12 environmental impact statement 12.1 … resources management kangra coal (pty) ltd. 12-1 12...

ENVIRONMENTAL RESOURCES MANAGEMENT KANGRA COAL (PTY) LTD.

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12 ENVIRONMENTAL IMPACT STATEMENT

12.1 INTRODUCTION

Kangra Coal intends to extend the current operations under the 2014

Consolidated EMPr. This Chapter describes the key findings of the EIA and

summarises the positive and negative impacts and risks associated with the

following activities:

The development of the Central Discard Dump at Maquasa East

operations;

The mining of the MWE underground works (portion of the Maquasa

West Extension omitted activities from the current 2014 Consolidated

EMPr);

The development of Adit 5 to access the MWE underground workings;

and

The development of an overland conveyor and service road connecting

Adit 5 with the existing Maquasa West operational area.

12.2 SUMMARY OF IMPACTS IDENTIFIED AND ASSESSED

The following sections present a brief summary of the impacts identified and

assessed in Chapter 7. In accordance with Appendix 3, condition 3 (l) of the

EIA Regulations, December 2014, the final site map has been included below

(Figure 12.1). This map superimposes the proposed activities on the

environmental sensitivities of the site.


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Figure 12.1 Final Site Map


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12.2.1 Central Discard Dump

A summary of the potential impacts associated with the construction,

operation and decommissioning of the central Discard Dump is presented in

Table 12.1.

Most of the environmental disturbances are expected to occur during the

construction phase when vegetation clearance, topsoil removal, excavations

and construction will take place. The most significant impacts (medium to

high) are associated with the vegetation removal; exposure of soils to the risk

of erosion and uncontrolled impact from the site. These impacts include the

siltation and contamination of the Egude River and associated wetland, as

well as the erosion within the footprint area.

Geology: No impact is expected on the geology of the site.

Topography: In the context of the surrounding mine area, the impact on

the topography of the site is not considered to be of great significance and

rehabilitation is expected to occur in accordance with the approvals

received in order to ensure the site is in line with the planned end land use

of the MRA.

Soils, Land Use and Land Capability: The potential impacts to the soil,

land use and land capability are not considered to be a fatal flaw to the

proposed project, largely because the intention for this proposed project is

that the facility be adequately lined. The proposed Discard Dump is

located adjacent to a rehabilitated opencast pit, within the MRA, which

precludes the use of this land for any other purposes during the LoM.

Therefore, while soil compaction and a change in land use have been

identified as permanent changes to the soils on this site, these are not

considered to be fatal flaws to the development.

Terrestrial Ecology: During the impact assessment, the following

conclusions were reached:

o Impacts during the construction phase were considered to be

medium to low after mitigation.

o During the operational phase, impacts were considered to be

medium to low after mitigation.

o Post closure activities were considered to have a positive impact on

the vegetation, after mitigation.

o During the decommissioning phase, impacts were considered to be

low after mitigation.

o Impacts at a regional scale were considered to be low after

mitigation.

Based on the results obtained during the survey, there is no reason why

the development of the proposed Discard Dump, cannot commence.

Avifauna: The main identified impacts for the site on the avifaunal


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community are during the construction and operational phases. The

closure and post closure phases through appropriate rehabilitation are

generally associated with lower impacts. During the construction phase

the impacts are expected to be moderate. These impacts are generally

reduced through the mitigation measures. However due to the nature of

construction most still remain as moderate impacts.

If all mitigation and action plans are followed the overall impact will be

limited to moderate or low. Appropriate measures for rehabilitation post –

closure need to be followed to ensure low levels of impacts associated with

the area.

Wetland and Aquatic Environment: The wetland unit delineated has

already been modified; however, further contamination during the life of

the facility will further degrade the wetland ecosystem. The aquatic

habitat is still in a generally good state, but face potential degradation due

to the development. However, based on the results presented in the

Wetland and Aquatic Assessment the proposed development will not

have a detrimental effect on these systems if all the mitigation measures

recommended are adhered to. Furthermore, the implementation of a

Wetland Rehabilitation Plan compiled by a qualified wetland specialist

may improve the wetland conditions in the long term.

Surface Water: Although the proposed Discard Dump is located within

100m of the Egude River, this is not considered to be a fatal flaw. The

development may safely proceed, provided that the liner system (after

approval of the design by the DWS) and detailed stormwater management

plan are implemented. Furthermore, all mitigation measures

recommended in this document, the EA and IWUL (once issued) should

be adhered to.

Groundwater: No fatal flaws were identified during the groundwater

assessment. The potential groundwater quality and quantity impacts

associated with the proposed Discard Dump and PCD is countered by the

fact that the facilities will be designed to mitigate all adverse

environmental impacts on groundwater resources (i.e. liner system,

concurrent rehabilitation methodology). The environmental impact

significance rating is expected to reduce to a low significance.

Heritage and Archaeology: No sites of heritage or archaeological

significance were encountered, therefore no impacts are anticipated.

Noise: The location of the proposed development within the existing MRA

means that the noise to be created is not expected to be above the current

ambient noise levels. The noise impacts are therefore considered to be of

low significance and do not represent a major environmental issue for the

proposed development.

Visual: The proposed Discard Dump is not located within the viewshed of


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any residential or rural areas, or major roads. The location of the site close

to the existing mining and mining related activities also means that there

will be a limited impact on the character of the overall area.

Air Quality: The air quality impacts are limited to dust creation, which

can be managed through the implementation of the mitigation measures

recommended in this report. These impacts do not represent a major

environmental issue for the proposed development.

Socio-economic: The proposed Discard Dump is expected to have a

limited negative impact on the nearby Driefontein community in terms of

the nuisance impacts created, such as noise and dust. Furthermore, the

development will accommodate for the expansion and continuation of

Kangra’s mining operations in the area, which will allow for the

preservation of jobs in the long term and the implementation of Kangra’s

SLP. The net impact on the socio-economic environment is therefore

positive.


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Table 12.1 Summary of Potential Impacts: Central Discard Dump

Impact Description Construction Phase Operational Phase Decommissioning Phase

Significance

before Mitigation

Significance after

Mitigation

Significance

before Mitigation

Significance after

Mitigation

Significance

before Mitigation

Significance after

Mitigation

Topography

Change to natural topography M L H H

Improvement to topography M (+) M (+)

Soils, Land Use and Land Capability

Soil Erosion M L M L

Soil Compaction L M M L M L

Soil Contamination M L M L L L

Loss of Land Capability H M

Change in Land Use H H

Acidification of soils overlying

carbonaceous horizon

M L

Improvement of soil conditions over

time

M (+) M (+)

Terrestrial Biodiversity

Loss of flora species of conservation

importance

L L

Displacement of fauna species,

human-animal conflicts & interactions

M L M L

Loss of ecological connectivity and

ecosystem functioning

M L

Loss of fauna species of conservation

importance

L L

Indirect impacts on surrounding

habitats

M L

Indirect impacts to surrounding plant

and animal communities

(fragmentation)

M L

Increase in alien vegetation M L

Improvement in vegetation M (+) M (+)

Avifauna

Avifauna species identified as

common residents

L L


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Significance

before Mitigation

Significance after

Mitigation

Significance

before Mitigation

Significance after

Mitigation

Significance

before Mitigation

Significance after

Mitigation

Avifauna species identified as fairly

common residents

M L


uncommon residents

M M


migratory

M M M L

IUCN listed avifaunal species H M

Loss of habitat suitable for IUCN or

uncommon species

H M

Loss of unique or protected habitat

types (including loss and

degradation)

M M

Loss of nesting site for breeding

species

M M

Loss of ecological connectivity and

ecosystem functioning

M L M L

Indirect impacts on surrounding

habitats

M L M L

Impacts on water and riparian habitat M L H (+) H (+)

Degradation of the rehabilitated area H L

Rehabilitation of the wetland and

associated riparian zones

H (+) H (+)

Wetland and Aquatic Environment

Increased sediment transport into

down slope water resources

M M M M

Altered runoff characteristics of the

landscape

M M M M

Erosion within watercourses M L M L M M

Water quality deterioration M M H M

Increase in alien vegetation M M

Improvement to riparian zones L (+) L (+)

Surface Water

Siltation of surface water resources

and associated soil erosion

H L M L H L

Reduced runoff to surface water

resources

H L M L


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Significance

before Mitigation

Significance after

Mitigation

Significance

before Mitigation

Significance after

Mitigation

Significance

before Mitigation

Significance after

Mitigation

Increased runoff to surface water

resources due to surface compaction

H L

Surface water contamination M M M M M L

Deterioration of surface water quality

– Discard Dump Footprint H M

Deterioration of surface water quality

– PCD H L

Improvement to surface water quality M (+) M (+)

Groundwater

Groundwater quantity: reduction of

recharge from site preparation

L L M L

Groundwater quantity: reduction

from use of liners

L L L L

Groundwater quantity: reduction of

recharge from compaction of soils

L L

Groundwater quality: deterioration –

PCD

M M M M

Groundwater quality: deterioration –

Discard Dump

M M M L M L

Air Quality

Dust creation M L M L M L

Release of fugitive dust from exposed

discard material

M L

Noise

Noise creation M L M L L L

Visual

Change to aesthetics of the landscape L L

Poor visibility due to dust creation L L M L

Visual impact of discard dump M M

Light pollution M M

Improvement of landscape

appearance

M (+) M (+)

Socio-Economic

Creation of temporary employment L (+) L (+)

Nuisance caused by dust & noise

creation

L L L L


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Significance

before Mitigation

Significance after

Mitigation

Significance

before Mitigation

Significance after

Mitigation

Significance

before Mitigation

Significance after

Mitigation

Maintenance of long term

employment

M (+) M (+)

Reduction of nuisances such as noise

and dust

L (+) L (+)


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12.2.2 Maquasa West Extension Underground Works

The MWE underground works are an extension of existing mining operations,

and as such there will be no construction phase and therefore only impacts

associated with the operational and decommissioning phases are presented in

Table 12.2.

Surface Water: Impacts on surface water quality due to contaminated

decant from baseflow outlets (wetlands) and springs during the

decommissioning phase will be Medium prior to mitigation.

Groundwater: Impacts to groundwater include:

o Reduction in groundwater baseflow to the Kransbank Wetland due

to mine dewatering. Bord and pillar mining will have a Low

impact on fountains and therefore streams in the long term with

mitigation.

o Impact on groundwater quality due to contaminated mine water:

the mine water will decrease in quality as the materials in and

adjacent to the mining horizon has high pyrite content. Poor

quality mine water will have a Medium impact on the

groundwater quality in the long term if mine water is introduced

into the environment through decant.

Socio-economic: The development will accommodate for the expansion

and continuation of Kangra Coal’s mining operations in the area, which

will allow for the preservation of jobs in the long term and the

implementation of Kangra’s SLP. The net impact on the socio-economic

environment is therefore positive.


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Table 12.2 Summary of Potential Impacts: MWE Underground Works

Impact Description Operational Phase Decommissioning Phase

Significance before

Mitigation

Significance after

Mitigation

Significance before

Mitigation

Significance after

Mitigation

Geology

Impacts on geology associated with underground

mining activities

L L

Surface Water

Impacts on surface water quality due to

contaminated decant from baseflow outlets

(wetlands) and springs

M L

Groundwater

Reduction in groundwater baseflow to the

Kransbank Wetland due to mine dewatering

L L

Impact on groundwater quality due to

contaminated mine water

M L

Socio-Economic

Job retention and employment opportunities H (+) H (+)

Loss of jobs due to cessation of underground

mining activities

H M


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12.2.3 Adit 5 and Overland Conveyor

A summary of the potential impacts associated with the construction,

operation and decommissioning of Adit 5 and the overland conveyor is

presented in Table 12.3.

Most of the environmental disturbances are expected to occur during the

construction phase when vegetation clearance, topsoil removal, excavations

and construction will take place. The most significant impacts (medium to

high) are associated with the vegetation removal; exposure of soils to the risk

of erosion and uncontrolled impact from the site.

Geology: No impact is expected on the geology of the site.

Topography: No impact is expected on the topography of the site

Soils, Land Use and Land Capability: The potential impacts to the soil,

land use and land capability are not considered to be a fatal flaw to the

proposed project, largely because the following embedded controls will be

included in project design:

o Project footprint to be minimized to limit surface disturbance;

o Existing roads to access the site to be used where possible;

o Drainage control measures and culverts to control natural runoff

and overland flow to be used;

o Topsoil stripping, stockpiling and management will be planned

prior to ground disturbance works commencing to establish the

volume of soil to be stripped and areas where it will be stockpiled;

and

o Construction of conveyor line will be done in a way to minimise

surface disturbance.

Terrestrial Biodiversity: Impacts on terrestrial ecosystems are only

associated with the construction phase and include the loss of

conservation important floral species and the sensory disturbance and

displacement of fauna. These impacts were considered to be Low after

mitigation.

Wetland and Aquatic Environment: Three distinct wetland types were

identified as being associated with the proposed main adit and overland

conveyor, namely: Channelled Valley Bottom Wetlands; Unchannelled

Valley Bottom Wetlands; and Hillslope Seepage Wetlands. It is unlikely

that surface water flows will be affected to any degree by the proposed

Main Adit. Although the adit will overlie one spring, and be directly

adjacent to another, these systems do not contribute a large amount of

surface flow to the Kransbank wetland. Reduced surface run-off resulting

from the capturing of surface water runoff from surface infrastructure can

be mitigated by the construction of clean- and dirty-water separators to

allow clean water to reach streams, and by minimising unnecessary

retarding of surface water recharge.


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Groundwater: No fatal flaws were identified during the groundwater

assessment. Groundwater levels are unlikely to be affected by surface

infrastructure developed as part of Adit 5.

Heritage and Archaeology: The burial ground containing at least 12

graves, reportedly associated with an Ngwenya family, lies within the

proposed footprint of Adit 5. As these burial grounds fall within the

footprint of Adit 5, the impact will be a High significance prior to

mitigation and will require relocation in accordance with Section 36 of the

National Heritage Resources Act (Act 25 of 1999), Regulations 33 -35.

Noise: The location of the proposed Adit 5 and overland conveyor within

the existing MRA means that the noise to be created is not expected to be

above the current ambient noise levels. The noise impacts are therefore

considered to be of low significance and do not represent a major

environmental issue for the proposed development.

Visual: The location of Adit 5 and the overland conveyor close to the

existing mining and related activities means that there will be a Low

impact on the character of the overall area.

Air Quality: The air quality impacts are limited to dust creation, which

can be managed through the implementation of the mitigation measures

recommended in this report. These impacts do not represent a major

environmental issue for the proposed development and would vary

substantially from day to day depending on the level of activity, the

specific operations, and the prevailing meteorological conditions.

Socio-economic: The development will accommodate for the expansion

and continuation of Kangra Coal’s mining operations in the area, which

will allow for the preservation of jobs in the long term and the

implementation of Kangra’s SLP. The net impact on the socio-economic

environment is therefore positive.


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Table 12.3 Summary of Potential Impacts: Adit 5 and Overland Conveyor


Significance

before Mitigation

Significance after

Mitigation

Significance

before Mitigation

Significance after

Mitigation

Significance

before Mitigation

Significance after

Mitigation


Soil erosion M L M L M L

Soil compaction M M M M M M

Loss and sterilisation of fertile topsoil

layer

L L

Chemical soil pollution M L M L M L

Loss of current land capability L L L L L L

Change of land use M L M L


Loss of Conservation Important Floral

Species

H L

Sensory disturbance and

displacement of fauna

L L


Increased sediment movement M L

Confinement of longitudinal flow H M

Loss and disturbance of wetland

habitat

H M

Habitat fragmentation M L

Reduced water quality from point

source discharges

M L

Reduced water quality from erosion

from point source

M L

Reduced water quality due to surface

exposure of acid generating materials

at Adit 5

M L

Surface Water

Surface water quality M L M L M L

Air Quality

Dust generation M L M L M L

Noise

Generation of noise M L M L L L

Visual


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Significance

before Mitigation

Significance after

Mitigation

Significance

before Mitigation

Significance after

Mitigation

Significance

before Mitigation

Significance after

Mitigation

Impacts to the landscape and visual

environment

L L L L L L

Heritage

Burial grounds and graves H L

Exposed natural geological features L L

Socio-Economic

Creation of employment

opportunities

M M

Procurement and spending in local

economy

M M

Physical displacement H M

Economic displacement M L

Community health and safety M L

Increased pressure on social

infrastructure

M L


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12.2.4 Cumulative Impacts

The preceding impact assessments assessed the impacts associated with the

Project largely in isolation. A cumulative impact is one that arises from an

impact associated with a proposed Project, that when viewed in isolation may

be acceptable, but when combined with multiple developments in the greater

area affected by the proposal may not be acceptable. A summary of the

cumulative impacts is presented in Table 12.4.


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Table 12.4 Summary of Potential Cumulative Impacts

Impact Description Significance before Mitigation Significance after Mitigation

Topography

Change in topographical characteristics of the site M L

Change to topography of MRA H L

Groundwater

Potential groundwater contamination risk (ore stockpiles at plant) M L

Potential groundwater contamination risk (contaminant soil) M L

Continued groundwater contamination M M

Contaminated groundwater reaching surface water, impact nearby

groundwater and surface water

M M

Potential groundwater contamination risk (overburden dump) L L

High sulphate containing water may form and water quality may continue to

deteriorate

H M

Water decanting from operations will be high in SO4 and TDS – forming AMD H M

Reduction in groundwater quantity M M

Degradation of groundwater quality (discard dump and PCD) M M


Loss of arable land capability H M

Soil erosion M L

Soil compaction H M

Loss of land capability H M

Change in land use H H


Increase in local & regional fragmentation / isolation of habitat M L

Increase in environmental degradation, pollution of air, soils and water M L

Loss of fauna and flora of conservation importance M L

Further fragmentation of vegetation communities and habitats M L

Harm to animals and plants and introduction of invasive plant species M L

Loss of resident avifaunal species L L

Loss of migratory avifaunal species M L

Loss of Conservation Important species H M

Fragmentation of vegetation communities and habitats M L

Introduction of invasive plant species and loss of nesting sites M L

Loss of wetland and riparian habitat and decrease in water quality M L



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Impact Description Significance before Mitigation Significance after Mitigation

Decline in habitats and biota M L

Increased sedimentation M L

Surface Water

Erosion, siltation and hydrocarbon contamination of surface water resources M M

Overall reduction in clean water runoff M L

Degradation of water quality within the downstream surface water resource

(Egude River and Heyshope Dam)

M M

Air Quality

Increase in ambient PM10 levels M M

Degradation of air quality within the mining area and immediate surrounds M L

Noise

Increase in environmental degradation and pollution M M

Additional noise impacts M M

Traffic

Increase in traffic volumes M L

Traffic safety issues M L

Visual

Change to aesthetics of the landscape M M

Socio-Economic

Disruption and nuisance factors associated with decommissioning (noise,

visual and traffic impacts)

M M

Job losses due to mine closure H M

Population changes and “out flux” of people from the area M M

Safety and security risks M M


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12.3 RECOMMENDATIONS

Based on the detailed impact assessment undertaken and the proposed

mitigation and management measures, the EAP is of the opinion that the

proposed amendment of the Kangra Coal Consolidated EMPr (MP

30/5/1/2/2/133MR) for the proposed expansion into the MWE area, the

construction of the Adit 5, overland conveyor and servitude road and the new

discard dump should be granted Environmental Authorisation (EA). The EA

should be granted provided Kangra Coal adheres to the management and

mitigation measures proposed. The EAP recommends that the following

should be made conditions of the EA:

Central Discard Dump

Surface water: It is recommended that the monitoring points identified in

Section 9.1 (GCS, 2016) are included in the monitoring programme to

establish the baseline conditions of the affected reach of the Egude River

prior to the establishment of the proposed Discard Dump.

Groundwater: It is recommended that a numerical model is constructed,

during the operational phase of the proposed Discard Dump. This model

should be updated using the groundwater monitoring data collected to

assist in closure planning objectives and management plans.

Aquatic environment: There is currently no biomonitoring programme in

place within the vicinity of the proposed Discard Dump. It is

recommended that a programme is established prior to construction in

order to establish the baseline conditions of the affected watercourse.

Aquatic biomonitoring surveys of the aquatic invertebrate community

(SASS5) should be undertaken on a biannual basis.

MWE Underground Works

Groundwater:

o The potential interaction of the flooded underground workings on

the local groundwater systems, many decades after mine closure,

should be investigated further in terms of:

Mine water quality.

Preferential flow along coal seam outcrops.

Potential for contaminant movement in the local aquifers.

o Soon after the commencement of mining, high risk areas should be

identified where the flooded underground will have the highest

potential to impact the local surface water regime (e.g. mining close

to the mountain side and/or at shallow depths). A cost-benefit

analysis should be performed to determine if such areas can be

excluded from the mine plan.

o After the cessation of mining, the proposed Adit 5, should be sealed,


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based on engineering and hydrogeological considerations.

Adit 5 and Overland Conveyor

Air Quality: Fine particulates (specifically PM10) and ambient dustfall

monitoring should commence during the construction phase and continue

throughout the life of the project.

Surface and Groundwater: monitoring every quarter to determine

compliance with site specific Water Quality Objectives (WQO).

Noise: Noise complaints received during construction and operation are to

be addressed through the formal grievance mechanism. If a complaint is

received, it will be tested and verified by an independent noise specialist.

Should the complaint be valid according to acceptable limits as per best

practice guidelines, then Kangra Coal will design and implement a

localised mitigation measure to abate the noise impact and will follow up

the implementation of the mitigation measure with monitoring to confirm

its efficacy.

Terrestrial Biodiversity: Floral species search and rescue - all footprint

areas approved for development will be resurveyed in detail by a qualified

botanist with appropriate field experience and locations of all conservation

important species identified for transplanting recorded and visually

marked. The designated Environmental Officer should be included in the

search. Protected Species will require permits for removal. e.g. Eucomis

autumnalis can be successfully relocated to surrounding areas.

Heritage and Archaeology: Relocation of burial grounds and graves must

be in accordance with the National Heritage Resources Act (Act 25 of

1999).

Socio-Economic:

o Development of a project specific Recruitment Policy in accordance

with the Employment Equity Act (Act 55 of 1998), Basic Conditions of

Employment Act, 1997 and The Broad-based Socio-economic

empowerment Charter for the South Africa Mining and Minerals

Industry, 2010.

o Development and implementation of a Resettlement Action Plan and

Livelihood Restoration Plan for those households requiring

resettlement.

Kangra Coal will establish a “Grassland and Wetland Rehabilitation

Fund” (GWRF) for the exclusive purpose of “Additional Conservation

Actions” (ACA’s), in particular to rehabilitate the wetlands within the

impact zone of the Eastern Highveld Grasslands habitat. The GWRF will

be established under the following conditions:

o The GWRF will be to a value of ZAR 6,000,000 (Six million South


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African Rand);

o The GWRF will be established at the same time as the start of

construction of the main adit and the overland conveyor;

o Funds from GWRF will be used exclusively for planning and

implementation of biodiversity rehabilitation with a focus on

rehabilitation of grassland and wetland habitats;

o The GWRF will be used exclusively for the area as delineated in

Annex 12A: “Kangra Coal GWRF Rehabilitation Area”;

o Activities that will be funded by the GWRF will include:

Removal of alien vegetation, particularly within water courses;

and

Rehabilitation of wetlands within the Eastern Highveld

Grassland Ecosystem.

o Due consideration will be given to the loss of a source of fuelwood

used by the affected local people (due to alien vegetation removal)

and provision of a suitable substitute or replacement;

o The GWRF will not be used for standard mitigation and

rehabilitation actions associated with the direct impacts of the

construction of the main adit and overland conveyor or other

rehabilitation and mitigation measures already committed to by

Kangra Coal in existing permits or pending permit applications; and

o Implementation of rehabilitation actions funded by the GWRF will

commence one year after the completion of the construction of the

main adit and overland conveyor.

Given that this is a response to a cumulative impact, the proposed GWRF

may be referred to in other applications proposed by Kangra Coal. It

should be noted that Kangra Coal proposes a single fund to the value of

ZAR 6,000,000.

12.4 CONCLUSION

The aim of the inclusion of the proposed expansion of the current operations

under the 2014 Consolidated EMPr is to provide information to inform

decision-making that will contribute to environmentally sound and

sustainable development. This report is to be submitted to the MDMR to

provide information and an independent assessment, thus enabling the

MDMR to make an accountable and properly informed decision regarding

whether or not to grant approval of the amended EMPr in terms of Section 102

of the MPRDA.

This report will also assist the MDMR to define under what conditions the

development should go ahead if authorisation is granted. In considering the

expansion of the current operations, it is inevitable that there will be certain

negative environmental impacts. However, these have largely been mitigated

and should be viewed along with the fact that new resources are required to

maintain the current levels of production and employment. Should the mining

operations close, jobs will be lost, both directly at the mine and indirectly in


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terms of local contractors and businesses providing goods and services to the

operation, as well as the people dependent on those working for Kangra Coal

(both directly and indirectly).

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