balanced water and cyanide
spillages management system;
 Adequate containment facilities and binding will be provided to
ensure that cyanide is contained within the site and to prevent
the drainage of accidentally spilled cyanide to the environment
from Leach pad processing and cyanide storage facilities;
● Procedures for continuous monitoring to ensure that the cyanide
concentration of the processed tailings does not exceed 20ppm
cyanide (total) on a daily average basis should be implemented;
 The TSF, tailings dam sedimentation pond and return water pond
other facility will be fenced to exclude livestock and wildlife.
Potential for  Adequate containment facilities and binding will be provided to 4,000,000
contamination ensure that cyanide is contained within the site and prevent the
of surface and drainage of accidental spilled cyanide to the environment from
groundwater leach pad processing and cyanide storage facilities
from spillage  Procedures for continuous monitoring to ensure that the cyanide
135
Potential Management/Mitigation Measures Responsibility Estimated
Impacts Costs [TZS]
and seepage concentration of the processed tailings does not exceed 20ppm
cyanide (total) on a daily average basis should be
implemented;
 Monitoring of seepage of cyanide and associated compounds
from the site will be established using the drilled boreholes.
Where the potential for seepage is detected appropriate
remedial measures such as relocation and collection of seepage
and recycling will be taken in order to stop the continuation of
such seepage.
Contamination  Adequate containment facilities and binding will be provided to 5,000,000
of sediments ensure that cyanide is contained within the site and prevent the
and down- drainage of accidental spilled cyanide to the environment from
gradient soils processing and cyanide storage facilities
through  Procedures for continuous monitoring to ensure that the cyanide
cyanide concentration of the processed tailings does not exceed 20ppm
seepage cyanide (total) on a daily average basis will be implemented;
 Monitoring of seepage of cyanide and associated compounds
from the tailing storage area will be established using the
drilled boreholes. Where the potential for seepage is
detected appropriate remedial measures such as relocation
and collection of seepage and recycling will be taken in
order to stop the continuation of such seepage.
SOCIO – ECONOMIC ASPECTS
Contribution  Timely submission of all revenue to respective departments 6,000,000
to government
revenues
Support to  The company will work all along with the Government to achieve 4,000,000

136
Potential Management/Mitigation Measures Responsibility Estimated
Impacts Costs [TZS]
local social the millennium development goals mainly in the area of poverty
services reduction. This will be done through a non-partisan scheme set
by the Company, tailored towards extending support to
disadvantaged sections of various communities in the area to
enable them access education, health care and clean safe water
Employment  The company shall give preference to employing the local 4,000,000
and training population.
 The PMC shall employment hierarchy strategy that gives
preference to the people of the local village and the most
vulnerable group from the project impacts,
 PMC shall design a phased training program that will enable
community members to inherit those positions.
Impacts  To minimize population influx in the area, Company 3,000,000
related with employment policy shall give preference to the local
population population. Only after exhausting the human resources
influx available shall the company resort to hiring people from outside
the immediate area. This measure will easily be achieved by
adopting the census results as a guide in establishing the local
population.
 This policy will also prevent conflict between the local people
and outsiders who may feel that people from outside are
grabbing their opportunities.
 The employment policy shall give preference to the people of the
local village and the most vulnerable from the project impacts,
and then move to the district level, then to the regional level and
eventually to the national level. Also the company will devote
time in raising awareness of the dangers of the HIV/AIDS.
Although basic knowledge of HIV/AIDS is high among Tanzanians,
137
Potential Management/Mitigation Measures Responsibility Estimated
Impacts Costs [TZS]
knowledge of self-protection measures and behavior change will
be provided and a preference will be given to those who are
vulnerable and to empower women since they compose one of
the most vulnerable groups.
DECOMMISSIONING PHASE
Health  Personal protective equipment (PPE), e.g., helmets, boots, 5,000,000
hazards to goggles, earplugs, gloves and others will be provided and their
workers from use enforced to all workers involved in demolishing of structures
demolishing during closure;
work  All workers involved in the demolishing work will be provided
with training on health and safety matters
 Hygienic conditions within the working areas will be maintained
and enforced;
Pollution of  The top surface will be covered with top soil layer (not less than 8,000,000
surface and 30cm) and planted with indigenous grasses and trees. In order to
groundwater establish the suitable type of vegetation, tests of various species
and soil types and conditions will be carried out. The soil types
and condition will be created by utilizing the tailings materials
with varying water contents in simulation of the possible
scenarios. The top soil cover will be obtained from stockpiles
created from stripping operations in various parts of the project
site.
 Continuous monitoring of the vegetation for metal uptake will be
undertaken. If harmful levels of metals are detected,
rehabilitation procedures will be reviewed in order to address
and mitigate the situation and ensure levels that are safe for
animals and plant life.

138
Potential Management/Mitigation Measures Responsibility Estimated
Impacts Costs [TZS]
 Water quality monitoring points will be established downstream
the tailings storage area and regular monitoring to ensure the
water quality meets the standards specified in the Fifth Schedule
of the Mining Act, 2010 (Act No. 14/2010) and Environmental
Management (Water quality standards) regulations, 2007)
Increased  Rainfall will not be allowed to accumulate on the upper surface 5,000,000
sediment load of the tailings. All drains will be diverted away from the course of
from erosion the water bodies downstream to prevent suspended materials
entering down-slope streams directly.
 All suitable discharge points for storm water drainage from the
pit, waste rock dump and surrounding areas will be identified
and used to control pollution of downstream water sources.
 Plant trees and grass on the tailings (use of native grass shall be
considered
Loss of  Preparing the workers to be employed anywhere else in the Gold 10,000,000
employment Mineral Processing Plant through provision of extensive training
opportunities in modern exploration and mining techniques.
 Preparing the workers for forced retirement by providing skills
for self-employment, wise investment.
 Ensuring that all employees are members of the Pension
Fund and the employees should ensure that the developer’s
contributions are made.
 In time of decommission of this project, Proponent Company may
consider its employees in development of new projects as well as
for those skilled Tanzanian miners and minerals processors
TOTAL 135,000,000

139
140
 CHAPTER NINE:
9.0 ENVIRONMENTAL AND SOCIAL MONITOING PLAN
9.0: INTRODUCTION
Monitoring is the long-term process that normally begins at the start of the
project and throughout the lifetime of the project. Its purpose is to establish
benchmarks so that the nature and magnitude of anticipated environmental
impacts are continually assessed. Environmental monitoring involves
measurement of relevant parameters, at a level of details accurate enough,
to distinguish the anticipated changes. Monitoring aims at determining the
effectiveness of actions to improve environmental quality. The environmental
management and monitoring plans have been developed and outlined to
bring home the key findings of the Environmental Impact Assessment of the
project in mentioning, recommending necessary mitigation actions, defining
roles, indicators to be monitored and the estimated cost.

The EMPs outlined in tables hereafter address the potential negative impacts
and mitigation measures as well as roles, costs and indicators that can help
to determine the effectiveness of actions to upgrade the quality of
environment; as regards the proposed project. The EMPs have considered
construction, operation and decommissioning phase. There are four types of
monitoring that are relevant to this plan of proposed elution processing
project as described below

9.1 Baseline monitoring

This refers to the measurement of the environmental parameters during a
pre-project period and operation period to determine the nature and range of
natural variations and where possible establish the process of change.
Baseline monitoring for this project involves observation of the types and
rate of changes on the baseline conditions that had been discussed in the
previous chapter (chapter 4) which represents conditions prior to the start of
the project

9.2 Impact / effect monitoring

This involves the measurement of parameters (performance indicators)
during establishment, operation and decommissioning phase in order to
detect and quantify environmental and social change, which may have
occurred as a result of the project. This monitoring provides experience for
future projects and lessons that can be used to improve methods and
techniques. For this project impact monitoring involves analysis of the impact

141
of the proposed project such as employment opportunities, revenue
increases, and noise pollution.

9.3 Compliance monitoring

This takes the form of periodic sampling and continuous measurement of
levels of compliance with standards and thresholds – e.g. for waste discharge
and air pollution. The monitoring for this project involves collecting data for
the key parameters and compares them with the national and international
standards as provided in this ESIA report.
9.4 Mitigation monitoring
This aims to determine the suitability and effectiveness of mitigation
programs, designed to diminish or compensate for adverse effects of the
project. With regards to this project, mitigation monitoring involves
examining the effectiveness of the mitigation measures on whether
immediate measures are needed to enhance best practices. To ensure that
mitigation measures are properly implemented then monitoring plan is
important. The table below provides details of the attributes to be monitored,
monitoring frequency and institutional responsibility and estimated costs.
These costs are only estimations and therefore indicative. These costs are to
be covered by developer.

142
 Table 9. 1: Environmental and Social Monitoring Plan for the proposed mining project
Potential Impacts Parameter to be Monitoring Sampling Target Level/ Responsibilit Estimated
monitored Frequency Area Standard y Costs [TZS]

MOBILIZATION/CONSTRUCTION PHASE
Disruption of various Affected people, Once every Project area As minimum as Proponent 5,000,000
current land users of project land month possible
the project sites

Damage/disturbance Biodiversity Before Mined area As previously or Proponent 4,000,000

to protected habitats commissioning better
and species and once every
three months

Loss/disturbance of Natural habitats Before Mined area As previously or Proponent 6,000,000

biodiversity due to commissioning better
vegetation clearance and once every
three months
Potential for Number of Continuously Project No injury Proponent 5,000,000
increased road injured people during operation area and
accidents or animals, nearby
vehicle convoys villages

145
Potential Impacts Parameter to be Monitoring Sampling Target Level/ Responsibilit Estimated
monitored Frequency Area Standard y Costs [TZS]

Air pollution from Dust Once every after Project TBS LIMITS Proponent 1,000,000
emissions generating three months area [TZS845:2005]
equipment’s 0.06-0.09
250mg/Nm3(24hr
mean value)
NOx 24h mean value)
100 mg/Nm3 for
15 minutes,
Cox Not exceed
250mg/Nm3

Sox Not exceed

250mg/Nm3

Visual intrusion, dirt Dust level Once every Along the WHO and/or Proponent 4,000,000
on amenities and months road Tanzania
plants along the road standards

Noise pollution Noise levels, Once every after project 109 dBc (EMDC 6) Proponent 6,000,000
Availability and every three area
use of months
protective gear

146
Potential Impacts Parameter to be Monitoring Sampling Target Level/ Responsibilit Estimated
monitored Frequency Area Standard y Costs [TZS]

Loss of aesthetics Aesthetics of Continuously Project As minimum as Proponent 4,000,000

project site during the area possible
construction

Potential for surface Suspended WHO and/or Proponent 6,000,000

and groundwater solids in water Tanzania
pollution standards

BOD TBS LIMITS

30mg/L
COD 60 mg/L
Water quality after
PH every three Project 6.5-8.5
months area
TSS 100 mg/L

Turbidity 300 NTU

147
Potential Impacts Parameter to be Monitoring Sampling Target Level/ Responsibilit Estimated
monitored Frequency Area Standard y Costs [TZS]

Oil and Grease 10

(fatty
maters and
hydrocarbons),

Potential for health Health status of Once every after All project OSHA standards Proponent 1,000,000
and safety impacts to the workers three months areas
workers Safety records
Presence of
PPE’s
OPERARTION
Impairment of local Dust Once every after Project TBS LIMITS Proponent 4,000,000
air quality from dust, three months area [TZS845:2005]
fumes and noise 0.06-0.09
250mg/Nm3(24hr
mean value)

(24h mean value)

NOx 100 mg/Nm3 for
15 minutes,

148
Potential Impacts Parameter to be Monitoring Sampling Target Level/ Responsibilit Estimated
monitored Frequency Area Standard y Costs [TZS]

COx Not exceed

250mg/Nm3

SOx 60 mg/Nm3 for 30

minutes;
Losses and misuse of Security Continuously Cyanide No theft incidence Proponent 6,000,000
toxic chemicals due measures in during operation store
to theft of chemicals place, Number
and other inputs of theft
incidences

Potential for pollution BOD Water quality after Project TBS LIMITS Proponent 3,000,000
of soils, surface and every three area 30mg/L
underground water COD months 60 mg/L
from spills

pH 6.5-8.5

TSS 100 mg/L

Turbidity 300 NTU

149
Potential Impacts Parameter to be Monitoring Sampling Target Level/ Responsibilit Estimated
monitored Frequency Area Standard y Costs [TZS]

Oil and Grease 10

(fatty
maters and
hydrocarbons)

Air pollution from Fire Hazards, Once per every Project No fire incidence Proponent 6,000,000
release of noxious Number of fire three year area
gases in case of fire incidences,

Poisoning by Deterioration of Weekly for All project OSHA standards Proponent 300,000
hydrogen cyanide gas air quality occupational; areas
built-up in the store monthly for
ambient

Health impacts from Health status of Once every All project OSHA standards Proponent 5,000,000
accidental spillage of the workers, months areas
cyanide from general public,
storage facilities Safety records

150
Potential Impacts Parameter to be Monitoring Sampling Target Level/ Responsibilit Estimated
monitored Frequency Area Standard y Costs [TZS]

Potential impacts to pH, Weekly (during All project 30mg/L Proponent 4,000,000
wildlife from spillages DO, wet season) areas 60 mg/L
TSS 6.5-8.5
NO3 100 mg/L
TSS 0.2
Arsenic (As) 0.1
Cadmium (Cd) 2.0
Copper (Cu) 500
Sulphate SO42 0.
Silver (Ag)

151
Potential Impacts Parameter to be Monitoring Sampling Target Level/ Responsibilit Estimated
monitored Frequency Area Standard y Costs [TZS]

Potential for pH, Weekly (during All project 30mg/L Proponent

contamination of DO, wet season) areas 60 mg/L
surface and TSS 6.5-8.5
groundwater from NO3 100 mg/L
spillage and seepage TSS 0.2
Arsenic (As) 0.1
Cadmium (Cd) 2.0
Copper (Cu) 500
Sulphate SO42 0.1
Silver (Ag)

Contamination of Suspended Once every Nearby WHO and/or Proponent 10,000,000

sediments and down- solids in surface months surface Tanzania standard
gradient soils through waters (TSS waters 100mg/L
cyanide seepage Tailing
dam
Contribution to Timely First year of Project As maximum as Proponent 6,000,000
government revenues remittance of operation records possible
revenue

152
Potential Impacts Parameter to be Monitoring Sampling Target Level/ Responsibilit Estimated
monitored Frequency Area Standard y Costs [TZS]

Support to local social Support provided First year of Project As maximum as Proponent 4,000,000
services operation records possible

Employment and Local people Continuously Project As maximum as Proponent 4,000,000

training employed during operation records possible Company
Trained conducted

Impacts related with Number of people Report files Once every As minimum as Proponent 3,000,000
population influx six months possible Company

Health hazards to Health status of During All project WHO standards Proponent 5,000,000
workers from the workers decommissioning areas Safety Procedure. Company
demolishing work Safety records

DECOMMISSIONG PHASE

Pollution of surface BOD During Nearby TBS LIMITS Proponent 8,000,000

and groundwater decommissioning surface 30mg/L

153
Potential Impacts Parameter to be Monitoring Sampling Target Level/ Responsibilit Estimated
monitored Frequency Area Standard y Costs [TZS]

(seepage from TSF) COD waters, 60 mg/L

Tailing
TSS dam 6.5-8.5

PH 100 mg/L

Arsenic (As) 0.2

Cadmium (Cd) 0.1

2.0
Copper (Cu)

Sulphate SO42 500

Silver (Ag) o.1

Increased sediment Water quality, During Nearby WHO and/or Proponent 5,000,000
load from erosion Suspended decommissioning surface Tanzania standards Company
solids in surface waters,
waters Tailing
dam

154
Potential Impacts Parameter to be Monitoring Sampling Target Level/ Responsibilit Estimated
monitored Frequency Area Standard y Costs [TZS]

Loss of aesthetics due Aesthetics of PL During Project As minimum as Proponent 20,000,000

TSF decommissioning area possible Company
structure

Loss of employment Pension fund Once every year Plant All workers Proponent 10,000,000
opportunities remittance Company

TOTAL COST 145,300,000

155
 CHAPTER TEN:
10. COST BENEFIT ANALYSIS
10.1 FINANCIAL COST BENEFIT ANALYSIS
Cost benefit analysis as a valuation technique takes a long view of
projects (further as well as near future) and a wide view (in the sense of
allowing for side effects). The fundamental evaluation principle is to
measure in monetary terms where possible and then reduce all these
costs and benefits to the same capital or annual basis. Chapter 6 and 7
of this EIS report have documented the cost/impacts of the Gold
Mineral Processing Plant project to Tanzania and the degree to
which they can be substantially mitigated. Cost-benefit analysis is
normally done in the framework of feasibility study of an activity.

The aim of cost-benefit analysis is to inform the project developer

to make a decision on: whether it makes economic sense to
continue with the project; whether the chosen option is a cost
effective alternative; and the estimate of the size of a project. For this
project the costs will include: capital expenditures; operating and
maintenance costs; staff costs; materials; research and
development; and environment, health and other social costs.
Benefits may include: better, understanding of the target business;
accurate targeting of the resource; potential for additional revenues
generated from new resources; protection of environment and health;
and provision of other social benefits. The proposed project has
undertaken a feasibility study and has confirmed that the project is
economically viable.

10.2 COST STRUCTURE

The tangible and intangible annual benefits of the project would include
the following:
 Monies gained from sale of gold
 Potential to increase employment locally
 Potential to increase local economy by injecting funds into the
surrounding community
 The ability to contribute over the long term to a better internal
economy in Tanzania The tangible and intangible costs of project
include:
 The cost of general operations, paying employees, food, and
maintenance. All running costs
 The initial start-up cost of establishing a process area and the
operational costs also associated with running it
 The environmental costs would include a definite loss of
biodiversity as construction of plant would entail the clearance of
natural vegetation to allow activities to take place effectively

156
  The destruction of the natural landscape which cannot be
completely restored to its original pristine shape once altered
 The potential cost to surrounding communities in terms of
heightened noise levels, increased contamination of both
surrounding air and water, and increased dust as a result of
the gold processing activities.

10.3 FINANCIAL EVALUATION

The total investment cost for the proposed establishment of the
Establishment of the Project is about TZS 2,000,000,000.00. This
covers the construction and operation cost.

The installation of the Processing Plant will also present the opportunity
for producing a higher grade of gold concentrate, potentially resulting in
conc. Shipping cost savings and reduced overall smelting costs plus
increasing gold reporting to the tailings. It is estimated that an additional
gold can be recovered and the gold recovery plant increase the
production by over 5%. Failure to install the plant will result in the
continued loss of gold revenue and employment. Whilst this gold would
still be available for future reclamation it would be significantly diluted by
the low grade tailings requiring a much larger plant and a higher
production cost per ounce.

The economic viability of the project has been evaluated by

conventional discounted cash flow techniques using the production
rate, capital expenditure and operating cost estimates summarized
above, together with the following additional provisions and
assumptions:
 Expenditures incurred prior to the production decision date are
assumed to be sunk costs and are not included in the financial
analysis, except for tax purposes.
 In addition to direct life-of-project capital expenditures and
operating costs, the following cost provisions have been
included in the financial evaluation:
 Applicable royalties

At a 90% gold recovery from a 720tpd heap leaching plant and projected
85% purity of gold, will yield at least 19,222 Oz Au per year for 11 years.
With the current gold price at US$ 1963 and predicted to stay around
US$1959, a total of at least US$ 11.53 M is expected every year for 11
years’ period. With significant spending on brown fields exploration in the
areas contiguous to Sailat Investment Limited (e.g. northeastern and
southwestern extensions of Reefs, detailed exploration of high-ranking
targets identified along the contact between oxide-facies BIF and felsic
volcanic rocks. Prospects and deposits generated through this process will
157
upgrade the mineral resource base for the Sailat Investment Limited.

Project’s Economic Valuation

Evaluation of the project’s costs and revenues is re-assessed in terms of a
discounted cash flow analysis with a positive Net Present Value (NPV) and
an Internal Rate of Return (IRR) of the project has been presented in Table
24. Since, the project NPV is positive and IRR is greater than >1 then the
project is accepted.
The following important economic parameters have been used in
generating a discounted cash flow analysis:
(a) A discounted Rate of Return on the Project of 14%; Mine life of 10
years
(b)Income Tax rate of 30% applicable for Tanzania
(c) A five-year investment tax credit has been considered under
Tanzanian tax rules.
(d)Tax exemption on fuel, oils, and other imported supplies have not
been considered and when incorporated will also greatly boost
the cash flow of the project.
Based on the above parameters the project has shown to have good
potential to generate cash as summarized in some of the important
economic indicators shown in Table 10.

10.3.1 Cash Flow Analysis

Evaluation of the project’s costs and revenues is re-assessed in terms of a
discounted cash flow analysis with a positive Net Present Value (NPV) and
an Internal Rate of Return (IRR) of the project (Table 24). Given a
projected gold price of US$ 1,959/Oz, a discount rate of 15% and low
CAPEX (US$ 5 M in Year 1 and OPEX pertaining to this project, a Net
Present Value (NPV) of U$ 153.57 Mill (positive=investment creates value)
with the Internal Rate of Return (IRR) of 509.44 % point to a viable project
worth investing in by Gold Project. Since, the project NPV is positive and
IRR is greater than >1 then the project is accepted.

The following economic parameters used in generating a discounted cash

flow analysis:
a) A discounted Rate of Return on the Project of 14%; Oxide Mine life
of 10 years
b) Income Tax rate of 30% applicable for Tanzania
c) A five-year investment tax credit has been considered under
Tanzanian tax rules.
d) Tax exemption on fuel, oils, and other imported supplies have not
been considered and when incorporated will also greatly boost the
cash flow of the project.
e) Based on the above parameters the project has shown to have good
potential to generate cash as summarized in some of the important

158
 economic indicators.

10.4 EFFECT ON THE LOCAL COMMUNITY

The benefits from Mineral processing development can be judged in
terms of employment and the local economy (wages, goods and
services). Thus, there will be a substantial spread of the benefit within
the community. In maintaining the high production on the land of the
project area, it is important that the people who live in the neighborhood
enjoy and share with the project proponent the comforts and advantages
of other material wealth. This is because every local person would
wish to secure for himself better educational opportunities for his
children and improve medical services for his family. Local people are
anxious to have the benefits of electricity, running water, power and
health services, so that life in the village will be attractive, healthful and
satisfying to all members of the family. This will also go a long way
towards reverting and finally curbing the current rapid rural-urban
migration of youths in search of employment. Therefore, the
contribution of the project to the local economy by way of wages
and the purchase of goods and services will further accelerate the
attainment of this objective.

Although people of all ages are involved in the migration to the Region, it
is the loss of the youth from the rural areas that is regarded as most
serious both economically and culturally. When the youth from these
areas migrate to the cities when they attain the working age, the rural
areas suffer a serious loss. The migration of the rural youth to the cities
without a counter movement of the Region youth to the rural areas
results in an important net loss for the rural areas. This regular
outflow from the rural areas results in the dramatic increase of the urban
populations.

10.5 INFRASTRUCTURE DEVELOPMENT

The upgrading, development and maintenance of local infrastructure are
benefits that will extend far beyond the project's scope and lifetime.

10.6 ADVANTAGES FOR THE BROADER COMMUNITY AND COUNTRY

The earnings of the project will in the final analysis increase the foreign
exchange earnings of Tanzania. A major portion of the Project
Proponent’s expenses will be in Tanzania Shillings, specifically on freight
and transportation of equipment and some of the services have already
been contracted to Tanzanian suppliers and contractors. Under the
development of the project, the broader community and the government
participate in the establishment and success of the operation through:-

a) an increase in those direct foreign exchange earnings on gold

159
 sales and through leverage the increase contributes to other
potential financial structuring.
b) Generation of income through royalties and taxes, including taxes
on personnel.
c) Employment, development and training of Tanzania nationals.
Tanzania has many mineral opportunities, notably diamond, nickel,
gemstones and industrial minerals. Personnel trained by the
company in modern gold processing will in time, leave to
spread their acquired skills to other operations. In time and with
the development of new projects, the Project Proponent will provide
a source of employment for its employees as well as for those
skilled Tanzanian miners and mineral processors.
d) The Project Proponent will implement modern innovative gold
processing methods with an extremely high level of quality
control. Such skills, together with the training of artisans to new
technologies will be transferable to industry in general.

10.7 ENVIRONMENTAL COST AND BENEFIT ANALYSIS

Environmental cost benefit analysis is assessed in terms of the
negative and positive impacts. Furthermore, the analysis is considering
whether the impacts are mitigatable and the costs of mitigating the
impacts are reasonable. As it has been mentioned in Chapters 6 – 9, the
potential benefits of the project, in terms of financial and social benefit
are substantial. The environmental impacts are reasonably mitigatable
and the financial resources needed to mitigate negative impacts, when
compared to the required investment are relatively small.

CHAPTER 11
11.0 PRELIMINARY DECOMMISSIONING PLAN
11.1: INTRODUCTION
This plan establishes feasible decommissioning schemes that can be
accomplished without undue risk to the health and safety of the public
and decommissioning personnel, without adverse effects on the
environment, and within established guides and limits of the appropriate
regulatory agencies. While not a detailed document, this preliminary plan
will serve to ensure that the decommissioning and ultimate disposition of
a facility are considered during the initial design and construction of
that facility. The preliminary plan will remain a “living document,” and
revisions will be made throughout the operating life of the plant. It must
be reviewed periodically and revised to reflect any changes in facility

160
construction or operation that might affect decommissioning. Prior to the
initiation of actual decommissioning activities for the Mineral processing
plant, a detailed final disposition plan will be prepared.
The final plan should be based on the preliminary plan and
revisions, and will define specific work activities and include safety
evaluations of planned decommissioning methods, new technology, and
the facility status that will result from the decommissioning program. In
addition, this plan must contain sufficient information to obtain any
approvals needed from the appropriate regulatory agencies to
proceed with decommissioning activities.

11.2 PURPOSE AND CONTENT

11.2.1 Plan Purpose
The preliminary plan serves to establish decommissioning as an
important consideration from the inception of the project, during design
and throughout the operation of the facility. The plan has the following
purposes:
a The primary purpose of the preliminary plan is to ensure that
gold mineral processing plant designers are cognizant of
decommissioning during the initial design of a facility. Thus,
where design choices that would enhance decommissioning are
available for types of materials and system components, and
location of components, these choices should be made.
b Another purpose of the preliminary plan is to identity the
ultimate decommissioning options and final facility status. These
options would be evaluated and narrowed to the decommissioning
method of choice as the end of facility life is approached.
c The final purpose of the preliminary plan is to demonstrate to
regulatory agencies that important aspects of decommissioning
are considered as early as possible during the initial design of
a facility. The plan serves as the starting point to demonstrate that
areas such as decommissioning methods, costs, schedules, and
operating impact on decommissioning will be reviewed and refined
throughout the operating life of a facility.

11.2.2 Plan Content

The preliminary plan will provide a general description of
decommissioning methods considered feasible for the facility. The
description should demonstrate that the methods considered are practical
and that they protect the health and safety of the public and
decommissioning personnel. Design personnel should study the proposed
decommissioning methods and take steps to ensure that the design
incorporates features that will facilitate decommissioning.
Considerations include:

161
 (a) An estimate of manpower, materials, and costs anticipated to
support decommissioning.
(b)A description of the anticipated final disposition and status of the
Heap Leaching Processing Plant and site.
(c) A discussion demonstrating that adequate financing will be
programmed for decommissioning.
(d)Identification of records that should be maintained during
construction and operation which might facilitate
decommissioning, including a set of “as built” drawings.

11.3 PRELIMINARY PLAN

11.3.1 Project Removal Methodology and Schedule
The company shall fund and implement all aspects of project
decommissioning, including but not limited to, all engineering,
environmental assessment, permitting, construction, and mitigation
activities associated with the removal of the Mineral processing plant, in
accordance with this Plan and mitigation of Project removal impacts on
site. The company shall monitor environmental impacts during and after
Project removal to respond to defined events during the monitoring phase.
The company shall remove the plant and ancillary structures safely and in
a manner that:
 minimizes environmental impacts;
 Satisfies company’s obligations under the EMA (2004);
 restores the site to a condition suitable for multiple use; and
 Pays all dues (workers, government, suppliers etc.).
Project removal will begin six months after closure and continue for six
months. Within the six months from closure, the companies will
inventories all components that need to be removed and or disposed of.
This inventory will include building structures/tents to be demolished,
debtors and creditors to be settled. Also mode of disposal will have to
be finalized. This information will assist in the preparation of the final
decommissioning plan, for approval by NEMC.

After the approval of the decommissioning plan the metal parts will
be removed first within the first month (this is important to ensure
that they are not vandalized). The second month of the
decommissioning will be used to remove concrete structures and
foundations. Debris will be used as road fills for rural roads. Plant and
associated facilities (e.g. Stores)
 All serviceable equipment and machinery will be auctioned or
relocated to a new and operating site of the Company;
 All concrete structures will be demolished and the area rehabilitated
in order to restore the value of the land to that which existed prior to
commencement of the mine;
 All left over chemicals will be destroyed in accordance to the
162
 procedures outlined by the “Industrial and Consumer Chemicals
(Management & Control) Act, 2003”. Prior to destruction of the
chemical, the developed procedures for implementation will be
submitted to the Ministry of Energy and Minerals, Government
Chemist and the National Environmental Management Council for
approval.
 All scrap metals will be disposed through recycling through
steel manufacturing mills that are licensed to use such
materials. Currently, the mine disposes scrap metal through
auctioning to licensed metal dealers.

Tailings Storage Area

 The top surface will be covered with top soil layer (not less than
30cm) and planted with indigenous grasses and trees. In order to
establish the suitable type of vegetation, tests of various species and
soil types and conditions will be carried out.
 The soil types and condition will be created by utilizing the tailings
materials with varying water contents in simulation of the possible
scenarios. The top soil cover will be obtained from stockpiles created
from stripping operations in various parts of the site.
 Continuous monitoring of the vegetation for metal uptake will be
undertaken. If harmful levels of metals are detected, rehabilitation
procedures will be reviewed in order to address and mitigate the
situation and ensure levels that are safe for animals and plant life.
 Water monitoring points downstream the tailings storage AREA will
be utilized to ensure the water quality meets the standards
specified in the Fifth Schedule of the Mining Act, 2010 (Act No.
14/2010).
 All the water courses in the area will be rehabilitated to a
condition that ensures the long-term maintenance of water quality
to that specified in the Fifth Schedule of the Mining Act, 2010 (Act
No. 14/2010).
 Drainage will be restored either to water courses or to new
water courses that will sustain themselves without maintenance
and will aim to ensure the use and productivity objectives are
achieved to the level that is not less than that prior to mining.
 A All serviceable equipment and machinery will be relocated to
new and operational sites of the company.
 All structures like workshop buildings, pillars, platforms or ramps
on which machinery/equipment stood will be demolished and
made safe. Areas on which these structures stood will be
rehabilitated and re-vegetated accordingly.
 All unserviceable equipment will be sold through auction to scrap
dealers.
 The future use of water supply infrastructure (pipeline and dams)

163
 will be established through the National and Town Closure
Committees.
 All disturbed areas will be landscaped and re-vegetated using
indigenous trees.
 Project decommissioning has five phases: (1) pre-removal
monitoring; (2) permitting; (3) interim protective measures; (4)
Project removal and associated protective actions; and (5) post-
removal activities, including monitoring of environment and socio
economic activities The first three phases will occur prior to removal
of the Project (i.e. within the first six months). The fourth phase —
project removal and associated protective actions — will take place
six months after closing business. The fifth phase will begin after
total removal and due to nature of the project (medium scale, with
relatively moderate impacts) removal and continue for at least one
year.

The description that follows outlines the activities that will occur in each
phase:
1) Pre-removal monitoring: Pre-removal monitoring includes
environmental and socio economic status of the Mineral processing
plant, and the surrounding. This monitoring is essential to identify if
there is any environmental or social liability which need to be settled
before the permit for closure is given. This period will also be used to
inventories all assets and facilities that need to be disposed of, and
to prepare a final decommissioning plan for approval by NEMC.
2) Permitting: the company shall obtain all permits required to
undertake removal of the Project. This basically will include
NEMC, TRA, Pension Fund, Local Government Authorities,
Misungwi District council etc.
3) Interim Protective Actions: This will take care of any interim
protective measure that needs to be implemented to protect human
health and environment, if any.
4) Project Removal: As noted above, the removal of the project will be
completed within six months.
5) Post-Removal Activities: Post-Project removal monitoring will
continue for one year.
6) The implementation of the Closure Plan will demonstrate the
successful completion of the closure process and justify
relinquishment of the Special Mining Licence lease.

Table 11. 1: Impact mitigation measures for the proposed project during
the decommissioning phase
Impact Mitigation Measure Responsible Costs
Institution
(x000)

164
Soil erosion -Rehabilitate degraded Proponent and 10000
areas with natural trees Contractor
and grasses

Ground water -Domestic liquid waste Proponent and 10000

pollution and solid waste from the Contractor
demolished facilities shall
be well managed and not
discharged to the open
environment
Noise and Air -Limit noise to core work Proponent and 5000
pollution areas and use low noise Contractor
equipment
- Movement of vehicles to
and from the project site
shall be kept to minimum
as the place is purely a
protected area
Loss of employment -Alternatives source of Proponent and 20000
employments and income Misungwi
generation such as District Council
Agriculture
Health and Safety -Proponent shall ensure Proponent and 15000
issues use of PPE’s Contractor
-Signs shall be posted
indicating
decommissioning and
prevent non-authorized
persons from entry to the
site
Change in the life -Sensitization to workers Proponent and 20000
style and quality of prior to decommissioning Misungwi
life to plan and adapt to new District Council
environment including
looking for alternatives
employments such as self-
employment
Total 80,000 TSH

165
 CHAPTER TWELVE:
12.0 SUMMARY AND CONCLUSION
12.1 SUMMARY AND CONCLUSION
The ESIA study clearly demonstrated that with relatively easy and cost
effective mitigation strategies, social and environmental impacts can all
be kept to a low significance while beneficial impacts can be easily
enhanced. Furthermore, the ESIA study clearly revealed that the
anticipated negative impacts will be short-term, site specific, confined and
reversible and can be managed through the application of corresponding
mitigation and monitoring measures while beneficial impacts can be
readily enhanced. Mindful of the greater socio-economic significance of
investment of the project, their successful implementation will improve
the quality of life of to the local community living nearby the project area,
Shilalo District and the country at large.

The ESMP has been prepared from the ESIA report and has suggested
comprehensive generic mitigation measures. Predicted impacts shall be
managed through the proposed mitigation measures and implementation
regime laid down in this EIS. Implementing such mitigation and
enhancement measures will reduce the limited potentially significant
adverse environmental impacts to acceptable levels. Therefore, increase
environmental and social soundness of the program in line with applicable
national and international environmental policies, legislations and
procedures. It is certainly up to proponent to ensure an effective and

166
 efficient coordination mechanism for safeguard management at the
Ministry and local levels particularly for the implementation of the project.

REFERENCES

1. Barth, H., 1990. Provisional Geological Map of the Lake Victoria Goldfields,
Tanzania, 1: 500,000 (with explanation notes). Géol. Jb B 72, 3-59.
2. BRGM (Bureau de RecherchesGéologiques et Minières), University of Dar-
es-Salaam, Tanzania Geological Survey., 2004. A 2,000, 000 scale
Geology and Mineral Map of Tanzania. In: Pinna, P., Muhongo, S., Mcharo,
B.A., LeGoff, E., Deschamps, Y., Ralay, F., Milesi, J.P., (compliers), 20th
Colloqulum of Africa Geology 2-7th June 2004. BRGM, Orleans France..
3. Chamber of Mines of South Africa, March 1996, “Guidelines for
Environmental
Protection, the Engineering Design, Operation and Closure of
Metalliferous, Diamond and Coal Residue Deposits”.
4. Harpum, J.R., 1970. Summary of the geology of Tanzania: structure and
geotectonics of the Precambrian. Tanzania Geological Survey, Memoir 1,
Part V, 58pp.
5. Hester, B.W., Barnard, F., Johnson, A., 1991. Tanzania: Opportunities for
mineral resource development in Tanzania, pp. 108.

167
6. International Organization for Standardization, ISO 14001, 1996,
Environmental Management Systems – Specification with Guidance for
Use.
7. iLanda Water Services, 2013, ‘Bulyanhulu IWMP’, Report 0070-Rep-002
Rev0.
8. Laine, D.L. and Darilek, G.T., 1993, “Detecting leaks in geomembranes”,
Civil
Engineering 63, no. 8:5-53.
9. Kabete J., Groves D.I., McNaughton N., Mruma A.H., (2012). A new tectonic
and temporal framework for the Tanzanian Shield: Implications for Gold
Metallogeny and Undiscovered Endowment. Ore Geology Reviews 48
(2012) 88–124.
10. Kimambo
Africa Publications, Arusha, pp 144.
11. Ministry o
Assessment Guidance, October2014
12. Murray, G
rates through flexible membrane liners”, Fall 1995 GWMR pp 148-154
13. Pinna, P.,
Godynamic evolution and metallogenic controls in the East-African Craton
(Tanzania, Kenya, Uganda). Scientific and Technical Communications.
Chronique de la Recherche Miniere 525, 33- 47.
14. Quennell,
geology of Tanganyika: introduction and stratigraphy. Tanganyika
Geological Survey, Memoir 1, Pt. 1, 264pp.
15. Responsib
16. URT, The
17. URT, The
(G.N. No. 348/2005)
18. URT, The
19. URT, The
20. URT, The
21. URT, The
22. URT, The
23. URT, The
24. URT, The
25. URT, The
26. URT, The

168
27. URT, The
28. URT, The
29. URT, The
30. URT, The
31. URT, The
32. URT, The
33. URT, The
34. URT, The
35. URT, The
36. URT, The
37. URT, The
38. United Re
Guideline’’,2020
39. World Ban
(Policies, Procedures, and Cross-Sectoral Issues), Volume II (Sectoral
Guidelines) Volume III (Guidelines for Environmental Assessment of
Energy and Industry Projects), Washington

169
 APPENDICES
APPENDIX 1: TERMS OF REFERENCE
1.0 INTRODUCTION
DF METAL MINING LIMITED of P.O. Box112 Kahama–Tanzania is a private
company incorporated under companies Act, 2002 and given registration
number177686476. The company is also registered as a Taxpayer with TIN
(Tax identification number) 177-686-476 by Tanzania Revenue Authority.
The company is limited and a new venture intending to engage in mineral
processing activities. The company is proposing to establish the gold ore
mining and Heap leaching Plant which will process tailings as raw materials
from exiting small scale gold miners and from open cast mining at the site
to obtain gold. The company intends to establish gold mining and
processing plant project (Heap leaching) at Ikungumhulu Village, Shilalo
Ward, Misungwi District in Mwanza Region.

DF METAL MINING is expecting to conduct gold mining activities in 6

Primary mining licenses namely PML0228MZA, PML0229MZA,
PML0230MZA, PML0231MZA, PML0232MZA and PML0317MZA with total
area of 54.85 hectares which were mined previously by small scale miners.
The 6 primary mining licenses are owned and licensed to M/S JIKOMBOE
MINING IKUNGUMHULU of P.O. Box 112 Kahama-Shinyanga. The JIKOMBOE
MINING IKUNGUMHULU Company has entered a Mining Agreement with DF
METAL MINING LIMITED for technical support. The site for the proposed
development is legally owned by M/S JIKOMBOE MINING IKUNGUMHULU
Company.

The total investment cost for the proposed establishment of the

Establishment of the Project is about TZS 2,000,000,000.00.

During scoping several key environmental issues were identified after site
reconnaissance, holding consultations with stakeholders of the project and
reviewing various literatures related to the project. Similarly, expert
opinion was sought on various key issues identified as requiring
specialized knowledge.

The purpose of Terms of Reference (TOR) therefore, is to provide formal

guidance to the Proponent /EIA Consultant on the range of issues that
must be addressed in the EIA process. They also form a basis for
subsequent review process. In these ToRs, strategies for addressing
issues identified during scoping have been incorporated to make the EIA
focused.

OBJECTIVES OF THE EIA STUDY

170
Gold mining and processing plant project is included in the mandatory list
of projects for which EIA is mandatory according to the Environmental
Management Act (2004). Part IV of the EIA and Audit Regulations (2005)
provides the general objectives for carrying out EIA; among others a list
includes the following:
a) to ensure that environmental considerations are explicitly
addressed and incorporated into the decision making process;
b) to anticipate and avoid, minimise or offset the adverse significant
biophysical, social and relevant effects of developmental proposal;
c) to protect the productivity and capacity of natural systems and
ecological processes which maintain their functions; and
d) to promote development that is sustainable and optimises
resources use and management opportunities.
Consequently, the proponent would like to undertake Environmental
Impact Assessment so as to translate principles of sustainable
development and environmental protection into strategies and actions
that can be practically applied to her intended project.
The specific objectives of the EIA are to:
 Establish baseline information on both natural and built
environment including socio- economic conditions of the proposed
project area;
 Identify, predict and evaluate foreseeable impacts, both beneficial
and adverse, of the proposed investment;
 Develop mitigation measures that aim at eliminating or minimising
the potential negative impacts and promote positive ones; and
 Develop management plan and monitoring plan for ease of
reference during project implementation.

DESCRIPTION OF THE PROJECT

The proposed project is concerning with small scale gold mining and
processing. The construction of the project infrastructure will entail
clearing of vegetation and removal of rubble (where surface mining is
applied), drilling, blasting, and further activities will include loading and
hauling of blasted rock to the stockpile or dumping on waste rock dumps.
In order for the mine to operate, the construction of support facilities will
be required. These will include:
 Processing plant and foundations that will accommodate
machinery;
 Magazine;
 Two Staff quarter;
 Workshop;
 Laboratory;
 Office administration building of movable quality;
 Analytical laboratory;

171
  Technical services infrastructure dealing with grade control, short-
term and long term mine planning and safety health and
environmental matters (SHE);
 Engineering workshops (by blocks), involves serving of light
and heavy vehicles, maintenance and pre-start check-up; and
 Staff housing units areas;
 Health facilities;
 Site clearing and levelling for construction of the various
project facilities; and Overburden waste removal to access the
gold mineralized deposits.
The operational phase will commence after development has been
completed and infrastructure to support the production operations is
commissioned. The strategy of the company is to first mine and process
the ores under lying within the surface zones in the license. This entail
site construction has the purpose of determining the extent of
mineralization at depth as well establish the resource. Based on the
topography and geology of the mining site preparation will involve
clearing ground for access to the mine process plant area stockpile area
waste area vehicle parking and maintenance areas staff quarters and a
recreation area.
Development of the open pit will require minimum development as the
mineralized gravels and bedrock are within 1-2 m from the ground
surface
Production operations will include routine unit operations, which include:
 Drilling and blasting of rock for both waste and worth rocks;
 Loading and haulage of waste and ore;
 Waste rock dumping in waste rock dump;
 Processing of the ore to recover bullion;
 Further exploration; and
 Other associated activities.

Once ore has been mined and stockpiled near the processing plant wheel
loaders will start feeding the crusher to crush the material into sizes that
can be milled by a ball mills. Processing (heap leaching of crushed ore
with dilute cyanide solutions with precious metals production in carbon
adsorption-desorption recovery (ADR) plants to produce gold/silver ore
bars and elution plant will be applied. Within this framework, leach
solution that becomes pregnant state resulted from leaching process and
exposed to serial active carbon columns in the ADR plant, will provide
precious metals contained within the solution to be adsorbed onto
activated carbon and Elution Plant

Under the Environment Impact Assessment & Audit Regulations, 2005 GN

No.349 of 2005, the project is categorized under Type A project for which
a full EIA is mandatory.

172
4.0 SCOPE OF THE EIA STUDY
The EIA shall be conducted in accordance with the guidelines laid down by
the Environment Management Act (EMA, 2004). The main steps to be
followed by the Consultant in the environmental impact assessment will
involve:
 Identifying, collecting and analysing information which include:
o project characteristics and activities;
o baseline data of the environmental and socio-economic
setup;
o predicting impacts;
o evaluating impacts’ significance;
o identifying and proposing mitigation measures;
o preparing the Management and Monitoring Plan and Follow
up; and
 Presenting the information which involves writing an
environmental Impact Statement (EIS).
The approval process shall also be according to the laid down procedure
whereby these Terms of Reference will be approved by NEMC before the
full EIA commences. Following the EIA study the Environmental Impact
Assessment Report will be submitted to NEMC for review and approval.
The Consultant shall carry out the following tasks:

Tas 1: Stakeholders Consultations

Consultations with stakeholders have been undertaken during the scoping
stage of the EIA. Main stakeholders and their concerns are elaborated
under chapter 5. The Consultants shall carry this further during the
impact study. Among other things in task 1, the EIA report shall also
feature how the views and concerns of the stakeholders have been
addressed. Consulted stakeholders shall sign against their names and
shall be appended.

Task 2: Description of project area

In order to cover assessment of all key issues related to the project, the
study area shall be much wider than that covered by the project site
where most of the project operations and facilities and services will be
located. This is because some of the impacts might have local, regional or
national implication. The core area has been determined to be the whole
area that is covered by the project site.

The Consultant shall: further determine and set the project

boundaries particularly spatial boundaries (i.e. impact area coverage
and area of influence).
The Consultant shall give details of:

173
  Location of all project-related development and operation sites;
 General layout of facilities at the site - diagrams of facilities, design
basis, size, capacity;
 pre-construction activities and construction activities;
 Organizational relationships, mandates and interactions among the
different parties to be involved in the project.
In addition to the above the tasks the consultant shall give details of the
following:
 Activities to be carried out in each phase of the project i.e.
pre-construction, construction, operation and decommissioning
phase;
 The purpose and objectives of the proposed development shall be
clearly stipulated;
 Types and quantities of material and inputs
needed during pre-construction, construction and
operational phases ;
 The types and quantities of wastes, energy and residual materials
and the rate at which these will be produced;
 The description of methods used to make estimations of waste
generated, and the proposed methods of waste treatment and
disposal; and
 The project capital cost and source of funds.

Task 3: Description of the Environment

The Consultant shall provide description of:
 The location and area of land affected by the development. This
shall also be shown on maps and the current land uses of the area
shall be clearly demarcated;
 Definition of affected site shall be broad enough to include any
potential effects occurring away from the construction site (e.g.
dispersal of pollutants, traffic, changes in channel capacity of
water sources as a result of increased surface run off etc.);
 Baseline condition of the current biophysical, ecological, socio-
economic and cultural environment and prediction of the future
condition if the project did not take place; and
 The method used to gather the baseline information.

Baseline data shall be gathered in such a way that the importance of the
particular area to be affected can be planned into the context of the
region or surrounding area and that the effect of the proposed change be
predicted and monitored

Task 4: Legislative and Regulatory Considerations

The Consultant shall:

174
Describe pertinent local, national and international regulations and
standards governing environmental quality, health and safety, protection
of sensitive areas and underground water resources, land use control etc.
The EIS shall show how the company will comply with the cited policies
and Legislation

Task 5: Prediction, Identification and Analysis of Impacts

Under this activity the consultant shall:
i. identify issues and concerns in order to find suitable remedies;
ii. identify linkages among project components and the issues;
iii. identify where project activities or elements interact with social
and biophysical environment (direct impacts):
iv. identify indirect impacts of the project on the environment;
v. identify cumulative impacts that may be anticipated;
vi. identify residual impacts if any;
vii. predict probability, magnitude, distribution and timing of expected
impacts:
viii. carry out assessment of alternative sites and alternative
technologies in order to come out with the best option; and
ix. Forecast what will happen to the affected environmental
components if the project is implemented as is or if the alternatives
(e.g. sites and technologies) are chosen (a no- project option will
also be considered).

The consultant shall also outline:

 The methodology used to identify and analyses likely impacts;
 The logic used to identify key impacts on human beings, flora and
fauna, soil, water, air, climate, landscape, cultural heritage or their
interaction, should be explained; and
 The data used to estimate the magnitude.

Furthermore, the consultant shall: assess:

 The significance of impacts using the appropriate national and
international quality standards where available; and
 Remaining impacts after mitigation using the appropriate national
and international quality standards where available. Where no
such standards exist, the assumptions and value systems used to
assess significance should be justified.

Task 6: Estimation of the Significance of the Impacts

The consultant shall:
i. determine which environmental components are mostly affected by
the project or its alternatives;
ii. list issues raised by the public and classify them according to the
level and frequency of concern whenever possible;

175
 iii. list regulatory standards, guidelines etc. that need to be met; and
iv. Rank predicted impacts in order of priority for avoidance, mitigation,
compensation and monitoring.

Task 7: Analysis of alternatives to the project

The consultant shall:
 Discuss alternative sites, undertakings, processes, technologies
and design;
 Discuss the main environmental advantages and disadvantages
and the reasons for the final choice given; and
 Make a comparison of the alternatives in terms of potential
environmental impacts as well as capital and operating costs i.e.
cost benefit analysis of each alternative/option

Task 8: Development of Environmental and Social Management

Plan (ESMP)
In preparation of the ESMP the following activities shall be performed:
 Specific mitigation measures and enhancement measures shall be
identified on all significant impacts.
 Effectiveness of mitigation methods shall be ascertained. Where
the effectiveness is uncertain justification of the acceptance of the
suggested interventions/assumptions shall be provided.
 Effective environmental and social management plan shall be
prepared. The Environmental and Social Management Plan shall
identify, among other things: Phase of the project, identified
impacts, mitigation measures, responsibility and budget estimates.

Task 9: Development of Environmental Monitoring Plan

In preparation of the Monitoring plan the consultant shall ensure that the
plan is consisted of the following:
i. Phases of the project,
ii. Identified impacts.
iii. Mitigation measures
iv. Parameter to be monitored
v. Sampling area/points
vi. Frequency of monitoring
vii. Standard/target level
viii. Responsible institutions
ix. Budget estimates

The consultant shall also:

 determine and assess methods to monitor impacts for predicting
accuracy remedial measures for effectiveness;
 describe follow up scheme and post project action plan;

176
  assess the level of financial commitment by the proponent
for management and monitoring plan and follow activities;

The consultant shall be guided by the cost-effectiveness principles in

proposing mitigation measures. Estimation of costs of those measures
shall be made. The assessment will provide a detailed plan to monitor the
implementation of the mitigation measures and impacts of the project
during construction and operation.

Task 10: Reporting requirement and Report Presentation

The final draft of the EIS document shall be concise and in line with EIS
format stipulated in the Environmental Impact Assessment and Audit
Regulations (2005) G.N. No. 349 0f 2005. The contents and the structure
of the main text (EIS) shall be presented according to Regulations 18(1)
and (2) of the Environmental Impact Assessment and Audit Regulation,
2005.

The Executive summary shall not be in separate document rather, shall be

part of the EIS. The contents and structure of the Executive Summary shall
be as per Regulation 18 (3). There shall be a standalone/separate
document of Non-Technical Executive Summary to be both in Kiswahili and
English languages stating the key findings, conclusions and
recommendations as per the requirement of Regulation 19(2) of the EIA
and Audit Regulations of 2005 and its amendments of 2018.

Submission of the EIS, Non-Technical summary and prescribed fees shall

observe the requirements of Regulations 19 to 21 of the EIA and Audit
Regulations of 2005 and its amendments of 2018.

5.0 STUDY TEAM

The consultants shall deploy consultants/experts with the demonstrable
practical experience in conducing EIA studies, with specific experience in
environmental management, environmental engineering, Mineral
processing, health & safety specialist and a sociologist

177
APPENDIX 11: CERTIFICATE OF INCORPORATION AND TIN

178
179
APPENDIX 1II: PRIMARY MINING LICENSE AND TECHNICAL
SUPPORT AGREEMENT

180
181
182
183
184
185
186
187
188
189
\

190
APPEINDIX IV: STAKEHOLDER CONSULTATION FORM

191
192
193
194
195