ENVIRONMENTAL & SOCIAL IMPACT ASSESSMENT

STUDY

FOR

Gold Mining Activities

Final Report
 EXECUTIIVE SUMMARY

This report is an Environmental and Social Impact Assessment study ESIA study for the gold
mining activities in the Northern State. The objectives of the ESIA are to identify and predict
the sources and types of environmental and social impacts related to the construction and
operation phases of the gold mning proposed activities. The study also aimed at prescribing
appropriate mitigation measures for the identified adverse impacts. Other aims included
establishing of an Environmental Monitoring and Management Plan (EMMP), which is a
management tool to ensure that mitigation measures and actions approved through the ESIA
report to protect the environment are adopted and implemented.

The methods adopted by the study team to fulfill these objectives included review of available
data, field work and meetings with company’s field personnel as well as consultation with
community members in the project area.

A condensed engineering description of the company’s activities in Block 52 are given as

background information.

The report includes a synopsis of the policies, legislation and institutions of the Government
of the Sudan in the field of environmental and natural resources management and protection.
The most relevant legislations are the EPA (2001), Mineral Resources Development and
Mining Act (2015), Environmental Health Act 2009, Wildlife Protection Act 1986, Desert
Control Act (2009) and the Ordinance for the Protection of Antiquities (1999).

The present status of the environment of the area was documented through a baseline survey
which embraced geology, hydrology, water resources, meteorology, air quality, soil,
vegetation, land use, wildlife, archaeology, and socio-economic aspects. The study area is arid
rocky with sparse vegetation except along the River Nile banks and the seasonal water courses.
Other gold mining companies and artisanal miners are within or near Block 52.

A stakeholder consultation meeting was held with local community where the people aired
their views, expressed their fears and put forward their aspirations. The content of the
consultation process is disclosed in a separate section in the report.

During the construction phase the project activities are not expected to cause any adverse
impacts on the general pattern of the climatic elements. During the normal operation stage the

1
emission of air pollutants is expected to be minimal. But the impact of poisonous gases such
as HCN could be high if the cyanide code directives are not strictly adhered to. The noise levels
during construction and operation phases could be high but they are restricted to the immediate
vicinity. Impacts on water sources are expected to be insignificant. The chances that some
seasonal surface water courses could be a potential source of water pollution to the River Nile
if there is seepage from extraction or spent ponds is very small. The design and location of the
ponds, the precaution of the company by adopting the Best Available Techniques (BAT)
system, the long distance to the river, the presence of natural barriers, the interception of the
highway road, the high rates of evaporation and the almost absence of flashfloods are all in
support of the postulation.

The HG-CN interlink in gold mining is a complicated issue where both chemical interactions
and environmental implications need to be carefully considered. The problem is too
complicated to be shouldered by one company. The IES Consultant, therefore, calls for the
urgent tackling of the issue at a national level by the Ministry of Minerals.

A summary of the expected impacts and the proposed mitigation measures is portrayed in the
compendium below.

On the other side, the proposed facilities and activities of the gold mining are expected to
induce positive social impacts for the community within and near the company’s activities such
as availing job opportunities, improvement of services such as compacted roads, health centres,
good quality water and contribution to better schooling. The Company is encouraged to lay
long and short term Corporate Social Responsibility (CSR) plans through consultation and
involvement of the local communities.

An environmental monitoring and management plan (EMMP) is proposed and outlined to

ensure that the environmental impacts predicted are properly addressed and managed during
project implementation.

2
 Table of Contents

Page

Executive Summary 1

Table of Contents 8

List of Tables 11

List of Plates 11

List of Figures 13

List of annexes 13

Abbreviations and Acronyms 13

Structure of the Report 14

1: Introduction 15

1.1 General 15

1.2 Objectives of the study 17

1.3 Methodology 17

1.3.1 General methods 17

1.3.2 Specific methods 18

1.4 Analysis of Alternatives 19

1.5 Study team 21

2: Project Description 22

2.1 Gold tailing source 22

2.2 Process description 23

2.3 Cyanidation 23

2.4 Water sources 25

2.5 Power supply 25

2.6 Security system 25

3: Legal and Institutional Environmental Framework 27

3.1 Introduction 27

3.2 Environmental policies and management in Sudan 27

3.3 The Environmental Protection Act 28

3.4 States’ environmental legislations 28

3.5 Natural resources legislations 28

3.6 Mining legislations 29

3.7 Investment encouragement Act 2011 29

3.8 Environmental impact assessment legislations 30

3.9 Environmental institutions 30

4: Baseline of Environmental and Social Features 32

A) Physical Environment 32

4.1. Climate and air quality 32

4.2 Geology and geomorphology 34

4.2.1 Regional geology 34

4.2.2 Geology of Block 52 38

4.3 Soil 40

4
4.4 Water Resources 40

B) Natural Environment 42

4.5 Flora 42

4.6 Fauna 46

C) Socioeconomic Environment 47

4.7 Human Environment and Population 47

4.8 Cultural Heritage and Archaeology 51

5. Stakeholder Consultation and Disclosure 52

5.1 Introduction 52

5.2 The consultation process 52

6: Assessment of Environmental Impacts and Proposed Mitigation Measures 67

6.1 Introduction 67

6.2 General assessment 67

6.3 Specific expected impacts 71

6.4 Proposed mitigation measures 73

7: Environmental Management and Monitoring Plan (EMMP) 85

7.1 Conceptual considerations 85

7.2 Features of the EMMP 85

7.3 Management procesudres in case of spillage 86

7.4 Avoidance of contamination and poisoning of surrounding environment 87

7.5 Environmental monitoring programme 87

7.6 Frequency of monitoring 87

5
 7.7 Monitoring parameters 87

Bibliography 89

Annexes 91

List of Tables

3.1 Governmental institutions in the realm of natural resources and environmental 31

4.1 Wadi Halfa annual rainfall 33
4.2 Natural vegetation in the project area 45
4.3 Localities of Northern State 48
6.1 Gold industrial impacts and buffer distances 70
6.2 Workplace exposure limit for cyanide 77
6.3 A compendium of impacts and proposed mitigation measures 80
7.1: Monitering parameters and frequencies 88

List of Plates

1.1 Meeting with stakeholders 19

2.1 Artisanal gold tailings 22
4.1 Typical geomorphological feature in the project area 39
4.2 Sunrise in Abri 41
4.3 Riverine vegetation showing 43
4.4 Halfa grass 43
4.5 Seasonal water course (Wadi) vegetation 44
4.6 A view of Sawarda village 47
4.7 A small plot of tomato plantation 48
4.8 Artisanal mining market 49
4.9 Artisanal mining mill 50
4.10 Panning of milled material with mercury 50
4.11 Mercyey-bearing gold 50
5.1-5.13 Stakeholders’ meeting at Abri 55-66
6.1 Hydrogen cyanide detector 76

6
 List of Figures

1.1 Sketch location map of the gold mining project 16

1.2 Location map of mining project 18
2.1 CIL process flow chart 23
2.2 Anodic cyanidation model for gold 24
4.1 Dongola annual rainfall 33
4.2 Regional geology of project area 35
4.3 Drainage system within and around Block 52 42

List of Annexes

Annex 3.1 Sudan’s position in international conventions 92

Annex 4.1 Groundwater analysis 94
Annex 4.2 Mercury content of groundwater 95
Annex 5.1 List of people met in the project area 96
Annex 6.1 Implementation Guidance for the International Cyanide Manmgement 97
Code

7
 Abbreviations and Acronyms

ADR Adsorption-desorption- regeneration

BAT Best Available Technologies
CIL Carbon in Leach
CIP Carbon –in-Pulp
CPA Comprehensive Peace Accord
CSR Corporate Social Responsibility
ESIA Environmental and Social Impact Assessment
EMMP Environmental Management and Monitoring Plan
GOS Government of the Sudan
HCENR Higher Council for Environment and Natural Resources
HDPE High Density Polyethylene
HSE Health, Safety and Environment
ITCZ Inter Tropical Convergence Zone
MEFPD Ministry of Environment and Physical Development
NCAM National Authority for Antiquities and Museums
NCS National Comprehensive Strategy
NGO Non-Governmental Organization
ORP Oxidation Reduction Potential
RQD Rock Quality Designation
NSCD National Strategy for the Comprehensive Development
POPs Persistent Obsolete pesticides
PPE Personal Protection equipment

8
 STRUCTURE OF THE REPORT

The report starts with an Executive Summary featuring the main findings and
recommendations. Chapter One is an introductory chapter including the objectives, scope of
work and the methods adopted for the conductance of the study are outlined, besides analyzing
the project’s alternatives. Chapter Two portrays the technical and engineering features of
the mining project and its activities in Block 52. A synopsis of the policies, legislation and
institutions of the Government of the Sudan in the realm of environmental protection is the
subject of Chapter Three. The description of the current status of the natural and socio-
economic environment of the area is displayed in Chapter Four. The summary of the
consultation sessions with the different stakeholders in the project area and the disclosure of
the outcome of the consultation are displayed in Chapter Five. The impacts on the
environment of the gold mining activities in Block 52 and the proposed measures to deal
with expected negative impacts are shown in Chapter Six. Chapter Seven is dedicated for
establishing an Environmental Management and Monitoring Plan where a monitoring
programme is proposed to ensure that the environmental impacts predicted are properly
addressed and managed during project implementation. The literature consulted is listed in
the Bibliography Chapter. The study report is augmented by maps, figures, scenery plates
and appendices.

9
 1. INTRODUCTION

1.1 General
This report is an Environmental and Social Impact Assessment (ESIA) study ………..for
Mining and processing project in Block 52, the Northern State (Fig.1.1& 1.2). It is located at
about 7 km from the Eastern Bank of the River Nile.

A E 31º 33́ 29.4

N 21º 33 42.8
B E 31º 30́ 30.2
N 21º 32′ 21.5
C E 31º 30́ 30.2
N 21º 32′ 21.5
D E 31º 31′ 38.9
N 21º 33′ 43.4

The ESIA is a method of analysis that attempts to predict the impacts of a proposed
development on the social and natural environment of the surrounding area and secondly, to
propose alternative methods of carrying out the project, which might help avoid or mitigate
any negative effects. Originally ESIA was conceived as a mechanism to fulfill a legal
requirement. Increasingly, in both developed and developing countries, environmental
assessment is seen as an ongoing iterative process, which can contribute to the formulation of
sound environmental management and planning strategies to help achieve sustainable
development.

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Fig.1.1. Gold mining project location
1.2 Objectives of the study

The objectives of the ESIA study are:

To identify and predict the sources of impacts from the activities related to construction and
operation of the gold mining and processing project§

a) To address potential environmental problems at an early stage of the project

b) To specify and prescribe appropriate mitigation and abatement measures for the
impacts identified
c) To establish an environmental and monitoring management plan (EMMP).

1.3 Methodology
1.3.1 General methods

In fulfilling the TOR, the Consultant’s team resorted to a package of methods, which was
adopted for the present assignment. The package included:

i) Review of documents
The documents reviewed included the following reports:

• Various EIA reports for similar projects in similar climatic and geographic zones which
the Consultant has performed or participated in such as the tailings’ processing of
AlHasour Mining (Sudan) near Kodurma Village, Northern Sudan State and that for
Delgo Mining Company.
• The ESIA and the RAP reports for Kajbar Hydropower Project prepared by Fichtner
Consultant (Germany).
• Information provided by the Client

ii) Field visits

The Consultant made a visit to the project area and to the nearby villages. Documentary
photographic shots and GPS points were taken.

iii) Meetings
The Consultant met with the company’s staff, with Administrative Officer of Abri
Administrative Unit and with local people at from Abri, Sawarda Village and from other nearby
villages (Plate 1.1).
 iv) Impact assessment technique
The ESIA study was guided by the World Bank Environmental and Social Safeguards Manual
based on the guidelines of the World Bank Operational Directives OD 4.00 (1998) and OP 4.01
(1999).

1.3.2 Specific methods

a) Climatology

The climatological conditions at the project site were collected from the nearest meteorological
stations of Wadi Halfa and Dongola Towns.

b) Vegetation

The components of the woody vegetation (trees and shrubs) were identified and recorded as
well as the herbaceous vegetation (grasses and forbs). As the area is a rocky desert area,
emphasis was laid on the bank vegetation of the River Nile near Sawarda.

c) Socio-economic aspects

Socio-economic information was collected from official documents, from field and
via meeting with local people.

Fig.1.2: Location of the mining project in Northern State

13
 Plate 1.1: Meeting with stakeholders

1.4 Analysis of alternatives

The World Bank’s Operational Policy 4.01, 1999 has identified certain angles through which
the alternatives to meet the objectives of a developmental project could be analyzed. For this
specific project two aspects are considered:

• No- project
• Location of the project

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The “No – project” option

The “No – project” option will imply that the mining company will not invest in reprocessing
of the tailings resultant from and heaped by the artisanal miners. This will mean that the current
aspects and status of the environment in the project area and in the gold tailings sites will
remain as they are now. This will have both economic and social manifestations. If the tailings
resultant from the artisanal mining were not reprocessed by gold mining and other companies,
several economic and environmental implications are foreseen:

1. The artisanal miners use mercury for extracting gold from the grinded and milled rocks.
As the process is not highly efficient, the tailings will still contain considerable amounts
of gold. If the tailings were not reprocessed, a valuable resource will be lost which is a
considerable economic loss to the individuals and to the country’s GDP at large.
Missing such an opportunity to replenish the meager country’s hard currency could not
be justified.

2. The tailings contain appreciable amounts of mercury which constitute an environmental

and health hazards. The situation could be aggravated by wind erosion which could stir
the mercury in the form of very fine particles and dust to the atmosphere and transfer it
to the River Nile nearby and to the narrow fertile agricultural fields. Rain and
flashfloods could also leach the soluble mercuric compounds that might reach the Nile
River or seep into the groundwater.

3. Without the current project a valuable opportunity for availing employment to the local
community will be missed.

4. The tailings are distorting the natural landscape and portray a poor aesthetic impact on
the area.

On the other hand, the benefits that will accrue due to the project will not be confined to the
tailings’ owners by selling the tailings to the company, but will be extended to the whole
country. Unlike the “No-Project” scenario, the project will have many benefits and could
alleviate serious environmental and health hazards. However, if any negative environmental
and social impacts are foreseen during the different phases of the project, these could be
considered and dealt with in the present ESIA study.

15
Site selection
The site for the project in the Northern State is governed by the following factors:
1. The locations of the gold tailings such as near Sawarda which is only a few km from
the re-processing site;
2. The license given by the Ministry of Minerals to the Mining Company
3. The availability of water from the River Nile;
4. The appropriate distance of the project site from the nearby water sources, cultivated
land and human dwellings.
5. The absence of human dwellings in the project site;
6. The location of the project in an area with no or sparse natural vegetation cover; and
7. The Basement rock formation is very near to the surface with no fractures.

All the above features imply that the effects of the present project - along its various phases
and activities - will be confined to a limited space and will not interfere with human dwellings
and activities. Both aspects are in favour of the project when its environmental and social
impacts are taken into consideration.

1.5 Study team

16
 PROJECT DESCRIPTION

1.2 Gold tailing source

The company will get the material from which it will extract gold from the tailings of artisanal
mining which is being practiced in Abri Administrative Unit. Based on a mutual agreement the
company has control over three mining markets viz-a-viz., Farka, Abri and Sawarda.
Currently only the tailings from Sawarda will be processed. (Plate 2.1).

Plate 2.1: Artisanal gold tailings complied by the company

The technology for extracting gold adopted by mining company is Carbon in Leach (CIL) Fig
2.1. The plant is required to utilize 600,000 tons per annum (milling and CIL) from the artisanal
mining tailings receiving hopper through the final gold. The CIL process usually comprises
the following operations: extraction, elution, electrowinning, and thermal reactivation. The
filter cake is transferred to a tailing dam lined with HDE. Unlike the CIP process, the leaching
and adsorption processes occur simultaneously.

17
 Fig. 2.1: Carbon in Leach (CIL)

2.2 Process description

The process layout and equipment have been selected to maximize the project - economics and
provide minimal operating costs. The plant will adopt a closed circuit system. The milling
facility includes, ore receiving bin, ball mills, hydrocyclones, thickener, CIL tanks, agitation
and leaching, absorption/desorption tanks, smelting units, regeneration kiln and final tailing
filtrations.

2.3 Gold cyanidation

Gold cyanidation is a metallurgical technique for extracting gold from low-grade ore by
converting the gold to a water soluble coordination complex. It is the most commonly used

18
process for gold extraction. Production of reagents for mineral processing to recover gold,
copper, zinc and silver represents approximately 13% of cyanide consumption globally, with

the remaining 87% of cyanide used in other industrial processes such as plastics, adhesives,
and pesticides. Due to the highly poisonous nature of cyanide, the process is controversial and
its usage is banned in a number of countries and territories.

Cyanide is mainly produced for the mining of gold and silver: It helps dissolve these metals
and their ores. In the cyanide process, finely ground high-grade ore is mixed with the cyanide
(concentration of about 0.5 kilogram NaCN per ton); low-grade ores are stacked into heaps and
sprayed with a cyanide solution (concentration of about one kilogram NaCN per ton). The
precious metals are complexes by the cyanide anions to form soluble derivatives, e.g.,
[Au(CN)2]− and [Ag(CN)2]−.

4𝐴𝑢 + 8𝑁𝑎𝐶𝑁 + 𝑂! + 2𝐻! 𝑂 → 4𝑁𝑎[𝐴𝑢(𝐶𝑁)! ] + 4𝑁𝑎𝑂𝐻

4𝐴𝑢 + 8𝐶𝑁 " + 𝑂! + 2𝐻! 𝑂 → 4[𝐴𝑢(𝐶𝑁)! ]" + 4𝑂𝐻"

This equation, called Elsner’s equation, is stoichiometrically correct. However, it does not
completely describe the cathodic reactions associated with the dissolution.

A boundary model of anodic cyanidation is shown in Fig 2.2. The reaction starts on the metal
surface and continues as layers.

Fig. 2.2: Anodic cyanidation model for gold (Deglo Mining Company, 2016)

The method which will be adopted by the company is carbon-in coloumn (Fig. 2.2).

The "pregnant liquor” is separated from the solids, by the help of activated carbons while the

19
Slurry is pumped to tailing storage. The adsorption of gold from aqueous solutions onto
activated carbon has apparently been known since 1847 (Fleming, 1992). The continuous
processes of gold adsorption, namely the carbon-in-pulp (CIP) and the carbon-in-leach (CIL)
processes, have been widely used since 1970s. CIP and CIL processes have been the dominant
gold recovery methods in use worldwide, accounting for approximately 44% of world
production. Other methods are about 30% for solid liquid separation and zinc precipitation
(CCL & Zn) and 19% for flotation and gravity concentration (MISC). These adsorption
processes are significantly used since they avoid the need for solid-liquid separation stages, for
example, thickening and filtration, thus can reduce the operating costs.

The mechanism of gold recovery from cyanide liquors is presented in equation below. The
dissolved gold cyanide is adsorbed as the cation gold cyanide ion pair.

"
𝑀#$ + 𝑛𝐴𝑢(𝐶𝑁)! ↔ 𝑀#$ [𝐴𝑢(𝐶𝑁)! " ]#

where the ion pair,𝑀#$ [𝐴𝑢(𝐶𝑁)! " ]# , is the adsorbed gold species. M can be H, Na, K and Ca.
The rate steps are the mass transfer of gold cyanide and cations across the solution film
surrounding the carbon particles to the outer surface of the carbon particles, transfer in the
solution filling the pores, the adsorption reaction and possibly transfer of the adsorbed cation
gold cyanide ion pair along the pore walls by surface diffusion. It has been claimed that film
transfer controls the adsorption rate of aurocyanide onto the activated carbon in the initial
stages of gold recovery.

2.4 Water sources

The water for the various project’s activities will be brought from the River Nile near Sawarda
Village. During the construction phase water will be brought by tankers and when the project
enters the operation phase a pump station will be constructed at the River Nile bank and a
pipeline will transfer water to the camp. To rationalize the water consumption, the company
plans to dewater the spent tailings and to divert water to a large pond covered with net to be
resued in the milling phase. The spent tailing is transferred away and left to dry.

20
2.5 Power supply
Diesel generators will be the source of power during the preparatory and construction phases
of the project. Later on and when the project commences the operation phase, electric supply
will be from the national grid.

2.6 Security system

In order to prevent the ingress of livestock and trespassers, the complete plant area will require
being fenced. The process plants, offices, leach area and accommodation is to be fenced using
full security fencing.

21
 2. LEGAL AND INSTITUTIONAL ENVIRONMENTAL FRAMEWORK

3.1 Introduction

The Sudan is currently governed by the Transitional 2006 Constitution, which is based on the
Comprehensive Peace Accord (CPA) signed between the Government of the Sudan and the
Sudanese People Liberation Movement in January 2006 but has been subjected to many
amendments since the severance of Southern Sudan in 2009. Two types of laws: The Islamic
Law and the Customary Law are main sources of legislation in the Sudan. A third set of laws
is included in the Statutory Law. The majority of enacted environmental and natural resources
laws, such as those relating to fisheries, game and wildlife, forestry legislation, etc., fall under
statutory law.

Attitudes to these different laws vary. Although customary law usually has less sophisticated
means of implementation and/or enforcement, as compared with statutory law provisions such
as regulations, licenses fines, etc., it has a higher rate of compliance than statutory law. Some
of the statutory laws are outdated and out of step with economic, social, political and
environmental developments. Although statutory law covers by far the bulk of environmental
and natural resources, both the content and the inadequacies in the machinery for enforcement
render it the least effectual of the three.

3.2 Environmental policies and management in the Sudan

Since independence, Sudan's variable governments have strived to achieve welfare for their
people via development based on its natural resources. Sudanese policy in the realm of natural
resources and environmental conservation has taken great strides in the last three decades.
There was an oblique reference to environmental policy in the 1973 Constitution but no
national body was entrusted with the responsibility for environmental and natural resources
management. Key ministers dealt with natural resources as part of their administration such as
the Ministry of Agriculture, Food and Natural Resources and the Ministry of Irrigation.

Within the last decade of the twentieth century prominent milestones were achieved. The year
1992 saw the establishment of the Higher Council for Environment and Natural Resources
(HCENR) to oversee, co-ordinate and liaise on issues pertaining to, and linked with the
environment. The State adopted a National Strategy for the Comprehensive Development

22
(NSCD) for the decade 1992-2002, within which the environment had a committee to itself.
The culmination of these governmental steps occurred in 1994 when the environment portfolio
was promoted to ministerial level. A second strategy plan for the next 25 years is taking place
for the period 2007- 2032, and is being implemented on a 5-year phases.

3.3. The Environmental Protection Act 2001

Although the HCENR shouldered the role of overseeing and coordinating the process of EIA, it
was not backed by any legislation mandating the conductance of EIA studies. The process of EIA
system in the Sudan eventually received formal legal support when the Environmental Protection
Act was passed in 2001. According to Article 17, all projects thought to affect the environment
had to undergo an EIA study, and the EI Statement had to be scrutinized and passed by the
HCENR. Unfortunately, till now EIAs are carried out without any by-laws or regulations
stipulated from the EPA. In such a context, there are no clear directions as to the duration of study,
the timing of the study, cost of study and protocols of EIS review and monitoring and follow-up
procedures. On the institutional side, real law enforcement capabilities are either weak or lacking.

3.4 States' environmental legislation

Within the federal system of governance, and in line with the Transitional Constitution,
responsibilities for environmental management are divided between the Federal and States
governments. The Federal Government has the exclusive jurisdiction over matters relating to
natural resources, minerals, sub-terrain wealth and trans-boundary waters. Detailed regulations
on lands, State forests, agriculture, livestock and wildlife are a State responsibility but subject
to Federal planning and coordination. At States’ level, issues and activities pertaining to and
within the realm of the environment are dealt with under the custody of the Ministry of
Agricultures, Irrigation and Natural Resources.

3.5 Natural resources legislations

The first natural resource law enacted was the Forestry Act of 1901 followed by the Land
Tenure Law of 1908. The early 1930s witnessed several environmental initiatives. The Forestry
Law came into force in 1932, the Wildlife Act and the proclamation of several National Parks
came in 1935. However, in the absence of comprehensive environmental and natural resources
legislation, regulatory measures for environmental management have been affected on a piece-
meal, sect oral basis. There are over 150 laws and sect oral regulations dealing with health,
water supply, land tenure, game, protected areas, fisheries and marine resources and other

23
aspects of natural resources. Some of these laws date back to the first years of the Anglo-
Egyptian Condominium. Among these are (Environmental Health Act 1976), (Public Health
Act 1975), (Labour Act 1998), (Wildlife Protection Act 1936), (Freshwater Fisheries Act 1984)
and (Road and Traffic Act 1983). Sudan has signed and ratified many international conventions
such as the UNFCCC, Biological Biodiversity, UNCCD, Ramsar, Basel Convention on (POPs)
and the most recent is the Paris Climate Change Convention 2016 (Annex 3.1)

3.6 Mining legislation

Within the realm of mining sector, a number of laws and acts are available. The most recent
legislation in the field of mineral resources exploitation is the "Mineral Resources and Mining
Act of 2015” - which has repealed the 2007 Act. However, the licenses for mineral exploration
and certificates of registration, mining contracts, licenses for quarries and contracts for
extraction of salt and gypsum issued under former law, are in force as if they had been issued
under the provisions of latter law. Act embraces several chapters dealing with the
proprietorship of mining materials and organizing their exploration, reporting the discovery of
mining material and offences and penalties. In the area of research, the “Law of the General
Authority for Geological Research” has come to existence in 1986.

3.7 Investment Encouragement Act

This Act in particular aspires to encourage investment in developmental projects in the Sudan.
Certain fields are deemed strategic investment, namely those relating to infrastructure, roads,
ports, electricity, dams, communications, energy, transport, contracting business, education,
health and tourist and information technology services and water projects; relating to extraction
of subterranean and deep seas wealth; agricultural, animal and industrial production. Those
considered strategic projects are exempted from taxes from the business profits tax for a period
of ten years as well as exempted from customs duties, or "customs privileges", as prescribed
by the Minister. The "Investment Encouragement Act also specifies that no project shall be
granted license, nor shall it be granted any such privileges and guarantees, as may be set out in
the Act, save after presenting a technical and economic feasibility study of the project. The
Investment Encouragement Act has been recently revised and upgraded under the newly
formed Higher Council for Investment Encouragement, 2011.

24
3.8 Environmental impact assessment legislation

Although many EIAs were conducted in the Sudan during the eighties and nineties of the last
century, the rate of conductance has accelerated after 1998, linked primarily with the onset of
oil activities and roads construction in the Sudan. However, with no national legislation to
mandate the execution of EIA, the process was driven by the donors who required and usually
supervised the conductance of the particular EIA as a prerequisite for releasing the allocated
funds for project implementation, and/or in compliance with their respective national laws.

The process of EIA system in the Sudan received formal legal support when the Environmental
Protection Act was passed in 2001. According to the Act, projects regarded as would negatively
impact the environment and the natural resources base, should undergo an environmental
feasibility study signed by the Assessment and Follow-up Committee formed by the Council
(HCENR).

However, as yet there are no passed regulations stipulated from the EPA (2001) dedicated to
the conductance of EIA in the Sudan, nor is there an institutional body solely responsible for
its administration. The State of Khartoum has passed the “Law for Environmental Protection
in 2010, and formulated, among others, the Regulations for Environmental Impact
Assessment”. The HCENR has very recently set up a committee of national experts assigned
to prepare national guidelines for the EIA process in Sudan.

3.9 Environmental institutions

The formation of the Higher Council for Environment and Natural Resources (HCENR) in
1992 was considered a milestone in the process of environmental management in Sudan,
responsible for overseeing, coordinating and liaising on environmental issues at the national
level. In 1994 a Ministry of Environment and Tourism was formed and the HCENR became
its technical arm. The Ministry later took the name Ministry of Environment and Physical
Development. A list of national institutions in the realm of natural resources and environment
is shown in Table 3.1.

25
Table 3.1: Governmental institutions working in the realm of natural resources in Sudan

No. Name
1 Federal Ministry of Environment and physical Development
2 The Higher Council for Environment and Natural Resources
3 Federal Ministry of Water Resources, Irrigation and Electricity
4 Federal Ministry of Agriculture and Forestry
§ Forests National Corporation
5 Ministry of Science and Technology
§ Forest Research Corporation
§ Wildlife Research Corporation
§ Agricultural Research Corporation
§ Food Research Corporation
§ Range Management Administration
6 Federal Ministry of Oil
7 Federal Ministry of Minerals
§ Geological Research Corporation
§ Sudan Company for Mineral Activities
8 State Ministries for Agriculture and Water
9 Khartoum State Higher Council for the Promotion of Urban and
Rural Environments
10 Higher Education institutes

26
 4. BASELINE Of ENVIRONMENTAL AND SOCIO-ECONOMIC FEATURES

A/ Physical Environment

4.1 Climate and air quality

According to the climatic zones of the Sudan, the project area lies within the arid desert zone.
The climate pattern in Sudan is primarily determined by the Inter Tropical Convergence Zone
(ITCZ) which migrates north/south across this area following the apparent movement of the
sun. When the ITCZ lies to the north of the project area, wet, cloudy and rainy weather prevails
while dry weather dominates the area when the ITCZ is to the south. The northward advance
of the ITCZ is, however, limited and usually does not extend to the far northern regions of the
Sudan. The ITCZ rarely reaches or surpasses latitude 20°, the southern boundary of Block 52.
Therefore, these rain-bearing winds rarely extend as far as the study area and rain occurs on
only a few days each year, if at all. When it does occur, rain is usually in the form of short,
intense thunderstorms.

The tailing reprocessing project of the mining company lies near Sawarda village with Wadi
Halfa in the north and Dongola in the south as the nearest meteorological stations. The climatic
characteristics of Wadi Halfa are shown in Table 4.1. Occasional short-time rainstorms, which
can form flood torrents alongside the water courses, are reported. The air temperature is high
during the summer and varies between 38 and 43 ºC. However, the temperature decreases to a
minimum of 18 ºC in the winter times. Summer (from March to October) is extremely hot and
dry, with a generally high temperature during the day, exceeding 45°C. Winter is from
November to February, with an average temperature of 25°C.

Relative humidity is rather low throughout the year (ranging between 22 % and 26 %). Wind
is blowing constantly southwards and days or even hours with still air are rare. Most windy
months are during winter with an average speed of 4.2 km/h. These factors, in combination
with the very high summer temperatures lead to extremely high evaporation rates of 300 mm
in the project area during the summer time. As for Dongola the average rainfall is shown in
Fig.4.1.

Table 4.1. Wadi Halfa annual rainfall (Meteorology and Climatology Authority, Sudan)

27
 Ja Ma
Feb Mar Apr Jun Jul Aug Sep Oct Nov Dec
Month n y
Mean
Maximum
23.
Temperat 25.7 30.5 36.1 39.6 41.1 40.7 40.1 39.2 36.1 29.2 24.8
3
ure (deg.
C)
Mean
Temperat 16.
18.1 22.5 27.7 31.5 33.1 32.8 32.5 31.8 28.8 22.5 18.1
ure 4
(deg. C)
Mean
Minimum
Temperat 9.5 10.5 14.6 19.4 23.3 25.0 24.9 24.9 24.4 21.5 15.7 11.3
ure (deg.
C)
Rainfall
Amount 0.1 0.5 0.0 0.0 1.0 0.0 1.0 0.5 0.0 1.0 0.0 0.5
(mm)
Mean
Daily
Sunshine 9.8 9.9 9.8 10.1 10.5 10.8 10.7 10.4 9.6 10.0 10.1 9.5
Duration
(hours)

Dongola Annual Rainfall

90.0 (1945 - 2013)
80.0
70.0
Rainfall (mm)

60.0
50.0
40.0
30.0
20.0
10.0
0.0
45
49
53
57
61
65
69
73
77
81
85
89
93
97
01
05
09
13
19
19
19
19
19
19
19
19
19
19
19
19
19
19
20
20
20
20

Years

Fig.4.1: Annual rainfall in Dongola

28
Due to the low population density and the lack of industrial activities in the Abri Locality and
the Northern State at large, the air quality in the investigation area is very good save for the
significant amount of fine particles in winter, depending on the velocity of northern winds from
the desert. This purity of air does not apply to the company’s area of activities where dust is
stirred by vehicles and other machineries.
4.2 Geology and Geomorphology

4.2.1 Regional geology

The Neoproterozoic crust of the Nubian Shield occupied an area between the Red Sea in the
east and the Nile valley to the west (Vail,1988; Kroner et.al., 1987). The Pan-African Orogeny
in the Arabian-Nubian Shield (ANS) is formed in the period 950-550 Ma (Greenwood et. al,
1976; Kroner, 1984). The area is underlained by arc volcanics and associated intrusive rocks,
immature sediments and ophiolites of arc and back arc basin affinities which are predominantly
in the greenschist facies. The Arabian Nubian Shield is composed of a number of terranes
which are separated by E to NE trending ophiolite-decorated sutures formed during the Pan
African Orogeny between 900 –550 Ma ago (Kroner et al., 1987a). The Shield is composed of
low-grade metamorphic juvenile Neoproterozoic island arc/back arc basin assemblages
(Abdelrahman, 1993) (Fig.4.2). The Precambrian rocks exposed west of the Shield were
previously referred to as the Nile Craton (Rocci, 1965).

In summary the general geology of the area under consideration consists mainly of basement
complex rocks, comprising high-grade gneisses complex, low grade volcano-sedimentary–
mafic-ultramafic assemblages and granitoids of variable composition and age.

29
Fig. 4.2 Tectonic map showing the Precambrian structure and major shear and suture
zones. (Modified after Abdelrahman, 1993).

30
Litho-Stratigraphy of the Area

The area consists of different Precambrian lithological assemblages comprising a wide variety
of high grade gneiss, metasediments, metavolcanics, intrusive rocks and Cretaceous sediment
which have been subjected to varying degrees of metamorphism and deformation. It occupies
a position of particular interest lying at the interface between the predominantly high-grade
gneisses to the west and the dominantly low-grade assemblage of the ANS to the east. Based
on field observation the geology of the area can be classified according to the following
lithostratigraphy:

1- Recent Sediments.

2- Cretaceous Sediments.

3- An-Orogenic granites.

4- Orogenic granites.

5- Meta_ volcanosedimentary sequences.

6- High grade gneisses complex.

High grade gneisses complex

Gneisses rocks dominate in the western side of the area. They are strongly foliated, banded and
they show a wide compositional variation. Biotite and muscovite are predominant gneiss
although hornblende-biotite gneiss, quartzo-feldspathic gneisses; flaggy augen gneisses and
hornblende gneiss also occur. Hume, (1934-1935) considered these mica-gneisses resulted
from the metamorphism of argillaceous sedimentary rocks, while others resulted from the
foliation of the micaceous granitic rocks. The gneisses are characterized by the wide
distribution of pegmatite veins and felsite and calc-silicate dykes.

Meta- volcano sedimentary sequences

These are inter-bedded and intercalated volcanic and sedimentary sequences include varieties
of lithologies ranging from basic to acid volcanics and meta-sediments of pure and impure
carbonate sediments.

31
Basic rocks include andesite and gabbro occurred in the east of the area. These rocks are
homogenous, fine to medium grained, porphyritic and black to dark greenish in color. Acid
metavolcanics are garnetiferous sericite schist, occurring in many localities and in the central
part are interbedded with the metavolcanics and metasediments.

The metasedimentary unit extends to southeast of the metavolcanics, and composed mainly
of marl and marble. The series is weakly metamorphosed.

Orogenic granites
The syn-tectonic granites intruded the high grade gneiss with it associated low-medium grade
meta-volcanosedimentary sequences. Lithologically, these rocks are heterogeneous bodies
characterized by a wide range of composition from acid to intermediate, and from well-
developed foliation to slight mylonitization. It occurs in north centre of the area. The plutons
have various sizes, shapes and composition. They include syenite, biotite-granites, biotite
muscovite-granites, diorites-granodiorite and biotite-foliated granites. The NW–SE elongation
of the syn-tectonic plutons suggests that these rocks were emplaced during regional shortening.

The syenite represents large intrusion characterized by weak foliation parallel to the regional
structural trend. Some syenite bodies are of massive appearance suggesting that these are not
affected by shearing. They are medium to coarse-grained; composed mainly from alkali
feldspar, biotite, plagioclase and quartz.

An-Orogenic granites
These rocks are non-foliated, form distinct hill masses that consist of a succession of
intersecting ring structures. The most common rock in these complexes is a coarse grained sub
alkaline syenite and granites.

In contrast to the orogenic granites, it is not foliated, relatively homogenous in texture,

heterogeneous in mineral composition and containing xenoliths of the older units. It comprises
medium to coarse-grained, and made up of quartz, alkali feldspar, biotite, plagioclase and
amphibole.

32
Cretaceous Sediments
The Cretaceous sedimentary sequence occur in many parts of the area as isolated outcrops, and
capping the higher mountains, it is consists of remnants of cross-bedded, pebbly sandstones.
They resemble the Nubian Sandstone Formation, and probably belong to the Cretaceous
system. They are made up of white or cream, coarse, poorly sorted and strongly cross-bedded
sandstones and sandy conglomerates and mudstone which unconformable overlain the
basement rocks.

Recent Sediments
All the lithologies mentioned above are covered by Quaternary to Recent sediments. These
sediments include rock fragment, gravels, sands, clays, sandy clays and silt. The alluvial
deposits are very thick around the River banks consisting mainly of dark clays and clayey silt
with fined-grained sands. The Wadi alluvial consists of fine to medium-grained sands, which
form the middle and lower courses of the wadies, while the upper parts are covered with
unconsolidated screen and gravels.

4.2.2 The Geology of Block 52 Area

The geology of Block 52 area comprises variably deformed and metamorphosed late-
Proterozoic granite-greenstone terrane. The area consists mainly of a sequence of highly
schistosed rocks with evidence of regional greenschists facies metamorphism. They form low
relief outcrops of dominated by metavolcanics (basalts and basic andesite); amphibolities;
chlorite schists; with subordinate of minor felsic volcanic rocks (quartz-porphyry and rhyolite);
calc-silicate; marble and pelitic sedimentary bands. These rocks are generally repeated
throughout the sequence. Although they have been intensively sheared and overturned into
light- isoclinal fold, the contacts between these different lithologies are usually gradational and
the various units often alternate with each other on different scales (1 to 10 meters).

In the eastern part of the area, the acidic and the mafic rocks interfinger to form a complex
interaction zone. In the western part), the rocks are dominantly sheared agglomeratic tuffs. In
the central where the mineralization seems to be extensive (e.g. exhausted works), the rocks
become more acidic with carbonates-rich pyritferous|quartz mica schists and quartz feldspar
porphyry are predominant.

Hydrothermal alteration is widespread, particularly within the acidic metavolcanics and

33
metasedimentary rocks, and it is often accompanied by carbonization ,pyritization and
silicification in the form of quartz vein or quartz stringers. The most potentially favourable host
rocks for gold include sheared and folded carbonate –rich pyritiferous metavolcanic and the
associated volcanogenic metasediments. Extensive well rock alteration is associated with most
of the lode gold deposits .The most favorable metavolcanic grade of supracrustal units is green
schist facies .

Plutonic intrusion (granite and quartz diorites, as well as basic dykes were emplaced within or
near the deformation zones with which gold mineralized material is associated. Generally, the
gold mineralization and magmatic activity could be genetically related. Alternatively a
compositionally uniformed fluid of either magmatic or metamorphic or of both derivation
events at Abu Sari lode gold deposit occurred.

There are also outliers of Tertiary basalts and Nubian formation sediments immediately south
–east of the area. This might suggest a deep weathered profile below the Nubian unconformity.

Plate 4.1: A typical geomorphic feature within the project area

4.3 Soil
The soils are gravely and shallow covered by pebbles of stones of different rock types. The
soils are mixtures of wind-blown sand and alluvial deposits containing ill-sorted sand particles
with silt and clay. The silt and clay are deposited by the running water in the channels of the

34
wadis. The soils of the project area are generally deep to shallow and characterized by a cover
of quartz gravel and pebbles. In alluvium deposits on the terraces along the Nile and in wadis
there is some cracking heavy clay – and fine silt.
Generally, the following six types of soils can be found in the area.

• Soils of the Recent/Lower Terrace

• Soils of the Older/High/Upper Terrace
• Soils of the abandoned arms of the Rive Nile
• Soils of Colluvial Fans
• Sand Dunes
• Miscellaneous Land Types

Lahmeyer (2009) carried out a reconnaissance soil survey along the Nile between Khartoum
and the Egyptian border, covering an overall total of 4 million ha. The extent of the soil surveys
was limited to include potential command areas to be served from future reservoirs of six
projected dams by either a gravity canal or by boosting pumps.

The overall figures derived for the lands show that only a small fraction of the surveyed land
has potential for irrigated agriculture. Besides, almost the entire strip along the Nile channel
itself is already being used for irrigated agriculture. Therefore, the additional currently unused
lands identified are very limited within the investigation area.

4.4 Water resources

Surface water
The Nile River is the main hydrological feature in the project area (Plate 4.2). Its hydrological
regime is marked with annual and seasonal periodicity. The Hydrological Data at the gauge
site at Dongola indicate a long term average flow of 72.56 km3/yr or 2,294 m3/S, with huge
differences within the annual hydrological events but also between the different years.
Annually the average daily water levels of the Nile at Dongola show a peak in August and
September, which is about 4 to 5 m higher than the average low water level (December to July).

At Dongola station, the flow of the Nile during the famous 1988 flood period was 25 milliard
m3 in August. This flow was reduced to 8 milliard m3 and 4 milliard m3 successively in

35
November and December. Normally, the average low flow at Dongola station is only two
milliard m3 in February.

Plate 4.2: Sunrise over the River Nile

The region is characterized by chains of hills separated by dry valleys forming dry seasonal
water courses. The drainage system is dominated by the River Nile into which numerous small
seasonal streams (Khors) flow (Fig 4.3). Many of these khors follow fracture lines and joints
in the underlying rocks and their tributaries form rectangular and sub - dendritic drainage
pattern. The khors are dry most of the year and filled with gravels and sand. During field work
the study team counted nine such wadis on the eastern bank of the Nile between Abri and Delgo
village flowing towards the Nile River. Some water channels flow from the Northern State
Hills in the east to the river Nile in the west. The wadis and the khors contain no significant
surface flow except when very heavy storms occur (every 10 years). These dry drainage courses
are filled with thick layers of sand or gravel deposits. During the flood seasons, the Nile water
flows back into the lower parts of the khors and wadis. The length of this back-flooding into
the seasonal water streams as well as the volume of the flooding water depends on the intensity
and duration of the Nile flood.

36
 Fig. 4.3: Drainage system within and around Block 52 (Fichtner, 2009). Yellow shape
indicates location of Gold Mining project

Groundwater
The area of the project is underlain by crystalline Basement rocks unconformable overlain by
a thin sandstone cover. Groundwater could only be found in fractures and weathered rocks and
the fact that the area arid there is no recharge. A water sample was taken from a borehole in
the vivinity of the artisanal miners’ site which turned to be unfit for human consumption due
to its high iron content, high electrode conductivity due to high sodium salts and a very high
mercyry concentration of 0.398 mg/l (Annex 4.1). It is to be noted that the MPL for HG in
drinking water is 6, 2, 1 and 7 ug/l for WHO, USA, EU, and Sudan , respectively. The source
of this high concentration is natural rather than anthropogenic.

B) Natural Environment
4.5 Flora
According to FEOW (2009), area is located within the Lower Nile Ecoregion. The project area
lies well within the desert zone according to the vegetation maps of Sudan (Andrews, 1948;
Jackson and Harrison, 1958). There is no national or international protected area within or near
projects’ site.

The natural vegetation in the project area is confined only to the Nile banks and a few seasonal
water courses in the vicinity of the Nile (Plate 4.3 and 4.4). Similar to other riverine areas, at
least three vegetation zonation occur, namely on the River bank, the Geruf and the seasonal
water courses beds and edges east and west of the river banks.

37
 Plate 4.3: Typical riverine vegetation showing, from left
to right, (Mimosa pigra, Phragmites reeds and Tamarix trees -Tarfa)

Plate 4.4 Halfa grass (Demostachya cynosuroides) stabilizing sands on the river bank

On the banks and Geruf, where date palm orchards, wheat crops and other forages and
vegetables are grown, natural woody and herbaceous flora abound. The seasonal water courses
flora is known to be drought resistant and occurs widely scattered: Capparis decidua,
Calotropis procera, Leptadenia pyrotechnica, Senna italica, and Panicum turgidum; their
densities depend on the availability of water (Plate 4.5) and in dry areas only the more drought
resistant Acacias prevail; A. ehrenbergiana, A. raddiana and the widely distributed. Maerua
crassifolia bushes (Table 4.6).

38
 Plate 4.5: A dry shallow seasonal khor with sparse vegetation

To document the natural and planted crops three sites were visited:
1. The base camp and the plant site selected for further processing gold from
The artisanal mining residues (Tailing).
2. Gold market, where the tailing material is available to be transported
to the plant site.
3. The natural vegetation and planted crops along the eastern bank of the River Nile , west
of Sawarda village.
On the base camp, the gold processing plant site and the gold market landscapes the natural
vegetation is completely absent.

39
Table 4.2 The flora of the project area
A) Natural trees and shrubs along the eastern bank of the River Nile strip at Sawarda
village
Botanical Name Local Name Uses
Acacia ehrenbergiana Salam Wood, charcoal, Browse.
Acacia seyal Talih Wood, charcoal, Browse, Medicinal.
Acacia nilotica Sunut Timber, Medicinal, Browse.
Balanites aegyptiaca Hegleig Browse, Fuel, Timber
Cappris decidua Tundub Browse, Medicinal.
Calotropis procera Usher Fibre, Wood.
Leptadenia pyrotechnica Marikh Browse.
Hyphaene thebaica Dom Fruits, mats and robes.
Mimosa pigra Essit Elmosthya Bank stabilization.
Tamarix spp. Turfa Browse.
Ziziphus spina-christi Sidder fruits, Browse.

B) Planted Trees and Shrubs along the eastern bank of the River Nile of Sawarda

Botanical Name Local Name Uses

Azadirachataindica Neem Shade, Timber.
Phoenix dactyleifera Nakheel Fruit, Food, Construction.
Parkinsonia aculeata Esisaban Shelter belt .
Prosopis chilensis Mesquite Shade ,becoming weed in.

C) Natural Herbs (Grasses & Forbs) along the eastern bank of the River Nile strip in Sawarda

Botanical Name Local Name Uses

1- Aerva javanica Arra Browse.
2- Abutilon spp. Hambouk Fiber,browse.
3- Demostachya cynosuroides Halfa Sand stabilizer on river bank & source of fiber.
4- Phragmites communis Bous Local building material
5- Senna italica Senameka Medicinal.
6- Haplophyllum tuberculatum Haza Medicinal.
7- Tephrosia apollinea Amayoga Toxic to goats.
8 - Indigofera oblongifolia Dahasir Valuable browse.
9 - Fagonia critica Um shewika Liked by rodents.
10- Euphorbia aegyptiaca Um Lebaina Grazed by small ruminants.
11- Cynadon dactylon Nageila Valuable grazing grass.
12-Daicanthium annulatum Hamaria Valuable grazing grass.
13- Rhynchosia minima Addana Valuable grazing grass, legume.
14- Crotalaria thebiaca Natasha Valuablegrazing grass, legume.
15- Chrozaphora spp. Argasi Good grazing plant.
16- Panicum turgidum Tomam Sand dune fixation , Grazing
17- Solanum incanum Gubein Milk coagulation , Grazing
18- Citrullus colocynthis Handal Medicinal, Grazing.
19- Boerhavia repens Turraba Grazing (sheep and goats).
20-Cyperus rotundus Seida Weed, grazed.

40
 D) Food and Forage crops planted along the eastern bank of the River Nile strip-
west of Sawarda Village
Botanical Name Local Name Economic Uses
Triticum vulgare Gamih Food ,By-product as feed
Sorghum vulgare Dura Food
Sorghum bicolor Abu sabein Forage
Medicago sativa Berseem Forage
Vigna unguiculata Lubia Food and forage feed
Dolicus lablab Lubia Food and forage feed
Hibiscus esculentus Bamia Food and residues as feed
Viciafaba Foul Masri Food and residues as feed
Phaseolus vulgaris Fasolia Food and residues as feed
Lupinus termis Turmus Food and residues as feed
Cicer aritenum Homus Food and residues as feed
Allium cepa Basal Food and residues as feed
Lycopersicum esculentus Tamatim Food and residues as feed

E: Natural vegetation of seasonal water courses

More than (5) five seasonal water courses exist having broad sandy beds supporting sparse
natural vegetation composed of the woody species:

4.6 Fauna
Wildlife in the project area is sparse and foxes, squirrels and hyenas are reported to be present.
In the River Nike both the Nile crocodile (Crocodylus niloticus) and the Nile monitor (Varanus
niloticus) are frequent.

Bird life in the area may be characterized by the absence of seasonal breeders and the temporary
presence of migrants passing through. The autumn passage of Palaearctic migrants starts
mainly in August and reaches its peak in September/October, which coincides with the rainy
season and with emergent vegetation and invertebrates. The migrants arrive via the Northern
State and Nubian Desert following the Nile River until Dongola, where many strikes off to
south-western regions of Kordofan and Darfur. Others cross central Sudan to arrive in Southern
Sudan and other African counties where the majority stay during winter. The spring passage
starts by March, with the advent of the hot dry season and the shortage of food. The migrants
follow the Nile until Abu Hamad and then strike off to the Northern State or the Nubian Desert.

41
C) The Socioeconomic environment
4.7 Human Environment and Population
The mining project lies west of …..Village (Plate 4.7) within …..Administraitive Unit (Wadi
Halfa Locality) of the Northern State of Sudan. The Northern State is the country´s largest in
size and least in population state (about 500000), with a density of 2 inhabitants per km2. There
are seven Localities in the Northern State as shown in table 4.4.

Plate 4.6: A view of Sawarda village

River Nile is the only source of water for irrigation, watering animals and domestic uses,
besides being an important mean of cheap transportation and a central element for recreation
activities such as swimming and fishing.

Agriculture is the main occupation but as more than 35% of population is landless and more
than 58% have less than 10 feddans (4.2 hectare) many farmers either work as unskilled worker
or peasants for landowners or in other occupations like trading, transporting or fishing.

Nile banks are planted with date palm forests. Dates are the main exporting product, besides
constituting a basic source of fuel, raw material for several uses and building materials and
having great dietary value. Seasonally flooded fertile banks produce onions and vegetables but
in the last decades, wheat, sorghum and beans prevailed, as palms are absent in the low terraces.
Small land plots are cultivated with vegetables such as water melons, fasolia and tomato (Plate
4.7).

42
 Table 4.3: Localities of the Northern State
No. Locality Administraitive Units

Halfa
1 Old Halfa Abri
Delgo
2 Delgo Al Birka
Furraig
Kerma
3 Al Burgeig Argu
Sharag El Neel
4 Dongola Dongola
Al Hafeer
Al Golid
5 Al Golid Al Gaddar
Al Gaba
6 Ad Debba Ed Debba
Al Tadamun
Merwoe
Al Gurair
7 Merwoe Karima
Umm Jawasseer
Source: Norther Sttae documents

Plate 4.7: A small tomato plot east of the Nile bank

The role of livestock in agriculture is decreasing to a large extent and the population converted
their preference to small animals like fowl, sheep, goats, cattle, donkeys and camels. Fishihng
is also gaining attraction by the youth.

As for the services there are 25 basic education schools and ywo secondary schools.
Concerning the health services there are health centers in each village besides the hospital in

43
Abri. There are no edemic diseases and a joint project to control Gambia mosquito is operating
with Egypt. According the Adminstraitive officer no diseases related to mining have been
noted.

The traditional livelihood pattern has been threatened by the proliferation of artisanal mining
activates in the state (Plates 4.8 - 4.12). Recently more and more young people are being
attracted to gold mining activities at the expense of agriculture. There are several sites of
artisanal minining with two markets in Sawarda and Al Khannag. The total number of artisanal
miners is about twenty thousand.

Plate 4.8: Artisanal mining’s market near east of Selaim- Halfa Road

Plate 4.9: Artisanal miners milling machine

44
Plate 4.10: Panning of milled rock for extracting gold

Fig. 4.11: Gold bearing mercury

According to the Administraituive Officer there were benefits from the artisanal mining
activitieia in the form of regular revenues. The revenues have been directed towards imorving
the educational services in Abri. This has been manifested in the satiability of the school year,
provision of free education, free meals, transportation and stationery. Even teachers have been
granted financial incentives. Unfortunately this revenue has ceased as the all the artisanal sites
have been brought under the control of the Federal Ministry of Minerals.

Another positive social impact of the mining activities is the phenomenon of reverse
immigration as more and more people are being attracted by the lure of gold.

4.8 Cultural Heritage and Archaeology

Located in the central area of the old Nubian homeland and previous cultures there is an
abundance of archaeological sites and places of cultural heritage located in the Northern State

45
eastern along the River Nile stretch. West of Bari Town and near Block 52 lies Sai Island, the
second largest island in Sudan which has a diverse and extensive history and has been inhabited
since the Palaeolithic era. There is also evidence across the island for Neolithic, Pre-Kerman,
Kerman, New Kingdom, Napatan, Meroitic, Post-Meroitic, Medieval, Christian and Islamic
occupation, qualifying the island as the most comprehensive archaeological unit of Nubia.
However, due to the proliferation of mining activities, illegal excavations and smuggling are
occurring.

46
 5. STAKEHOLDER CONSULTATION AND DISCLOSURE

5.1 Introduction
Stakeholder consultation is an integral part of the ESIA process. The accurate, impartial
conveyance of the content and outcome of the process follows the consultation phase and the
role of the ESIA consultant is to display and disclose them in the report.

5.2 The consultation process

i- Abri Administraitive Unit Officer
The team first met with Administraitive Unit Officer. Information collected from the meeting
included the population and livelihoods in the village. The population is estimated to range
between 1000 and 12000 people. Their main work is bank cultivation which is restricted to a
narrow River Nile belt. However, a large percentage of the population are expatiates, mainly
in the Gulf countries.

The village is devoid of health services as there is no Health Centre. The common diseases in
the area according to villages are Malaria, Asthma, Cancer but no data were given. A local gold
market (Souk) has been established in the village concomitant with the advent of the artisanal
miners. The villages claim that the health and sanitation status has deteriorated after the onset
of the artisanal mining period. Whereas in the past the nuisance insects were Nimitti and
mosquitoes only, now there are flies and other insects. They attribute such worsening to low
hyaline in the area as human faeces and domestic waste are left in the open. More diseases are
reported such as Tuberculosis, nasal pockets. The impact of the artisanal mining and the ads
vent of foreign people in the village have also been reflected in the cultural values of the village.
A case in point in this respect is that the villages used to keep their house doors open all the
time. Now they shut their houses during the night and even during the day when they leave
their houses.

He enlightened the ESIA study members how the AU has benefited from the artisanal gold
mining within the Locality. The economic revenue that accrued has been directed to better
schooling.

ii- Meeting with local community

47
The ESIA team held a meeting in the market of Abri with a representative group of the village
dwellers (Plates 5.1-5.5). More than forty people participated in the meeting. A list of those
who attended the meeting is shown in Annex 5.1.

At the beginning of the meeting the ESIA team leader explained the objective of their mission
and the importance and significance of conduction an environmental and social impact
assessment for the gold activities carried out by the mining company in their region. He then
introduced his team members. The representative of mining company introduced his company
and explained the procedures followed by the company to get the permission to reprocess the
gold tailings. He also pointed out that the site of the camp where the reprocessing activities are
intended to be carried out has been granted by the Ministry of Minerals. He highlighted the
company’s proposed activities and the technology they intend to use to extract gold from the
tailings.

The floor was then opened to the locals to air their views. Many of the people present
expressed their fear from the potential dangers they expect to take place from the activities to
be commenced by the company. Their fears mainly stemmed from the experiences and
activities of other gold companies in the Northern State south and north of Abri such as Al
Deweishat and Al Hasour. Others were worried about the pollution that will entail the River
Nile from the cyanide.

The ESIA study team leader addressed the local people that they represent an independent
consultant corporation and their mandate is to foresee the potential adverse impacts that might
take place as a result of the proposed activities of the gold mining project in the project area.
They will give proposals to avoid, eliminate or reduce these impacts. He also assured them they
will take all their views and fears and incorporate them in the ESIA report.
Many questions were raised most of them were about the use and dangers of using cayanide.
The loclas thought that the trucks they have seen were carrying cyanide but the company’s
representative assured them that the trucks were carrying equipment for the construction phase
and chemicals were brought yet to the site.

An important item of the meeting with villagers was their relation with mining company where
many expressed that the company has not laised with them. The Director of the company’s
project, who was attending the meeting, explained the technologies they are going to adopt to

48
process the tailings and assured the people about their precautions to prevent pollution and
hazards. He also invited the people to come and visit the sute to see for themselves the aactivties
currently going on.

A suggestion was brought up by the meeting in the form of a request for the University of
Khartoum to conduct studies for the companies working on gold as well as for the artisanal
mainlining activities to investigate the effect of the miming activities and to study the different
types of wastes and how to deal with them.

Plates 5.1: Stakeholders’ meetings

49
50
51
6. ASSESSMENT OF EXPECTED ENVIRONMENTAL IMPACTS AND PROPOSED
MITIGATION MEASURES

6.1. Introduction
This Environmental Impact Assessment study is part of the feasibility study of the mining
Project. The EIA is a method of analysis that attempts first to predict the impacts of a proposed
development on the social and physical environment of the surrounding area and secondly, to
propose measures to avoid or mitigate any negative effects. In both developed and developing
countries, environmental assessment is not just a step to fulfill a legal requirement, but is seen
as an ongoing iterative process, which can contribute to the formulation of sound
environmental management and planning strategies to help achieve sustainable development.
Within such a context this EIA endeavours to achieve the goals of EIA within the context of
the mining project.

The present EIA study stems from and is in conformity with the country's laws and legislations.
The Environment Protection Act 2001 makes it mandatory to conduct studies to ensure that the
environmental dimension has been catered for in all the stages of major developmental projects.
Regulations for EIA conductance in Sudan have just recently been prepared by the HCENR
pending to be passed by the Minister of MEFPD.

The overall objective of the mning project EIA study is to assess any environment impacts that
are likely to befall the area of the project and to put forward appropriate recommendations to
mitigate adverse impacts and to enhance positive impact. Another major objective is to
establish an environmental management and monitoring plan (EMMP) i.e. a
tracking/monitoring programme used to ensure that the environmental impacts predicted are
properly addressed and managed during project implementation.

6.2 General assessment

The anticipated impacts of the project are displayed in the following matrix of impact table. A
set of primary environmental parameters that are relevant to the study are determined. The
tendency and likelihood of impacts are categorized as positive, of no impact and negative.
(Table 4.4).

52
Building on field investigations and drawing from other mining projects in similar
environmental setups, the general assessment is that the project is not envisaged to cause
serious environmental impacts on the area. This is based on the observation that the
environment of the area is part of the desert region. No fear – due to project implementation -
of natural vegetation removal, wildlife decline, groundwater depletion or natural heritage
destruction.

Cyanide hazard

Sodium cyanide is used mainly to extract gold and other precious metals in mining industry.
This application exploits the high affinity of gold for cyanide, which induces gold metal to
oxidize and dissolve in the presence of air (oxygen) and water, producing the salt sodium gold
cyanide (or gold sodium cyanide) and sodium hydroxide.

Sodium cyanide, like other soluble cyanide salts, is among the most rapidly acting of all known
poisons. NaCN is a potent inhibitor of respiration, acting on mitochondrial cytochrome oxidase
and hence blocking electron transport. This results in decreased oxidative metabolism and
oxygen utilization. Lactic acidosis then occurs as a consequence of anaerobic metabolism. An
oral dosage as small as 200–300 mg can be fatal to human.

For the gold mining project, the dangers of Cyanide could be due to bad storage (for both store
and containers). In the gold extraction ponds, some of the Sodium cyanide will be hydrolysis
process and HCN gas is emitted. Another potential threat could be in the case of tailing pond
breach. There are history instances when tailing ponds broke and NaCN solution was washed
down into water ways.

The Mercury -Cyanide problem

The issue of cyanide in the gold industry is even more complicated if mercury is available
either in the original gold ore or in the artisanal heaps. This is mainly due the ability of NaCN
to mobilize mercury rendering it more active.

Two points need to be taken into consideration:

1. The tailings to be re-processed by gold companies are expected to contain residues of

Mercury

2. Ore bodies from which gold is mined are often composed of minerals containing S, Se and
Te. Mercury is also associated with these three elements and is simultaneously dissolved during

53
gold extraction. When cyanide salts are used to extract gold, the soluble mercury- cyano
complexes which are formed, such as Hg (CN)2 and Hg (CN)4 enhance mercury mobility and
increase mercury concentrations in groundwater. It is estimated that current gold mining
techniques may be responsible for extracting more mercury than they do gold.

The cyanide salt requirement needed to be greater than that amount consumed by the gold
alone, since other metals present in the ore will also react with the cyanide and a large amount
of the cyanide used escapes into the atmosphere.

If the environmental costs of using cyanide salts for extracting gold are factored into the total
costs, then the gold cyanidation process could be, or could soon become, economically
unviable (Coles and Cochrane, 2006).

It has been, so far, a normal practice in the mining sector to deal with Hg and CN separately.
The HG-CN in gold mining is a complicated issue where both chemical interactions and
environmental implications need to be carefully considered. The problem is too complicated to
be shouldered by one company. The IES Consultant, therefore, calls for the tackling of the
issue at a national level by the Ministry of Minerals.

As for the company, the hazards due to cyanide storage, handling, use during gold extraction
and in the final spent heap, could be alleviated if the Cyanide Code is strictly adhered to (Annex
6.1 ).

The Australian Environmental Protection Authority (AEPA) has issued a guidance for the
assessment of environmental factors. Of relevance to the current study are the guidelines for
“The separation distances between industries and sensitive land uses”. The separation distance
is the shortest between the boundary of the area that may potentially be used by an industrial
land use, and the boundary of the area that may be used by a sensitive land use.

The Buffer is defined by the AEPA as all the land between the boundaries of the area that may
potentially used by an industrial land use within which unacceptable adverse impacts due to
industrial emissions on the amenity of sensitive land use are possible. This may be represented
by the separation distance. The activities pertaing to gold extraction and the required separation
distance is extracted from the Australian guidance as shown in Table 6.1.

54
Table 6.1: Impacts and buffer distances for gold industrial activities

Industry Description of Industry Impacts Buffer

Gase Noise Dust Odur Risk distance ( m)
s
Sodium Production of NaCN HC √ √ √ 1000 - 2000
cyanide N
manufacturi NOx
ng
Tailings Contain cyanide √ √ √ Case by case
disposal
Gold ore Grinding & milling √ √ 1000-2000
works- rocks ore etc. depending on
processed by grinding, location,
milling or separated by process used
sieving, aeration, etc and size

The reprocessing site is a rocky terrain underlain by Basement complex and groundwater is,
found, could be in much deeper depth. Besides, fear of seepage of NaCN to the groundwater is
not considered as the tailing ponds will be lined by HDPE. Fear still exists that the ponds may
break and water with NaCN may flow with the drainage pattern towards the River Nile. But
this fear is not serious for the following reasons:

1. The amount of NaCN residue in the sepent pond is too dilute

2. The distance from the tailing ponds to the River Nile is large (6km). This distance is more
than enough for the water – bearing cyanide to evaporate, taking into consideration the high
temperatures and intense sunlight that will accelerate the cleavage of the CN bond into C and
N, or for the company’s staff to interrupt the flow. Nevertheless, measures are still outlined in
the next section to avoid such possibilities.

55
6.3 Specific expected impacts

a) Impact on micro-climate
No impact is expected on the microclimate in temperatures, relative humidity, and
precipitation. Dust blowing is expected to increase due to the increased truck movement and
as a result of the project activities such as, crushing and milling. However these impacts are
localized and are not expected to be of large scale.

b) Noise
During the project operation the source of noise will be construction of camp and excavation
and leveling of roads. This noise impact will be localized and last throughout the project
lifetime. Away from the project site, the water pump on the River Nile bank will produce high
noise. However, this will be localized within the pump station. Another source of noise is the
diesel power generators in the camp. If later, when an AC current is supplied from the national
grid, the former source of noise will cease.

c) Impact on landscape

By virtue of its activities, such excavation of rocks the project is expected to change some of
the natural features of the area’s landscape. The excavation of the tailing ponds will also alter
the general landscape. However, these impacts will be confined to the company’s site. Away
from the project site, the water pump on the River Nile bank will alter the landscape of the
river’s bank entailing removing some vegetation. However, this will be localized within the
pump station. No changes on landscape along the proposed pipeline corridor are anticipated as
the terrain is rocky and the pipeline is lain on the surface i.e. no trenches will be dug.

d) Impact on water resources (Distance standard)

Then main source of water in the project area is the River Nile which lies around seven km
from the company’s camp. No direct impact is expected to occur to the river hydrological
regime. Even the abstraction of water for the company’s industrial and could form a point
where domestic use will have no significant effect on the river. Nevertheless, the site of pump
station itself could form a congregation point where people could come and bath and wash their
clothes and as such could constitute a point source of pollution.
If in the unlikely case where large amounts of the tailings’ solution laden with cyanide escape
from the company’s site and find its way to one of the wadis, it could only reach the Nile if it
coincided with the advent of flash floods, a rare event. But this event could be safeguarded
against by the adhering to the measures proposed in the next section.

The impact on groundwater is not considered as the area of the project is within the Basement
Complex where groundwater could only occur in fractures and /or in shallow weathered zones
in Precambrian bedrocks where permeability has been increased. Nonetheless, if care is not
administered by the project‘s field technical staff and operators, leakage of contaminated water
could find its way via these fractures. However, according to the project operational policy,
the use of impermeable lining in the tailings’ ponds would further alleviate this risk.

e) Impact on vegetation cover

As the project area lies in a desert hilly zone with very sparse vegetation cover, mainly confined
to the wades which flow with water only during the rare flash floods. If in the unlikely case
where large amounts of the tailings’ solution laden with cyanide escape from the company’s
site and find its way to one of these wades, then one would expect the sparse vegetation to be
adversely affected. Away from the project site, the site of water intake at the pump station on
the River Nile bank will entail removal of bank trees and herbs. However, this will be localized
within the pump station site.

f) Impact on wildlife
As the project area lies in a desert hilly zone with very sparse wildlife, there is no reason to
expect that the project will lead to serious impact on wildlife. As for birds, the temporary
presence of migrants passing through the Northern State and Nubian Desert, should raise the
alarm that these birds are exposed to any polluted waters during their short stopovers.

g) Impact on archaeology
There is no current information as to the presence of archaeological sites within the vicinity of
the project. However, the area at large is renounced to be rich in archaeological sites. It is still
most likely that during the various excavation processes, it is most probable that one could
come across some archaeological artifacts. If care is not administered, the archaeological
artifacts could be destroyed. The policy to be implemented in such chance findings will be
elaborated on in the mitigation section.

h) Socioeconomic impacts

The presence of the tailings re-processing activities near Sawarda village will be considered
beneficial to the people. The company is expected to avail jobs for the local people, thus
offering them another avenue of income generating. On the other hand, through its Corporate
Social Responsibility (CSR) programme, the mning company will be envisaged to improve the
area’s amenities via providing many services in the realm of health, education and water
supply. The revenues that the State down to the Administrative Units receives from the mining
companies will contribute to achieving the developmental projects and upgrading the
livelihoods standards. The ideal way execute such services is by making good relations with
the local stakeholders and respond to their suggestions. Within such a context, the company is
urged to adopt a bottom-up approach.

From a different perspective, certain activities could be a source of annoyance to the locals if
care is not administered. The main chemical compound used in gold extraction is Sodium
cyanide, a hazardous chemical which need to be used with the utmost care. Otherwise, local
workers could be exposed to the harmful effect of the salt and/or of the hydrogen cyanided
emitted.

6.4 Proposed mitigation measures

i) Measures for cyanide hazards

The hazards due to cyanide storage, handling, use during gold extraction and in the final spent
heap, could be alleviated if the Implementation Guidance for the International Cyanide
Management Code prepared by the Internatinal Cyanide Management Institute (Annex 6.1) is
strictly adhered to.

The transportation of cyanide need to be conducted in such a way as to protect the communities
and the environment. The standards of practice include:

• The establishment of clear lines of responsibility for safety, security, release

prevention, training and emergency response in written agreements with producers,
distributors and transporters.
 • The assurance that the cyanide transporters implement appropriate emergency response
plans

The pH of a solution containing cyanide significantly affects the amount of evolved hydrogen
cyanide and the potential for workers to be exposed to toxic concentrations of hydrogen
cyanide gas. In aqueous solution, the cyanide ion hydrolyzes to form hydrogen cyanide. At a
pH of 9.3 - 9.5, the cyanide ion, and hydrogen cyanide are at equilibrium. Higher pH conditions
result in greater concentrations of the cyanide ion. At a pH of 10.0, 88% will be in the form of
the cyanide ion and when the pH is increased to 11.0, more than 99% will be in the ionic form.
Below a pH of 9.3 - 9.5, hydrogen cyanide will be the predominant form of cyanide. While
aqueous hydrogen cyanide is soluble in water, it volatilizes rapidly under the temperature and
pressure conditions typically found in gold cyanidation operations. Therefore, maintaining
process solutions at a sufficiently high pH is necessary to effectively prevent evolution of
significant amounts of hydrogen cyanide gas. However, in high saline water or when
processing certain ore types, solution chemistry limits how high the pH can be adjusted.
Operations should evaluate their solutions to determine the appropriate pH for limiting the
evolution of hydrogen cyanide gas, and develop operating procedures and controls to reduce
risks to its workforce.

Handling of cyanide containers and application of the chemical should be restricted to as

minimal as possible of company’s personnel. Appropriate personal protection equipment such
as gloves and eye and nose goggles should be used. Hydrogen cyanide detectors and meters
should be worn by the cyanide workers to monitor their expoaure to hydrogen cyanide (Plate
6.1).

Personal protective equipment. Whenever the risk of exposure exists, such as opening sodium
cyanide containers, non-routine operations and emergency circumstances, the following
personal protection measure are recommended: Respiratory protection Canister respirator P2
type if air sampling indicates hydrogen cyanide level is between 11 and 50 mg/m3. Air
supplied, or positive pressure, self-contained breathing apparatus SCBA recommended where
air sampling indicates hydrogen cyanide gas concentration exceeds 50 mg/m3. Hand protection
PVC or butyl rubber gauntlet-type gloves. Eye protection Chemical splash goggles (gas tight
type preferred) and full face shield. Skin protection PVC overalls or jacket and pants and butyl
rubber Wellington boots.
Warning signs should be placed where cyanide is used and should alert workers that cyanide
is present, that smoking, open flames, eating and drinking are not allowed and that the
necessary cyanide-specific personal protective equipment must be worn.

All workers potentially exposed to cyanide should be subjected to annual ans semiannual
medical checkup. A baseline medical status to all the workers is needed to be established prior
totheir engaegement in the company’s work activities to identify the level of cyanide, mercury
and lead in their blood and Arsenic in their hair. Workplace exposure limits for cyanide is
shown in Table 6.2.

For propoer design of tailing ponds and for the prevention of seepage and other hazards, the
following measures and recommendations should be implemented: Cyanide seepage could be
prevened via the following methods:

1. The location of the tailing ponds where the gold extraction process is executed and the
final tailing where the spent heap is discarded, should be as far as possible from seasonal
water courses, the base camp and any residential areas.
2. Choose as far as possible an impermeable rocky ground.
3. Construct strong and well established embankments
4. Prepare a pond with an area suitable to accodmaode the whole volume
5. Ponds should be well constructed to prevent any bank breach
6. The ponds should be lined with an impermeable plastic such as HDPE
7. Fencing is important to prevent access by domestic and wild animals.
8. Provide spill prevention or containment measures for process tanks and pipelines.
9. Implement quality control/quality assurance procedures to confirm that cyanide
facilities are constructed according to accepted engineering standards and
specifications.

A further precaution is needed to protect the residential and passing migrating birds by covering
the tailing ponds by a fine net. The fact that the carbon nitrogen triple bond is readily broken
by sunlight, necessitates that both extraction and spent ponds should not be covered or placed
in shaded areas.
Process for disposing of cyanide empty containers
Empty cyanide containers should not be reused on or off the mine site for any purpose other
than holding cyanide. Prior to disposal or re-use, cyanide drums should be rinsed three times
with high-pH water to remove cyanide residue. All rinse water should either be added to the
cyanidation process or assumed to contain cyanide and disposed of in an environmentally
sound manner. The rinsed drum may then be crushed and placed in a landfill. Plastic bags and
liners should also be triple-rinsed prior to disposal. Wooden crates are difficult to effectively
decontaminate; it should be assumed that they have come in contact with cyanide and they
should be burned or otherwise disposed of in an environmentally sound manner. Cyanide
containers that are specifically meant for return to the vendor for reuse may not require internal
rinsing, but any cyanide residue on the outside of the container should be washed off and
managed consistent with the Code, and the container should be securely closed for shipment.
All empty boxes and bags shall be burnt in a specific cyanide burning pit.

Plate 6.1 A Hydrogen cyanide detector

ii) Measures for impact on micro-climate

Dust blowing due to the increased truck movement and handling of tailings could be reduced
by frequent sprayings with water.
Table 6.2: Workplace exposure limit for cyanide

TWA STEL
Chemical name CAS No. Carcinogen Notices
TWA TWA STEL STEL Category
(ppm)) (mg/m3 (ppm) (mg/m3)
Cyanides (as 151-50-8 - 5 - - - Sk
CN)

CAS No.: Chemical Abstracts Services Regestry Number

TWA: Time Weighted Average
STEL: Short Term Exposure Limit
Sk: Skin exposure
Current Limits for CN exposure:
• 10 ppm on an 8 hour TWA
• 5 ppm on a 12 hour TWA
• New suggested, but not approved yet, limit is 4.7 ppm maximum.

iii) Measures for noise

Ear defenders are recommended for workers in high noise points are for heavy truck drivers.

As mentioned in the impact section, the noise from the water pump will be localized within the
pump station. Still, the site of water intake should be chosen carefully and as far as possible
from the residential areas and cultivated lands. The consultation of the local stakeholders is
very necessary in this issue.

To reduce the nose of the generators, those models with noise control are preferred. The
location of the generators needs to be not too near to the accommodation and office premises
and not in lee wind site. In the future the company should probe the option of using an AC
current from the nearest national electricity grid.

iv) Measures for landscape impacts

The company is required to cause as minimal as possible change of the area’s original
landscape. The excavation of the tailing ponds will also alter the general landscape. However,
these impacts will be confined to the company’s site. As for the water pump on the River Nile
bank, and although the impact is localized within the pump station, unnecessary destruction of
bank and removal of vegetation should be avoided. Because no changes on the landscape along
the seven km pipeline corridor are anticipated, no mitigation measures are required.

v) Measures for impacts on water resources

As the site of pump station on the Nile bank could form a congregation point where people
could come and bath and wash their clothes, and as such could constitute a point source of
pollution, the site of the pump should be fenced and protected and a guard be appointed.

Proper dykes should be constructed to prevent tailing pond breach. In the unlikely event of
such an instance occurs, the flow of the pond water should be stopped and redirected away
from the nearest water course. A standby containment pond could be constructed. The use of
impermeable lining (HDPE recommended) , in the tailings’ ponds would alleviate this risk of
groundwater contamination. In addition the washed off shall be treated with Ferrous Sulphate
and Calcium/Sodium Hypochlorite.

In case of fire CO2 fire extinguishers shall not be used. The fire is to be excinguished with
water spray or fog (do not use straight stream of water). Most foams will react with sodium
cyanise solid and release toxic and corrosive fumes. For small fires dry chemical extinguishers
or dry sand are to be used.

vi) Measures for impact on archaeology

As the area of the project is renounced for its rich archaeological sites, it is most likely that
during the various excavation processes and construction activities, that one could come across
some archaeological artifacts. In case of such chance findings, the activities should be halted,
the site protected and the nearest archaeological authority should be notified.

vii) Measures for socioeconomic impacts

Disturbance to the residents by blasting activities should be minimized by notifying them of
the time and place of blasting. The locals should be made aware of the hazards of cyanide and
they and their animals should not be allowed to trespass into the company’s camp or sites of
activities.
A Compendium of expected impacts of mining activities in Block 52 and proposed mitigation
measures is shown in Table 6
Table 6.3: A Compendium of expected impacts of mining activities in Block 17and proposed
mitigation measures

Environmental Source Impact Level Mitigation

Component/Aspect
Camp Particulates during M 1. Masks during
establishment soil movement and construction.
compaction. 2. Stable site soil
and protected from
winds
Vehicles M 1.Masks

Rock drilling M 1. Masks 2. Wet

Dust drilling

Loading and L 1. Masks 2.

unloading Flying dust and Mist spraying
particulates
Rocks L 1.Masks 2.
transportations Mist spraying

Ore supply L 1.Masks 2.

Mist spraying

Ore crushing H 1.Mask. 2.

Mist spraying

Ore screening M 1.Masks 2.

Mist spraying

Tailing points. L 1.Masks 2.

Water sprinkling

Diesel H 1.Masks. 2. High

equipment quality equipment.

Unexpected fire H 1. Protective

Harmful gases disaster clothes

H 1.Proptective
clothes and HCN
Emission of detector/meter
HCN
2. Nearby
dispensary with
available antidotes
 Drill rods H 1.Ear Defenders.
2. High quality and
low noise
equipment

H 1.Ear Defenders
Crushing 2. High quality and
equipment low noise
equipment
3.Sound absorbing
facilities

1.Ear Defenders
Ball mills H 2.High quality and
low noise
equipment
3.Sound absorbing
facilities in duty
room
Noise
1.Ear Defenders

Vibrating H 2. High quality and

screening low noise
equipment

3.Sound absorbing
facilities in duty
room

Belt conveyors L 1.Ear Defenders

Dust collectors L 1.Ear Defenders

Air compressors L 1.Ear Defenders

Electric M 1.Sound absorbing

generators facilities
2. Greening
Vehicles and M 1.Ear Defenders
other
machineries

Liquid wastes Leaching water Heavy metals M 1.Recycling

 Suspended solids 2.Seepage
Cyanide salt prevention
HCN
Mineral M 1.Recycling
processing
(cyanide- 2.Seepage
containing) prevention,

Tailings M 1.Recycling
reservoir
2.Seepage
prevention

Domestic Pathogens 1. Construct septic

sewage tanks
M
2. Proper
purification

3.Use treated water

in irrigation

1.Proper stacking
of used rocks
Mining Hazards of M
scattered rocks 2. Make use of as
building and paving
Solid wastes material.

3. Refilling of
deserted mines to
avoid collapse.

Trenching Hazards of trenches M 1.Clear sign posts

2. Fence by local
tree species

Tailings Spent heap M 1. Strong dykes

2. Expose to
direct sunlight

Domestic Breeding sites for M 1.Regular deep

rodents burial

2. Burning if
unavoidable

Water pipes M
 Water tanks M 1.Regular
monitoring
Surface water
Seepage may create
River Nile breeding sites for
mosquitoes M 2.Avoid obstruction
1.Oil leakage from of natural run off
pump 3. Regular
2. Domestic maintenance
pollution by locals
1. Fencing of pump
washing clothes
platform
and bathing
2. Appointment of
guard

River Nile NaCN Reaching ___

River Nile from No mitigation
measaures
tailing ponds

Settlements No impact as there No mitigation

are no settlements measures are
Socio-economics ___
nearby required
Artisanal miners Temporary Filling trenches and
H mining wells
(holes)

Flora Natural Very low as L Greening of the

vegetation is sparse camp area

L 1. Fencing of the
extraction and spent
Fauna Natural Very low as it is ponds.
sparse
2. Lining & netting
of extraction &
spent ponds.
3. Proper sewage
system
1. Liaise with
NCAM to
Archaeology Excavation, Not known as no M
obtain
blasting and information is
trenching, available information
2. Halt activities
and notify
authorities in
case of chance
finding of
artifacts.
 7. ENVIRONMENTAL MANAGEMENT AND MONITORING PLAN

7.1 Conceptual consideration

The proposed avoidance and mitigation measures proposed in Section Five need to be
implemented timely and properly, otherwise the Environmental Impact Assessment activity
thus conducted and described in this report, would not fulfill its objectives. Therefore, to
guarantee that the construction and operation activities are executed within the framework of
Best Environmental Practices, an Environmental Management and Monitoring Plan (EMMP)
needs to proposed and implemented.

Environmental Management Plan is an integral part of an EIA to ensure that mitigation

measures and actions during construction and operation - as approved through the EIA to
protect the environment- are properly addressed and adopted and implemented. The EMMP
could also identify and recommend new mitigation measures for any possible further adverse
impacts. Within such a context, the proposed EMP should be subjected to continuous revision
and improvement.

The proposed EMP in this report would serve as a blue print for the Owners of the project to
prepare their own EMP to be implemented during the preparation phase of the project. Later on,
and during the implementation phase, the Northern State could then incorporate the project, and
all the associated commercial amenities into the Northern State Environmental Monitoring Plan.

7.2 Features of the Environmental Management and Monitoring Plan

The findings and recommendations embraced within the Environmental Impact Assessment in
the previous sections constitute the framework for the implementation of the proposed EMMP.

This tracking/monitoring process, which usually commences after the commissioning of the
project, normally includes: a monitoring programme, personnel responsible for implementation
of the plan, recommendations for emission and effluent standards and institutional requirements
for training and development.

The first and foremost recommendation in this context is for the project owner to establish and
implement an Environmental and Social Management Unit. This ESMU specifies and approves
implementation plans, monitor implementation, identify areas of non-compliance and instruct
corrective measures. The implementation and operation of this EMSU will be the main
mechanism to ensure that:

Ø Environmental and social safeguarding measures already identified in the EIA report
are observed;
Ø Any other measures to be further specified during the implementation phase will
actually be carried out; and
Ø Northern State Environmental Law and guidelines, if available, are complied with.

7.3 Management procesudres in case of spillage

Spill prevention or containment measures should also be provided for process solution
pipelines. Examples include secondary containment ditches, differential pressure sensing with
alarms and/or automatic shutoff systems, and preventive maintenance programs with pipe
thickness measurements. While a program of regular visual inspections should also be
conducted, visual inspections alone are not typically sufficient unless the inspections are
conducted at a frequency that can identify and prevent significant releases. If a risk exists for a
release of process solution from a pipeline to adversely affect surface water, such as where
pipes cross streams, operations should evaluate the need for special protection such as double-
walled

Ø Emergency plan
Ø Control the spilled cyanide into a confined area
Ø Prepare detailed emergency response plans for potential cyanide releases.
Ø Involve site personnel and stakeholders in the planning process.
Ø Designate appropriate personnel and commit necessary equipment and resources for
emergency response.
Ø Develop procedures for internal and external emergency notification and reporting.
Ø Incorporate into response plans monitoring elements and remediation measures that
account for the additional hazards of using cyanide treatment chemicals.
Ø Periodically evaluate response procedures and capabilities and revise them as needed.
7.4 Avoidanve of contamination and poisioing of surrounding environment
Design and construct unloading, storage and mixing facilities consistent with sound, accepted
engineering practices, quality control and quality assurance procedures, spill prevention and
spill containment measures. Details in Annex 6.1. Further an awareness programme should
be designed and executed for all the company’s workers about the hazards of cyanide and
other chemicals and machineries.

7.5 Monitoring Programme

Monitoring is essential to understanding the effects of a project and to evaluating the degree of
implementation and the success or failure of mitigation efforts. The following elements are
found necessary for adequate monitoring and need to be developed as early as possible, if they
were not developed during project planning:

• Identifying the monitoring areas and time frame for data gathering
• Planning what data to be collected
• Gathering of data
• Identifying of Ecological elements at risk
• Design and implement monitoring
• Analyze trends and recommend changes to the responsible authority.

7.6 Frequency of monitoring

The Environmental Monitoring Programme could be executed annually. However, if needed
for specific parameters, the frequency of monitoring could be shortened.

7.7 Parameters for monitoring

Certain parameters could be considered as indicators and trends of the environmental
performance of mining activities. The parameters would be determined jointly with the
company and the designated Consultant. It is very pertinent to mention here that within the
detailed preparation of the EMMP and, as the project takes off, the proposed monitoring
parameters could be revised and other parameters could be considered.

A proposal for the parameters to be monitored as well as thir monitoring frequenciesvis shown
in Table 7.1
Table 7.1: Monitoring parameters and frequencies

Environmental Parameters Site Frequency

component
Air HCN, PM, Hg, CO2, Gold miming Monthly
Noise Compound
Water Hg, NaCN, Gold miming Every six month
compound
Soil Hg, CN, Oil & grease, Gold miming Every six
compound
months
Workers HCN, HG, General health Gold miming Monthly
compound
 BIBLIOGRAPHY

Abdel Rahman, E. M. (1993). Geochemical and geotectonic control of selected ophiolite

complexes from Sudan. Geowiss Abh. A (145).

Coles, C. A. and Cochrane, K. (2006) Mercury Cyanide contamination of groundwater from

gold mining and prospects for removal. Sea to Sky Geotechnique .

DIU (2011). ESIA for Dal Hydropower Project.

Delgo Mining Company(2016). ESIA for Delgo Gold Reprocessing Plant. Institute of
Environmental Studies, University of Khartoum.

AEPA (2005). A Guidance for the Assessment of Environmental Factors. “The separation
distances between industries and sensitive land uses”. The Australian Environmental
Protection Authority.

Fichtner (2009). ESIA for Kajbar Hydropower Project. Dams Implementation Unit.

Greenwood, W. R., Hadley, D. C., Anderson, R. E., Fleck, R. G. and Schmidt, D. L. (1976).
Late Proterozoic cratonization in southwestern Saudi Arabia- Philos. Trans. Roy.
Soc. London, Ser. A, 280, 517-527, London.

Kroner, A., Greiling, R., Reischmann, T., Hussien, IM., Stern, R., Durr, S. Kruger, J.,
Zimmer, M. (1987) Pan African crustal evolution in northeast Africa. In: Kroner, A.
(eds) Proterozoic Lithosphere evolution. American Geophysics. Union, Geodyn.
Series 17: 235-257.

Kroner, A. (1985): Ophiolites and the evolution of tectonic boundaries in the late Proterozoic
Arabian-Nubian Shield of northeast Africa and Arabia – Precambrian Res., 27, 277-
300, Amsterdam.

Lahmyre International Consultant (Germany) (2009). Merowe Agricultural Project Feasibility

Study (Dams Implementation Unit)

Rocci, G. (1965): Essia de interpretation de measures geochronologique – la structure de L’

Ouest Africa-Sci. Terre, 10, 461-478, Nancy.
Stern, R. J., Kroener, A., Bender, R., Reischmann, T. and Dawoud, A. S., 1994. Precambrian
basement around Wadi Halfa, Sudan; a new perspective on the evolution of the East
Saharan Craton: Geologische Rundschau, v. 83, p. 564-577.

Vail, J.R. (1988). Tectonics and evolution of the Proterozoic basement of NE Africa. In: El
Gaby, S., and Greiling, R. (eds.), The Pan-African belt of NE Africa and adjacent
areas. Earth and Environmental Sc.: 192-226, Wiesbaden (Vieweg).
Annexes
Annex 3.1: Sudan’s position on International Conventions and Agreements

Binding International Conventions

Convention/Declaration Sudan Position

Ratified / Accepte
Date d/
Signed
Geneva Convention concerning Use of White Lead in Paints 1921 X X
London Convention on the Preservation of Fauna Flora their Natural State 1935
1933
Paris International Convention for the Protection of Birds 1950 X X
Rome International Convention for the Preservation of Flora 1951 1971
Moscow Treaty Banning Nuclear Weapons Tests in the Atmosphere in the 1966
Outer Space Under Water 1963
Rome Agreement for the Establishment of a commission for Controlling 1967
Desert Locust in the Near East 1965
African Convention on the Conservation of Natural Resources 1968 1973
Convention on Wet Land of International Importance Specially as Water 2004 2004
fowl Habitat (RAMSAR) 1971
Washington Treaty on the Prohibition of Placement of the Nuclear and other 1971
Weapons of Mass Destruction udder the Sea Bed and the Ocean Floor and
the sub-soil thereof 1961
Paris Convention concerning the Protection of the World Culture and Natural 1973
Heritage 1962
After Stockholm 1972
Washington Convention on Int. Trade in Endangered Species of World 1982
Fauna and Flora (C.I.T.E.S) 1973
Bonn Convention on the Conservation of Migratory Species of Wild Life X X
(CMS) 1979
Jeddah Regional Convention for the Conservation of the Red Sea and Gulf 1982
of Eden Environment 1982
Jeddah Protocol Conserving Regional Cooperation in Combating Pollution X X
by Oil and other harmful Substance in Cases of Emergency 1982
Montivo U.N. Convention of the Law of the Sea 1982 1985
Vienna Convention of the Protection of the Ozone Layer Vienna 1985 1993
Montreal Protocol on Substances that Deplete Ozone Layer 1987 and 1993
amendments 1990, 1992
Vienna Convention on Early Notification on Nuclear Accidents 1986 1986
Basel Convention on the Control of the Trans-boundary Movement of X
Hazardous Wastes and their Disposal, 1989
Bamako Convention on the Ban of import into Africa and Control of Trans- X X
boundary movement and management of Hazardous Wastes within Africa
1991
Rio 1992+
Rio United Nations Framework Convention on Climate Change 1992 1994
Rio Convention on Biological Diversity 1992 1994
Convention to Combat Desertification (UNCCD) 1994 1995
Prior Informed Consent on Hazardous Chemicals in international trade 1998
(PICs) 1989
Convention on Persistent Organic Pollutants (POPs) 2001
Paris Declaration on Climate Change 2016

Non-Binding Environmental Instruments

Instruments Sudan
Positio
ns
Principles of Conduct in the Field of the Environment for the Guidance of State in X
the Conservation and Harmonious Utilization of Natural Resources Shared by Two
or More States
Conclusion of the Study of Legal Aspects concerning the Environment Related to X
Offshore Mining and Drilling within the Limits national Jurisdiction
Montreal Guidelines for the Protection of the Marine Environment Against X
Pollution from Land-Based Sources
Cairo Guidelines and Principles for Environmentally Sound Management of X
Hazardous Wastes
Goals and Principle of Environmental Impact assessment X
London Guidelines for the Exchange of Information on Chemicals in International X
Trade
Code of Ethics on the International Trade in Chemicals X
Global Programme of Action for the Protection of the Environment from Land X
Based Activities
International Technical Guidelines for Safety in Biotechnology X
Annex 4.1: Water analysis of growndwater well

THE UNIVERSITY OF KHARTOUM

THE INSTITUTE OF ENVIRONMENTAL STUDIES

20/12/2016

Analysis of Ecological Material

Type of Material : Groundwater

Site: Milling Market

No. of Samples: 1

Result

No. Parameters Result Unit

1 pH 8.5
2 Colour Colourless
3 Odour Unobjectionable
4 Electric Conducticity (E.C. ) 2.08 mS/cm
5 Salinity 1.0 %
6 Total Dissolved solids 1010 mg/l
(T.D.S )
7 Total suspended solids 00 mg/l
(T.S.S)
7 NH3-1-N 0.04 mg/l
8 NO3-1 2.7 mg/l
9 NO2-1 10 mg/l
10 SO4-2 36 mg/l
11 Total S-2 16 µg/l
12 Total Cl-1 0.55 mg/l
13 Calcium (Ca) 1.6 mg/l
14 Magnesiuym (Mg ) 0.8 mg/l
15 Sodium (Na ) 19.13 mg/l
16 Phosphorus (P) 0.6 mg/l
17 Potasium (K) 1.02 mg/l
18 Iron (Fe ) 0.43 mg/l
19 Mercury (Hg)* 0.398 mg/l

Analyzed By :
 Ahmed Abdel Rahim

Chief Technician

* Analysed by the Petroleum Laboratories of the Ministry of Petrleum and Gas (Annex 4.2)

Annex 4.2: Water analysis of growndwater well for mercury

Annex 5.1 People who participated in the stakeholder’s meeting in Abri Village

on Sunday 24 July 2016

No Name location
1 Badri Dawowd Badri Sawarda
2 Ramzi Osman Badr ,, ,,
3 Mohamed Sayed Hussein ,, ,,
4 Mahmoud Sayed Hussein ,, ,,
5 Nadir Ahmed Mohamed ,, ,,
6 Bakri Abdelkarim Ochi Wawa
7 Hatim Sharif ,, ,,
8 Abdo Rabo Mohamed Omar ,, ,,
9 Adil Sharaf Ed-dein Mohamed Kudurka
10 Omer Abdelseid ,, ,,
11 Shazaly Elomda ,, ,,
12 Rami Salah Zubeir Eiru
13 Mugahid Elhusseein ,, ,,
14 Saad Eddein Deyab ,, ,,
15 Ghorashi Ibrahim Taha ,, ,,
16 Salih Idris Salih ,, ,,
17 Rami Salah ,, ,,
18 Samir Seif Ed-dein Aboud
19 Mohamed Ahmed Osman Badri ,, ,,
20 Elhadi Hassan Osman ,, ,,
21 Mohamed Elsir Abbas ,, ,,
22 Mohamed Hussein Mahmoud Etmatka
23 Mohamed Saied Ahmed Tabag
24 Fawzi Mohamed Badri Abri
25 Khatmi Basheir ,, ,,
26 Arif Mohamed Osman ,, ,,
27 Mohamed Elzein Ali ,, ,,
28 Mohamed Mahmoud Abd- elrrahman ,, ,,
29 Mohamed Eisa ,, ,,
30 Mohamed Mahmoud Elshorbagi ,, ,,
31 Ibrahim Mohamed Abdu Salih ,, ,,
32 Talal Mohamed Osman ,, ,,
33 Sami Suleiman ,, ,,
34 Rushdi Gamal ,, ,,
35 Hussein Gamal ,, ,,
36 Asim Ali Hussein ,, ,,
37 Salah Mohamed Salih Abri
 38 Rushdi Gamal Hussein ,, ,,
39 Nur eddein Mohamed ,, ,,
40 Abdelkhalig Abdoun ,, ,,
41 Ma’ala Elsadig ,, ,,
42 Mahdi Salih Mahdi ,, ,,

Annex 6.1: Implementation Guidance for the International Cyanide

Management Code