TAILINGS STORAGE FACILITY

DESIGN REPORT

SUBMITTED TO: GOD MWANGA GEMS LIMITED

PREPARED BY: Joseph E. Mgina

&
Dunstan Chamu
SANSUTWA SIMTALI LIMITED.

September 2021
 1.0 INTRODUCTION

About the Company and the Project

God Mwanga Gems Limited is a locally registered company under companies Act of 2002.
The company established graphite mining as a small scale through existing two Primary
Mining Licenses, PML 0754-0755TNG of 19.91 early 2021. Environmental Protection Plan
was prepared for the environmental management and control system. The small scale
mining project has proved successfully and expanded to medium scale mining level thus
requiring audit to confirm the level of compliance. This report will give a clear idea of the
objectives of the exercise and the steps required to achieve it auditing. The project is known
as Kwedikabu Graphite Mining and Processing Project at Kwedikabu village- Kwamsisi
Ward in Handeni district of Tanga region.

Rare Element Resources (RER) contracted Golder Associates Inc. (Golder) to complete
an updated preliminary feasibility (prefeasibility)-level design and cost estimate for their
Bear Lodge Project tailings storage facility (TSF). The prefeasibility design update for the
TSF is in support of their ongoing revisions to the Bear Lodge Project Preliminary
Feasibility Study (PFS), which reflects an increase in ore reserves and additional
advancement of the ore processing and product recovery process since completion of the
initial PFS in April 2012.

1.1 Project Description

The project area is located at Msenga area in Kwedikabu village in Kwamsisi ward of
Handeni district. It is accessed by 60km From Chalinze-Segera highway off Mandera village
via Miono and Java villages or 55km off Chalinze-Segera highway at Mkata via Kwa msisi
and Msenga villages. Location coordinates for the combines Two PMLs are shown on table
 Table 1
Corner LatDeg LatMin LatSec LonDeg LonMin LonSec
Pt
1 -5 55 57.50 38 36 40.87

2 -5 56 2.40 38 36 40.81

3 -5 56 9.40 38 36 40.36

4 -5 56 9.34 38 36 25.80

5 -5 55 1.96 38 36 26.14

6 -5 55 52.50 38 36 26.08
Coordinates of the combined two PMLs in the project.

1.2 Scope of Report

The scope of this report is to present a summary of the TSF layout and design
considerations to:

o Document the work completed for the TSF design update

o Document the design criteria used in developing the TSF level design
update
o Document the assumptions made regarding design criteria, tailings
characteristics, tailings deposition, and the TSF foundation and borrow
materials
2.0 DESIGN CRITERIA
The general regulatory and engineering design criteria used to develop design for the
TSF are summarized below. Consultant developed the TSF Design Criteria to meet
applicable regulatory guidelines, specific project parameters provided by God Mwanga
Gems Limited, and -accepted standards of care regarding prefeasibility-level TSF design
and analysis.

2.1 Regulatory Guidelines

The prefeasibility-level design presented herein is intended to meet or exceed the primary
technical guidelines applicable to the TSF with respect to tailings containment and ground
and surface water protection. God Mwanga Gems Limited will address issues regarding
related environmental compliance, as necessary, with respect to water rights and air
quality as these are outside the scope of this report.

2.2 Engineering Criteria

There are no prescriptive criteria presented in the Non-coal Rules and Regulations for
mine waste management. However, it is stated that “tailings impoundments, tailings
disposal areas…shall be designed, constructed, and operated in accordance with
established engineering principles using best technology currently available to ensure
long term stability and to prevent contamination of surface or groundwater” (WDEQ 2006).
This guideline served as the primary basis for developing the design criteria for the TSF
prefeasibility level design.

The tailings produced by the rare earth element processing plant will be a non-hazardous
waste based on current test data and geochemical characteristics of the waste stream.
The tailings solids will be non-acid generating material; however, the residual moisture in
the tailings will be acidic because of the rare element extraction process. Amendments
will be added to the tailings to neutralize the material prior to transport to the TSF. In
addition, the tailings delivered to the TSF will be dewatered to a moist soil-like
Material suitable for truck hauling and deposition using conventional earthwork practices.
Based on these waste characteristics and the TSF design guidelines referenced above,
the following criteria were set for the prefeasibility-level design study for the TSF.

o “Zero discharge” facility with respect to contact surface water

management and any precipitation infiltration (i.e., seepage) emanating
from the tailings stack at the base of lined TSF
o Non–contact surface water runoff diverted around the facility and into
the current receiving stream
o Composite liner system consisting of minimum 12-inch compacted low
permeability soil liner exhibiting a hydraulic conductivity no greater than
1x10-7 cm/sec overlain by 80-mil high-density polypropylene (HDPE)
geomembrane liner
o Staged construction to minimize exposure of unused portions of TSF and
limit active areas of disturbance
o Capture, control, and separation from groundwater springs within the TSF
footprint by construction of an underdrain system to prevent impacts to
groundwater quality and to convey the spring flows beyond the TSF
boundary as non-contact or non-impacted waters
o Truck haul and controlled dump plan for waste disposal
o Factors of safety (FOS) for cut and fill slopes and embankments and
stacked tailings slopes within TSF meet or exceed minimum allowable
FOS as set by the State Engineer’s office for like structures or as
considered accepted industry standards for TSF operations and not
covered under the State Engineer’s Office regulations

2.3 Operations Criteria

Once the TSF is in operation, the site operations criteria will be regulated by approved
permit conditions and by health and safety regulations. Consultant incorporated
allowances in the TSF layout and design criteria for the TSF operations based on our
experience and anticipated environmental permit conditions. In particular, the active
tailings stacking area with be limited and the stability of the working area will meet factor
of safety allowances typical for end construction conditions in earthen dams. It is assumed
that placement of waste will be during day shift hours. Stockpile facilities have to be sized
to accommodate 24-hour plant operations and will allow for shut down periods due to bad
weather and for emergency equipment maintenance. The actual storage volume will be
determined in final design of the project facilities. Additional criteria for TSF operations
are included with the technical design criteria.
2.4 Environmental Criteria
Environmental criteria for design and operations are included in the design layout and
assumed operations and overlap with the engineering and operations criteria discussed
above. Provisions to monitor facility performance will be included in detail as part of final
design of the TSF. TSF performance monitoring will comply with the appropriate non-coal
rules and regulations and any additional requirements recommended in outstanding
permits and specified in completed permits. For purposes of developing phased
construction layouts and initially addressing potential air and water quality issues,
consultant assumed the following guidelines:

o The active area of stacked tailings will not exceed 20 acres

o Tailings slopes and surfaces placed and graded to the final design
configuration will be reclaimed concurrently with tailings placement in
active areas
o The area of runoff of contact water will be limited to 40 acres (including
the 30 acres of active tailings placement)
o Any active area that will remain dormant for 4 weeks or more before
receiving additional tailings will be protected with a temporary cover and
managed as an area of contact surface water runoff
o Runoff from reclaimed areas will routed away from the active TSF areas
and managed as non-contact water

The intent of the above guidelines is to present initial considerations for project
development, operations, and environmental concerns employing best management
practices. Consultant optimized the actual areas and time lines presented above or adjust
to comply with permit conditions as development of the project moves forward. Additional
criteria for TSF environmental protection are included with the technical design criteria
3.0 EXISTING SITE CONDITIONS
The proposed site for the TSF is along a broad slope that will require a side-hill type of
embankment for containment of the tailings. Vegetation in and around the proposed TSF
footprint generally consist of native grasses and sagebrush. Carbonate deposits on the
ground surface are present primarily in the northern portion of the site. Surficial soils
generally consist of clay apparently derived from erosion and or in-place weathering of
the exposed shale formations in the area.
The regions around Upton, including areas adjacent to the TSF.

3.1 Geology
The TSF is located near the contact of the Lower and Upper sided of the graphite plant.
The area is fully of Germiston and graphite belt zones.
3.2 Topography
The TSF site is located along the western flank of a broad flat-lying valley that slopes in
a southeasterly direction as shown in Drawing. A modest northwest-southeast trending
ridgeline with a maximum elevation of approximately 4,450 feet defines the west side of
the valley. The slopes extending from the ridge down into the valley are slightly rough
with an average grade of 45 to 50 percent towards the valley. The slopes are cut with
incised drainage channels created by groundwater springs and erosion due to surface
water runoff that initiate primarily in the upper third of the ridgeline slopes based on site
observations. The channels appear less defined below their transition into the shallow
sloping valley. An irrigation dam remains intact on one channel. The existing grade within
the TSF footprint slopes gently to the east-southeast with slopes of approximately 0.5 to
1.0 percent. Within the TSF footprint, existing ground surface elevations vary from
approximately 4,230 to 4,285 feet above mean sea level (amsl).

3.3 Surface Water and Groundwater

Surface water within the God Mwanga Gems Limited property boundary is limited to
seasonal flows.
3.4 Climate
Climate data used for hydrology design consideration in the TSF site are summarized
in and described below.

Table 2 Climate Data

Upton Site
Precipitati Evaporati
Month on on
(inches) (inches)
January 0.46 0.6
February 0.46 0.9
March 0.66 1.9
April 1.5 3.4
May 2.5 5.1
June 2.59 6.4
July 1.89 7.5
August 1.38 6.6
Septemb 1.19 4.2
er
October 1.1 2.4
Novemb 0.6 1.0
er
Decemb 0.6 0.6
er
Annual 14.95 40.6
 4.0 GEOTECHNICAL FIELD EXPLORATIONS AND LABORATORY TESTING

4.1 Field Explorations Summaries

Geotechnical field exploration and laboratory testing programs were completed to support
conceptual and design studies of the TSF Consultant included the geotechnical
information generated from explorations and soil testing to design the levels of the TSF

Table 3: Summary of all boreholes

BH-ID Type Depth Length Value

BH 1 DS 2.00 0.45
BH 1 DS 3.50 0.45
BH 1 DS 5.00 0.45
BH 1 DS 8.00 0.45
BH 1 SPT 1.50 0.45 21
BH 1 SPT 3.00 0.45 24
BH 1 SPT 4.50 0.45 13
BH 1 SPT 6.00 0.45 10
BH 1 SPT 7.50 0.45 27
BH 1 SPT 9.50 0.45 31
BH 2 DS 2.00 0.45
BH 2 DS 3.50 0.45
BH 2 DS 5.00 0.45
BH 2 DS 6.50 0.45
BH 2 DS 8.00 0.45
BH 2 SPT 1.50 0.45 24
BH 2 SPT 3.00 0.45 21
BH 2 SPT 4.50 0.45 46
BH 2 SPT 6.00 0.45 46
BH 2 SPT 7.50 0.45 49
BH 2 SPT 9.50 0.45 10

Average 5.12 0.45

Maximum 9.50 0.45 50
Minimum 1.50 0.45
Table 4: Standard Penetration Test

BH Depths SPT SPT Corrected

No. (m) SPT N- Corrected (N1)60 Estimated
Value Overburde Allowable Bearing
s n -Values Capacity (After Terzaghi

Values and Peck, 1967) kN/m2

BH
No.1 1.50-1.95 21 21 230
26
3.00-3.45 24 24 250
30
4.50-4.95 13 13 130
16
6.00-6.45 10 10 100
13
7.50-7.95 27 27 300
34
9.50-9.95 31 31 350
39
BH
No.2 1.50-1.95 25 25 280
31
3.00-3.45 21 21 240
26
4.50-4.95 47 47 400
59
6.00-6.45 46 46 400
58
7.50-7.95 50 50 400
63
9.50-9.95 10 10 100
13
BOREHOLE LOGS
5. CLOSING

This report has been prepared for the use of God Mwanga Gems ltd in support as
appropriate their mining project study update. No third-party engineer or consultant
shall be entitled to rely on any of the information, conclusions, or opinion contained
within this report without prior written approval from us or God Mwanga Gems ltd
The data and findings in this report have been prepared in a manner consistent with
the level of care and skill ordinarily exercised by engineering professionals currently
practicing under similar conditions subject to the time limit and financial and physical
constraints imposed on, or otherwise applicable to internal analysis.
We sincerely appreciates the opportunity to support God Mwanga Gems ltd in this
project.