draft environmental impact assessment report for the ... · the development of the mine up to this...

uKhozi Environmentalists (Pty) Ltd. (2004/013846/07 t/a “uKhozi”).

Building 32, Cambridge Office Park, 5 Bauhinia Street, Centurion. Postnet Suite 1454, Private Bag X1007, LYTTELTON, 0140

Tel +27 (0)12 665 2471 Fax +27 (0)86 767 8072 Web address: www.ukhozi-enviro.co.za

Directors: Inus de Wit; Alpha Hadebe; Tommy Olivier; Ken Smith

Draft Environmental Impact

Assessment Report

for the

Refurbishment and Recommissioning

of

Kwasa Colliery

situated on the Remaining Extent of the farm Goedehoop 169 HT

in the

Mkhondo Magisterial District of the Mpumalanga Province,

Republic of South Africa

Ref no: 17/2/3 GS-222

Proponent:

Siphiwo Investments (Pty Ltd Report Reference: KPS600

P O Box 652706

Benmore Report Status: Draft EIA/EMPr

2010

Date: February 2016

Tel: +27 (0)11 064 4836

Cell: +27 074 104 0662

[email protected]

http://www.ukhozi-enviro.co.za/

mailto:[email protected]

Proponent: Siphiwo Investments (Pty) Ltd February 2016

Draft EIA/EMPr for the Refurbishment and Recommissioning of Kwasa Colliery, Piet Retief, Mpumalanga

Preface

This Environmental Impact Assessment Report has been compiled by uKhozi

Environmentalists, based on the guidelines provided by the National Environmental

Management Act, 1998 (Act no 107 of 1998), Environmental Impact Assessment

Regulations. Full acknowledgement is made for use of the NEMA EIA regulations guideline

in compiling this report. This document includes uKhozi ‘s own interpretation of the

requirements of the National Environmental Management Act (Act 107 of 1998), the

regulations, the guidelines and the integration with other statutory and best practice

criteria. This Environmental Impact Assessment Report forms part of the process of

applying for environmental authorisation for the refurbishment and recommissioning of

the underground coal mining operation, Kwasa Colliery.

Contact details:

uKhozi Environmentalists (Pty) Ltd . t/a “uKhozi” Registration No. 2004/013846/07

Practitioners

Contact Person for this project: Tommy Olivier

Alternative contact persons: Inus de Wit

Tel.: +27 (0) 12 665 2471

Cell: +27 (0) 82 521 8870

Fax: +27 (0) 86 767 8072

Postnet Suite 1454, Private Bag x 1007, Lyttelton, 0140

[email protected]

[email protected]





uKhozi: KPS600/0216 Page i of xxi

Executive Summary

The Mining Right for Kwasa Colliery has recently been applied to be transferred to Siphiwo

Investments (Pty) Ltd., for which a S.11 transfer of ownership is required, and has been

submitted to the DMR. In line with the policy of operating within the framework of the

various, relevant laws, Siphiwo and its various partners has appointed KSE Services to

manage the process of applying for the environmental authorisations, and uKhozi

Environmentalists as the independent environmental assessment practitioners.

The National Environmental Management Act (107) 1998 (“NEMA”) and Environmental

Impact Assessment Regulations, 2010 specifies certain requirements for assessing the

impacts of the proposed project with the Public and this is complemented by requirements

of the National Water Act (36) 1998 (“NWA”).

This report is the result of fulfilling those requirements with information collected from

site visits to the Rem. of Goedehoop 169 HT, previous studies in the area, specialist

studies and a public participation process. Kwasa Colliery is situated in the Gert Sibande

Magisterial District which falls within the Mkhondo Local Municipality in Mpumalanga. The

coal reserve is located approximately 37 km south-west of the town of Piet Retief, 22 km

due East of the town of Dirkiesdorp and 58 km East of the town of Wakkerstroom

The Department of Economic Development, Environment and Tourism (DEDET) has

accepted the scoping report completed in terms of the National Environmental

Management Act, 1998 (Act No. 107 of 1998) and the Environmental Impact Assessment

Regulations, 2010 on the 16th September 2014 for the authorization to recommission the

underground coal mine. The listed activities applied for by this application are to ensure

that the application for environmental authorisations for the envisaged operation is

aligned with what is planned in practice. This application focusses on the NEMA

requirements: a Water Use licence Application process has started. The mine has been

issued with a Mining Right (Reference Number MP 30/5/1/2/2/415MR

F2009/04/28/004). An Environmental Impact Assessment Report (EIAR) along with an

Environmental Management Programme report (EMPr) is required to be submitted as the

next step in the application process.

This report is part of fulfilling the requirements of the NEMA, NWA and NEMA:WA for

environmental authorisation and has been compiled with information collected from site

visits to portion 0 of Goedehoop 169 HT, previous studies in the area, specialist’s studies

and a public participation process conducted during the scoping and EIA phases.



uKhozi: KPS600/0216 Page ii of xxi

The existing status of the site must be described during the environmental impact

assessment in order that the environmental management programme is applied directly

to the situation at hand. The Terms of Reference or plan of study for the EIA will need to

be verified by the participants in the consultative process, enabling the EIA to proceed

smoothly without gaps or duplication in the information generated.

Please note that these conclusions and recommendations have been made for discussion purposes: The

Applicant, Authorities, IAPs and specialist consultants will be given the opportunity to comment on this

EIAR and EMPr, while the Applicant will be able to make an informed decision as to the management

and mitigation commitments that will become necessary.

Project Description

Kwasa is a small, underground coal mine. It is planned to establish a wash plant on site.

The mining methods will be bord and pillar, using a coal cutter with minimal drill and

blast. There will be no secondary mining of the pillars to ensure that the roof will remain

competent.

Completed Activities

The development of the mine up to this point in time have all been done and funded by

Kwasa Mining Services (Pty) Ltd. The following activities had been completed

approximately three years ago but would probably need to be refurbished:

Refurbishment of access road to the mine and shafts;

Installation of Eskom power lines and transformers;

Refurbishment of the underground workings, with

a) roof stabilisation,

b) conveyor system,

c) ventilation infrastructure,

d) water management.

Fencing of the shafts;

Development of access control;

Setting out of a stockpile and loading area in place;

Infrastructure on site

The following infrastructure is currently on site:

Access roads as well as internal roads;

Security berms and palisades;

Old mining equipment;

Abandoned buildings;

Power Lines.

Planned Activities for the Construction Phase

The following activities will be carried out during the construction phase:



uKhozi: KPS600/0216 Page iii of xxi

Refurbishment and reconstruction of the water pollution control system;

Construction of one fresh water storage dams;

Construction of four pollution control dams (PCDs);

Construction of the silt traps at each PCD;

Transport to site and erection of a modular washing plant;

Preparation of the discard management facility;

Construction of offices and a change house;

Installation of a septic tank system;

Commissioning of an existing weighbridge;

New security house at main gate;

Final trenching and berms;

New runoff water catchment areas;

Three freshwater towers and tanks;

Installation of a new conveyor belt in the Alfred seam belt adit;

Road signs;

Water pumps and piping for PCDs and clean water storage dam;

Security lights at gates.

Five year contractual commitments for the supply and operation of crushing

and screening equipment;

Five year contractual commitments for underground mining services.

The facilities inside the operational area will be fenced such as the PCDs, fresh water

dam, washing plant area, co disposal site and stockpile areas.

Planned Activities for the Operational Phase

Activities to be conducted during the operational phase of the mine are:

Underground board and pillar mining with continuous miner which will not

involve blasting;

Transportation of run-off mine from the shaft to crushing and screening area

via a conveyor belt system;

Crushing and screening of run-off mine;

Stockpiling of the coal product;

Spraying of water on access roads to suppress dust;

Transportation of coal product to client via trucks;

Cleaning of silt traps;

Disposal of discard and silt at the Co-Disposal site;

Toil stockpiling (hard and softs);

Sewage management;

Solid waste management;

Dirty water handling including pumping water from PCD 3 to the coal washing

plant.



uKhozi: KPS600/0216 Page iv of xxi

Planned Activities for the Closure and Post Closure Phases

Activities to be conducted during the closure and post-closure phase of the mine are:

Plugging/sealing of the three adits (ventilation, access and exit);

Removal of storage equipment;

Cleaning and re-vegetation of the discard dump and product stockpile area at

the plant;

Removal of coal wastes;

Demolition of unwanted (by the post-mining land users) infrastructure such

as offices, change house, pollution control dams, access roads, high wall etc.;

The pollution control dams will be cleaned before it is filled and re-vegetated.

Landscaping and re-vegetation of disturbed areas.

Ground and surface water monitoring.



uKhozi: KPS600/0216 Page iv of xxi

Layout plan of the washing plant and adit area



uKhozi: KPS600/0216 Page v of xxi

Layout of product stockpile area and fresh water dam.

Alternatives

There are three main sets of alternatives associated with the recommissioning of this

underground coal mining operation, namely:

a) The underground operation with no additional washing plant and discard dump,

where the Run-of-Mine coal is beneficiated (washed) off site at a remote plant (this

proved to be not feasible over the past three years of operation).

b) The underground operation together with a wash plant and associated discard

dump, in the vicinity of the current operation (preferred).

c) The underground operation together with a wash plant and associated discard

dump, located at the abandoned Goedehoop colliery, some seven kilometres north

of Kwasa.

Legislative Requirements

The proposed operation requires a Water Use License in terms of Section 21 of the National

Water Act, 1998 (Act 36 of 1998) as well as a full scoping and environmental impact

assessment (EIA) in accordance with the requirements of the National Environmental

Management Act (NEMA) (2010) triggering activities nr 5, 6 and 20 in GN 545 (Listing notice

2) and National Environmental Management: Waste Act (NEM: WA) triggering listed activity

7 in Category B for the Co-Disposal Dump Site as well as PCDs.

Public Participation

During the Scoping/EIA process a public participation process was undertaken to allow IAPs

to voice their concerns and issues regarding the project. The key elements of the process

included:



uKhozi: KPS600/0216 Page vi of xxi

Development and distribution of a background information document (BID);

Informing IAPs of the proposed mining operation through a newspaper

advertisement and notification letters.

A key stakeholder meeting held in Piet Retief on the 5th of September 2013 (refer

to Appendix A.6.1 for the NfR).

A meeting was held with the landowner Ms Reinette Boshoff’s representatives,

Foster Attorneys in Ottosdal on the 24th of February 2014 (refer to Appendix

A.6.3 for the NfR).

A public meeting held in Piet Retief on the 25th of February 2014 (refer to

Appendix A.6.2 for the NfR).

A 2nd public meeting held in Piet Retief on the 5th of December 2014 (refer to


During this process a register of IAPs was compiled, together with a record of their

comments and responses from the project proponent and the EAP (refer to Issues and

Response Report in section 8.6 of this report).

The comments received during the review period will be taken into account in finalising the

Environmental Impact Assessment Report for submission to DEDET.

Environmental Baseline, Impacts and Mitigation

Geology

This coal reserve falls within the Karoo Super Group and is part of the Vryheid Formation

of the Ecca Group. Although there has been much transgressed activity, there are a number

of smaller faults within the mining area; no major faults traverse the area. A range of

anthracitic and lean to bituminous type coal is found within the reserve.

Main Impacts

Altering the geotechnical characteristics of the geological strata.

Main Mitigation Measures

The impact on the geology will be permanent and cannot be mitigated due to the

nature of the activity.

Stability of the high wall will be ensured by the use of split blasting techniques.

No secondary mining such as stoping and goafing must take place.

Topography

The pre-mining, natural topography of the area is a combination of steep slopes and

relatively flat (natural) terraces.

Main Impacts



uKhozi: KPS600/0216 Page vii of xxi

Altering the characteristics of the existing topography.


This area will be kept to the minimum needed for the mining operation.

The various stockpiles will be managed to prevent erosion and will be shaped where

required.

Soils

The soil within the mining area is generally deep, interspersed with dolerite boulders of

varying sizes. The dominant soil form in the disturbed area is the Hutton Form which is

associated with the dolerite boulder based scree slope as the pedology of the soil.

Main Impacts

Erosion and sedimentation

Contamination of the soil


The topsoil will be stockpiled separately, grassed, and used for the construction of

berms.

A vegetation layer on the berms will be maintained.

The height of the stockpiles must not exceed 1.5m.

Define routes for the circulation of heavy machinery and vehicles.

Land Capability

The land capability can be described as largely grazing and wilderness, with the area under

the operational, adit complex, potentially (post-mining) falling into the category of

rehabilitated mining land.

Main Impacts

Change in existing land capability.


The disturbed area will be kept to the minimum required for construction of the adit.

The topsoil and subsoil will be managed to ensure effective rehabilitation back to

the pre mining land capability during the decommissioning phase.

Land Use

The surface area under application can be divided into the following two categories:

Wilderness used for grazing;

Unrehabilitated mining area.

Coal waste is lying around on the unrehabilitated mining area and has the potential to

pollute the surrounding water resources during rainfall events.



uKhozi: KPS600/0216 Page viii of xxi

Main Impacts

Changes in land use from a defunct colliery to an operational colliery.


Control of the area disturbed during the construction phase to ensure no unplanned

(and/or unauthorised) expansion, with a direct effect on land use.

Vegetation

Kwasa Colliery is situated on the remaining extent of the farm Goedehoop 169 HT on the

lower scree slope of the mountain. The lower lying areas do show some signs of being

grazed by cattle but the extent of the grazing has been low and so it is not an issue of

concern. Plant species diversity is high and basal cover is generally good. While there are

some Wattle Trees (Acacia mearnsii) present in places, alien plants are generally not

abundant. Soil erosion is largely restricted to the drainage lines and is not extensive at any

site seen other than in the actual footprint of the mining area. In the higher lying areas,

located generally at or above the level of the mine adits, the vegetation is in pristine or

near pristine condition.

In broader terms, Kwasa Colliery falls within the Acocks’ veld type known as Veld-type

Number 63, namely Piet Retief Sourveld. The area is used for grazing and bi-annual burning

programmes common to the area would suggest that – in general, the veld type is no longer

pristine. However, the area on the southern sections of the mining rights area (on top of

the mountain range) is part of high altitude grasslands and has been included in the

Nkangala Grasslands project.

Main Impacts

Loss of vegetation.

Proliferation of alien vegetation inside the footprint area.


The disturbed areas will be kept to a minimum.

The topsoil containing the seed bank will be used as efficiently as possible.

Implement weed eradication programme.

Animal Life

A Highveld Grassland habitat once occurred over much of southern Mpumalanga, but this

has now largely been transformed into monocultures by agriculture and forestry. Where

pristine grassland remains, the biodiversity needs to be retained. Part of the area has been

disturbed by mining thus most of the animals have moved to adjacent areas.



uKhozi: KPS600/0216 Page ix of xxi

Main Impact

Loss of habitat/faunal diversity.


The enclosure fences erected around the operational areas will prevent domestic

livestock and discourage larger wild animals from entering the operational sites.

Prohibit activity outside of the demarcated area.

Surface Water

The mining area falls in the Usutu Catchment. The study area falls within the farm

Goedehoop 169 HT which is in turn is situated in quaternary sub-catchment W51C; the

catchment of the Vegkop River is 161km2. The Vegkop River is a tributary of the

Annysspruit which flows into the Assegaai (Mkhondo) River, which flows from this drainage

region north-eastwards, joining the Great Usutu River in Swaziland, and flowing into the

sea in Mozambique.

The water quality in the upper Usutu catchment is excellent, which is why Eskom source

their water for the cooling of coal-powered power stations from this catchment. The

surface water quality of the Annysspruit is being polluted by the defunct Kwasa Colliery.

During rainfall events the water falling onto the disturbed site gets polluted by coal waste

and flows downstream into the Annysspruit which in turn flows into the Assegaai River.

The surface water associated with the mining area is mainly used for stock watering,

aquatic eco-systems, and also for human (potable) requirements.

There are no registered wetlands associated with the operational area or in close proximity

to the site according to SANBI however the landowners have pointed out wetlands found to

the north of the site.

Main Impacts

Contamination of surface water.

Decrease of surface water runoff.

Disturbance of the bed and banks of the water courses.


All “dirty” water runoff should be kept on site and not allowed to mix and

contaminate clean runoff.

Clean storm water run-off will be diverted around the operational areas so as to

discharge into the natural surface water courses.

The disturbance footprint should be kept as small as possible in order to minimize

the impacts on the riparian habitat;



uKhozi: KPS600/0216 Page x of xxi

Groundwater

The mining area is mainly located across the mountain area; however the adit complex is

located on a terrace in a lower down the hill-slope.

The lower hill-slopes topographical areas have two principle aquifers. These are the

following:

A weathered aquifer occurring at a depth from 2 to 15 metres.

A fractured Karoo aquifer occurring at depths below 15 metres.

A perched aquifer system occurs above the dolerite sills and that more than one unconfined

/ semi-confined aquifer system occurs above the regional aquifer system that is associated

with the lower topographical system.

The mountain area has various fountains and springs indicating a shallow water table.

The groundwater is mainly used for livestock watering (from fountains and springs) with a

limited use for domestic supply.

Main Impacts

Contamination of the underlying aquifer.

Decrease in the groundwater level.


Any groundwater seepage that may flow into the adit during its excavation will be

pumped to the pollution control dam.

Separate the aquifer from the facility by lining the pollution control dams with HDPA

(2mm) and clay on top.

Ensure the impermeability of all storage areas for fuel, lubricants and other

chemicals.

Slope the surface of the stockpile areas to avoid pooling.

Limit groundwater use as much as possible and measure groundwater abstraction

levels.

Air Quality

In the pre-mining environment, there are no major local sources of air pollution. Adjacent

to the site to the south-west of the study area there is an existing coal mining operation

(Kiepersol Colliery Operations) which contributes to air pollution through dust as well as

diesel fumes from the operational trucks and vehicles. In the immediate vicinity, there is

some potential for dust pollution due to traffic on the gravel roads and general agricultural

activity.



uKhozi: KPS600/0216 Page xi of xxi

Main Impacts

Creation of fugitive dust.


Dust from the internal roads and operational areas will be suppressed with water

and a dust inhibitor.

The disturbed area will be rehabilitated in order to prevent the generation of dust.

Sensitive Landscapes

The abandoned Kwasa Colliery falls inside the Wakkerstroom Wetlands Grassland proposed

exclusion area in terms of Section 49 of the MPRDA.

The Annysspruit along with other small tributaries flowing in close proximity of the Kwasa

Colliery is also considered sensitive areas.

The wetland north of Kwasa Colliery’s entrance is considered a sensitive area. According to

the landowners there are various different species of waterfowl (spur winged geese,

Egyptian geese, crowned cranes, blue cranes) relying on this wetland.

Main Impacts

Decrease in the surface water runoff into the downstream wetlands.

Degradation/damage to the wetlands and streams due to mining operations.


Construct clean water diversion structures prior to construction to divert clean water

away from the construction area and prevent damming of clean water.

A 500m buffer zone must be maintained around all wetland areas.

All “dirty” water should be contained in lined pollution control dams.

No polluted water should be allowed to leave the site or flow into the surface water

system.

Noise

Noise in the area is restricted to routine traffic to and from the surrounding farms and

adjacent mining operations conducted by Kiepersol Colliery. Agricultural activities such as

the cultivation of lands and harvesting of crops also contribute a low scale source of noise

to the ambient level.

Main Impacts

Increase in the ambient noise level.



uKhozi: KPS600/0216 Page xii of xxi


Carry out the noisiest labours as quickly as possible and during normal working

hours (07:00 – 17:00) or according to applicable legal criteria.

All vehicles and machines must undergo periodic maintenance and inspection.

Visual

The site is visible from the R543 (Piet Retief – Wakkerstroom) district road, lying some

twelve kilometres to the north of the site. The un-rehabilitated Kwasa Colliery and the

Kiepersol Colliery have already altered the visual character of the Mhlangamvula and

Mhlanganpisi Mountains, especially when looking at the mountains from the north and

west. However the size of the disturbed area at the Kwasa Colliery is very small compared

to the disturbed area at Kiepersol Colliery directly to the west.

Main Impacts

Change in the visual aspects of the area. The landscape impacts with the highest

significance would occur during the construction phase of the mine as the activities during

this stage involve clearing of grassland vegetation for the establishment of the discard

dump, fresh water dam and coal product stockpile areas. This would leave exposed soil

and associated construction components.


Demarcate vegetation clearance areas so as to ensure that the minimum amount of

vegetation is removed.

Vegetate berms as far as possible.

Remove the minimum amount of topsoil and store for use in post-construction

rehabilitation.

Salvage indigenous vegetation for re-planting during post-construction

rehabilitation.

Socio Economic Environment

The area for the proposed mine falls within Ward 7 of the Mkhondo Local Municipality which

forms part of the greater Gert Sibande District Municipality.

In terms of Gross Geographical Product the two most important employment sectors are

agriculture at 36% and community services at 18%. The area has a large economically active

population (56%), a total of 43% of the economically active population is unemployed. This

indicates that the economy is unable to accommodate these people, which will either lead

to the out migration of youngsters and/or an increase in domestic poverty.

The N2 is the only national road which traverses the area. Three provincial roads traverse

the area. These include:



uKhozi: KPS600/0216 Page xiii of xxi

R33 from the N17 in the north, through Amsterdam and Piet Retief to Vryheid in the

south;

R65 between Ermelo and Swaziland via Amsterdam.

R543 between Swaziland and Volksrust via Piet Retief.

All these roads are tarred but in fairly poor condition and therefore need to be upgraded

and maintained. The R543 is the road that will be used to the Kwasa Colliery.

Main Impacts

Additional employment opportunities

The local and regional road transport network will suffer additional pressure from the

haulage trucks.


Use local workers as far as possible.

The construction vehicles must remain on site as far as possible during the

construction period.

Cumulative Impacts

The area in which the mine is located is already substantially transformed by a range of

human activities of which the most significant are mining, agriculture, timber production,

and urban and rural residential developments. As a result the biodiversity of the area is

already significantly reduced and several cohorts of species are either totally or largely lost.

Ecosystem service delivery is impaired and although the degree has not yet been quantified,

there are costs to society. Examples of these costs include expensive water purification,

and reduced public health especially in the poorer communities. The Kwasa mine will not

introduce any new forms of environmental impact but its impacts will act in a cumulative

fashion with the existing impacts. It is considered that the most important of these will be

the following:

Loss of biodiversity. The mine is situated in an area of naturally high biodiversity.

However, human activities such as agriculture, mining, timber production, and urban

and rural residential development have led to serious depletion of the original

biodiversity. At present there are still areas of rich floral diversity on the property

but some of these will be lost as the mine develops.

Reduction of water quality. The mine is unlikely to cause water quality to deteriorate

to levels which are any worse than those at other mines in the region. However, the

change from uncontaminated water yield to contaminated water yield suggests that

the Anysspruit will be affected by loss of dilution of existing pollution. If, however,

significant wetland rehabilitation is undertaken then then this impact will be

reduced.



uKhozi: KPS600/0216 Page xiv of xxi

Loss of food production. The development of the mine implies that agriculture on

the property will largely cease. Thus food production will be reduced and the general

food shortfall of the country will be exacerbated.

Recommendation

When comparing the environmental impacts that will occur if the Kwasa Colliery is

recommissioned to those that is currently occurring due to the state the environment was

left in, the recommissioning of the Kwasa Colliery should not have unmanageable

additional impacts. Some of the impacts that are currently occurring especially those

pertaining to the contamination of the surface and groundwater will be reduced when

proper mitigation measures are installed.

Considering the above the option of mining out the remaining reserve and then using the

funds to rehabilitate the area is the best practical option to stop the pollution that is

currently occurring at the mine. Therefore it is recommended that environmental

authorisation for the listed activities applied for.



uKhozi: KPS600/0216 Page xv of xxi

Table of Contents

Executive Summary ........................................................................................... i

1 Introduction and Background ................................................................... 1

Project Team ......................................................................................................... 2

1.1.1 Contact Details of EAP ................................................................................. 2

Contact Details of Applicant .................................................................................. 3

1.2.1 Name and Contact Details of Mineral Right Holder ...................................... 3

Legal Requirements ............................................................................................... 3

Approach to the Project ......................................................................................... 6

1.4.1 Scoping Phase ............................................................................................. 7

1.4.2 Scope of the EIA .......................................................................................... 7

1.4.3 Authority Involvement ................................................................................. 7

1.4.4 Public Participation ..................................................................................... 8

1.4.5 Decision Making.......................................................................................... 9

1.4.6 Authorities .................................................................................................. 9

1.4.7 Application Procedure ............................................................................... 10

Assumptions and Limitations .............................................................................. 11

1.5.1 Assumptions ............................................................................................. 11

1.5.2 Gaps in Knowledge ................................................................................... 12

Independence ..................................................................................................... 12

Report Structure .................................................................................................. 13

2 Project Description ................................................................................ 15

Regional Setting .................................................................................................. 15

Property Description ........................................................................................... 17

2.2.1 Adjacent Land Tenure and Use .................................................................. 18

2.2.2 Presence of Servitudes .............................................................................. 19

2.2.3 Zoning ...................................................................................................... 21

Objectives of the project ..................................................................................... 21

Physical Project Description ................................................................................. 21

2.4.1 Completed Activities ................................................................................. 21

2.4.2 Planned Activities ...................................................................................... 25

2.4.3 Water Pollution Management Facilities ....................................................... 27

2.4.4 Domestic water use and sanitation ............................................................ 31

2.4.5 Waste Management ................................................................................... 31

Mine Plan ............................................................................................................ 33



uKhozi: KPS600/0216 Page xvi of xxi

2.5.1 Mineral deposit ......................................................................................... 33

2.5.2 Mine products ........................................................................................... 33

2.5.3 Estimated Reserve ..................................................................................... 36

2.5.4 Mining Methods ........................................................................................ 36

Project Phases ..................................................................................................... 41

2.6.4 Development Procedure ............................................................................ 42

Aspects of Mine Health and Safety ....................................................................... 44

2.7.1 Background ............................................................................................... 44

2.7.2 Health and Safety: General ........................................................................ 44

2.7.3 Traffic ……………………………………………………………………………………..44

3 Need and Desirability ............................................................................ 45

Socio Economic ................................................................................................... 45

Biophysical .......................................................................................................... 46

Project Market ..................................................................................................... 46

Labour Force ....................................................................................................... 46

The Multiplier Effect ............................................................................................ 46

4 Alternatives .......................................................................................... 47

Development Alternatives ................................................................................... 47

Operational Alternatives ...................................................................................... 49

4.2.1 Mining Method .......................................................................................... 49

4.2.2 Mineral Processing Methods ...................................................................... 50

4.2.3 Transport .................................................................................................. 50

4.2.4 Sources of Water ....................................................................................... 50

4.2.5 Mine infrastructure sites ........................................................................... 51

4.2.7 Mine residue disposal site ......................................................................... 51

4.2.8 Domestic and Industrial Waste Disposal Sites ............................................ 51

4.2.9 Housing Sites ............................................................................................ 51

4.2.10 Land Use Option after Rehabilitation ......................................................... 52

5 Existing Status of the Environment ......................................................... 53

Description of the potentially affected environment ............................................ 53

Description of the landscape surrounding the operation ..................................... 54

Assessment of the environment likely to be affected and description of current

environmental state of the study area ................................................................. 54

5.3.1 Climate ..................................................................................................... 54

5.3.2 Air quality ................................................................................................. 55

5.3.3 Geology .................................................................................................... 55



uKhozi: KPS600/0216 Page xvii of xxi

5.3.4 Topography .............................................................................................. 56

5.3.5 Land capability .......................................................................................... 56

5.3.6 Land Use ................................................................................................... 57

5.3.7 Soils ……………………………………………………………………………………..58

5.3.8 Vegetation ................................................................................................ 58

5.3.9 Surface Water ............................................................................................ 67

5.3.10 Groundwater (Aquifer description) ............................................................ 86

5.3.11 Sensitive Areas .......................................................................................... 87

5.3.12 Noise ……………………………………………………………………………………..90

5.3.13 Visual ……………………………………………………………………………………..90

5.3.14 Socio Economic Environment ..................................................................... 92

5.3.15 Heritage .................................................................................................... 96

Specific environmental features occurring on site which may require protection,

remediation, management or avoidance .............................................................. 96

6 Environmental Impact Assessment ......................................................... 98

Mine Risk Assessment ......................................................................................... 98

The Definition of Significance in the context of this EIA ....................................... 99

6.2.1 Context ................................................................................................... 100

6.2.2 Spatial ……………………………………………………………………………………100

6.2.3 Temporal ................................................................................................ 100

6.2.4 Intensity .................................................................................................. 101

6.2.5 Certainty ................................................................................................. 101

6.2.6 Special knowledge................................................................................... 101

6.2.7 Perceptions ............................................................................................. 101

6.2.8 Levels of Significance .............................................................................. 101

6.2.9 Implications of the Significance Rating Scale ........................................... 102

6.2.10 Summary of the Significance Rating Matrix .............................................. 102

Environmental Impact Assessment .................................................................... 111

6.3.1 Construction Phase ................................................................................. 111

6.3.2 Operational Phase ................................................................................... 122

6.3.3 Decommissioning Phase.......................................................................... 130

7 Environmental Management and Implementation Plan ........................... 139

Environmental Management Plan ....................................................................... 139

Roles and Responsibilities ................................................................................. 140

Probability of Impacts Occurring Pre and Post Mitigation ................................... 167

Environmental Objectives and Goals for Mine Closure ....................................... 170



uKhozi: KPS600/0216 Page xviii of xxi

7.4.1 Geology .................................................................................................. 170

7.4.2 Topography ............................................................................................ 171

7.4.3 Soils ……………………………………………………………………………………171

7.4.4 Land Capability ....................................................................................... 171

7.4.5 Land Use ................................................................................................. 172

7.4.6 Vegetation .............................................................................................. 172

7.4.7 Animal Life .............................................................................................. 173

7.4.8 Surface Water .......................................................................................... 173

Closure objectives ............................................................................................. 173

7.4.9 Groundwater ........................................................................................... 174

7.4.10 Air Quality ............................................................................................... 174

7.4.11 Noise ……………………………………………………………………………………175

7.4.12 Sites of Archaeological and Cultural Interest ........................................... 175

7.4.13 Sensitive Landscapes ............................................................................... 175

7.4.14 Visual Aspects ......................................................................................... 176

7.4.15 Regional Socio-economic Structure ......................................................... 176

7.4.16 Interested and Affected Parties (IAP’s) ..................................................... 176

7.4.17 Infrastructure areas ................................................................................. 177

7.4.18 Mine residue deposits ............................................................................. 177

7.4.19 Disposal facilities .................................................................................... 177

7.4.20 Ongoing seepage, control of rainwater .................................................... 177

7.4.21 Long-term stability ................................................................................. 178

7.4.22 Final rehabilitation in respect of erosion and dust control ....................... 178

7.4.23 Sealing of underground workings and rehabilitation of dangerous

excavations. ................................................................................. 178

7.4.24 Final rehabilitation of mine haul ramps. .................................................. 179

8 Public Participation Process ................................................................. 180

Creating Public Awareness ................................................................................ 182

8.1.1 Site Notice .............................................................................................. 182

8.1.2 Newspaper Adverts ................................................................................. 182

8.1.3 Background Information Document ......................................................... 183

Public Meetings ................................................................................................. 183

8.2.1 Public Meeting ........................................................................................ 183

8.2.2 Focus Group Meetings ............................................................................. 185

Authority Meetings ............................................................................................ 185

Register of IAPs ................................................................................................. 187



uKhozi: KPS600/0216 Page xix of xxi

Issues Raised .................................................................................................... 190

Issues and Responses ....................................................................................... 191

9 Methodology ...................................................................................... 214

Desktop Analysis............................................................................................... 214

Guiding Principles ............................................................................................. 215

9.2.1 Balanced sustainable approach................................................................ 215

9.2.2 Best Practicable Environmental Option (BPEO) .......................................... 215

9.2.3 Precautionary Principle ............................................................................ 216

Assumptions and limitations ............................................................................. 216

10 Environmental Impact Statement .......................................................... 217

11 Appendices ........................................................................................ 218

List of Figures

Figure 1: Locality Map .................................................................................................. 16

Figure 2: Title Deed ...................................................................................................... 17

Figure 3: Specific location of planned activities ............................................................. 18

Figure 4: Map showing surrounding farm .................................................................... 20

Figure 5: Graphical representation of the storm water management plan ...................... 29

Figure 6: Layout plan of the mining area....................................................................... 32

Figure 7: Product Stockpile area at the access gate ....................................................... 33

Figure 8: Mining Plan .................................................................................................... 34

Figure 9: Proposed Kwasa operation adjacent to the Kiepersol Colliery ......................... 35

Figure 10: Elevation profile of the proposed site (North to South) ................................. 56

Figure 11: Dominant vegetation types on the mine property. Source: Mucina and

Rutherford (2006) .............................................................................................. 60

Figure 12: Mpumalanga Biodiversity Sector Plan (2014) for the area around the mine site.

.......................................................................................................................... 61

Figure 13: Areas which have been, or still are, under cultivation and timber production62

Figure 14: Usutu to Mhlatuze WMA ............................................................................... 68

Figure 15: Upper Usutu Catchment ............................................................................... 69

Figure 16: Water Management Areas............................................................................. 71

Figure 17: Layout of the mine property showing the proposed infrastructure in relation to

the water courses ............................................................................................... 74

Figure 18: Rivers in close proximity to Kwasa Colliery................................................... 75

Figure 19: The five streams with its 100m buffer zone in relation to the operational areas

of the proposed colliery ..................................................................................... 77



uKhozi: KPS600/0216 Page xx of xxi

Figure 20: Health categories used for describing the Present Ecological State (PES) of

wetlands. From Macfarlane et al, 2008. .............................................................. 81

Figure 21: Kwasa Colliery Proximity to Registered Wetlands .......................................... 82

Figure 22: Land Uses in the Usutu to Mhlathuze WM ..................................................... 84

Figure 23: Sectorial Water Requirements (Usutu to Mhlathuze) ...................................... 85

Figure 24: Schematic representation of the different aquifer systems (GCS, 2009) ........ 86

Figure 25: The Wakkerstroom Wet Grasslands (WWG) proposed exclusion area (233, 393

ha) extending over 120 farms within the Pixley Ka Seme and Mkhondo Local

Municipalities ..................................................................................................... 89

Figure 26: Population per Ward .................................................................................... 93

List of Tables

Table 1: Identified Listed Activities in terms of NEMA EIA Regulations, 2010 .................. 3

Table 2: Relevant Authorities ........................................................................................ 10

Table 3: Application Procedure ..................................................................................... 10

Table 4: Distance to the Neighbouring Towns and Villages ........................................... 15

Table 5: Property Details .............................................................................................. 17

Table 6: Activities during Rehabilitation ........................................................................ 42

Table 7: Summary of Development Activities ................................................................ 43

Table 8: Pre-mining land capability of the operational adit complex ............................. 57

Table 9: Vegetation types on the original Farm Goedehoop 169 HT (Conservation status

.......................................................................................................................... 59

Table 10: Vegetation types on the original Farm Goedehoop 169 HT. Conservation status

from Mucina and Rutherford (2006). .................................................................. 59

Table 11: Indigenous flowers found on the site ............................................................ 63

Table 12: Indigenous trees found on the site ................................................................ 64

Table 13: Grass species found in the site ...................................................................... 64

Table 14: Red Data listed bird species recorded in the area around the mine. ............... 66

Table 15: Common Mammal Species occurring in Mkhondo .......................................... 67

Table 16: Threatened Mammal Species occurring in Mkhondo ...................................... 67

Table 19: Water chemistry readings from four streams ................................................. 73

Table 20: Centre points and areas of the four dams found on the property................... 78

Table 21: Primary hazard class type if mineral mined ................................................... 98

Table 22: Classification of Mines .................................................................................. 99

Table 23: Example of Natural Vegetation (Summarised Impact) ..................................... 99

Table 24: The Significance Rating Scale ...................................................................... 102

Table 25: Implications of the Significance Rating Scale ............................................... 103



uKhozi: KPS600/0216 Page xxi of xxi

Table 26: Categorization of the main activities in terms of the aspects of the operation

........................................................................................................................ 104

Table 27: Responsible role players ............................................................................. 140

Table 28: Potential impact and mitigation register for the construction phase ............ 141

Table 29: Potential impact and mitigation register for the operational phase .............. 150

Table 30: Potential Impact ad Mitigation Register for the Decommissioning Phase ...... 158

Table 31: Probability of Impact Occurring Pre and Post Mitigation .............................. 168

Table 32: IAPs Register ............................................................................................... 187

Table 33: Issues and Responses ................................................................................. 191

Appendices

Appendix A: Public Participation

A.1 Proof of Placement of Notices

A.2 Proof of Notification of key Stakeholders

A.3 Information Provided

A.4 Authorities Involvement

A.5 List of Registered I&APs

A.6 Minutes from Meetings Held

Appendix B: Historical Date

B.1 VBA Shelly Colliery EMPR Groundwater and Surface Water Quality Sections (Feb 1998)

B.2 VBA Environmental Management Report – Goedehoop Colliery Washing Plant (June

2002)

Appendix C

Motivation for the consideration of the Wakkerstroom Wet Grasslands under Section 49 of

the MPRDA

Appendix D: Maps and Plans

D.1 Layout Plan (A3)

D.2 Silt Trap Design

D.3 Water Balance Diagram

Appendix E: Site Photographs

Appendix F: Specialist Studies

F.1 Integrated Water Management Report

F.2 Biodiversity and Wetland Assessment Report

F.3 Visual Impact Assessment Report

Appendix G: Environmental Awareness Plan



uKhozi: KPS600/0216 Page 1 of 218

1 Introduction and Background

At the end of 2009 Kwasa Mining Services (Pty) Ltd purchased an abandoned underground

mine previously operated as Protea Colliery by kwaZulu Collieries which has been

liquidated. Kwasa Mining Services (Pty) Ltd abandoned the colliery and left the area in an

un-rehabilitated state with old equipment, scrap metal, old coal dumps and rock heaps.

Five shafts in the adit complex were left open and in an unsafe state and the area was also

eroded by water erosion over the years. Although Kwasa Mining Services (Pty) Ltd. is

currently the responsible party, a formal process has been initiated under Section 11 of the

MPRDA for the appointed Business Rescue manager to apply to the DMR to transfer the

Mining Right to Siphiwo Investments (Pty) Ltd, who is able and willing to take this over,

together with the environmental liabilities.

The area that is planned to be mined by Siphiwo Investments (Pty) Ltd is larger than 5

hectares. The previous mining company Kwasa Mining Services (Pty) Ltd. has been issued

with a Mining Right over the farm Goedehoop 169 HT on 2nd March 2011, Protocol Number

1092/2011, DMR Reference Number MP 30/5/1/2/2/415MR F2009/04/28/004. The list

of activities in this report has been compiled to ensure that the application for

environmental authorisations for the envisaged operation is aligned with what is planned

in practice. This application focusses on the NEMA requirements: a Water Use license

Application process has started.

In line with the policy of operating within the framework of the various, relevant laws,

Siphiwo and its various partners has appointed KSE Services to manage the process of

applying for the environmental authorisations, and uKhozi Environmentalists as the

independent environmental assessment practitioners.

The following studies have been conducted at Kwasa Colliery in the past and were used

during the compilation of this report:

Addendum to the Environmental Management Programme Report (EMPR) for the

Kwasa Colliery (old Protea Colliery) compiled by uKhozi Environmentalists in March

2010;

Water Use License application screening report compiled by uKhozi

Environmentalists;

VBA Shelly Colliery EMPR Groundwater and Surface Water Quality Sections (Feb

1998);

VBA Environmental Management Report – Goedehoop Colliery Washing Plant (June

2002).




Project Team

uKhozi Environmentalists aims to provide an independent, quality, and time efficient

service to proponents of environmentally responsible developments throughout Southern

Africa (SADC), and to advise those proponents that do not advocate such an approach.

The identification, assessment and coordination of participative and sustainable

environmental solutions have developed since 1996 as a focal mission of KSE and its sister

company uKhozi–Community Upliftment Services: these two companies have now merged,

to form uKhozi Environmentalists.

Operational Frameworks

Code of Practice: International Assessment for Public Participation (IAP2);

Code of Practice: International Association for Impact Assessment (IAIA);

Code of Ethics: South African Council for Natural Scientists;

Code of Ethics: SA Institute of Forestry;

Environmental Assessment Practitioner (EAP) Interim Certification Board.

Environmental Assessment Practitioner Team Consists of:

Mr Tommy Olivier

Environmental Consultant completed his BSc in Ecology as well as his BSc Environmental

Management and Analysis Honours degree at The University of Pretoria. His honours

project focused on climate change and the effects that modern society has thereon. He has

five years’ experience working as an environmental consultant at uKhozi Environmentalists

where he has managed a number of different EIA’s, Basic Assessments and Water Use

License Applications mainly for coal mining operations. Tommy has been a member of the

International Association for Public Participation (IAP2) since 2012.

Mr Inus de Wit

Environmental Consultant completed his BSc in Ecology as well as his BSc Environmental

Management and Analysis Honours degree at The University of Pretoria. His honours

projects focused on Soil particles size and the distribution of Juliana’s Golden Mole. He

recently completed his Master’s Degree in MSc Water Resource Management. His thesis

focused on the physiological effects of turbine pressure on freshwater fish species. He has

3 years’ experience working as an environmental consultant.

1.1.1 Contact Details of EAP

Name: Tommy Olivier

Telephone: (012) 665 2471

Fax: 086 767 8072

Cell: 082 521 8870




E-mail: [email protected]

Contact Details of Applicant

Name: Bob Nkosi

Telephone: 074 104 0662

Fax:

Cell: 074 104 0662

E-mail: [email protected]

1.2.1 Name and Contact Details of Mineral Right Holder

Siphiwo Investments is busy with a Section 11 Transfer to transfer the Mining Right from

Kwasa Mining Services to Siphiwo Investments (Pty) Ltd.

Legal Requirements

The proposed operation requires a full scoping and environmental impact assessment (EIA)

in accordance with the requirements of the National Environmental Management Act

(NEMA) (2010) triggering activities nr 5, 6, 15 and 20 in GN 545 (Listing notice 2).

The following legislation is relevant to the environmental authorisation of the proposed

development.

National Environmental Management Act (Act 107 of 1998):

The National Environmental Management Act (NEMA) creates the fundamental legal

framework that gives effect to the environment right guaranteed in Section 24 of the

Constitution of the Republic of South Africa, 108 of 1996. NEMA sets out the fundamental

principles that apply to environmental decision making, some of which derive from

international environmental law and other from the Constitution. The core environmental

principle is the promotion of ecologically sustainable development.

The following listed activities have been identified in terms of NEMA EIA Regulations 2010:

Table 1: Identified Listed Activities in terms of NEMA EIA Regulations, 2010

Listing Notice No

. Description of activity

BAR/

Scoping

and EIA

GN No. R.544

18 June 2010 9

Constructions of two pipelines from the fresh water

dam and PCD 3 to the washing plant, both pipelines

exceeding a 1000m in length.

BAR






GN No. R.544

18 June 2010 11

Construction of a runoff berm within 32 meters of the

watercourse between the water course and the plant to

protect the wetland.

BAR

GN No. R.544

18 June 2010 12

Construction of a fresh water dam with a capacity of

more than 50 000 m3. BAR

GN No. R.544

18 June 2010 13

Storing diesel on site in containers that can hold more

than 80m3 but less than 500m3. BAR

GN No. R.544

18 June 2010 18

Construction of the in stream fresh water dam. BAR

GN No. R.544

18 June 2010 23

The development of the discard dump area which will

include an access road, fence, pollution control dams

and plastic lining.

BAR

GN No. R.544

18 June 2010 39

The expansion of five crossings to allow mine

management to access the PCDs and other areas

around the colliery.

BAR

GN No. R.545

18 June

2010

5

The application for a water use licence for the following

water uses:

Section 21 (a), (b), (c), (g), (i) and (j).

Scoping

EIA

GN No. R.545

18 June 2010 6

Transportation of run-off mine from the shaft to

crushing and screening area via a conveyor belt system.

Scoping

EIA

GN No. R.545

18 June 2010 15

The development of the operational area which will

include a Co-Disposal dump site, access road, pollution

control dams, product and ROM stockpile areas and a

fresh water storage dam.

Scoping

EIA

GN No. R.545

18 June 2010 20

Kwasa Colliery has an existing mining right. Scoping

EIA

Mineral and Petroleum Resources Development Act (Act 48 of 2008) (MPRDA)

The objective of the MPRDA is to facilitate meaningful participation of HDSAs in the mining

and minerals industry. In particular, section 100(2) (a) of the MPRDA provides for the

development of the Mining Charter as an instrument to effect transformation with specific

targets. Embedded in the Mining Charter of 2002 is the provision to review the progress

and determine what further steps, if any, need to be made to achieve its objectives.

The previous mining company Kwasa Mining Services (Pty) Ltd. has been issued with a

Mining Right over the farm Goedehoop 169 HT on 2nd March 2011, Protocol Number

1092/2011, DMR Reference Number MP 30/5/1/2/2/415MR F2009/04/28/004.




Although Kwasa Mining Services (Pty) Ltd. is currently the responsible party, a formal

process has been initiated under Section 11 of the MPRDA for the appointed Business

Rescue manager to apply to the DMR to transfer the Mining Right to Siphiwo Investments

(Pty) Ltd, who is able and willing to take this over, together with the environmental

liabilities.

National Environmental Management: Waste Amendment Act, 2014 (Act 26 of 2014) (NEM:

WA):

To reform the law regulating waste management in order to protect health and the

environment by providing reasonable measures for the prevention of pollution and

ecological degradation and for securing ecologically sustainable development; to provide

for institutional arrangements and planning matters; to provide for national norms and

standards for regulating the management of waste by all spheres of government; to provide

for specific waste management measures; to provide for the licensing and control of waste

management activities; to provide for the remediation of contaminated land; to provide for

the national waste information system; to provide for compliance and enforcement; and to

provide for matters connected therewith.

GN No. 921 Category B Activity nr 7 – The disposal of any quantity of hazardous

waste to land.

According to the NEM: WA, which came into effect in May 2014, residue stockpiles are

seen as hazardous waste. NEM: WA defines residue stockpiles as follows:

“Any debris, discard, tailings, slimes, screening, slurry, waste, rock, foundry sand, mineral

processing plant waste, ash or any other product derived from or incidental to a mining

operation and which is stockpiled, stored or accumulated, within the mining area for

potential re-use, or which is disposed of, by the holder of a mining right, mining permit

or, production right or an old order right, including historic mines and dumps created

before the implementation of this Act”.

According to GN No. 921 a person who wishes to commence, undertake or conduct a waste

management activity listed in Category B of GN No. 921, must conduct a Scoping and

Environmental Impact Reporting process set out in the Environmental Impact Assessment

regulations made under section 24(5) of the National Environmental Management Act, 1998

(Act 107 of 1998) as part of the waste management license application.

National Environmental Management: Air Quality Act, 2004 (Act 39 of 2004) (NEM: AQA):

The objective of the Air Quality Act is to protect the environment by providing the necessary

legislation for the prevention of air pollution. The Act also covers potential air pollution

originating from stockpiles. As with NEMA, the Act will specify listed activities that may not




be conducted without an atmospheric emission licence. The licensing of such activities will

be under the control of the metropolitan and district municipalities.

National Environmental Management: Biodiversity Act (10 of 2004):

The Act provides for the management and conservation of South Africa’s biodiversity within

the framework of the National Environmental Management Act, 1998. Among other things

the Act deals with the protection of listed threatened or protected ecosystems and species,

and requires permits to be issued to authorise restricted activities (which include

conveying, moving or otherwise translocation of any specimen of a listed threatened or

protected species) involving such ecosystems and species. The Act’s permit system is

further regulated in the Act’s Threatened or Protected Species Regulations, which were

promulgated in February 2007.

Occupational Health &Safety Act (85 of 1993):

The objective of Act is to provide for the health and safety of persons at work. In addition,

the Act requires that “as far as reasonably practicable, the employers must ensure that their

activities do not expose non-employees to health hazards” (Glazewski, 2005: 575). The

importance of the Act lies in its numerous regulations, many of which will be relevant to

the proposed manganese smelter. These cover, among other issues, noise, lighting,

emergency preparedness, management of dust and handling, storage and transportation

of hazardous materials.

National Water Act, 1998 (Act no. 36 of 1998)

A Water Use License Application has been made with the Department of Water and

Sanitation in terms of Section 21 of the National Water Act, 1998 (Act 36 of 1998) for the

following water uses:

S.21 (a): Taking water from a water resource;

S.21 (b): Storing water;

S.21 (c): Impeding or diverting the flow of water in a water course;

S.21 (g): Disposing of water or water containing waste in a manner that may

detrimentally impact on a water resource;

S.21 (i): Altering the bed, banks or characteristics of a water course;

S.21 (J): Removing, discharging or disposing of water found underground for the

continuation of an activity or for the safety of persons.

Approach to the Project

The EIA process is divided into two main phases, which are the Scoping Phase and

Environmental Impact Assessment Phases. During these phases public participation is

conducted to get input from key stakeholders where the potential exists for them to be

affected by a proposed activity.




1.4.1 Scoping Phase

The scoping phase objectives is to identify in broad terms the environmental issues and

project alternatives that must be assessed in the subsequent EIA phase. Explicit provision

is made in the scoping phase for the involvement of Interested and Affected Parties (IAPs)

in the EIA process.

1.4.2 Scope of the EIA

The EIA will focus on the biophysical, social and economic impacts that might be caused

by the proposed operation and will also address the mitigation measures that will be

implemented to avoid and/or minimise these impacts.

The public will form part of the process in identifying these impacts during the public

participation process that will be conducted throughout the EIA process.

1.4.3 Authority Involvement

The Department of Economic Development, Environment and Tourism (DEDET) Ermelo

conducted a site visit in September 2014 after the final scoping report was submitted. On

the 16th of September 2014 the final scoping report was accepted by DEDET (refer to the

acceptance letter in Appendix A.4.1.1).

The Department of Water Affairs (DWA) conducted a site visit on the 21st of May 2013. After

the site visit DWA issued a warning letter on the 24th of June 2013 to Kwasa Mining Services

(Pty) Ltd indicating that the mine has water use activities that are unlawful and that activities

at the mine imposes a risk of polluting the surrounding water resources. DWA afforded

the mine an opportunity to make written representations to the Department within 30 days,

if according to the responsible party, compelling reasons can be submitted to the

Department (refer to Appendix A.4.2 for the full letter).

KSE Services representing Siphiwo replied to DWA’s warning letter on the 19th of July 2013

stating that:

There are several non-compliances at the mine, as noted during the visit by Officials

of the Department in June 2013.



Rescue manager to apply to the DMR to transfer the Mining Right to Siphiwo

Investments, who is able and willing to take this over, together with the

environmental liabilities.

Siphiwo recognises the urgency of the pollution control measures needed on the

site.

uKhozi Environmentalists prepared an application for a Water Use Licence which was

submitted to Kwasa Collieries in March 2010. Siphiwo is currently following up to




determine the date and office to which this application was submitted. The

Department is requested indicate if a copy of this application can be made available.

Siphiwo recognises the need for a coal washing plant to beneficiate the Run-of-Mine

coal to an acceptable product specification, and this implies the need for a discard

dump.

Siphiwo has received a proposal from uKhozi Environmentalists to address:

Water Use Licence in terms of the National Water Act, 1998 – revision and

amendment as per the requirement for a washing plant and discard dump;

Environmental Authorisation in terms of the National Environmental Management

Act, 1998– as may be relevant.

In the email accompanying the letter KSE Services indicated that uKhozi

Environmentalists have been appointed to conduct the Water Use Licence Application

and EIA.

A period of some eight months (plus?) will thus be required for the mine to become

environmentally compliant, and STA needs to confirm the feasibility thereof in terms

of accepting the responsibility liabilities for the mine (refer to Appendix A.4.2 for

full letter).

The Inkomati-Usuthu Catchment Management (IUCMA) Agency conducted a site visit on

the 17th of November 2014 in order to advise on the way forward with regards to the

Water Use License application.

On the 25th of February 2015 a meeting was held with the Inkomati-Usuthu Catchment

Management (IUCMA) Agency and the DMR to find a collective way forward as to who is

liable to rehabilitate or to contain the pollution at Kwasa Colliery.

uKhozi requested an extension for the submission of the draft EIA/EMP Report in order to

finish the necessary specialist studies. The landowner did not allow access for all the

specialists in time therefor the report has to be submitted in order to stick to the deadline

of February 2016 set by the department.

1.4.4 Public Participation

During the Scoping/EIA process a public participation process was undertaken to allow

IAPs to voice their concerns and issues regarding the project. The key elements of the

process included:

Development and distribution of a background information document (BID);

Informing IAPs of the proposed mining operation through a newspaper

advertisement and notification letters.

A key stakeholder meeting held in Piet Retief on the 5th of September 2013

(refer to Appendix A.6.1 for the NfR).




A meeting was held with the landowner Ms Reinette Boshoff’s

representatives, Foster Attorneys in Ottosdal on the 24th of February 2014

(refer to Appendix A.6.3 for the NfR).

A public meeting held in Piet Retief on the 25th of February 2014 (refer to


A 2nd public meeting held in Piet Retief on the 5th of December 2014 (refer

to Appendix A.6.5 for the NfR).

During this process a register of IAPs was compiled, together with a record of their

comments and responses from the project proponent and the EAP (refer to Issues and

Response Report in section 8.6 of this report).

The Draft Environmental Impact Assessment Report will be emailed or posted to the

registered IAPs for their comment. A copy will also be made available at the public library

in Piet Retief.

A final public meeting will be held after the IAPs have had time to work through the draft

EIA/EMPr. The comments received during the review period and public meeting will be

taken into account in finalising the EIA/EMPr for submission to the DEDET. The outstanding

specialist studies also need to be completed before the EIA/EMPr can be finalised. This

depends on whether the landowner and Applicant can come to an agreement.

1.4.5 Decision Making

The decision-making framework comprises of the following:

Department of Economic Development, Environment and Tourism

(DEDET), Ermelo;

Inkomati-Usuthu Catchment Management Agency (IUCMA (Nelspruit);

Department of Water and Sanitation (DWS Nelspruit)

Department of Mineral Resources (Witbank) (DMR);

Mkhondo Local Municipality;

Gert Sibande District Municipality;

The Applicant Siphiwo Investments (Pty) Ltd.

1.4.6 Authorities

The relevant authorities are described in Table 2.




Table 2: Relevant Authorities

Department Description of applicable

department

Contact person

DEDET Department of Agriculture

and Environmental Affairs

(Ermelo) which regulates

activities as listed under

NEMA.

Thabile Mahlakudt

[email protected]

Cell: 072 571 8851

DMR Department of Minerals

Resources (Witbank) which

regulates mining related

activities.

Matshilele Ramovha

[email protected]

Tel: 013 653 0500

IUMCA Responsible for water use

applications in the Usutu

Catchment.

Thabo Rasiuba

[email protected]

Golden Mthembi

[email protected]

Tel: 013 753 9000

Cell: 083 825 8894

Fax: 086 668 8681

DWS The Department of Water

and Sanitation (DWS),

which regulates water and

environmental related

issues. Responsible for

water use applications

The Usutu Catchment is

the relevant catchment

management area.

Adolph Mbetse – 078 893 8924

/ [email protected]

Mdu Nkuna – 083 634 8769 /

[email protected]

Tel: 013 932 2206

1.4.7 Application Procedure

Table 3: Application Procedure

Application for Environmental Authorisation in terms of the National Environmental

Management Act (107), 1998 (“NEMA”)

Date Activity

27 November 2013 Application was accepted by DEDET

on or before

30 May 2014

Submit a Draft Scoping Report R.29.










Application for Environmental Authorisation in terms of the National Environmental

Management Act (107), 1998 (“NEMA”)

Date Activity

10 July 2014 40 day comment period ends for Draft Scoping Report.

30 July 2014 Submit Final Scoping report.

16 September 2014 Final Scoping Report Accepted by DEDET;

October 2014 Appoint Specialists as per the plan of study in the Scoping

Report.

February 2016 Submit Draft EIAR.

March 2016 30 day comment period ends for Draft EIAR.

30 April 2016 Submit final EIAR.

June 2016 Finalization of the application by the Department.

30 June 2016

onwards

If approved –project goes ahead

If not approved, applicant to review options.

Assumptions and Limitations

The report is based on currently available information and, as a result, the following

assumptions and limitations are implicit in it:

1.5.1 Assumptions

The report is based on project descriptions from the EMPR that was done for Kwasa

Mining Services in March 2010 and these are likely to undergo a number of

iterations and refinements before it can be regarded as definite.

The information provided by the applicant is correct and accurate;

A project description based on the final design would be provided if changes occur.

Descriptions of the natural and social environments are based on available studies

and field work. More information will be provided in the Final EIA/EMPr based on

the outcomes of the specialist studies. The following specialist studies are being

conducted:

Hydrogeological and Geochemical Study (Groundwater Consulting Services

GCS);

Hydrology Study (GFK Consulting Engineers);

Biodiversity study and Wetland Delineation (Terratest);

Soil Specialist Study (uKhozi Environmentalists);

Visual Impact Assessment (uKhozi Environmentalists);

Heritage Impact Assessment (eThembeni Cultural Heritage);




Integration of the Social and Labour Plan with the Socio Economic Assessment

(KSE Services).

The groundwater model will be updated as information becomes available during

the operational phase of the colliery.

1.5.2 Gaps in Knowledge

The specialist studies were conducted to certain levels of confidence, and in all instances

known methodologies have been used and confidence levels are generally high. This

means that in most cases the situation described in the pre-mining environment is

accurate at high certainty levels, but there exists a low probability that some issues have

not been identified during the studies. Such situations cannot be avoided simply due to

the nature of field work and have therefore not been further discussed below.

Furthermore, statistical analyses and mathematical models are merely tools which assist

the researcher in assessing field observations and have innate assumptions which can

reduce objectivity of the results obtained. This is not seen as a major flaw but should

always be considered when assessing results.

This report aims to identify potential environmental impacts associated with the proposed

activities, however seeing as it is an on-going process the scope of the impacts identified

could change through new information coming to light. Should this happen, the new

information and changes to the scope will be added to the report. The following specialist

studies have not been completed because the landowner refused access to the site and

will form part of the final EIA/EMPr:

Hydrogeological Assessment;

Hydrology Assessment;

Heritage Impact Assessment;

Soils and Land Capability.

Independence

uKhozi Environmentalists (Pty) Ltd are:

the independent environmental practitioners in this application;

do not have and will not have any vested interest (either business, financial, personal

or other) in the undertaking of the proposed activity, other than remuneration for

work performed in terms of the Environmental Impact Assessment Regulations, 2010;

will perform the work relating to the application in an objective manner, even if this

results in views and findings that are not favourable to the applicant;

declare that there are no circumstances that may compromise our objectivity in

performing such work;




have expertise in conducting environmental impact assessments, including knowledge

of the National Environmental Management Act, 1998 (Act107 of 1998), regulations

and any guidelines that have relevance to the proposed activity;

will comply with the National Environmental Management Act, 1998 (Act107 of 1998),

regulations and all other applicable legislation;

will take the provisions of regulation 7(2) of the EIA Regulations, 2010 into account

when preparing any report relating to this application;

undertake to disclose to the applicant and the KZN Department of Agriculture,

Environmental Affairs and Rural Development all material information in our

possession that reasonably has or may have the potential of influencing its decision

with respect to this application;

will ensure that information contained in all reports in respect of this application is

distributed or made available to interested and affected parties and that their

participation is facilitated in such a manner that they will be provided with a

reasonable opportunity to participate and provide comments on the reports;

will provide the competent authority with access to all information at our disposal

regarding this application, whether such information is favourable to the applicant or

not;

declare that all the particulars furnished by uKhozi in this report are true and correct;

realise that a false declaration is an offence in terms of regulation 71 of the EIA

Regulations, 2010 and is punishable in terms of section 24F of the National

Environmental Management Act, 1998 (Act 107 of 1998); and

will comply with all the requirements as indicated in the National Environmental

Management Act, 1998 (Act 107 of 1998) and Environmental Impact Assessment

Regulations, 2010.

Report Structure

This report, which complies with the minimum requirements of National Environmental

Management Act (Act 107 of 1998), Environmental Impact Assessment Regulations, has

been structured as follows:

Chapter 1: Introduction and background. This chapter includes the background to

the project, EAP and project teams details, the applicant’s contact details, legislative

requirements, the approach to the project, assumptions, limitations and gaps in

knowledge;

Chapter 2: Project Description. This chapter includes the property description,

objectives of the project, physical project description, mine plan, project phases as

well as aspects of mine health and safety.

Chapter 3: Need and Desirability. This chapter describe the socio economic and

biophysical need and desirability of the proposed project.




Chapter 4: Alternatives. This chapter describes the development alternatives and

operational alternatives that have been considered for the proposed project.

Chapter 5: Environmental Status Quo. This chapter describes the baseline

environmental conditions on and around the site.

Chapter 6: Environmental Impact Assessment. This chapter describes the criteria

and rating system applied to assess the significance of the impacts along with the

impact assessment of each identified impact before mitigation.

Chapter 7: Environmental Management Plan. This chapter describes the roles and

responsibilities, mitigation measures for each identified impact, implementation

schedule, and significance rating after mitigation, the probability of the impact

occurring pre and post mitigation as well as the closure plan.

Chapter 8: Public Participation Process. This chapter describes the steps taken by

uKhozi to consult with stakeholders and relevant authorities, the results of the

consultation process thus far, IAP register as well as an Issues and Response

Report;

Chapter 9: Methodology. This chapter describes the methodology used during the

EIA process, guiding principles, as well as the assumptions and limitations;

Chapter 10: Environmental Impact Statement.

Chapter 11: References. All documents consulted during the formulation of this

report are cited in this chapter.




2 Project Description

Kwasa is a small, underground coal mine. It is planned to establish a wash plant on site.

The mining methods will be bord and pillar, using a coal cutter with minimal drill and blast.

There will be no secondary mining of the pillars that would compromise the long term

integrity of the roof.

Regional Setting

Kwasa Colliery is situated in the Gert Sibande Magisterial District which falls within the

Mkhondo Local Municipality in Mpumalanga.

The coal reserve is located approximately 37 km south-west of the town of Piet Retief, 22

km due East of the town of Dirkiesdorp and 58 km East of the town of Wakkerstroom

(please refer to Figure 1 and Table 4).

The locality of the area under application is illustrated in the Regional Setting Map.

Reference is made to Figure 1 which shows the main features of the land and mining area

to which the application relates.

Table 4: Distance to the Neighbouring Towns and Villages

Town Distance

Dirkiesdorp 22km

Piet Retief 31km

Wakkerstroom 58km




Figure 1: Locality Map




Property Description

The abandoned Kwasa Colliery is located on the farm Goedehoop 169 HT. Please refer to

the property details and title dead below.

Table 5: Property Details

No. Property

Description Area (ha) Land owner Capacity

1

Goedehoop 169 HT

(remaining extent)

801.1229 I.J.C Boshoff Surface owner

Figure 2: Title Deed

The previously disturbed area was abandoned in an un-rehabilitated state with old

equipment, scrap metal, old coal dumps and rock heaps. Five shafts in the adit complex




were left open in an unsafe state and the area was also eroded by water erosion over the

years.

Figure 3 indicates the specific locations of all the activities planned on portion 0 (RE) of

the farm Goedehoop 169 HT for the refurbishment of the Kwasa Colliery.

Figure 3: Specific location of planned activities

2.2.1 Adjacent Land Tenure and Use

The adjacent land use consists mainly of agriculture and (to a lesser extent) also coal

mining. Agricultural use is in the form of scattered forestry plantations, crops (maize),

domestic livestock (cattle and sheep) and artificial pastures. Coal mining activities

include:

Protea Colliery (defunct and abandoned), some 12km to the north-east;

Kiepersol Colliery (operational since 2004) adjacent, to the west, and

Savmore Colliery to the North West (defunct).

Parts of the area are inhabited by communities that were relocated from an area south of

the mountain (Mhlangamvula). Other areas are still scarcely inhabited as they are

commercial farming areas. The current land use thus includes:

Residential – subsistence farming;




Commercial agriculture – grazing;

Commercial agriculture – arable;

Commercial plantations (“Blue gum Trees”).

Bulk sampling has been done in the surrounding area as well.

2.2.2 Presence of Servitudes

The following servitudes have been identified on site:

Power lines: overhead, supplied and owned by Eskom.

Access road: Through the portion of the RE of Goedehoop 169 HT (runs from North to

South).




Figure 4: Map showing surrounding farm




2.2.3 Zoning

The site is currently zoned for agriculture.

Objectives of the project

The purpose of the project is to reclaim the remaining reserve at the old Kwasa Colliery.

Mining methods will include underground mining. During the mining operation, the

current pollution footprint will be decreased by the establishment of a pollution control

system to contain the current source of pollution. The un-rehabilitated areas outside the

mining footprint will be rehabilitated as part of the first phase of the project.

Physical Project Description

Kwasa Colliery is a small underground coal mine that was left in an unrehabilitated state.

There are construction activities that have been completed as well as infrastructure left

on site but these would need to be refurbished during the construction phase. There are

also a number of additional construction activities required before sustainable mining can

continue. These are described in detail below.

2.4.1 Completed Activities

The development of the mine up to this point in time have all been done and funded by

Kwasa Mining Services (Pty) Ltd. The following activities had been completed

approximately three years ago but would probably need to be refurbished:

Refurbishment of access road to the mine and shafts;

Installation of Eskom power lines and transformers;

Refurbishment of the underground workings, with


b) conveyor system,



Fencing of the shafts;

Development of access control;

Setting out of a stockpile and loading area;




Photo Plate 1: Open adits

Photo Plate 2: Existing access road

Infrastructure on site

The following infrastructure is currently on site:

Access roads as well as internal roads;

Security berms and palisades;

Old mining equipment;

Abandoned buildings;

Power Lines.

Refer to the photographs below.




Photo Plate 3: Old Mining Equipment

Photo Plate 4: Abandoned Buildings




Photo Plate 5: Old mining equipment and abandoned buildings

Photo Plate 6: Existing security berm




Photo Plate 7: Palisades on the mining area

Photo Plate 8: Power lines

2.4.2 Planned Activities

Construction Phase

The following activities will be carried out during the construction phase:

Refurbishment and reconstruction of the water pollution control system;

Construction of one fresh water storage dam;

Construction of four pollution control dams (PCDs);

Construction of silt traps at each PCD;


Power is available




Preparation of the discard management facility (Co-Disposal Dump site);




New security house at main gate;

Final trenching and berms;

New runoff water catchment areas;

Three freshwater towers and tanks;

Installation of a new conveyor belt in the Alfred seam adit;

Road signs;

Water pumps and piping for PCDs and clean water storage dam;

Security lights at gates.

Five year contractual commitments for the supply and operation of crushing and

screening equipment;

Five year contractual commitments for underground mining services.

The facilities inside the operational area will be fenced such as the PCDs, fresh water dam,

washing plant area, co disposal dump site and stockpile areas.

Operational Phase

Activities to be conducted during the operational phase of the mine are:

Underground board and pillar mining with continuous miner which will not

involve blasting;

Transportation of run-off mine from the shaft to crushing and screening

area via a conveyor belt system;

ROM Stockpiling;

Crushing and screening of run-off mine;

Stockpiling of the coal product;

Spraying of water on access roads to suppress dust;

Transportation of coal product to client via trucks;

Cleaning of silt traps;

Disposal of discard and silt at the Co-Disposal dump site;

Soil stockpiling (hard and softs);

Sewage management;

Solid waste management;

Water management and dirty water handling including recycling water from

PCD 3 to the coal washing plant for process water.




Closure and Post Closure Phase

Activities to be conducted during the closure and post-closure phase of the mine are:

Plugging/sealing of the adits (ventilation, access and exit);

Removal of storage equipment;

Cleaning and re-vegetation of the Co-disposal dump site and product

stockpile area at the plant;

Removal of coal wastes;

Demolition of unwanted (by the post-mining land users) infrastructure such

as offices, change house, pollution control dams, access roads, high wall

etc.;

The pollution control dams will be cleaned before it is filled and re-

vegetated.

Landscaping and re-vegetation of disturbed areas.

Ground and surface water monitoring.

The fresh water dam will be left on site for the community and landowner.

However if the landowner wants it to be rehabilitated it will also be filled and

re-vegetated.

2.4.3 Water Pollution Management Facilities

Storm water will be separated. Clean, unaffected water will be excluded from the area by

diversion berms, and storm water falling directly onto the operational areas and has the

risk of becoming contaminated, will be contained by berms and directed by cut off

trenches through silt traps to one of four pollution control dams. This water is then

recycled and used in the washing plant and for dust suppression. This is done to minimise

the amount of water extracted for the process from underground sources.

Sources of Contaminated Water

The Co-disposal dump site and coal stockpile areas are the biggest sources of

contaminated water during the operational phase of the mine. Incidental water from

precipitation that enters the site is another source of contaminated water, which should

be contained and prevented from entering the clean water system associated with the

mining activities. During the decommissioning phase of the mining operation, seepage

from the backfilled adits will be a source of contaminated water. Due to the nature of the

backfilled material, there is a possibility of acid mine drainage into the adjacent soils and

aquifers.




A graphical representation of the storm water management plan is shown below in

Figure 5. Please refer to Appendix F.1 for the Water Balance Report by GFK Consulting

Engineers.




Figure 5: Graphical representation of the storm water management plan




West Alfrid Adit

Clean water will be separated from the operational area by cut of trenches at the top of

the West Alfrid Adit. Pollution control berms/channels will be constructed around the

operational area to divert the potentially contaminated water falling onto the polluted area

into the adit complex from where it will be pumped to PCD 1 with the underground water.

The water in PCD 1 will be utilised for dust control to maintain PCD 1 at maximum 5%

capacity.

Central Alfrid Adit


the Central Alfrid Adit. Pollution control berms/channels will be constructed around the

central alfrid adit, Plant, Product and ROM Stockpile area (10ha) to divert the potentially

contaminated water falling onto the polluted area into PCD 2. The water falling onto the

Central Alfrid Adit complex will be diverted into the complex and pumped to PCD 2 with

the underground water. The water in PCD 2 will be utilised for dust control to maintain

PCD 2 at maximum 5% capacity.

East Dundas Adit


the East Dundas Adit. Pollution control berms/channels will be constructed around the

East Dundas Adit and soil stockpiles to divert the potentially contaminated water falling

onto the adit area into the complex. The water will then be pumped with the underground

water into PCD 3. The water in PCD 3 will be recycled and used as process water in the

washing plant.

Co-Disposal Site

Clean water will be separated from the Co-Disposal dump site by cut of trenches at the

top of the Co-disposal site. Pollution control channels will be constructed around the Co-

Disposal site to divert the potentially contaminated water from the site into PCD 3.

Product Stockpiles at Entrance

Clean water will be separated from the product stockpile area by the construction of cut

of trenches at the top of the stockpile area. Pollution control berms/channels will be

constructed around the product stockpile area to divert the potentially contaminated

water from the area into PCD 4. The water in PCD 4 will be utilised for dust control to

maintain PCD 4 at maximum 5% capacity.

Road Network

Measures that will be implemented for storm water regarding the roads are the

construction of five low level bridges on the internal road from the west adit to the east




adit. This will ensure safe passage over the streams with minimal damage to the water

resource as well as the riparian habitat. Contaminated storm water falling on the mine

area will be diverted to a pollution control dam, depending on the area on the mine.

2.4.4 Domestic water use and sanitation

The sewerage plant will be designed for 15 500 litre per day (15% safety margin on design

capacity). The water treatment plant will be located at the proposed new dam and will be

a small “package plant” consisting of two sedimentation tanks with flocculent dosing,

pump, two pressurized sand filters and chorine dosing. Liquid chlorine and flocculent will

need be replenished on a monthly basis. No other maintenance other than testing for

clarity and chlorine on a daily basis would be required as the system would be automatic.

A clear water tank of 30 000m³ would be required.

2.4.5 Waste Management

Solid waste management facilities

There will be no industrial waste disposal on the site; such waste will be removed by

specialist contractors.

Domestic Waste disposal sites

All domestic waste which may be generated on site will be collected daily and disposed

of at registered landfill site as required.

Hazardous Industrial Waste

Most of the hazardous waste originates from the operating, maintenance and servicing of

vehicles and equipment. All the hazardous waste will be disposed of in hazardous waste

bins and removed by the waste service provider to a hazardous waste site.

Mine Residue disposal sites

Waste rock generated from the mining activities will be disposed of at the Co-Disposal

dump site on the eastern part of the site. A portion of the discard generated during

mining will be sold. The facility will be lined and surrounded by berms. These measures

are set in place in order to minimise the chances of contamination due to storm water

runoff.

Other Waste

Other waste includes waste tyres and scrap iron. All scrap iron and waste tyres is sold off

to a scrap dealer and paper is disposed with the general waste.




Figure 6: Layout plan of the mining area




Figure 7: Product Stockpile area at the access gate

Mine Plan

In short the purpose of the project is to reclaim the remaining reserve at the old Kwasa

Colliery.

2.5.1 Mineral deposit

The mining layout plan, as depicted in Figure 8 describes the proven reserve as it is planned

to be mined, and Figure 9 below shows the location of the adjacent Kiepersol Colliery

(operational).

2.5.2 Mine products

The mine will produce crushed and screened anthracite and bituminous coal which will be

provided to the local and export metaliferous markets.




Figure 8: Mining Plan




Figure 9: Proposed Kwasa operation adjacent to the Kiepersol Colliery

Proposed Kwasa Colliery Operational Kiepersol Colliery




2.5.3 Estimated Reserve

In estimating the Coal Reserves, the following parameters have been applied:

Proven Reserves are tonnages computed from outcrop, mine workings and boreholes, with

the ability to establish average calculated quality of the coal within the given geological

environment. Normally the estimates would be considered accurate within 10% of the

tonnage-and grade, however, as there is some disturbance and the drilling pattern is

relatively incomplete, a geological loss of 20% is considered appropriate.

Note: The development of the Kiepersol Colliery on the adjacent farm to the west (where

applying various ‘standards’ of reporting demanded by a variety of disciplines, estimates

as - disparate as 4,2-million tones ‘sales’ and 3,0-million tones in situ were published)

serves as an example when accessibility for drilling, and therefore additional sampling

points, is precluded by inaccessible terrain. Drilling will always add to the level of

confidence, no matter how complicated the geology, but with limited access only practical

mining will solve the problem.

Probable Reserves are tonnages established on more widely spaced information and

samples, projected from known conditions, but where additional drilling is required to

confidently assess reserves and quality. A 30% geological loss is considered appropriate

here.

Alfred Seam

The probable Average Coal reserve in Block A (proven) and Block C (probable) totals 2 811

221 tonnes in situ. The Alfred Seam: Average thickness is 1,87m (range 1, 72m-2,74m).

Dundas Seam.

Block A Proven Block – 304 404 tonnes in situ and Probable Block C – 3 056 659 tonnes in

situ. The probable Average Coal reserve in Block A (proven) and Block C (probable) totals

37l 664 tonnes in situ. The Dundas Seam: Average thickness 1,90m.

2.5.4 Mining Methods

The planned mining methods of this proposed mining operation is underground and the

following methods will be used:

Bord-and-pillar method using a coal cutter with minimal drill and blast.




Production Rate

The estimated production rate at this stage is 10 000 – 15 000 tons per months.

Project Life Description

The life of the mine is estimated to be between 3-5 years.

Access to workings

The underground section will be accessed through the old shafts. The old shafts were

stabilised by Kwasa Mining Services for safety reasons. A high wall was created around the

mining areas to contain all the dirty water that might be generated within the mining

boundary. The storm water accumulating in the old adits will be pumped out and used

during the mining process.

Surface subsidence – Mining areas

During operations, surface subsidence may occur at the underground adits in the form of

landslides and or land slumps of soil or rock from the stockpiles and windrows into the

pits. Appropriate management such as geotechnical stability measures and maintaining

buffer zones will prevent or limit these negative effects of the movement of earth material.

Structures and drainage paths that may be affected by surface

subsidence

There are no structures that will be affected by the proposed mining. Rain falling within

the construction site will be reused during the construction phase. This water will be

prohibited from entering the drainage lines and stream and will therefore affect the

quantity of surface water. No subsidence after sealing is expected, however, the mining

area will revert back to grassland and no structures or drainage will be affected if limited

subsidence at the backfilled adit platform does occur.

Mineral processing

There are no processes that will affect the mineralogy of the run-of-mine coal from this

project that are applicable to either the extraction and/or preparation of the coal to comply

with the market requirements, as the coal will be crushed, screened and washed to meet

the metallurgical market requirements.

The beneficiation processes applied to the of the run-of-mine coal (in order to meet the

market requirements) are all proven technology.




Washing and the re-fuelling of the haulage trucks will be undertaken within the bunded

area designated and designed for these purposes.

Mine residue disposal

Mine residue produced from the production of coal can generally be divided into two

distinct types, namely:

Discard: resulting from the separation of a coal product from stone, shale and other

“contaminants”, and the discard generated is typically returned to the open pit or placed in

a discard dump. Generically, the residue is (ideally) placed right at the bottom of the pit

below the groundwater level, in order to minimize the amount of oxygen exposure. Where

there is a market for it the discard will be sold.

Overburden: this is removed from above the coal seam(s) during open cast mining to access

the coal. This is not applicable for this project as only underground mining is planned.

A runoff control drainage system for storm water will be constructed to collect run-off

storm rain water down slope – and to divert clean water upslope of the washing plant and

coal stockpiles. This water would feed into a containment / pollution control dam from

which water for dust suppression will be drawn.

The run-of-mine coal stockpiles will be limited to the washing plant area. This area will be

rehabilitated once mining has ceased. The extent of the stockpiles will be limited as coal

will be produced to satisfy the off-take agreement. The processed water from the crushing

and screening plant will be pumped into PCD 2.

An effective surface water management system would be constructed to protect the

wetlands ecosystems, to ensure that the risk of significant impacts will be acceptable.

These systems may also be used for post closure water treatment until a closure certificate

is issued. This will be designed in detail during the detailed mine planning phase.

In a similar manner to that proposed for the surface water management, the underground

water/decant will be intersected at predetermined point that will be engineered so that all

possible contaminated water from the underground sections will be drained from the

stoops and contained in the pollution control facility that is designed to contain the 1:50

year flood event.




Product Transport

The transportation of the coal will be by road haulage (trucks) via district and provincial

roads. The haul roads within the mining area will facilitate the movement of mine

machinery. The existing internal roads will be used. A road linking the plant area and

mining area will be constructed to facilitate transportation of the raw material. Existing

service roads will be used to access the adits and discard dumps.

The roads will be upgraded with adequate storm water management measures to prevent

erosion and to contain potentially contaminated surface run-off. Regular dust suppression

by water spray onto the dirt road surfaces will take place to minimize dust generation.

The existing Kiepersol Colliery access road will be used to transport the product from the

mining area to the district road R543.




Figure 9: Map reflecting the locality of the study area in relation to the access routes and neighbouring town

Kiepersol Access Road




Project Phases

The three broad components of the project have been listed as follows, and described

below:

Compliance (including application, planning and environmental authorisation);

Operation (including construction and operational phase and includes the

management of waste material); and

Decommissioning (including implementation and monitoring of rehabilitation).

The applicant, Siphiwo Investments plans to operate the Kwasa Colliery over a period of 10

years. Depending on the results for further prospecting, rehabilitation for the underground

sections will commence once the entire proven reserve has been mined. Rehabilitation is

expected to continue for three years thereafter.

The compliance phase would take another 6-9 months before the necessary environmental

authorisation is granted. Pollution control structures and roads will be established within

the first quarter of the construction phase. However Siphiwo Investments and uKhozi are

currently in discussions with DWS and IUMCA to start the construction of the pollution

control system before the granting of the WUL in order to contain the current source of

pollution (unrehabilitated area).

The actual target date for the commencing of the construction phase is September 2015.

The first year of operation will focus on the underground board and pillar mining.

2.6.1 Construction Phase

The construction phase would take three months before the necessary pollution control

measures are functional.

The main activities that will be undertaken during the construction phase will include the

following:

Construction of on-site haulage road between the proposed plant area, adit

complexes and stockpile area.

Construction /upgrading of service road.

Construction of berms and cut-off trenches.

Construction of pollution control dams and silt traps;

Construction of an off-stream storage dam;


Preparation of the discard management facility;

Preparation of ROM and product stockpile areas;







Installation of a new conveyor belt in the Alfred seam belt adit;

Water pumps and piping for PCDs and storage dam;

Erection of offices and other mining related infrastructure (weighbridge etc.).

2.6.2 Operational Phase

The mining operation is planned to run at a constant production rate for the proposed life

of the mine.

Once the Environmental Authorisation and Water Use Licence is issued, operations will

commence immediately. The mining will be undertaken by contractors, which will use

proven technology in terms of:

Underground mining: Bord-and-pillar method using a coal cutter with minimal drill

and blast.

The following additional activities will take place:

Crushing, Screening and washing of coal;

Dust suppression;

Dirty water management; and

2.6.3 Rehabilitation/Decommissioning

The following activities will take place during the rehabilitation phase:

Table 6: Activities during Rehabilitation

Activity Description

Removal of surface infrastructure

(buildings, etc).

Removal of temporary container offices and

chemical toilets.

Sealing of underground workings. Sealing of the underground workings and adit.

Implementation and management of

rehabilitation programme.

Rehabilitation of land for the target post-mining

land use of grazing.

2.6.4 Development Procedure

The public participation process has started and will be ongoing throughout the

environmental authorisation process. All the comments and concerns raised by the IAPs

need to be addressed in the Final EIA/EMP report and Siphiwo need to commit to adhere to

the mitigation measures and commitments made in this report. The IAPs need to be kept

in the loop throughout the proposed mining operation and especially afterwards with the

rehabilitation of the disturbed land.




A legal process has been initiated for the S.11 transfer of ownership of the Mineral Rights

from Kwasa Mining Services to Siphiwo Investments. A legal process is also underway to

buy the farm from the landowner Reinette Boshoff (Please refer to correspondence with her

attorneys in Appendix A.2.1 and Appendix A.6.3).

Once the environmental authorisation is granted for all the listed activities applied for and

a Water Use Licence issued by DWS for all the water uses applied for, Siphiwo will start with

the refurbishment and reconstruction of the water pollution control system. This will take

approximately 3 months. Please note that Siphiwo Investments and uKhozi are currently in

discussions with DWS and IUMCA to start the construction of the pollution control system

before the granting of the WUL in order to contain the current source of pollution from the

unrehabilitated area. If this is agreed to the departments and IAPs will be informed of this

decision.

The other construction activities will occur after the WUL and Environmental authorisation

is granted and will include:

Refurbishment of the underground working workings, with

(a) roof stabilisation,

(b) conveyor system,

(c) ventilation infrastructure,

(d) water management.

Refurbishment of the access roads;



Preparation of the discard management facility (Co-Disposal Dump site).

Please refer to Table 7 below for a summary of the development activities.

Table 7: Summary of Development Activities

No. Development Activities Duration

(months)

Responsible

party

1 Ongoing public participation process ongoing uKhozi

2 Ongoing legal processes: Matswani

2.a S.11 transfer of ownership of the Mineral

Rights

3 to 9 months Matswani

2.b Surface Rights. 3-6 months Matswani

2.c Mining Right completed Siphiwo

2.d EIA authorisations 4 months uKhozi

2.e Water Use Licence 4 months uKhozi




No. Development Activities Duration

(months)

Responsible

party

3 Refurbishment and reconstruction of the

water pollution control system

ASAP. 3 months. Siphiwo

4 Refurbishment of the underground

working workings, with


b) conveyor system,



3 months Siphiwo

5 Refurbishment of the access roads. 3 months Siphiwo

6 Transport to site and erection of a

modular washing plant

3 months after WULA

has been approved

Siphiwo

7 Preparation of the discard management

facility and stockpile areas

3 months Siphiwo

Aspects of Mine Health and Safety

2.7.1 Background

As a requirement of the Department of Mineral Resources towards compiling an integrated

EMP report, a provisional description of Mine Health and Safety aspects has been made to

assist the Department in its holistic approach to mining. This will be finalised in conjunction

with the final mine plan.

2.7.2 Health and Safety: General

Employees will be trained in safety and health and be issued with the necessary protective

clothing and equipment, including:

Hard-hats,

Safety shoes,

Safety goggles,

Gloves, and

Hearing protection.

2.7.3 Traffic

The speed limit on the internal roads will be 40km/h for heavy vehicles and 60km/h for

light vehicles. This will also assist in reducing the generation of the dust.




3 Need and Desirability

Socio Economic

The anthracitic coal produced by the colliery will be used for the local and export

metallurgical market thereby benefiting the whole of the country. The benefits of the

mining to the community largely centre on the Social and Labour Plan. Exporting of the

coal will contribute positively to the South African Economy.

The local socio-economically depressed and geographically marginalised communities

would benefit directly from the refurbishment and recommissioning of the mine. The

impact here would be long term, passed the life of the mine itself. The proposed operation

will be creating 60 new jobs which where possible will be sourced locally. All the staff will

be trained and this will also uplift the community. The activities will provide employment

for locals and support services, as well as empowerment and skills transfer opportunities.

Seen in the light of the current economic environment, having an income has a high effect

on the quality of life of families, creating a positive effect. This can therefore be considered

a significant benefit. The proposed operation will be creating 11 indirect jobs by employing

contractors for security (8), operating of the weighbridge and doing admin (3). The

employment opportunities on the mine will indirectly provide further opportunities for

small scale entrepreneurs to sell and produce other forms of consumables. The local

communities might be able to provide housing for the employees of the mine and make a

profit from the rent.

The proposed area is an abandoned mine, which poses a great safety risk. Should the

mining operations be approved, the area will be fenced off and rehabilitated. This will

increase the safety of the area, as well as provide possibilities for future land use. The

employees of the proposed activities, will be sufficiently trained in order to promote a safe

environment.

To summarize the impact that the mining would have in the local and sending communities

and the surrounding areas in line with the duration of the mining right, include but not

limited to the following:

A number of jobs created;

Small, Medium and Micro-sized Enterprises (SMMEs) development;

Infrastructure development;

Community Development;

Poverty Eradication and;

Rehabilitation of the area.




Biophysical

The local situation will also be directly and positively affected in that the defunct and

abandoned colliery will be rehabilitated after mining seizes. Currently the colliery is

polluting the surrounding environment especially the surface and groundwater resources.

During rainfall events the coal discard lying around on site ends up in the surrounding

streams which flow into the Annysspruit. Farmers have reported loss of livestock after they

drank the water of the streams flowing down gradient of the colliery. If mining goes ahead

proper storm water management measures will be implemented to contain the polluted

storm water runoff. After the source is contained the applicant can start a process to clean

up the streams. This will have a positive impact biophysically and socioeconomically by

reducing the pollution of the surrounding surface water resources and minimizing the risk

that livestock will be lost in the future. The site will be managed and kept in a better

condition and rehabilitated after mining seizes.

Project Market

The coal produced by this mine will mostly be sent to the export market (80% of in situ

tonnage). The remainder (20% of the in situ tonnage) would be used by the local iron and

steel production industries.

Labour Force

The proposed operation will be creating 60 direct jobs which where possible will be

sourced locally. The proposed operation will be creating 11 indirect jobs by employing

contractors for security (8), operating of the weighbridge and doing admin (3).

All the staff will be trained and this will also uplift the community.

The Multiplier Effect

According to multiplier affect there is an average of five persons per household in the Piet

Retief district. Thus, taking into account that the total labour force to be employed at the

mine is 60 persons, the multiplier effect comes to a calculated total of 300 persons

influenced. This means that the lives of a total of 300 people in the region will be directly

influenced by the refurbishment and recommissioning of the Kwasa Colliery.




4 Alternatives

Development Alternatives

There are four main sets of alternatives associated with the recommissioning of this

underground coal mining operation, namely:

a) The underground operation with no additional washing plant and discard dump,

where the Run-of-Mine coal is beneficiated (washed) off site at a remote plant (this

proved to be not feasible over the past three years of operation).

In order to produce a product that is marketable on an economically profitable and

sustainable basis the product must be washed. Dry screening and crushing would be an

alternative but would fail to produce the required product. Thus this alternative will not be

implemented because it is not economically profitable or sustainable for Siphiwo

Investments.

b) The underground operation together with a wash plant and associated discard

dump, in the vicinity of the current operation (preferred).

This is the preferred alternative. The area was left in an un-rehabilitated state with coal

waste lying around on site. During rainfall events this coal waste ends up in the surrounding

surface water resources. If the mining operation continues, storm water management

measures will be implemented in order to contain the polluted storm water falling onto the

mining area. This will mean that the source currently contaminating the surrounding water

resources will be contained.

As mentioned above in order for the mining operation to be sustainable a washing plant

needs to be constructed on site. If this does not happen the chances are good that the

planned mining operation will be cancelled which will mean that the pollution currently

occurring on site, will continue.

The main negative impact of this alternative would be the potential contamination of the

surrounding water resources if the storm water measures are not implemented correctly as

well as a cumulative effect on dust pollution caused by the haulage trucks.

Summary of negative impact for alternative (b)

Magnitude Timing Duration

Probability Level of Significance

Large Future L/T Temporary L/T Possible Moderate




The positive impact will be that the product can be mined on an economically profitable

and sustainable basis which would mean that the mining operation will continue thus

cleaning up the area and containing the source of pollution.

Summary of positive impact for alternative (b)

**Refer to all the identified positive and negative impacts of this alternative in section 6 of

this report.

c) The underground operation together with a wash plant and associated discard

dump, located at the abandoned Protea colliery, some seven kilometres north of

Kwasa.

This alternative would be considered if for some reason the wash plant and associated

discard dump could not be established at the underground operation.

This is not the preferred alternative because it would mean that a 7km road would need to

be upgraded from the underground operation to the abandoned old Protea Colliery. The

negative impacts would be that the ROM would need to be transported approximately 7km

from the underground operation to the washing plant which will increase the cumulative

impact of dust, noise and visual pollution. This will also increase the size of the mine

footprint and risks of contamination while transporting the ROM.

Summary of negative impact for alternative (c)

The main positive impact will be that storm water management measures would be

implemented at the abandoned old Protea Colliery thus containing the pollution of the

surrounding area that is currently occurring.

Summary of positive impact for alternative (c)



Moderate Future S/T Permanent Probable High



Large Future L/T Temporary L/T Probable High






d) No go Option.

Should the mine not proceed:

A source of 5 million tonnes of saleable coal will be lost.

Employment opportunities for 60-75 individuals will not be forthcoming.

The multiplier effect will not be realised; and

The area will remain un-rehabilitated and continue to pollute the surrounding

environment.

The positive impacts would be:

The community will not be disrupted by the mining activities;

No additional traffic on the district roads as well as the access road to Jindal;

There will not be a cumulative impact of dust pollution in the area;

There will be no risk for the landowners and IAPs that the area could be

contaminated further and left in a worse state;

Operational Alternatives

4.2.1 Mining Method

As this is purely an underground mine, the major impact on land use alternatives is from

the adit and infrastructure on site as well as from the impact on the water resources. The

adit site itself is not suitable for any agricultural activity. Mitigation measures can be

implemented in such a way, that the loss of the grazing areas due to the mining activities

is reduced.

The major alternative land use has been compromised due to the mine being left in an un-

rehabilitated state. The area would need to be rehabilitated before it can be used for

agricultural activities such as grazing. This will not be significantly compromised by the

proposed activity.

Underground mining is the most feasible method of mining and the bord-and-pillar

method will be used along with a coal cutter with minimal drill and blast. This technology

will be used to ensure stability of the surface. There will be no secondary mining of the

pillars to ensure that the roof will remain competent.

Large Future L/T Permanent Probable High




4.2.2 Mineral Processing Methods

In order to produce a product that is marketable on an economically profitable and

sustainable basis the product must be washed.

Dry screening and crushing would be an alternative but would fail to produce the required

product.

4.2.3 Transport

Existing Kiepersol Access Road

A 10km tarred access road from the district road to Kiepersol exists. If an agreement can

be reached with Jindal and the IAPs using the road this would be the best option for Siphiwo.

Internal roads would need to be upgraded between the plant area and the various adit

openings. All culverts along the internal roads would need to be upgraded to accommodate

a greater volume of storm water.

An alternative option would be to construct a new road from the district road directly

towards the Kwasa Colliery. This option will not make biophysical or economic sense.

Biophysically it will have significant impacts on the environment especially the wetlands

and streams found north of the Kwasa Colliery. Economically it would be extremely

expensive to construct a new 10km access road. Especially considering that there is an

existing road that can be used.

4.2.4 Sources of Water

Water supply from the old workings as well as contaminated water from the pollution

control dams will be used for dust suppression and make up water for the plant. It is

proposed that a fresh water dam is constructed to use for potable water and possible

make-up water for the plant during the dry winter months. As the water will be stored,

clean runoff will be captured in this dam and prevented from entering the natural

watercourses in the area. This will influence the quantity of runoff entering the streams

located downstream of the site. A pipeline of approximately 2.5 km have to be constructed

from this dam to the washing plant which will disturb the soils and vegetation.

The dam will have a positive impact on the community because it is planned that the water

stored in the dam will also be used by the community for irrigation and stock watering. The

fresh water dam must be constructed with an outlet in order to let water back into the

downstream water resources.




Alternative options are to source water from the Savmore dam or to drill boreholes for

make-up water.

4.2.5 Mine infrastructure sites

The disturbed areas on the RE of Goedehoop 169 HT have been selected as infrastructure

because of the existing de facto change in land use. Minimal infrastructure will be erected

at the adit sites to minimise the impact. Temporary offices will be constructed below the

plant area on an undisturbed surface. All old buildings as used during previous mining

activities (as located at the old central adit) will be removed.

Diesel will be stored in a bunded facility at the plant area.

4.2.6 Mine residue disposal site

The preferred site for the Co-Disposal Dump is shown on the surface layout plan in Figure

6, three candidate sites were considered and the final site as per the plan was selected

based on its suitability:

The other two mine residue deposit sites were found to be less suitable based on:

Distance from the plant area;

The locations were undisturbed land;

Uneven topography.

A detailed Discard management design and operation report has been prepared by GFK

Consulting Engineers during the Integrated Water Management report (refer to Appendix

F.1)

4.2.7 Domestic and Industrial Waste Disposal Sites

As there will be no housing on the premises only the office complex will generate a small

quantity of domestic waste which will be stored in containers. These containers will be

cleaned and the waste removed to a registered waste site of the premises. The details of

this waste site will be forwarded to the DEDET and the DMR once finalised.

Industrial waste such as used oils will be removed from the mining area by registered

contractors. The details of these contractors will be forwarded to the DEDET and the DMR

on appointment.

4.2.8 Housing Sites




No housing sites are being provided. The philosophy is that people can develop their own

homes in Piet Retief or the nearby villages around Dirkiesdorp. This provides more security

for the individuals and enables them to invest in their homes rather than live in mine

houses.

4.2.9 Land Use Option after Rehabilitation

The considered alternative land uses could include:

Extension of the agricultural/residential use over the entire area;

Grazing.

The RE of Goedehoop 169 HT is best suited to artificial grazing which could be sold to a

local entity post closure.




5 Existing Status of the Environment

The baseline information presented below concerns the environment which may be affected

by the mining activities in order to determine protection, remedial measures and

environmental management objectives.

Description of the potentially affected environment

A description is given below of the environment likely to be affected by proposed mining

operations:

Kwasa Colliery is situated on the remaining extent of the farm Goedehoop 169 HT on the

edge of the mountain. The area around the mine is severely transformed from the natural

state in some places, although the natural environment was pristine in others. The

important drivers of the transformation have been agriculture, livestock grazing, and coal

mining. In addition, it is probable that some impacts are associated with the existing mine

(Kiepersol Colliery) to the immediate west of the present site. These impacts will include

pollution and the existence of a sterile block, inhospitable to many species and which will

be a barrier to movements of key fauna including pollinators. There is a non-perennial

stream that flows on the western side of the mining area. In the immediate surroundings

of Kwasa Colliery, there are no public roads, railway lines, residential areas or cemetery or

any other land for public use that may prohibit this mining operation. Access to the colliery

is obtained via existing roads.

The area has a high conservation status, mainly because of high species diversity found in

the grassland biomes. In 1999, seven Natural Heritage Sites and a private nature reserve

had been registered. The two that are of importance to this proposed mine are the

following areas:

Site No. 83: uMhlangamvula (1,600 ha) registered as a result of the presence of

Aloe hlanganpise, Samango monkey, Oribi, Serval, martial eagle Ground hornbill

and Bald ibis.

Site No. 119: Rooikraal (1,170 ha) registered as a result of the presence of Oribi,

Aardwolf and Serval, as well as many species of Podocarpus, Alsophila and

Cussonia plants.

The mountain stream is a sensitive environment, as are the areas of indigenous vegetation

and the wetlands.

The identified land-use objectives after closure include:




Stabilise the affected areas by landscaping and vegetating the areas to afford the land

capability of grazing;

Manage the surface water and groundwater to ensure that the mining activities do not

cause an unacceptable, negative impact on the receiving environment nor on the

affected groundwater aquifer;

Recreate a land capability that will sustain an applied and controlled grazing

programme. The land should be suitably rehabilitated to sustain the planned post

closure use with a stocking rate of one large stock unit per eight hectares per annum.

Establish an area that can be used for the sustainable grazing of domestic animals.

Description of the landscape surrounding the operation

The general region within which the mine site is located is recognised for its wetland

richness and for the extensive biodiversity associated with the wetlands. This diversity,

together with that of the original grasslands and some forest patches has been the basis

for conservation measures such as an inter-provincial grasslands programme and the

establishment of the Important Birding Area. Therefore, the presence of extensive wetland

areas on parts of the mine property is in keeping with its surrounds. However, as is also

typical of the region, a large part of the wetlands have been lost as a result of past human

activities. According to Low and Rebelo (Low & Rebelo 1996) the wider study area forms

part of the North-eastern Mountain Grassland (Piet Retief Sourveld) Biome. This vegetation

type comprises the grasslands of the northern parts of the great escarpment mountains in

Mpumalanga which stretch northwards into the Northern Province, and southwards through

KwaZulu-Natal, reaching the northern parts of Eastern Cape. Altitude ranges from 1,400

to 1,900m above mean sea level (amsl). The abandoned Kwasa Colliery falls inside the

Nkangala Grassland project. A large part of the area surrounding and including Goedehoop

169 HT is also under application to become part of the Wakkerstroom Wetland Grasslands

protection area.

Adjacent to the defunct Kwasa Colliery is the Kiepersol Colliery that has been active since

2004 as well as the abandoned Protea Colliery.

Assessment of the environment likely to be affected and

description of current environmental state of the study area

5.3.1 Climate




Regional climate

The regional climate can be described as falling within the Highveld climatic zone (sub-

humid), with a summer (October to February) to winter (April to August) range of around

19º C with average temperatures in the contrasting seasons, of 26º C and 8º C.

Rainfall

Mkhondo Local Municipality falls within a summer rainfall area, with approximately 85% of

the annual rainfall occurring in the summer months from October till February in the form

of showers and thunderstorms. The average MAP of the Usutu (including Swaziland) is

approximately 850 mm/annum and ranges from 500 mm/annum in the eastern areas to

1 200 mm/annum in higher lying areas within Swaziland, then declining as one moves

further west to between 750 and 850 mm/annum on the eastern escarpment of the

Drakensberg.

5.3.2 Air quality

In the pre-mining environment, there are no major local sources of air pollution. Adjacent

to the site on the south-west of the study area there is an existing coal mining operation

(Kiepersol Colliery Operations) which contributes to air pollution through dust as well as

diesel fumes from the operational trucks and vehicles. In the immediate vicinity, there is

some potential for dust pollution due to traffic on the gravel roads and general agricultural

activity. In the dry season there is the possibility of air pollution during the burning of fire

breaks and uncontrolled veld fires. Smoke from cooking and heating fires from the nearby

settlements also have an impact on the air quality in the area.

5.3.3 Geology

Regional Geology

This coal reserve falls within the Karoo Super Group and is part of the Vryheid Formation

of the Ecca Group. The formation consists of sediments of varying grain sizes from shales

to course sandstones. Intrusive rocks would consist of Karoo dolerite with a series of dykes

and sills.

The succession of the four coal seams from top to bottom (with average seam thickness)

is as follows:

Eland seam (0,7 – 0,9 m),

Alfred seam (1,1 to 2,1 m),

Gus seam (0,5 to 1 m ) and the

Dundas seam (1,5 to 2,5 m).




Although there has been much transgressed activity, there are a number of smaller faults

within the mining area; no major faults traverse the area. A range of anthracitic and lean

to bituminous type coal is found within the reserve.

The uMhlangamvula Mountain is capped by the No 10 dolerite sill which overlies the B5

and B6 dolerite sills. The Zuinguin dolerite body intrudes the area as a dyke. The Ingogo

dolerite dyke also intrudes the area. The B3 intersects the coal seam in the west which has

caused a large section of coal to be burnt.

5.3.4 Topography

The pre-mining, natural topography of the area is a combination of steep slopes and

relatively flat (natural) terraces. The operational area has a modified topography consisting

of a terrace (cut and fill) sloping gradually back into the mountain.

Access to the colliery will be made via the existing properly constructed access road, which

follows the gradient of the mountain.

Figure 10: Elevation profile of the proposed site (North to South)

5.3.5 Land capability

Generic definitions of land capability

The land capability of the areas associated with mining can be classified into five classes,

namely:

Wetland;

Arable;

Grazing;

Wilderness; and

rehabilitated areas.

according to the Chamber of Mines of South Africa Guidelines for Environmental

Protection, Volume 3/1982.




The proportions calculated previously for the area have been used as a point of departure

for the current situation. An area of 5ha has been disturbed for the operational area, which

was used by the previous mining activities. Even taking into account, the more recent

guidelines having been made available by the Department of Water Affairs for the

delineation of wetlands, it is not expected that the percentage of area classified as wetland

would increase, as the water course is outside the operational area. This will not directly

affect the assessment of the impact of mining as the area developed does not include

pristine wetlands.

Description

Based on the description of the soils and topography in the area under application, the land

capability can be described as largely grazing and wilderness, with the area under the

operational, adit complex, potentially (post-mining) falling into the category of

rehabilitated mining land.

Table 8: Pre-mining land capability of the operational adit complex

Class Description (Ha) (%)

Class I Wetland 0

Class II Arable 0

Class III Grazing (prev. 1.5) (prev. 30%)

Class IV Wilderness 0 (prev. 3.5) (prev. 70%)

Class V Rehabilitated

Areas

5 (potentially) after closure: 100

Total 5 100

5.3.6 Land Use

The most significant land uses in the upper Usutu catchment are afforestation and

irrigation. The total area under afforestation in the South African portion of the Usutu

catchment is estimated at 1 930 km2, while the irrigated area is limited to 27km2.

The surface area under application can be divided into the following two categories:

Wilderness used for grazing;

Unrehabilitated mining area.

Coal waste is lying around on the unrehabilitated mining area and has the potential to

pollute the surrounding water resources during rainfall events.

Adjacent to the Kwasa Colliery to the west lies the operational Kiepersol Colliery. The other

adjacent land uses are afforestation and agriculture.




5.3.7 Soils

Description of the type of soil found on the surface of the site

Regionally, a number of soil forms can be found in the area. Predominantly, the soils are

loamy and clayey, and of red and yellow colour. Most of the soils are of a dystrophic and/or

mesotrophic nature.

The dominant soil form in the disturbed area is the Hutton Form which is associated with

the dolerite boulder based scree slope as the pedology of the soil. The soil texture has

high clay content and is rich in iron oxide. The soil is dystrophic as a result of the high

rainfall.

Please note that a specialist soil study is currently underway and the information from

this study will be included in the final EIA/EMPr.

Topsoil depth

The soil within the mining area is generally deep, interspersed with dolerite boulders of

varying sizes.

5.3.8 Vegetation

Plants, trees and grasses growing naturally in the area around the site

A biodiversity study was done by Terratest (Pty) Ltd in January 2016. It was recognised at

the outset that the study could potentially be hampered because, despite being undertaken

in the rainy season, the site surveys had to be done under drought conditions. The

implication of this were as follows:

Plant growth would have been reduced and so the observable diversity would be less

than could be expected.

According to Mucina and Rutherford (2006) the indigenous vegetation types in the area in

which the mine is located are as shown in Table 9 and in Figure 11.




Table 9: Vegetation types on the original Farm Goedehoop 169 HT (Conservation status

from Mucina and Rutherford (2006)

The Mpumalanga Conservation Plan was interrogated to search for conservation priorities.

It was found that the key features listed for the area around the site are the natural

vegetation types and the status accorded to the three types found at the site is indicated

in Table 10. The property in which the mine site is listed as being of “Least Concern” at the

northern end and ranges through “Highly Significant” to “Irreplaceable” in the high-lying

areas at the southern end. This spectrum appears to be in contradiction to the status of

the vegetation types present but is most probably based on the condition of the vegetation

in the various areas.

Table 10: Vegetation types on the original Farm Goedehoop 169 HT. Conservation status from

Mucina and Rutherford (2006).




Figure 11: Dominant vegetation types on the mine property. Source: Mucina and Rutherford (2006)




The Mpumalanga Biodiversity Sector Plan (2014) shows the ecosystems in the area around

the mine site to be “Endangered”.

Figure 12: Mpumalanga Biodiversity Sector Plan (2014) for the area around the mine site.

In 2011 the status of the site was “Vulnerable” but it has been downgraded as a result of

continued development in the area. The factors listed as responsible for the change include

urban development, agricultural expansion and increase in mining activities.

During the field assessment the transitions between the three vegetation types which are

present on the property are clearly apparent although there are clear differences in the

condition of the veld. On the lower, flatter areas much of the natural vegetation has been

displaced by agriculture. In a few places crops are still being cultivated with maize being

predominant. However, over considerable areas the lands have been abandoned and are

now lying fallow and are slowly being grown over by a variety of weeds and pioneer

indigenous species (See Figure 13).




Figure 13: Areas which have been, or still are, under cultivation and timber production


Draft EIA/EMPr for the Refurbishment and Recommissioning of Kwasa Colliery, Piet Retief,

Mpumalanga


The figure shows clearly that the crop lands and the timber plantation are

concentrated in the central and northern portions of the property since the lowest

gradients are in those areas. It is also apparent that in some places the agriculture

has taken place in wetland areas. The largest such area is at the far northern end of

the property where the area involved is considerable. It is not known when the

cultivation was first undertaken but it is likely to have been at least 40 or 50 years

ago. On those parts of the property where the topography is steeper the indigenous

vegetation remains in good condition. Within this area are portions of the

Paulpietersburg Moist Grassland and all of the Wakkerstroom Montane Grassland.

The tables below show some of the indigenous species found on site.

Table 11: Indigenous flowers found on the site

Acalypha spp, Adenathellum osmitoides

Aloe minima Agapanthus spp

Ammocharis coranica Anthericum spp

Anthospermum spp Aristia woodii

Astripomoea spp Berkheya spp

Buddleia salviifolia Commelina spp

Conyza podocephala Cyperus spp

Dianthus spp Eriospermum spp

Gerbera spp Haemanthus spp

Helichrysum spp Hypoxis spp (3 different species)

Indigofera spp Ipomoea spp

Kohautia spp Kyllinga alba

Ledebouria spp Leonotis Leonura

Lobelia spp Maytenus sp

Monopsis spp Moraea spp

Nesaea grandis Pachycarpus spp

Oxalis spp Pelagonium luridum

Pentanisia spp Pseudognphalium luteo album

Rhoicissus spp Satyrium sp

Sebaea sp Scabiosa spp

Sphenostylis angustifolia Waltheria densiflora

Watsonia spp Zantedeschia aethiopica



Mpumalanga


Table 12: Indigenous trees found on the site

Scientific Name Common Name

Leucosidea sericea Ouhout

Cussonia paniculata Cabbage tree or Kiepersol

Rapanea melanophloeos Cape Beach

Myrica pilulifera Broadleaf waxberry

Psychotria capensis Bastard lemonwood

Vaccinium exul Blueberry

Table 13: Grass species found in the site

Scientific Name Common Name

Themeda triandra Rooigras

Tristachya leucothrix Drieblomgras

Hyparrhenia hirta Thatch grass

Setaria nigrirostis Bristle grass

Eragrostis curvula Oulandsgras/weeping love grass

Rhynchelytrum nerviglume Bergblinkgras

Heteropogon contortus Assegaaigras

Melinis repens Natal red top

Aristida junctiformis Ngongoni

Pennisetum clandestinum Kikuyu

Cynodon dactylon Couch grass/ kweekgras

(Please refer to the Terratest Report: Assessment of the Biodiversity and Wetlands in

Appendix F.2 for the list of indigenous species found in the study area). The lower

lying areas do show some signs of being grazed by cattle but the extent of the

grazing has been low and so it is not an issue of concern. Plant species diversity is

high and basal cover is generally good. While there are some Wattle Trees (Acacia

mearnsii) present in places, alien plants are generally not abundant. Soil erosion is

largely restricted to the drainage lines and is not extensive at any site seen other

than in the actual footprint of the mining area. In the higher lying areas, located

generally at or above the level of the mine adits, the vegetation is in pristine or near

pristine condition.



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Photo Plate 1: Paulpietersburg Moist Grassland and Wakkerstroom Montane Grassland near

the western and central mine adits

Photo Plate 2: Woody vegetation along a stream channel (Note the absence of water)

Animals naturally occurring in the area

No detailed faunal survey was undertaken at the time of the site visit but note was

made of any animals seen. The list of species is presented in Appendix II of the

Biodiversity and Wetland Assessment conducted by Terratest. Please refer to

Appendix F.2.

None of the species actually seen is red data listed although the Aaardvark

(Orycteropus afer) is listed under the TOPS Regulations as a “Protected Species” as

defined in Section 56(1) (d) under the National Environmental Management:

Biodiversity Act (Act 10 of 2004. In addition, it is also probable that other listed

species are still present, or at least occasionally present, on the site. Examples of

such species are the Grey Crowned Crane (Balearica regulorum) and the Secretary



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Bird (Sagittarius serpentarius) as well as smaller grassland species such as the

Yellow-breasted Pipit (Anthus chloris) which is listed as “Vulnerable”.

In addition to the terrestrial fauna noted, it had also been intended to survey the

aquatic fauna using the SASS5 procedure for the invertebrates and electrofishing for

fishes. However, because of the dry conditions, with some streams having no flowing

water at all, these surveys could not be undertaken.

Avifauna

In broader terms, a Highveld Grassland habitat once occurred over much of southern

Mpumalanga, but this has now largely been transformed into monocultures by

agriculture and forestry. Where pristine grassland remains, the biodiversity needs to

be retained. The mine site lies within Important Bird Area number SA 020 but is

close to the eastern border. The site is important for its grassland and wetland bird

species and extends through parts of KwaZulu-Natal, Mpumalanga, and the Free

State Provinces. The area around the mine will be of more relevance in relation to

grassland birds although the northern is within a wetland which, although highly

degraded, could still hold a number of red data listed species as listed in Table 14.

Table 14: Red Data listed bird species recorded in the area around the mine.

Mammals

The following species of mammals are common to the broader area.



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Table 15: Common Mammal Species occurring in Mkhondo

3.2.1. Common name 3.2.2. Scientific name

Common (Grey) duiker Sylvicapra grimmia

Steenbok Raphicerus campestris

Rooikat Caracal Caracal

Porcupine Hysrix africaeaustralis

Yellow mongoose Cynictus penicillata

Slender mongoose Galerella sanguinea

Scrub hare Lepus saxatilis

The MTPA has also confirmed the following mammal species as being threatened

species in the broader area:

Table 16: Threatened Mammal Species occurring in Mkhondo

3.2.3. Common name Scientific name

Oribi Ourebia ourebi (Zimmerman 1783)

Aardvark Orycteropus afer (Pallas 1766)

Conservation Areas

The closest formal conservation area is the Paardeplaats Nature Reserve which is

approximately 10 km south west of the mine adits.

5.3.9 Surface Water

The mining area falls in the Usutu Catchment. The mine is in a portion of the

headwaters of the Anysspruit which in turn flows into the Assegaairivier downstream

of Heyeshope Dam.



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Figure 14: Usutu to Mhlatuze WMA



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The Usutu catchment is of strategic importance because water for the cooling of

coal-fired power generation plants, situated in the Vaal and Olifants systems, is

sourced from this catchment, with the Heyshope, Morgenstond, Westoe and Jericho

dams providing the transferable yield for these power stations. These dams are all

situated upstream of Swaziland and the catchment forms part of the Maputo River

Basin which is an international river basin.

Quaternary Catchment information

The study area falls within the farm Goedehoop 169 HT which is in turn is situated

in quaternary sub-catchment W51C; the catchment of the Vegkop River is 161km2.

The Vegkop River is a tributary of the Annysspruit which flows into the Assegaai

(Mkhondo) River, which flows from this drainage region north-eastwards, joining the

Great Usutu River in Swaziland, and flowing into the sea in Mozambique.

Reference is made to the Usutu Mhlatuze Water Management Area: Overview of Water

Resources Report No. P WMA 06/000/00/02/03. Refer to Figure 15 below.

Figure 15: Upper Usutu Catchment

Kwasa Colliery



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The central area of this catchment is quite dissected and has a high erosion potential

due to the intense rainfall events, but in general is utilised reasonably well by

commercial livestock farming and game reserves. Close to the Swaziland border

there are some population concentrations including Piet Retief town, but pollution

remains to be limited, localised and faecal in nature.

The Usutu River drains into Mozambique and thus international quality and quantity

requirements must be met. The catchment of the Vegkop River is 161 km2, and yields

a mean annual runoff of 21, 2 million m3 of water. The quaternary sub-catchment

W51C yields a MAR of 89.4 X 106 m3 p.a. (Conversely: 678km2 x 903mm p.a. x 14.6%

runoff factor).

The site Mean Annual Runoff (MAR) was (conservatively) calculated using estimated

areas. The runoff percentages for the sub-catchment above the adit sites were

described to be MAR = 0,876 m3 p.a. (That is: 6 ha x 903mm p.a. x 14.6% runoff

factor). How big is the surface operational area and the Mean Annual Precipitation

(MAP) i.e., the rainfall. The storm water is diverted around the operational area and

the contaminated run-off water is contained within the operational area in pollution

control dams.

Data has been used from various sources, including:

Usutu Mhlatuze Water Management Area: Internal Strategic Perspective

Report No. P WMA 06/000/00/03/04;

Surface Water Resources of South Africa : WRC Report No 298/6.1/94,

1990,

Shelly Colliery EMPR: Groundwater and Surface Water Quality Sections -

Report compiled by I du Toit and L Marot of Groundwater Consulting

Services cc, dated February 1998;

Water balance report by GFK Consulting Engineers for Kwasa Colliery,

2014;

Field work for geological and groundwater investigations at Goedehoop

section.




Water Management Areas

Kwasa Colliery

Figure 16: Water Management Areas



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Water Courses

Drainage on the mine property is from south to north. The ridge crest behind the

mine adits lies at an elevation of 2100 masl while the lowest areas in the north are

at 1330masl. Because of the altitudinal range, the site is in a catchment area and a

number of small perennial and seasonal first order streams flow off the high lying

ground and then converge into two third order watercourses which flow from the

mine property at its northern end. A short distance from the property they both

merge into a large wetland and then continue as the Anysspruit. Typically, the

watercourses appear to be in pristine or near-pristine condition at their higher

elevations. The channels have a bedrock or boulder substrate and the sides are often

vertically incised as a consequence of natural storm flow erosion. However, the

systems then degrade as they flow downwards. At first the degradation originates

from trampling of the channel banks by livestock which results in erosion of the

banks and deposition of sediment in the stream bed. Thus the channel changes from

a square or rectangular section to a “V” shaped section. The indigenous woody

vegetation which was dominated by species such as Diospiros lyciodes, Dias

cotonifolia, Buddleja salvifolia, Buddlija auriculata, Leucosidea sericea, and Rhus

montana is lost and, in places, alien species such as Acacia mearnsii come to

predominate. This process becomes progressively worse as the lower areas are

approached. The channels widen and in many places the fringing vegetation loses

almost all of the fringing vegetation of sedges and grasses. In a few places where

cattle are excluded the channel recovers its natural shape and the vegetation

persists. These areas are usually alongside old crop fields. The eastern stream has

in its lowest sections had an earth berm built along the crest of the left bank. It is

assumed that this is a measure to confine storm flows to the channel and so to keep

the drained wetland there in a dry condition. Once the watercourses have left the

property, they are soon diverted into drainage canals through wetlands which have

presumably be drained for agricultural purposes.

Water quality was measures at four sites in the vicinity of the mine adits and the

results of the analyses are shown in Table 19 below. NOTE: The stream below the

central adit was dry and so no readings could be taken there.



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Table 17: Water chemistry readings from four streams

The water quality in the upper Usutu catchment is excellent, which is why Eskom

source their water for the cooling of coal-powered power stations from this

catchment. However, there is a huge risk of coal mining activities polluting the

resource and this risk must be carefully managed through the formulation of pro-

active catchment management plans.

During the public participation process some farmers indicated that they have lost

livestock that drank the water of the stream flowing down gradient of the Kwasa

Colliery into the Annysspruit. Currently no water monitoring is taking place at Kwasa

Colliery. It is recommended that a water monitoring program is set in place as soon

as possible in order to establish the baseline water quality of the downstream water

resources.




Figure 17: Layout of the mine property showing the proposed infrastructure in relation to the water courses



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Impacts on the surface water resources

Figure 18: Rivers in close proximity to Kwasa Colliery

Annysspruit

The point of origin of a tributary of the Annysspruit is situated on the southern side

of the mining right area. The origin of the stream is situated at approximately 1828m

amsl which is approximately 360mamsl higher in relation to the centre of the

operational area (Please refer to the elevation profile below). The risk of

contamination is possible as the stream flows in close proximity of the proposed

mining operation. Monitoring of this stream will be done in order to determine if

contamination occurs, which will lead to better and more efficient pollution control

measures.

Vegkop River



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The point of origin of a tributary of the Vegkop River is situated approximately 2.8

km southwest of the mining right area. The origin of the stream is situated at

approximately 1684mamsl which is approximately 200mamsl higher in relation to

the centre of the operational area (Please refer to the elevation profile below). The

risk of contamination is possible but not likely, as the drainage line of the said river

flows parallel to the proposed area approximately 1.8km west of the proposed

mining right area. Monitoring of this stream will be done in order to determine if

contamination occurs, which will lead to better and more efficient pollution control

measures.

Boesmansspruit

The point of origin of a tributary of the Boesmansspruit is situated approximately

4.8 km south east of the mining right area. The origin of the stream is situated at

approximately 1519mamsl which is approximately 35mamsl higher in relation to the

centre of the operational area (Please refer to the elevation profile below). The risk

of contamination is possible but not likely, as the drainage line of the said river flows

parallel to the proposed area approximately 3km east of the proposed mining right

area. Monitoring of this stream will be done in order to determine if contamination

occurs, which will lead to better and more efficient pollution control measures.




Figure 19: The five streams with its 100m buffer zone in relation to the operational areas of the proposed colliery

The blue indicates the extent of the 100m buffer zones from the five streams that could be affected by the proposed

operation.

It must be noted that according to the farmers only the stream on the eastern side of the mining right area is still flowing.

During the site visits to the area this was confirmed.

The red line shows the mining right area.

The circle in the middle shows the extent of the operational area including the washing plant, ROM and product stockpile,

Co-Disposal dump site and PCD 3.

The two smaller circles to the left and right of the operational area shows the extent of the west and east adit respectively

along with the PCDs.

The small black circle at the entrance of the colliery shows the extent of the product stockpile along with its PCD.



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Dams

Four dams were located on the property. Three are situated on wetland areas on

the ridge above the mining areas while the fourth is an off-channel storage facility

that is not on a natural drainage line. The centre points and approximate areas of

the three are shown in Table 20.

Table 18: Centre points and areas of the four dams found on the property

From the table it is apparent that the storage capacity of the dams is small. Two, at

least will not be affected by the mining operations since they are situated high

above the mine adits.

Wetlands

The NFEPA database shows no natural wetlands within 500m of the study area. The

features that are shown in the general area are all dams or ponds and are classified

as “Artificial” (refer to Figure 21). However the landowners have pointed out wetlands

found to the north of the site. These were also noted during a site visit conducted on

the 8th of December 2014 (refer to the photographs below).



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Photo Plate 9: Wetland area at the north end of the property

A wetland delineation study was done by Terratest (Pty) Ltd in January 2016. The

below section is an abstract of the study done by Terratest (refer to Appendix F.2 for

the full report).

It was recognised at the outset that the study could potentially be hampered because,

despite being undertaken in the rainy season, the site surveys had to be done under

drought conditions. The implication of this were as follows:

Wetlands and wetland-related features would be at their most inconspicuous.

To deal with this issue use was made of Google Earth imagery taken at wet

times of the year.

However, once in the field, it was possible to find traces of the wetland vegetation

even if it could not be identified to species level. Soils, although dry and hard in some

places, could be augered at others, and so could be used as a marker. Thus, although

comprehensive biodiversity surveys were not possible, the presence of some

wetlands could be detected. Figure 21 shows the wetlands on the property but it must

be noted that not all were delineated in accordance with the DWAF (2005) Guidelines.

Those indicated as “Extant” were delineated correctly in as far as the very dry survey

conditions would allow. Use was made of a soil auger in places where the ground

was soft (damp) enough and the presence of hygrophilous vegetation could be

detected even if the plants were dry and brown. A wetland delineation will be done



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by Terratest and if it is confirmed that the wetland is within 500m of the planned

product stockpile area at the entrance of the colliery then this stockpile can be moved

further south towards the operational area.

Photo Plate 10: Drainage ditch in Wetland

Photo Plate 11: Extinct wetland. The drainage ditch and a soil berm are visible. The area to

the right has lost its wetland vegetation and was cultivated in the past

The exceptions to this procedure were those wetlands located in the high lying areas

at the south of the property. They were seen and their presence can be confirmed,

but they were delineated from Google imagery. The omission was deliberate as they



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are located on the high ridge well above the uppermost part of the proposed mining

operation and will not be affected by mining activities.

Those wetlands that are indicated as “Extinct” are those that are so severely damaged

that they now offer virtually no wetland ecosystem services to the landscape. They

were delineated on the basis of terrain conditions and on historic Google imagery.

However, because very little or no trace of these systems remains, it is probable that

the areas indicated are not indicative of all systems lost and that there were others

that have not been detected. The losses are primarily as a result of deliberate

drainage and conversion to crop lands. In places the drains and/or soil berms are

still clearly visible and their dendritic pattern leading toward streams is apparent.

Elsewhere, at higher elevations and on steeper terrain, the wetlands have been

damaged by erosion. Because of the characteristics of the sites, the causative agent

is thought to be excessive trampling by cattle or other livestock. The animals would

have been drawn to the wetlands for the greener vegetation available in dry seasons

and also for the water there. The damage done to the vegetation led to establishment

of preferential drainage runnels and, in time, these eroded and expanded to the point

where they became, in effect, drainage ditches which removed the water from the

wetland. This form of wetland loss is probably the most widespread incidental cause

of wetland loss in the grassland areas of South Africa.

It had been intended to model the Present Ecological State (PES) of the wetlands by

means of the WET-Health Model (Macfarlane et al, 2008) but since there is so much

uncertainty about the original extent of the wetlands, the outputs would be grossly

inaccurate and possibly misleading. Therefore, on the basis of expert opinion the

large wetland system at the north end of the property is subjectively considered to

be a PES Category E site in accordance with the criteria defined in Figure 20.

Figure 20: Health categories used for describing the Present Ecological State (PES) of wetlands.

From Macfarlane et al, 2008.




Figure 21: Kwasa Colliery Proximity to Registered Wetlands



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Water Authority

The Department of Water and Sanitation, (Usuthu Catchment) is the commenting

authority for this area.

Resource class and river health

The reserve determination for the W51C quaternary catchment was not available. The

Department of Water Affairs did not respond to uKhozi’s telephone or email requests

for the reserve determination.

Water Uses and Requirements

Water Uses

The use of water for the various listed purposes is one of the water uses regulated

in terms of the NWA. Water uses can take many forms and – especially in the case of

coal-mining and associated activities, there can be a direct impact on the water

resource if the impacts are not effectively mitigated. These uses need to be aligned

with the needs of the ecological Reserve and other downstream users. A central

philosophy is that current and future opportunities should not be unreasonably and

unnecessarily denied to users, and that the implementation of policy should ensure

that disadvantaged and poor people should also be able to avail themselves of

opportunities. The following uses of surface water have been identified:

Domestic - potable,

Aquatic ecosystems,

Mine process water make-up (possible), and

Agricultural - stock-watering.

As per Figure 22 below only a portion of the Usutu to Mhlathuze WMA’s resources

are undeveloped. This area further is one of the higher quantities of water being

used by alien species. The surface water associated with the mining area is mainly

used for stock watering, aquatic eco-systems, and also for human (potable)

requirements.

Water Requirements

As indicated in Figure 22 the most dominant land uses within the Usutu to Mhlathuze

WMA (As per DWA’s Situation Assessment of 2003), is Agriculture and Afforestation.

As indicated in Figure 23 the industry using the greatest amount of water (As per

DWA’s Situation Assessment of 2003), is Transfers out, with Agriculture with the

second most water requirements allocated to irrigation within the Usutu to

Mhlathuze WMA. Very little water is allocated to the mining industry.




Figure 22: Land Uses in the Usutu to Mhlathuze WM



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Figure 23: Sectorial Water Requirements (Usutu to Mhlathuze)



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5.3.10 Groundwater (Aquifer description)

The mining area is mainly located across the mountain area; however the adit

complex is located on a terrace in a lower down the hill-slope. Although these two

different areas are interlinked, they are very different in terms of the aquifer

description. The groundwater will be assessed in detail by GCS during the

Hydrogeological and Geochemical study which is currently underway.

Lower hill-slopes topographical areas

According to a hydrogeological study done by GCS in 2009 for the area directly west

of Kwasa Colliery, the lower hill-slopes topographical areas have two principle

aquifers . These are the following:

A weathered aquifer occurring at a depth from 2 to 15 metres.

A fractured Karoo aquifer occurring at depths below 15 metres.

Mountain topographical areas

As per the above referenced report it is assessed that a perched aquifer system occurs

above the dolerite sills and that more than one unconfined / semi-confined aquifer

system occurs above the regional aquifer system that is associated with the lower

topographical system. Figure 24 below depicts a schematic representation of the

aquifer systems.

Figure 24: Schematic representation of the different aquifer systems (GCS, 2009)

Depth to water table

The water table at the proposed site is estimated to be 15 m beneath the surface. It

should however be noted that is based on the experience of groundwater specialists

in the area and not based on any specific findings.



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Hydro census (Presence of water boreholes and springs)

The mountain area has various fountains and springs. During a field investigation

conducted by GCS it was found that water (which recharges the mountain aquifer

systems) eventually daylights as fountains along exposed contact zones and

depressions within the overburden material.

Groundwater quality

The groundwater quality at Kwasa Colliery is not currently being monitored. It is

recommended that a monitoring program is put in place as soon as possible in order

to establish a groundwater quality database.

Reserve Determination

The following groundwater specific preliminary resource quality objectives are

proposed based on the level of understanding aquifer systems and land-use activities

in the Usutu to Mhlathuze WMA:

Maintain groundwater levels and the groundwater gradients with specific

reference to maintaining the groundwater contribution to base flow.

Implement a groundwater level monitoring programme and specifically

monitor the quantity and quality of groundwater.

Continuously assess the potential impacts of the development activities, and

associated land-use activities, on the quality of the groundwater resources.

Implement a periodic groundwater quality sampling programme prior to and

during development operations.

Groundwater use

The groundwater is mainly used for livestock watering (from fountains and springs)

with a limited use for domestic supply.

Both the shallow groundwater base-flow in the region of the lower topographical hill-

slopes, together with spring water seeping from the higher topographical areas feed

the streams with water. This is considered to be a critical water supply to the local

farms and communities, especially in the dry, winter months.

The mine will recycle and re-use groundwater from the underground workings for

make-up process water, and water from the fresh water dam for potable water, and

possibly also for makeup water during the dry, winter months.

5.3.11 Sensitive Areas



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The abandoned Kwasa Colliery falls inside the Wakkerstroom Wetlands Grassland

proposed exclusion area in terms of Section 49 of the MPRDA (refer to Figure 25

below). A motivation was submitted to the Minister to include 120 farms, of which

Goedehoop 169 HT is one, inside the exclusion area to prevent further prospecting

or mining activities on these farms.

The following primary reason was given to include these farms in the Wakkerstroom

Wet Grassland area:

“The primary basis for the consideration of the WWG under Section 49 of the MPRDA

is the exceptionally high biodiversity value of the area that provide valuable

ecosystem services to the people of South Africa.

The map (found in the document mentioned above) below shows the extent of the

Wakkerstroom Wet Grassland proposed exclusion area as well as the area that is still

under application to become part of exclusion area. From this map it is clear that the

abandoned Kwasa Colliery falls inside the area that is still under application.

The Annysspruit along with other small tributaries flowing in close proximity of the

Kwasa Colliery is also considered sensitive areas and the current pollution that is

occurring, especially during the rainy season, must be stopped through the

establishment of a pollution control system at the mine. These pollution control

structures must be established as soon as possible, preferably before the rainy

season start to avoid further contamination of the water resources downstream.

The wetland north of Kwasa Colliery’s entrance is considered a sensitive area (refer

to Photos 9 and 10 above). According to the landowners there are various different

species of waterfowl (spur winged geese, Egyptian geese, crowned cranes, blue

cranes) relying on this wetland. The product stockpile area at the entrance of the

colliery can be moved further south to decrease the chance of contaminated water

ending up in this wetland during storm events. The construction of the in stream

fresh water storage dam will lead to the reduction of storm water runoff into this

wetland. The fresh water dam must be constructed with an outlet in order to let water

back into the downstream water resources.




Figure 25: The Wakkerstroom Wet Grasslands (WWG) proposed exclusion area (233, 393 ha) extending over 120 farms within the Pixley Ka Seme and Mkhondo Local Municipalities

Goedehoop 169 HT



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5.3.12 Noise

Noise in the area is restricted to routine traffic to and from the surrounding farms

and adjacent mining operations conducted by Kiepersol Colliery. Agricultural

activities such as the cultivation of lands and harvesting of crops along with forestry

activities also contribute a low scale source of noise to the ambient level.

Potential receptors which might be affected by the mining operation are the local

residents of the neighbouring farms and farm workers. The residential areas are not

located in vicinity of the mining activities and they are thus too far removed to be

regarded as a receptor.

5.3.13 Visual

The site is visible from the R543 (Piet Retief – Wakkerstroom) district road, lying some

twelve kilometres to the north of the site. The area already has a mining character

due to the state the environment was left in. The un-rehabilitated Kwasa Colliery and

the Kiepersol Colliery have already altered the visual character of the Mhlangamvula

and Mhlanganpisi Mountains, especially when looking at the mountains from the

north and west. However the size of the disturbed area at the Kwasa Colliery is very

small compared to the disturbed area at Kiepersol Colliery directly to the west. The

access road to the defunct operational area is visible from the Kiepersol road. The

visual aspect of the areas that have not been disturbed by mining can be described

as wilderness with pockets of forestry.

The visual receptors that will mostly be affected are these within a 5 km distance

from the site and include two farmhouses (Mr Trebble and Mr Prigge) as well as

various rural dwellings north of the colliery.

Tourism Context

The broader area (50 km radius from the site) includes two small nature reserves and

the small tourism hub of Wakkerstroom. The Paardeplaats Nature Reserve, situated

approximately 13 km south of the proposed site, is 2000 ha in extent. The Pongola

Bush Nature Reserve (18 km south) is characterised by mixed Yellowwood forest with

high altitude grassland. Both Reserves attract birding and nature enthusiasts and

remain important protected areas for biodiversity. A number of river systems and

dams in the area attract tourism in the form of fishing and birding.

Wakkerstroom, a small town situated 48 km southwest of the proposed site, is a focus

of tourism in the area, and due to the significance of the Wakkerstroom river



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biodiversity area, is one of the key birding sites on the Mpumalanga Birding Route.

The town is also host to a number of festivals, fairs, and workshops throughout the

year.

Tourism in and around Piet Retief is dominated by guesthouse facilities and

conservancies, including private reserve developments in the Ngwempisi and Assegai

River Valley and catchments (Mkhondo IDP, 2015). The Kwamandlangampisi

Mountains and the high grassland escarpment hold high biodiversity and scenic

value, although their true tourism potential has not yet been realised (Mkhondo IDP,

2015).

Existing Piet Retief Context

Piet Retief (eMkhondo) is located on the N2 at the intersection of the R543 (Volksrust-

Swaziland) and R33 (Vryheid-Amsterdam) roads. The surrounding area is dominated

by forestry plantations, from which much of its economy originated. At present it

boasts a well-diversified economy, including components from all sectors, from

manufacturing to personal services, real estate and tourism. It is strategically

situated in respect of rail and road freight transport (Mkhondo IDP, 2015), and is the

main link of both industrial and commercial transport from Gauteng to the

import/export harbour at Richards Bay.

Situated on the outskirts of Piet Retief (eMkhondo) is the town of eThandakukhanya,

which remains largely a dormitory town and is economically dependent on Piet Retief

and the surrounding forestry and rural areas (Mkhondo IDP, 2015).

Existing Surrounding Area Context

Local Area (<5 km from proposed site)

The immediate area surrounding the proposed site (5 km radius) is characterised by

farming and mining activities. The operational Kiepersol Colliery is situated 1.5 km

to the west and the proposed Goedehoop Colliery is situated 1.8km to the east, along

the lower slopes of the Kwamandlangampisi Mountain. Further north (5.3km), the

defunct Protea Colliery is located. The nearest households are situated 2.19km north

east from the proposed site. Further north, east, and northeast scattered clusters of

rural community households can be found located both on community and private

farm land.

Natural springs are located to the north and east of the proposed site, with the

resulting streams servicing the farmhouse to the north east as well as the surrounding

rural community.



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Broader Area (>5 km but <50 km from the proposed site)

The nearest formal urban centres are Dirkiesdorp (18 km west), Piet Retief

(eMkhondo) (27 km northeast), Paulpietersburg (38 km southeast), and

Wakkerstroom (48 km southwest), and the formal rural centre of Driefontein situated

21.2 km northwest of the proposed site. The surrounding 50 km area is

predominantly characterised by agricultural activities, with some mining,

conservation, and industrial activities occurring.

The nearest large dams are Savmore Dam (7.2 km northwest) and Heyshope Dam (14

km northwest), with the Assegai River running 17 km north of the proposed site at

its closest point. The general area is characterised by informal roads, many of which

are not tarred, with the closest main roads being the R543 and R33. The main R543

road is located 10 km to the north of the proposed site, and the R33 road is situated

28 km to the east. The small German community and school of Wittenberg is located

22 km east of the proposed site, and remains the closest large education facility to

the site. Outside of the main formal urban and rural centres, housing is limited to

established farm households and infrastructure, and rural community households

scattered on a combination of private and community lands.

5.3.14 Socio Economic Environment

The area for the proposed mine falls within Ward 7 of the Mkhondo Local Municipality

which forms part of the greater Gert Sibande District Municipality. Figure 26 below

shows the population per ward for the Mkhondo Local Municipality.



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Figure 26: Population per Ward

Demographic and Socio Economic Profile

Based on the figure above the Mkhondo Municipality has an estimated population of

106 452 people. It is estimated that about 54% of this population reside in the rural

parts of the Mkhondo municipality, and about 46% in the urban parts.

Based on the Mkhondo Local Municipality Draft IDP (2011-2016) the 106 457 people

residing in the Mkhondo Municipality represent about 29 927 households at an

average household size of 3, 6. An estimated 36% of the population is in the age

bracket 25-65. The percentage male residents in the municipality decreased slightly

from 2001, while the number of residents with tertiary qualifications (diplomas and

degrees) increased significantly which is positive. The percentage of the population

with no schooling background also reduced drastically since 2001.

Unemployment figures are relatively high at 43%, but it did show a 3% reduction from

2001. The average annual income per individual increased by almost 150% to R1281,

54, but is still very low in national context. The number of households residing in

formal houses increased to about 67% (from 33% in 2001).

Households having access to electricity more than doubled during this period, with

an estimated 69% of all households having access to electricity. Households with

sanitation services below RDP level decreased from 61% to 41% (pit latrines, bucket

latrines and no systems). The number of households with access to piped water inside

the dwelling/yard also increased drastically from 10 795 in 2001 to 20 169 in 2007

which represents about 67% of all households in the area.



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In terms of Gross Geographical Product the two most important employment sectors

are agriculture at 36% and community services at 18%. These sectors are followed by

trade at 13% and manufacturing at 12%. It evidences that the economy is not very

diversified still being highly reliant on the agricultural sector.

The above reinforces the fact that forestry is and will remain an important asset in

the region. There is little down-stream economic activity and much of the raw timber

is exported from the region, which is negative as value-adding opportunities and

increased income for the region are lost. Reliance on the community services sector

is also high, and thus indicative of the social needs provision in the region.

Although the area has a large economically active population (56%), a total of 43% of

the economically active population is unemployed. This indicates that the economy

is unable to accommodate these people, which will either lead to the out migration

of youngsters and/or an increase in domestic poverty.

Transport Network

The N2 is the only national road which traverses the area. It is an important tourist

and freight transport route connecting Gauteng with the KwaZulu Natal north coast

and Richards Bay. Though a national road, the road needs to be upgraded and

maintained, given its important connecting role. Three provincial roads traverse the

area. These include:

R33 from the N17 in the north, through Amsterdam and Piet Retief to Vryheid

in the south;

R65 between Ermelo and Swaziland via Amsterdam.

R543 between Swaziland and Volksrust via Piet Retief.

All these roads are tarred but in fairly poor condition and therefore need to be

upgraded and maintained. The local roads in the area are tarred, gravelled or graded.

All need maintenance, especially in the rainy season. The R543 is the road that will

be used to the Kwasa Colliery.

A freight railway service exists leading from Ermelo in the north to the north coast in

the south via Vryheid.



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Social Infrastructure

There are several primary schools distributed widely throughout the area. These are

not only centred in the urban areas, but generally also cover the rural areas, which is

appropriate given the high percentage of rural based people residing in the Mkhondo

area. There are 15 secondary schools in the municipal area which are located and

scattered across the wards, however as the population grows the need for more

arises. There is also a Mondi Science and Career Guidance centre which assists in

career guidance and youth development for the community of Mkhondo at large.

There is only one hospital in the municipal area which is located in Piet Retief. In

addition, there are 10 other health facilities which are mainly clinics. Of these, three

of the facilities are located in Piet Retief and the other seven are distributed in the

area. There are two Alcohol and Drugs Rehabilitation centres, two old age homes,

two disabled centres and two orphanages. There is a need for more health facilities

in the area to achieve easier access to basic health and family planning services –

especially in the rural areas.

There are also four police stations and three post offices in the Mkhondo municipal

area.

Water Provision

Sixty nine percent of households within the Mkhondo municipal area have direct

access to clean reticulated water either in-house or on site. The remaining 31% of

the population obtains water from streams, rivers or boreholes. According to the IDP

the municipality is in a process of addressing the water provision backlog, together

with the lack in sanitation services, to avoid serious environmental and health risks.

Sanitation Services

Sanitation services differ substantially throughout the area. Most of the newer urban

areas have access to full sanitation reticulation e.g. Piet Retief, eThandakukhanya and

Amsterdam ext 2 and 3, while the older urban areas still rely on septic tanks. A large

percentage of the population (49%) (urban and rural) in the municipal area still rely

on pit latrines, or chemical toilets, while 21% have no access to sanitation in their

households. The latter figures indicate possible environmental pollution problems

and increased health risks. Sanitation services need to be upgraded in 13 wards

excluding ward 7 and ward 12.



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Electricity

Slightly over 50% of households in urban areas obtain electricity from the MLM; the

remainder of the urban areas rely on candles for lighting and paraffin, gas and other

sources for energy. ESKOM supplies electricity to the rural areas.

The municipal areas with the largest concentrations of service backlogs are recorded

around Piet Retief / eThandakukhanya, Amsterdam / kwaThandeka, and Driefontein

/ kwaNgema.

5.3.15 Heritage

Since the area under application was found disturbed by previous mining activities

and left un-rehabilitated, there are no historical features, structures or artefacts of

significant historical importance that could remain within the surface operational

area. It should however be noted that no heritage or social assessment had been

conducted and therefore no definite description regarding the historical elements can

be described. A first phase heritage assessment is currently being conducted by

eThembeni Cultural Heritage and the information from this study will be included in

the final EIA/EMPr.

No social assessment had been completed for the area and the current state of the

cultural resources cannot be described.

Specific environmental features occurring on site which

may require protection, remediation, management or

avoidance

The proposed operational area has no sensitive environmental features remaining,

that could require protection or avoidance since the area had previously been

disturbed by mining activities. However during heavy rainfall events the coal waste

lying around on site flows into the downstream water resources. A detailed Storm

Water Management Plan needs to be designed in order to contain the source of

pollution. Once this source is contained programs can be set in place to rehabilitate

the contaminated water resources downstream of the mine.

The following specific areas in close proximity to the colliery requires protection,

remediation, management and/or avoidance:



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The Wakkerstroom Wet Grassland proposed exclusion area. This area must be

avoided at all cost.

The Annysspruit along with other small tributaries flowing in close proximity of the

Kwasa Colliery. These areas must be managed but separating the clean water from

the dirty water through the construction of berms and trenches. The dirty water must

be contained in Pollution Control Dams and the clean water allowed to enter the

downstream streams/rivers. These pollution control structures must be established

as soon as possible, preferably before the rainy season start to avoid further

contamination of the water resources downstream.

The wetland north of Kwasa Colliery’s entrance. In order to protect this area the

proposed product stockpile area at the entrance of the colliery can be moved further

south to decrease the chance of contaminated water ending up in this wetland during

storm events. The following management measures will also apply:

Maintain the 0.8 m freeboard at the pollution control dam;

Regular inspection of the PCDs and silt traps;

Line the PCD with appropriate lining (HDPA (2mm) and clay on top).

The construction of the in stream fresh water storage dam will lead to the reduction

of storm water runoff into this wetland. This could cause the wetland to become dry.

This must be managed by constructing the fresh water dam with an outlet in order

to let water back into the downstream water resources once it is filled to capacity.

A description is given below of the environment likely to be affected by proposed

mining operations:

The mountain stream is a sensitive environment, as are the areas of indigenous

vegetation and the wetlands.



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6 Environmental Impact Assessment

In order to conduct this assessment, the activities need to be described. Please

refer to Section 2.4 of this report for the physical project description.

Mine Risk Assessment

Table 19: Primary hazard class type if mineral mined

Mineral Ore

Size:

Large if

> than

(tpm)

Primary Hazard Class

Large Mine Small Mine

Mine

and

Mine

Waste

Mine,

Mine

Waste,

Plant &

plant

Waste

Mine &

Mine

Waste

Mine,

Mine

Waste,

Plant &

plant

Waste

Prospecting (All

Minerals) C C C C

Antimony 1000 A A C C

Asbestos 0 A A A A

Base metals (Copper,

Cadmium, Cobalt, Iron

ore, Molybdenum,

Nickel, Tin, Vanadium)

Sulphide 10 000 A A C A

Oxide 10 000 C A C A

Coal 0 A A A A

Chrome 10 000 C A C C

Diamonds & Precious

stones 10 000 C B C C

Gold, Silver, Uranium 10 000 A A A A

Phosphate 10 000 C B C C

Platinum 10 000 C B C B

Magnesium 10 000 C B C C

Manganese 10 000 C B C C

Mineral sands

(Ilmenite, Titanium,

Rutile, Zircon & Lead)

10 000 C B C C

Zinc & Lead 10 000 C A C A



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Industrial Minerals

(Andalusite, Barite,

Bauxite, Cryolite,

Fluorspar)

10 000 C C C C

Kwasa Colliery is classified as a Category A mine. Please refer to Table 22 for

classification of mines.

Table 20: Classification of Mines

CATEGORY A CATEGORY B CATEGORY C

Any gold or coal mine;

Any mine with an

extraction metallurgical

process, including heap

leaching; or

Any mine where

sulphate producing or

acid generating

material occurs in the

mineral deposit

Any mine where

significant impacts may

occur on water quality

or quantity of affected

water;

All other mines not

covered by A or B.

The Definition of Significance in the context of this EIA

Judgement on the significance of an impact has been influenced by both the context

and intensity of the impact. The nature, cause and effect are also described.

The level of significance has been determined for the EIA below (section 6.3), as the

combined result of a number of several factors, four of which are summarised in a

table describing each criterion on an individual basis. A fifth criterion namely “risk”

has been included in the description of groundwater impact assessment. An example

of such a summary table is given below:

Table 21: Example of Natural Vegetation (Summarised Impact)

Context Intensity Implication

Magnitude/Extent Timing Duration Probability Risk Level of

Significance

Small Present Temporary Definite Low Low

The first three, namely magnitude, timing and duration describe the context of the



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impact, while the intensity summarises probability and risk of the impact. These

parameters have been expanded below in order to expand the definition, meaning

and objectivity of the term “significance of an impact”. (Please note that the “Risk”

referred to above with regard to intensity is only used in the groundwater sections).

6.2.1 Context

Context comprises both spatial and temporal dimensions.

6.2.2 Spatial

Implies magnitude, extent and/or size. How big is the impact?

Impacts on the environment have been described according to their relative

magnitude (or size or extent). For example, topsoil may be totally affected but in a

localised, contained area by a construction or excavation, which is a relatively small

fraction of the greater area. In contrast, sheet and/or donga erosion over a more

general area may not have totally removed all the topsoil (yet), but the scale of

significance of the effect is relatively more severe.

6.2.3 Temporal

Implies timing and duration. When will it happen, and how long will it last?

Timing

Timing indicates when the effect will happen (manifest itself) namely:

Past (already happened)

Present and/or

Future (on-going).

Duration

Duration describes how long an impact will last on a project specific basis and

includes five levels namely:

Permanent: > 5 years after closure of the operation

Temporary, Long term: 5-10 years (duration of the project)

Temporary, Medium term: 2 - 5 years

Temporary, Short term: < 2 years

Reversible: If an impact is reversible, the predicted time frame becomes



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important.

6.2.4 Intensity

Intensity indicates the severity of an impact. It is assessed on the basis of certainty

(probability), special knowledge and/or perceptions of the Stakeholders.

6.2.5 Certainty

Certainty (probability) of occurrence or fact has been assigned five levels or

categories, namely:

Already happened: 100%

Definite: >90% of occurrence or fact

Probable: >70% of occurrence or fact

Possible: >40% of occurrence or fact, and

Unlikely: used also for the groundwater assessment to indicate that it is

not anticipated (through scientific methods) to occur,

Unsure: <=40% of occurrence or fact.

6.2.6 Special knowledge

Special knowledge recognises local, traditional knowledge of the environment being

assessed, and/or experience of local people and/or interested parties.

6.2.7 Perceptions

The perceptions, priorities, concerns and/or needs framework of the interested and

affected parties (IAP’s) and the relevant Authorities.

6.2.8 Levels of Significance

Five resultant levels of significance have been described on the basis of the

magnitude, timing, duration and probability of an aspect, namely:

“very low”,

“low”,

“moderate”,

“high”, and

“very high”.

This has been summarised below in Table 25: The Significance Rating Scale.



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6.2.9 Implications of the Significance Rating Scale

Various implications of the significance scale have been summarised below in Table

25: Implications of the significance rating scale. The scale is described as five levels

along a continuum. The order is described relative to within the bounds of impacts

which could occur. The significance rating scale could be replaced by one of the

following categories where relevant, namely:

“No effect” implies that there is not even the lowest order (very low /

negligible) impact on either the key issue or a component thereof.

“Can’t know” indicates that the impact assessor believes that, even with

additional information, an assessment is not possible, and finally

“Don’t know” accommodates the situation where the assessor cannot, or is

unwilling to make an assessment.

6.2.10 Summary of the Significance Rating Matrix

The various criteria that need to be considered when assessing the significance of

the aspect and its impact have been summarised below in Table 24. Please note: In

Table 25 (Implications of the Significance Rating Scale) the rating scale is relative to

within the bounds of impacts which would occur.

Table 22: The Significance Rating Scale

Magnitude Timing Duration Intensity Level of

significance Probability Risk

How big is it?

(Relative to what?)

When will it

happen?

How long will it

last?

Severity, certainty of

happening or fact /

perception

How serious is

it?

+’ve / –‘ve

Actual/Potenti

al

Negligible (to the

project area) Past Reversible (? Yr.)

Unlikely:

< = 40%

not

predicted to

occur

Very low Very low

Small (limited to

part of the project

area)

Present Temporary: S/T

<2 years.

Possible:

>40% Low Low

Moderate (limited to

the project area)

Future: S/T

(<6

months)

Temporary: M/T

2 – 5 years

Probable:

>70% Moderate Moderate



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Magnitude Timing Duration Intensity Level of

significance Probability Risk

Large (extends

beyond the project

area: contained)

Future: M/T

6 months –

5 years

Temporary: L/T

5-10 years.

Project duration

Definite:

>90% High

High Already

happened

100%

High

Extensive (extends

beyond the project

area: un-contained)

Future: L/T

(>5 years)

Permanent: >5

yr. after mine

closure

Unsure High Very high

Table 23: Implications of the Significance Rating Scale

Level Order Impact

Negative (Alternatives) Positive (Alternatives)

Very low Negligible Virtually unnecessary; easy,

cheap, simple

Generally better than means of

achieving the benefit.

Low Little real effect Easily achieved and / or little

required

Easier, cheaper, more effective

and / or less timeous.

Moderate Not substantial,

but real

Feasible and fairly easily

possible Equal in time, cost and effort.

High Substantial Feasible, difficult, expensive,

or time consuming

Feasible, difficult, expensive

and / or time consuming.

Very high Highest Not possible Nothing practicable

The main aspects that will have an impact on the environment have been categorised

below in Table 26. A description of each aspect is given along with the specific

activities, phase of the operation in which it will occur, and the duration. The specific

listed activities in terms of NEMA (GG No. R544 or GG No.R543) that are triggered by

each aspect is also indicated below. The impacts of these activities on the

environment were assessed in section 6.3 for the construction, operation and

decommissioning phases of the proposed mine.




Table 24: Categorization of the main activities in terms of the aspects of the operation

Aspect Listed Activity in terms

of NEMA

Activities Phases of

operation

Timeframe

Underground

mining

GG No. R543 Activity nr 5

GG No. R543 Activity nr

20.

Board and pillar mining with

continuous miner (no blasting will

be done);

Dewatering of the aquifer and

groundwater recharge in mine

workings;

Construction,

Operational,

5 years




Transport GG No. R543 Activity nr 6;

GG No. R543 Activity nr 5;


39.

Upgrading and construction of the

internal road network;

Expansion of five low level

crossings;

Transportation of coal will be

done via a conveyor belt from the

shaft to the washing plant;

After crushing and screening,

product will be transported to the

stockpile area;

Product will be loaded onto trucks

with front-end loaders and

transported via road to the

market(s).

No workers or contractors will be

staying on the mine; these

labourers will be transported daily

to and from the site.

All equipment will be brought

onto and again taken off the mine

via the existing access road

network.

It is not expected that roads will

be constructed to access the

operations. The existing road and

track network will be utilised as

far as possible.

Construction,

Operational

Daily for 5 years





of NEMA


operation

Timeframe

Washing of

coal



23;


11.

Establishment of the coal washing

plant along with associated

infrastructure;

Coal washing;

Recycling of process water from

PCD 3;

Disposal of waste water in the

PCDs;

Disposal of discard at the Co-

Disposal Dump site.

Construction,

Operational.

5 years

Stockpiling and

Loading

GG No. R543 Activity nr 5.


15.

Product stockpiling in two areas –

at the plant and at the entrance;

ROM stockpiling at the washing

plant.

Operational 5 years.




Water

Management



12;


18;


Construction of four pollution

control dams;

Construction of one fresh water

dam;

Construction of final trenching

and berms;

Establish new runoff water

catchment areas;

Installation of water pumps and

piping for PCD 3 and the fresh

water dam;

Storing of waste water in PCD 1, 2,

and 4.

Recycling transformed water from

PCD 3 to use as process water in

the washing plant.

Taking water from the freshwater

dam to use as process water in the

washing plant and for dust

suppression during dry winter

months.

Spraying of water on access roads,

stockpiles and the Co-Disposal

Dump Site to suppress dust.

Underground water will be

abstracted from the adits and

pumped into the pollution control

dams.

Construction,

Operational

5 years





of NEMA


operation

Timeframe

Fuel Storage GG No. R544 Activity nr

12.

Storing diesel on site in containers

that can hold more than 80m3

combined but less than 500m3.

Operational. 5 years

Dust

suppression


Water will be obtained from PCD

1, PCD 2, PCD 4 and the fresh

water dam via water carts and

sprayed on the roads and

operational areas for dust

suppression;

Construction,

Operational,

Decommissioning

6 years





of NEMA


operation

Timeframe

Waste

management


15;


Preparation of the Co-Disposal

Dump Site;

Discard will be disposed in the

Co-Disposal Dump site from

where it will be sold or disposed

of at a registered site.

Waste water will be disposed of in

PCD 1, PCD 2 and PCD 4.

A septic tank system will be

installed on site;

Sewage from mine workers will be

contained in the septic tank

system.

There will be no industrial waste

disposal on the site; such waste

will be removed by specialist

contractors.

Construction,

Operational,

Decommissioning

and Closure

6-7 years.

Plugging and

sealing of

shafts.

N/A Plugging and sealing of three

shaft i.e. ventilation, access and

exit shaft).

Decommissioning 3 months





of NEMA


operation

Timeframe

Removal of

infrastructure

N/A All infrastructure such as the

washing plant, offices, change

houses, pollution control dams,

access roads etc. will be

demolished and removed from the

site.

Decommissioning 3 months

Re-vegetation N/A Once all infrastructures have been

removed from the site, disturbed

areas will be re-vegetated in an

attempt to re-instate the land use

and land capability to its pre-

mining state.

Closure 2 months




Environmental Impact Assessment

6.3.1 Construction Phase

Geology

Impact

The geology will be disturbed by drilling and blasting and the excavation of the new adits.

The material excavated will either be used in the construction of the terraces or (the

remainder) stockpiled for later use during decommissioning to refill the adit. The

disturbance will be limited to a small part of the project area, it will be a permanent

disturbance that will definitely happen.

The refurbishment and operation of Kwasa Colliery as well as the multiple mining operations

in the area will have a cumulative impact on the geology of the area. Underground mining

will have a definite long term impact, as the geology cannot be restored, on the local and

regional geology of the area.

Summary of impacts on the geology

Topography

The topography will be altered by the excavation and terracing of the adits, the topsoil and

rock stockpiles and the construction of the plant complex, discard facility and associated

pollution control facilities. The disturbance will be limited to a relatively small part of the

project area, it is reversible in the long term (>7 years) as the post mining topography will

be landscaped to emulate the pre-mining topography and it will definitely happen.

The topography of the site will be affected by the planned activities which will require the

possible opening of an additional adit(s). The Alfred and Dundas seams are planned to be

mined using conventional underground board and pillar mining methods and it is therefore

not expected to have an impact on the topography during the construction phase. The

opening of any adit will however have an impact on the topography which is a steep sloped

to gentle sloped landscape. Construction activities will involve the levelling of an area to

accommodate the adit.

Various clean water diversion berms and a high wall will be created around the mining area

to contain all dirty water that might be generated within the mining boundary. These berms

as well as trenches will divert clean water away from the mining area into the surrounding

streams. Channels will also be created to divert the dirty water into the pollution control



Small Future S/T Permanent Definite Moderate




dams. These berms and dams will be constructed of in-situ material and will be limited to

the immediate vicinity of the infrastructure areas, and will have a small but significant effect

on the topography during the construction phase. The impacts will be limited to the site,

with a definite impact for the short term. The intensity and significance will both be low.

Multiple mining operations in the area exists thus there will be a cumulative impact on the

topography of the area in the long term as the tailings facilities are permanent features

affecting the relief of the area.

Summary of impact on the topography

Soils

Impact

The planned additional mining activities as mentioned above will affect soil in the area as an

additional adit and related structures will have to be constructed. The construction of the

four PCDs, the fresh water storage dam, new roads and the Co-Disposal Dump site will have

a significant impact on the soils because these structures will be constructed on undisturbed

surfaces.

The soil in the areas to be disturbed that is suitable for use as a growth medium will be

excavated (pre-stripped) and stockpiled for use during rehabilitation (decommissioning

phase). The pre-stripping and stockpiling of the soil will result in both physical and chemical

changes in the soil due to the disturbance, increased aeration and absence of vegetative

cover. This action on the soil will result in a breakdown of the macro- and micro-soil

structure, especially when excessively wet and with duplicate handling. As only the topsoil

and subsoil will be stockpiled, the mixing of the soil from the lower horizons with the bed

rock would alter the characteristics of the conglomerate as far as chemistry and water

retention capacity is concerned. The stockpiled topsoil and subsoil will be exposed to

contamination (such as coal dust, oils lubricants etc.) and erosion agents such as water and

wind during the construction phase.

It must be taken into account that the area was left in an unrehabilitated state and currently

erosion around the access road as well as in the mining area is a big concern for the local

farmers.

During construction there is the probability of sheet erosion occurring on the areas cleared

of vegetation. The extent of the cleared area is however relatively small and will only involve

portions of the mining area. As these sites will be actively managed (or be covered by



Small Future S/T Temporary L/T Definite Low




temporary structures) the duration will be long term. The probability of gully erosion will

be limited to the concentrated flow of collected water points or concentrated flow points

(such as culverts) around the planned activities. However proper berm construction and

erosion control measures will ensure that the intensity will be greatly reduced.

Summary of impact on the soils

Land Capability

Land capability will be compromised in the vicinity of the operational areas that are planned

to be pre-stripped of topsoil and growth medium material (for later re-use). The disturbance

will be limited to a relatively small part of the project area.

Where the land capability is grazing or wilderness, the post mining capability will not be

compromised and the impact is reversible in the long term (> 7 years) and will definitely

happen. The land capability of the mining area will be compromised during the construction

phase of the planned activities. This is mainly due to the intense impact that the construction

activities will have on the soil and vegetation of the site.

It has however a low level of significance mainly due to damage caused by previous mining

activities and the un-rehabilitated state that the land was found in.

Mining activities in the area will definitely have a cumulative impact as mining activities will

reduce the original land capability in the area to a homogenous area defined by mining.

Summary of impact of on the land capability

Land Use

The current land use of the defunct operational area will remain mining, while the area of

the new adit complex, pollution control dams, co-disposal dump site, fresh water dam etc.

would change from agriculture (grazing) to mining. The disturbance will be limited to a very

small portion of the mining right area (less than fifty hectares), it is reversible in the long

term (>7years) and will definitely happen.



Small Future S/T Temporary L/T Definite Moderate







The underground mining activities in the area will have a low cumulative impact in the

medium term as the surface infrastructure is limited in extent.

Summary of impact on the land use

Vegetation

Impact

The terrestrial vegetation at the site consists of three types which are as follows:

Eastern Highveld Grassland;

Paulpietersburg Moist Grassland;

Wakkerstroom Montane Grassland.

The first two of these are considered to be either “Endangered” or “Vulnerable” and so are of

conservation concern. In addition, because of regional landscape transformation, the

vegetation in the mine area is considered to be “Irreplaceable”. At present the vegetation in

the intermediate (> 1370 masl) and higher lying areas is in good to pristine condition and

alien weeds are not common. However, the vegetation in the lower-lying and flatter areas

has been substantially transformed by past agricultural activities.

The construction activities will lead to considerable loss of indigenous vegetation on the

property. The losses will come about through development of infrastructure, and also

through general contamination of the area. Natural ecological processes will be disrupted

and there is a strong probability that alien weed species such as Wattle (Acacia mearnsii) will

become more prolific. These impacts will be most apparent at elevations below that of the

mine adits while the higher lying areas will be relatively unaffected.

Summary of impact on the vegetation

Animal Life

The terrestrial fauna at the site is already very severely depleted with many of the original

species, especially the larger mammals, now being locally extinct. However, with the further

degradation of the area as a result of the mine development, further losses will take place.






Large Future S/T Permanent L/T Definite High




Affected groups will include the mammals, birds, reptiles, amphibians, and a wide variety of

invertebrate groups with the insects being the most obvious. Several species of conservation

have already been lost from the area as a result of human activities. None were seen at the

time of the site visit.

The disturbance and consequent habitat destruction will be limited to a relatively small part

of the project area: it is estimated that the zone of influence would be temporary in the long

term and will happen. The associated loss of habitat, disturbance in the area in terms of

noise, dust and water pollution associated with mining activities will possibly have a negative

cumulative impact on the fauna in the area in the long term.

Summary of impact on the animal life

Surface Water

Potential Impact: Contamination of surface water through storm water runoff

Rain falling onto the disturbed area is currently polluting the surrounding surface water

resources.

Once construction starts and storm water measures are implemented this will help contain

the source of pollution which will have a positive impact on the surrounding surface water

resources. Spillage from chemical toilets, oil spills and construction dumping may be picked

up by runoff and will contaminate the downstream watercourses.

Increased sediment movement off the construction sites will add to the cumulative impact

of increased sediment loads in the valley bottom wetlands and streams down gradient of the

site.

Summary of impact on the surface water quality

Potential Impact: There will be temporary decrease in surface water runoff as the



Moderate Future S/T Permanent L/T Definite Moderate



Large Future S/T Temporary S/T Possible Moderate




catchments will be closed off by construction activities.

The proposed mining activities will require the construction of a new adit complex, pollution

control dams, co-disposal dump site, stockpile area and a fresh water dam. Surface water

will be directed around these areas through various storm water measures. However rain

falling within the construction site will be contained in the PCDs during the construction

phase. This water will be prohibited from entering the drainage lines and stream and will

therefore affect the quantity of surface water runoff. Should storm water measures not be

implemented, surface water will be polluted by construction activities and the impact on the

surface water would have a greater significance.

Multiple mining operations in the area will probably have a moderate cumulative impact on

the catchment yield.

Summary of impact on the surface water runoff

Potential Impact: Disturbance of the bed and banks of the water courses running

through the mining site.

The expansion/upgrade of five low level crossings will have a potential impact on the riparian

habitat of the stream. Although the area will be rehabilitated, the riparian habitat (vegetation

and microenvironment) will definitely be disturbed. The bed/bank of these streams will be

altered which might lead to a potential decline in the quality of the water. The clearance of

vegetation around the site can pose as a potential risk for erosion, however it will be of low

significance as the disturbance would only be around the expansion site.

Summary of impact on the riparian habitat

Groundwater

Potential Impact: Contamination of groundwater through infiltration

The groundwater of the surrounding area is currently being polluted by the seepage of rain

water from the disturbed site into the underlying aquifer.

Spillage from chemical toilets, oil spills and construction dumping may infiltrate the



Large Future S/T Temporary L/T Probable Moderate



Small Future S/T Temporary S/T Definite Moderate




groundwater system and contaminate the groundwater resources. Dirty storm water

collecting in the Pollution Control Dams (PCD) during the construction phase has the

potential to leach into the groundwater.


the groundwater quality.

Summary of the impact on the groundwater quality

Potential Impact: Decrease in groundwater level through the opening of

additional adits

The opening of additional adits may have an impact on the groundwater as these adits,

depending on their location and in relations to the groundwater table and impermeable rock

layers. Once the precise location of the adits has been determined, one will be able to assess

whether the construction phase will have a significant impact on the groundwater level. The

existing adits would already have affected the groundwater.


the groundwater availability.

Summary of the impact on groundwater level

Air Quality

During the construction phase of the planned activities (the construction of the new adit

complex, washing plant area, stockpile areas, Co-Disposal Dump site, PCDs, fresh water

dam and associated roads), dust will mainly be produced by site establishment operations,

including stripping of topsoil and grading of access roads. The carbon-dioxide emissions

associated with the diesel machines are of such a small quantity that the impact thereof on

the air quality is considered to be of a low significance. Dust suppression by water tanker

will be employed to mitigate the release of dust which will lower the significance rating of

the impact.


Probability Risk Level of Significance

Large Present Temporary L/T Probable High Moderate



Large Future S/T Temporary L/T Possible Moderate Moderate




Construction activities in the area associated with development and mining activities will

probably have a cumulative impact on the air quality of the area if mitigation measures are

not implemented.

Summary of the impact on air quality


The area is a brownfields sites thus no sensitive landscapes will directly be affected by

construction activities. However, should the groundwater be affected, there is a significant

probability that springs and fountains which feed various wetlands, may be negatively

affected. It is therefore recommended that an assessment of possible impact on sensitive

landscapes be conducted prior to any such activities be conducted.

The wetlands on the mining property are already largely degraded or lost and none are

NFEPA listed. However, some of the mining activities will have the potential to impact further

on the systems

The construction of the pollution control system will have a positive impact on the surface

water resources quality down gradient of the site by containing the current source of

pollution but it will have a negative impact on the quantity of surface water runoff into the

downstream wetland.

During the establishment of the fresh water storage dam the bed and banks of a tributary

flowing into the Annysspruit will be altered.

Summary of the impact on sensitive landscapes

Noise

The main cause of an increase in the ambient noise level is the haulage trucks and other

plant equipment associated with the construction of additional adits, stockpile areas and

water management structures such as the pollution control dams and the fresh water dam

required for the planned activities. The reverse sirens of the construction vehicles and

general diesel engine running noise will add to the industrial noise of the site, which will be

in stark contrast to the natural noise character of the site. The noise will however be

mitigated by the natural topography of the site and high wall created on the site. The



Large Future S/T Temporary S/T Probable Low



Large Future S/T Permanent L/T Definite High




mountain will act as a noise buffer to the adjacent landowners on the southern and south-

eastern side of the mountain. The construction noise will extend from the site boundaries

and will definitely contribute to the existing noise levels.

Construction activities in the area associated with development and mining activities will

definitely have a cumulative impact on the noise level of the area.

Summary of the impact on noise

Visual Aspects

Of the planned activities, the mining of additional seams through additional adits and the

establishment of the washing plant and its associated infrastructure will have an impact on

the visual character of the area. The site is visible from the R543 (Piet Retief – Wakkerstroom)

district road, lying some twelve kilometres to the north of the site. There are some four

family communities who would have a direct line of vision of the mine.

The new presence of mining equipment and the erection of infrastructure will change the

aesthetics and “sense-of-place” of the area. The stockpiles and berms around the terraces

will also act as screens to mitigate sound and visual disturbance from the mining site.

Dust from the construction activities will also cause a visual disturbance that is temporary.

Coal dust fall-out along the sides of the roads and around the mining area will also impact

on the aesthetics of the area. Lighting from vehicles at night during construction activities,

lighting masts and security lights will also contribute to the visual impact.

However, as the area already has a mining character, the impact will only contribute to the

existing impact and the planned activities will have a moderate significance before

mitigation. Such mining activities are further screened from surrounding receptors (on the

southern and south-eastern side) by the local mountain range.

Summary of the impact on visual characteristics



Large Future S/T Temporary S/T Definite Low



Large Future S/T Temporary S/T Definite Moderate




Socio-economic Conditions (Construction Phase)

Potential Impact: The local economy will benefit from the new employment

opportunities and the knock-on effect of employment.

This project will ensure employment of personnel associated with the construction of the

mine, albeit on a temporary basis. There will be an opportunity for a permanent employment

framework, but this is covered under the section below, operational phase.

The families living on and around the property will have a major change in quality of life and

lifestyle due to the close proximity of the mining operation, and wealth that it will create and

distribute among the communities via salaries and services. The mine could negatively

impact upon the value of surrounding land.

As there is no evidence of the land value depreciating as a direct result of the adjacent

Kiepersol Colliery, it is not likely that the refurbishment and recommissioning of the Kwasa

Colliery would have a high impact on the land value in the area. This is a subjective issue,

(in that it would largely be determined by market forces), and has not been quantified.

The overall, residual impacts as determined by this qualitative impact assessment are such

that it is unlikely that a significant, long-term depreciation in land value would result.

Furthermore, should other local adjacent coal reserves be exploited, the regional community

will holistically, be sufficiently empowered to limit negative impacts to an acceptable level.

(This includes members of the community with skills and experience in legal and technical

issues).

The effect of the construction phase on the regional and socio-economic structure will

extend beyond the project area and will be temporary (short term - <6 months). It will have

a low to moderate level of significance, both negative and positive.

Summary of the impact on the local economy

Potential Impact: The local and regional road transport network will suffer

additional pressure from the haulage trucks.

The local and regional road transport network will suffer additional pressure from the

haulage trucks travelling on the surrounding district roads.







Additional heavy motor vehicle traffic will increase the road degradation of the road

infrastructure. However, it is not foreseen that the construction phase will contribute

significantly to the road infrastructure degradation as the construction vehicles will remain

on site during the construction period and will not travel on the surrounding district roads

frequently.

Summary of the impact on the regional road network

Impact on Interested and Affected Parties (IAPs)

The existing status quo of the local economy will be affected by the introduction of relatively

higher paying (assumed) but short term employment opportunities. Various IAP have

indicated concerns regarding the rehabilitation of the proposed mine and questioned

whether the applicant will have enough resources to rehabilitate the area when mining

seizes. Further concerns were related to the possible environmental degradation especially

the impact on the water resources.

It is therefore assessed that the proposed mine will have an impact during the construction

phase on the community cohesion and community perception which is linked to their

aspirations for the future.

Ongoing communication with IAPs will be conducted where monitoring information will be

made available through the annual audit reports.

A complaints register will be made available at the mine and an environmental monitoring

committee will be established.

Summary of the impact on the IAPs perceptions

Heritage/Archaeological Aspects

Due to the state that the environment was found in, it is not envisaged that there are any

graves or other structures of historical importance on the disturbed site and therefore most

of the planned activities will have no impact on any heritage aspects. However the

construction of the Co-Disposal dump site and the fresh water storage dam has the potential










to impact heritage resources. A heritage impact assessment is currently being conducted by

eThembeni Cultural Heritage to determine if there are any heritage resources on the

undisturbed areas.

If such aspects are discovered the appropriate mitigation measures as described by a

heritage specialist will have to be adhered to.

Cultural Aspects

No cultural or spiritual importance has been found to be associated with the mining area;

therefore the mining operation will have no impact on any cultural aspects of the site.

6.3.2 Operational Phase

Geology

The geology will be disturbed on a localised and limited basis by the primary mining

methods. The methods planned to be used are proven for this specific reserve, having been

employed by the contractor STA at the adjacent Kiepersol Colliery.

The disturbance will be limited to parts of the project area, will be permanent and will

happen. It has a high level of significance.

Multiple underground mining operations in the area will have a definite cumulative impact

on the geology of the area.

Summary of impact on geology

Topography

The topography of the area will be affected by the planned activities in terms of the various

stockpiles which will be moved, grown and reduced continually during the life of the

operations. It is however not foreseen that the planned activities will have an additional

impact which is significantly different to that of the impacts identified for the construction

phase.

Multiple mining operations in the area exists thus there will be a cumulative impact on the

topography of the area in the long term as the tailings facilities are permanent features

affecting the relief of the area.



Moderate Future M/T Permanent Definite High




Summary of impact on topography

Soils

As per the construction phase, the soils excavated will be separately pre-stripped as topsoil

or subsoil and stockpiled separately in a designated area for use during rehabilitation.

During the stripping operation of the soil, soil layers will be mixed when removed,

transported and stockpiled by the bulldozers. Seeds and roots within these layers will be

uprooted and may be exposed to the open air elements which could damage and kill them.

This will render the topsoil less fertile. Further stockpiling of the soil will expose the soil to

elements of erosion such as wind and water as well as risking the occurrence of compaction.

Due to the fact that the soils have already been compromised, possible further disturbance

will have a cumulative effect.

There is a probability of sheet erosion occurring on the areas cleared of vegetation. The

extent of the cleared area is however relatively small and will only involve portions of the

new adit area, stockpile areas and roads. As these sites will be actively managed (or be

covered by temporary structures) the duration will be long term. The probability of gully

erosion will be limited to the concentrated flow of collected water points or concentrated

flow points (such as culverts) around the mining area. However, proper berm construction

and erosion control measures will ensure that the intensity will be greatly reduced. The

impact on the soils of the area, due to erosion will therefore have a low level of significance.


Land Capability

The land capability will not continue to be impacted on by the activities associated with

mining.

Mining activities in the area will definitely have a cumulative impact as mining activities will

reduce the original land capability in the area to a homogenous area defined by mining.



Moderate Future M/T Temporary L/T Probable Low



Small Future M/T Temporary L/T Possible Moderate




Summary of impact on the land capability

Land use

The land use will remain as mining. There would be no further impact during the operational

phase as the land use was already changed to mining in the new area during the construction

phase.

The fresh water dam will be made available to the community to use for livestock watering

and/or irrigation purposes. If managed this way the fresh water dam will have a moderate

positive impact on the local community.

The underground mining activities in the area will have a low cumulative impact in the

medium term as the surface infrastructure is limited in extent.


Vegetation

Impacts on the vegetation will be on-going; however operational activities will produce dust

which may impact vegetation surrounding the operational areas. Alien invader species may

further establish on the disturbed areas if a weed eradication plan is not set in place. The

magnitude of such impacts during the operational phase is however limited to the disturbed

areas and does not have a high intensity.

The removal of vegetation over the mining area may lead to a decrease in the carbon sink

potential of the area which may have a cumulative impact in the long term due to the

increased carbon emissions from mining related activities. In addition, the disturbance in

the area will lead to an influx of invasive species and hence a potential loss in biodiversity.




N/A N/A N/A N/A No further impact



Moderate Future M/T Permanent Definite Moderate (Positive)



Moderate Future M/T Permanent L/T Possible Moderate




Animal Life

Several species of conservation have already been lost from the area as a result of human

activities. None were seen at the time of the site visit. If any of the species of concern are

still present, even if only for limited periods of time then the impact may be regarded as

“High”. However, because the affected area is already so depleted, the additional impacts

may be of lower significance.

The associated loss of habitat, disturbance in the area in terms of noise, dust and water

pollution associated with mining activities will possibly have a negative cumulative impact

on the fauna in the area in the long term.


Surface water

The property on which the mine is situated is part of a water catchment area and is

traversed by numerous drainage lines. Some of these are seasonal while others have

perennial flow in normal years. The water yield is regionally important.

The mining activities have the potential to impact on the watercourses in a number of

ways which include:

Deterioration of water quality through coal-related substances entering the system.

These substances will include both suspended solids such as coal dust and

dissolved solids including sulphates and metal ions which can lower the pH of the

water and can reach toxic levels.

Erosion of the veld as well as runoff from roads and other infrastructure can clog

the stream substrate with silt. This results in loss of habitat for aquatic fauna and

so biodiversity is reduced.

Reduction of flows. If excessive water is abstracted for use in the mine and the

associated operations, then stream flows are reduced and smaller systems may be

dried out completely. Aquatic biodiversity is then lost.

Groundwater

Potential Impact: Decrease in groundwater quantity

Mining of additional seams will have a definite impact on the groundwater. Since no

secondary mining (and possible total extraction) will be conducted, the roof (dolerite cap)



Moderate Future L/T Permanent L/T Possible Moderate




stability will not be compromised. However, should the impermeable layers be cracked water

will be allowed to flow through the mountain to the mine workings. Therefore no water

would daylight along the side and on top of the mountain. Springs and fountains being fed

by the groundwater will dry up.

Multiple mining operations in the area will possibly have a high cumulative impact on the

groundwater availability.

Summary of impact on the groundwater quantity

Potential Impact: Groundwater contamination

Water infiltrating into the mine workings will generate acid mine drainage.

Dirty water contained in the pollution control dams could contaminate the underlying aquifer

through seepage. Seepage could also occur on the operational areas (stockpile and discard

facility) if storm water is allowed to pool. The management measures should focus on

separating the aquifer from the facility by lining the pollution control dams with HDPA (2mm)

and clay on top, compacting the operational area and sloping the surface of the stockpile

areas to avoid pooling.

The potential exists that leakages from the septic tank system can seep through and

contaminate the underlying aquifer. If no management measures are conducted, the

groundwater quality will significantly be impacted.

Multiple mining operations in the area will possibly have a high cumulative impact on the

groundwater quality.

Summary of impact on groundwater quality


Potential Impact: Potential degradation/damage to the wetlands and streams due to mining

operations. The following sensitive areas could be affected during the operational phase:



Large Future M/T Temporary L/T Possible High High



Large Future M/T Temporary L/T Possible High High




The Wakkerstroom Wet Grassland proposed exclusion area. This area must be avoided at all

cost.

The Annysspruit along with other small tributaries flowing in close proximity of the Kwasa

Colliery as well as the wetland north of Kwasa Colliery’s entrance. The potential exist that

these streams/rivers could become polluted if the pollution control system does not contain

all the contaminated water.

The wetlands on the mining property are already largely degraded or lost and none are

NFEPA listed. However, some of the mining activities will have the potential to impact further

on the systems.

The construction of the pollution control dams and the in-stream fresh water storage dam

will lead to the reduction of storm water runoff into the surrounding streams and wetland.

Large parts of the proposed mining area is a brownfields site with no sensitive landscapes.

However, should the groundwater be affected, there is a significant probability that springs

and fountains which feed various wetlands, may be negatively affected.

The pollution control system will have a positive impact on the surface water resources

quality down gradient of the site by containing the current source of pollution but it will

affect the runoff negatively.

Summary of impact on the sensitive landscapes

Air Quality

Dust will be created from the localised operational area and the untarred access and district

roads during the operational phase from the primary beneficiation and screening operations

and the haulage trucks. The air outtake ventilation may transport intermittent increases in

(coal) dust levels. Coal dust particles may be transported by the medium of air and deposited

beyond the project area. A build-up of coal dust on grazing (especially during the dry winter

months) would make the grass less palatable, and would affect the yield of annual crops

such as maize. The effect will be temporary and will have a moderate significance rating.

Dust suppression by water tanker will be employed to mitigate the release of dust which will

lower the significance rating of the impact.



Large Future M/T Permanent L/T Possible High




Operational activities in the area associated with development and mining activities will

probably have a cumulative impact on the air quality of the area if mitigation measures are

not implemented.

Summary of impact on the air quality

Noise

During the operational phase noise will be caused by the mining of the adits, operational

vehicles, machines and washing plant. In addition construction activities will continue

through the operational phase. The main cause of an increase in the ambient noise level is

the haulage trucks and other plant equipment associated with construction of the additional

adits required for the planned activities. The reverse sirens of the construction and

operational vehicles and general diesel engine running noise will add to the industrial noise

of the site, which will be in stark contrast to the natural noise character of the site. The

disturbance would extend beyond the project area due to the haulage trucks and sirens; it

would be a temporary (long-term) disturbance and it will happen. It has a moderate level of

significance.

The noise will however be mitigated by the natural topography of the site and highwall

constructed on the site. The mountain will act as a noise buffer to the adjacent landowners

on the southern side of the mountain. The operational noise will extend from the site

boundaries and will definitely contribute to the existing noise levels.

Summary of impact on the noise

Visual Aspects

Of the planned activities, the mining of additional seams through additional adits and coal

washing along with the related operational requirements will have an impact on the visual

character of the area. The establishment of the discard dump along with dust pollution

caused by haulage trucks will have the biggest impact on the visual aspects during operation.

Lighting from vehicles at night during operational activities, lighting masts and security

lights will also contribute to the visual impact. However, as the area already has a mining



Large Future M/T Temporary L/T Probable Moderate



Large Future M/T Temporary L/T Definite Moderate




character, the impact will only contribute to the existing impact and can be describe as

having a moderate significance before mitigation.

Summary of impact on the visual aspects

Socio-economic Impacts (Operational Phase)

Potential Impact: The local economy will benefit from the on-going employment

opportunities and the knock-on effect of employment.

The proposed mine will create additional employment in the formal sector during the

operational phase. The mine will further ensure that the continuation of the mining

operations will contribute to increased sustainable income in the area. Furthermore, the

employment opportunities in the informal sector – such as street vendor providing food to

mine workers – may increase and stabilise. The associated sustainable employment

opportunities will have a moderate positive impact on the economic structures of the area.

The effect of the mine on the socio-economic structure would extend beyond the project

area, have a temporary effect in over the life of the mine and would happen.

On-going communication with the authorities will be maintained to make information

available for IAP’s. There are no management measures that can be implemented.

Summary of impact on the local employment

Potential Impact: The local and regional road transport network will suffer

additional pressure from the haulage trucks.

The impact of haulage trucks on the regional road infrastructure will be very high. Currently

the haulage industry is causing excessive damage to the road network and the transport by

road of coal from Kwasa Colliery to Piet Retief would result in an actual increase in traffic

over the long term (life of the mine). The effect of the mine on the road infrastructure would

extend beyond the project area, have a temporary effect in over the life of the mine and

would happen.










Summary of impact on road infrastructure

Potential Impact: The local community will have a reliable water resource to

use for irrigation and stock watering

The water contained in the fresh water dam will also be available for the local community

to use for irrigation or stock watering. This will have a positive impact on them because

there will be a more reliable source of water available throughout the year for their farming

activities.

Summary of impact on water resource


No graves or other structures of historical importance were identified therefore the planned

activities should have no impact on any heritage aspects. If such aspects are discovered

during operational activities, the appropriate mitigation measures, as described by a

heritage specialist will have to be adhered to.

A heritage impact assessment is currently being conducted by eThembeni Cultural Heritage.

The results from this study will be included in the Final EIA/EMPr.

Cultural Aspects

No cultural or spiritual importance has been found to be associated with the proposed site;


6.3.3 Decommissioning Phase

Geology

The rock and other substrates that were stockpiled from excavation of the adits, will be used

to backfill and landscape (terrace) the adit void on top of the plug. There will be no further

impact.



Large Future M/T Temporary L/T Definite High



Moderate Future M/T Permanent Probable Moderate




Summary of impact on the geology

Topography

The topography will be re-shaped by the rehabilitation of the adit complex and the plant

area. The remaining impact on the topography will be limited to a small part of the project

area, as the landscaped and vegetated Co-Disposal Dump site. It will be a permanent

disturbance and it will still need to happen. It has a moderate (positive) level of significance

as the post mining topography will be landscaped to emulate (except for the dump) the pre-

mining topography.

Summary of impact on the topography

Soils

The pre-stripped, top soil will be replaced over the remaining landscaped area. The

disturbance will be limited to part of the project area, it will have a permanent effect and it

will still happen. It has a positive, and moderate level of significance.

The impact on the soils during the decommissioning phase will focus on the amelioration

thereof through building up the nutrient status, organic carbon levels and bio-components

to self-maintaining levels. Activities associated with the decommissioning phase will aim at

rehabilitation of the site and associated soil to the extent that the site can revert back to

grazing use. The impact is therefore considered to have a positive impact on not only the

site after mining, but also when considering the current state soils.




Small Future L/T Permanent Definite Low



Small Future L/T Permanent Definite Moderate (Positive)







Land Capability

The mining area will be rehabilitated to an applied grazing land capability (actually a

rehabilitated mining area).

The disturbance will be limited to within the project area, it will be permanent and there is

a definite probability that it will happen. It has a moderate (positive) level of significance.

Summary of impact on the land capability

Land Use

The land use will be changed from mining back to agriculture. The disturbance will be limited

to the operational area, it will be a permanent disturbance and there is a good chance that

it will happen. It has a moderate (positive) level of significance.

The use of land will gradually revert to a combination of agriculture (grazing of domestic

livestock) during the decommissioning phase.

The underground workings will be sealed and dangerous excavations rehabilitated. Further

rehabilitation activities will include the final rehabilitation of stockpile and discard areas,

roads and pollution control structures.


Vegetation

The indigenous grasses will be encouraged to re-establish in the rehabilitation programme

under the initial protection of a nurse crop of pasture grasses such as Eragrostis tef. The

activity will be limited to the project area. It should provide a permanent solution and there

is a 90% chance that it will still happen. It has a moderate level of significance. As the site is

currently in a degraded state, the rehabilitation of the mining areas as proposed by this

application will have a positive cumulative impact on the environment.



Moderate Future L/T Permanent Definite Moderate (Positive)



Moderate Future L/T Permanent Probable Moderate (Positive)





Animal Life

As the habitats become re-established, the pre-mining animal species diversity will

gradually return to the vicinity of the previously disturbed areas. This will not be limited to

the project area. There is a 70% chance that it will happen. It has a low level of significance

and the effect would be positive.


Surface Water

The runoff will be diverted away from the rehabilitated sites by run-off control structures

until these are stable. The topography will be free-flowing, with no ponding of rainwater.

After this occurs, the catchment water make would be affected even less by the mining area.

The pollution control dams would have a certain retention and release capacity and would

contain the contaminated water, while the clean water would be released directly into the

river system.

The disturbance will be limited to the project area, it will be a permanent and positive effect

and will still happen. It has a moderate (positive) level of significance.

Summary of impact on the surface water

Groundwater

During the decommissioning phase, the dewatering will cease and the groundwater levels

in the zone of influence will start to recover. The decommissioning phase is considered to

be too short (approximately 6 months) for a significant impact on the groundwater levels or

qualities to become manifest.



Moderate Future L/T Permanent Probable Moderate (Positive)



Large Future L/T Permanent Probable Low (Positive)



Large Future L/T Permanent Definite Moderate (Positive)




Under conditions of no disturbance (such as abstraction), the suspended solids would settle

over time, and consequently a salt gradient (salinocline) would develop. This provisional

and conceptual impact assessment will be both quantified and qualified during the

groundwater modelling exercise currently being conducted by GCS, in terms of the expected

volume, quality and phreatic zones where seepage is expected to occur.

Summary of impact on the groundwater levels

Potential Impact: The potential for acid mine drainage

During the assessment of the potential for acid mine drainage, it is important to evaluate

the volume of leachate that could potentially be generated as well as the quality of leachate

emanating from the mining area. Both of these factors will affect potential acid mine

drainage from the mining area. In order to obtain site-specific information on the quality of

the leachate that will emanate from the mining area, rock samples need to be taken from

the mining area. The potential for acid-mine drainage or poor quality leachate forming in

the mining area is caused by the exposure of sulphide minerals to atmospheric oxygen.

Sulphur assay results are used to calculate the maximum amount of acid that could be

generated and the sulphide content is determined by subtracting sulphate sulphur from the

total sulphur percentage.

Acid Base Accounting (ABA) is a screening test that does not provide information on the

speed (or kinetic rate) at which acid generation or neutralization will proceed. For this

reason, it is often recommended that additional test work be undertaken on samples which

have acid potential especially, to determine the rate of acid generation (kinetic tests). ABA

is however a sound starting point for determining the risk of acid mine drainage from

selected rock samples.

The potential for any given rock to generate and/or neutralize acid is determined by its

mineralogical composition. This includes the quantitative mineralogical composition,

mineral grain size, shape and texture. The term “potential” is used because even the most

detailed mineralogical analysis, when combined with ABA, provides a worst-case value for

potential acid production.

During underground coal mining there is a very good chance that acid mine drainage will

occur. The risk of this happening as well as mitigation measures will be determined by

GCS during the Hydrogeological and Geochemical study which is currently underway. The



Large Future L/T Permanent Probable Moderate (Positive)




results of this study will be included and assessed in the Final EIA/EMPr.

Summary of impact on the groundwater quality

Potential Impact: Risk of decant

The rate of recharge to the underground workings after rehabilitation has been completed

will determine the risk of decant.

Two aspects have been considered in this section, namely, the volume of leachate that could

be generated, and the potential quality of the decant. The possible exposure pathway is

also of importance, since poor quality leachate becomes an issue at the point where aquatic

systems or other users become exposed to it.

The volume of decant will depend on the rate of recharge as well as groundwater seepage

to the underground workings.

The volume of decant should be confirmed by the aid of a groundwater model which is

currently being done by GCS. Note: The rate of rise of groundwater levels around the mining

area is provisional, and must be confirmed through on-going monitoring. It is not possible

to accurately predict the long-term quality of water in the underground workings with the

available information.

Summary of impact in terms of decant


There will be no impact on sensitive landscapes by mining-related activities during the

decommissioning phase.

Summary of impact on the groundwater



Large Future L/T Temporary L/T Probable High High



Small Future L/T Permanent Possible High High



N/A N/A N/A N/A No effect




Air Quality

Dust will be created during the decommissioning phase by the earth moving activities during

closing of the adits, terracing the adit areas, rehabilitation and grassing of the dump. The

dust created by the haulage trucks will cease and the area affected will be considerably

smaller than during the operational phase. The disturbance will be limited to the project

area, it will be temporary (short term <6 months after closure). It has a low level of

significance.

Summary of impact on the air quality

Noise

The earth-moving equipment that is involved with doing the rehabilitation activities will

create noise. The activity will be limited to the project area, it will be a temporary disturbance

and it will still happen. It has a low level of significance.

Summary of impact on the noise

Visual Aspects

Impact

The decommissioning programme itself will influence the aesthetics of the area negatively

as there will be much activity on the surface during the rehabilitation of discard dump,

removal of coal waste and ripping of hard surface areas, re-shaping of surfaces, and re-

vegetation of the footprint area. Once finished, the aesthetics will have been improved.

The impact after the decommissioning phase (post closure) is permanent and of moderate

significance (positive) due to the state the environment was found in.

Summary of impact on visual aspects



Moderate Future L/T Temporary S/T Probable Low



Large Future L/T Temporary S/T Definite Low



Moderate Future L/T Temporary S/T Probable Moderate (Positive)




Socio-economic Conditions

Impact: Unemployment

Upon decommissioning of the mine, there is a possibility that various labourers will be left

without employment. A decrease in employment levels will have a knock on effect of all

spheres of the social environment. It could result in lower household income, health and

social well-being as well as participation in deviant social behaviour. The effect on the IAP’s

associated with this specific project would extend beyond the project area, and it would have

a permanent effect and it will still happen. It has a moderate level of significance.

A complaints register will be made available at the mine reception and a toll- free complaints

number made available for the first year of the operation. An environmental monitoring


Summary of impact on the employment

Potential Impact: The local community will have a reliable water resource to

use for irrigation and stock watering

The dam will remain on site if this is agreed to by the local community and landowner. The

water contained in the dam will be used by the local community and farmers for irrigation

or stock watering. This will have a positive impact on them because a more reliable water

source will be available on a constant basis throughout the year for their farming activities.

Summary of impact on the water resource

Potential Impact: Expectations of the Interested and Affected Parties

Impact on the communities perceptions of the mining activity. If the decommissioning

activities exceed or fall short of the expectations of the IAPs regarding the decommissioning

of the mine it will have a significant impact on their farming activities as well as aspirations

for the future. It is anticipated that the IAP’s will be involved in a consultative closure

application process through the environmental monitoring committee. The closure



Large Future L/T Permanent Definite Moderate







certificate would be communicated to the IAP’s. The effect would extend to beyond the

project area. It has a high level of significance.

Summary of impact on the IAPs


Decommissioning activities will not have an impact on the heritage/archaeological aspects

of the site because these aspects would have been identified and avoided during the

construction of operational phase. If such aspects are discovered during decommissioning

activities, the appropriate mitigation measures, as described by a heritage specialist will

have to be adhered to.

Cultural Aspects

No cultural or spiritual importance has been found to be associated with the mining area;




Large Future L/T Permanent Possible High




7 Environmental Management and Implementation Plan

A description has been made of the environmental objectives and specific goals for the

proposed coal mining operation in terms of:

Management of construction, operation and decommissioning bio-physical as well

as socio economic issues

Mine closure

The Environmental Management Programme (EMP) will be implemented by means of an

operational procedure. It is the objective of the EIA process to determine whether or not this

will be sustainable (with acceptable risk and impact). A description of all mitigation measures

for the potentially significant impacts that could be introduced by the project has been

described.

The principal objectives for impact mitigation would be to:

Prevent or avoid;

Reduce or minimise the impacts; and/or

Contain (and treat where possible).

Only the impacts that could potentially be significant before mitigation will be addressed in

the EMP. The post-mitigation impacts will all be considered / assessed to establish whether

or not they have been adequately mitigated based on the EMP. The operation would be

subject to an EMP that is fully integrated with all outcomes of the EIA.

Mining would only proceed under the authorisation and control of an approved

Environmental Management Plan (EMP) Report (plus the other parallel legally required

environmental authorisations, such as a water use license, integrated water and waste

management plan, change in land use, amongst possible other requirements).

Environmental Management Plan

The following goals and objectives have been set as targets for the effective mitigation of

impacts caused by the coal-mining activities during the construction, operation and

decommissioning phases. These goals and objectives will be measured through the

monitoring programme. The significance of the identified impacts have been assessed pre

and post mitigation in Table 28, 29 and 30 below.




Roles and Responsibilities

Various parties will be involved during the construction, operation and decommissioning of

the proposed mine. As such, the responsibility of various mitigation measures, as identified

in the tables below, has been allocated to the various stakeholders involved.

It is proposed that the surrounding community be assisted by the local municipality to

establish a committee, which will represent their interests. Representatives of such a

committee should be tasked with liaising with Siphiwo Investments.

It is further proposed that an Environmental Control Officer (ECO) be appointed by Siphiwo

Investments to assist with the environmental monitoring of the construction and operational

phase. It is proposed that the ECO do weekly inspections and provide a monthly progress

report during the construction phase and a quarterly performance report during the

operational phase.

The key role players for this particular project have been tabled below:

Table 25: Responsible role players

Role-player

Siphiwo Investments (Pty) Ltd SI

The appointed contractors AC

The Environmental Control

Officer

ECO

The Community Liaison officer CLO

Each of the parties will have certain responsibilities, as indicated in the tables below, to

ensure that the EMP is being adhered to.

The table below have been designed as an easy reference for the impact which may occur

due to the construction, operation and decommissioning of the proposed mine. Linked to

each of the impacts is the correlating mitigation/management measure as well as the party

responsible for the implementation thereof. These tables have been designed for the

construction, operation and decommissioning phases.




Table 26: Potential impact and mitigation register for the construction phase

Potential Environmental

Impact

Activity Environmental

Significance

Before Mitigation

Recommended Mitigation Measures Responsible

Party

Schedule Environmental

Significance after

Mitigation

Management

Indicators

Geological and Geomorphological

Altering the

geotechnical

characteristics of the

geological strata.

Mining of all seams will have a definite long

term impact on the local and regional

geology of the area.

Moderate

Significance

The impact on the geology will be permanent

and cannot be mitigated due to the nature of

the activity.

Stability of the high wall will be ensured by the

use of split blasting techniques.

AC Construction phase Moderate

Significance

Stable High Wall.

Topography

Change in existing

topography.

The excavation of the adit, terracing and

stockpiling of overburden and topsoil, along

with the construction of pollution control

measures will alter the topography.

Low Significance The disturbed area must be kept to the

minimum needed for the mining operation.

The various stockpiles must be managed to

prevent erosion and shaped where required.

AC Ongoing: Quarterly Low Significance Erosion;

Pooling of surface

water.

Decrease of surface

water runoff.

Levelling the topography of the site and

establishment of diversion berms and the

high wall.

Moderate

Significance

During the levelling of the site ensure that the

surface water flow is directed away from the

construction area towards the surrounding

surface water resources.

AC Construction phase Low Significance Pooling of surface

water.

Soils

Erosion and

sedimentation.

The soils will be pre-stripped as topsoil or

subsoil and stockpiled in a designated area

for use during rehabilitation.

Moderate

Significance

The topsoil must be stockpiled separately and

used for the construction of berms: the gradient

of the sidewalls must be such as to prevent

excessive wash during storms. These must be

grassed and managed to prevent soil loss

through erosion and excessive dust.

The soils should be stockpiled in the form of a

berm not exceeding 1.5 m in height in a

position down slope of the adit to contain the

contaminated rain water run-off around the

area.

SI/ECO Quarterly Low Significance Erosion;

Vegetative growth

on soil stockpiles.

Contamination of soils. Oil and/or diesel spills from construction

vehicles.

Moderate

Significance

Defining routes for the circulation of heavy

machinery and vehicles;

Restricting machines’ movement to the strictly

necessary areas;

SI Ongoing: Life of mine Low Significance Visible oil spills;

Pooling of water on

the operational

area.





Impact


Significance

Before Mitigation


Party


Significance after

Mitigation

Management

Indicators

Ensuring the impermeability of all storage areas

for fuel, lubricants and other chemicals.

Land Capability

Change in existing land

capability.

The land capability will be compromised

through the construction of the adit site.

This is mainly due to the intense impact that

the construction activities will have on the

soil and vegetation of the site.

Low Significance The disturbed area must be kept to the

minimum required for construction of the adit.

The topsoil and subsoil must be managed to

ensure effective rehabilitation back to the pre

mining land capability during the

decommissioning phase.

SI Ongoing: Monthly Low Significance Vegetative cover;

Limited area of

disturbance.

Land Use

Changes in land use

from a defunct colliery

to an operational

colliery.

The land use will be compromised through

the construction of the adit sites, washing

plant and its associated infrastructure.

Low Significance Control of the area disturbed during the

construction phase to ensure no unplanned

(and/or unauthorised) expansion, with a direct

effect on land use.

SI Construction/Operational

phase

Low Significance Limited area of

disturbance.

Vegetation

Loss of vegetation. The vegetation will be removed during the

excavation of the box cut, the roads,

pollution control facility, fresh water dam

and other infrastructure. Some of these

areas have previously been disturbed and

the vegetation that has subsequently

established is not pristine.

High Significance A detailed mine plan which shows, as far as is

possible, all mine infrastructure must be

prepared. This plan should be reviewed by an

ecologist and, if areas of particularly valuable

vegetation are likely to be affected then

alternative layouts should be considered.

Plant salvage operations should be considered.

These operations should be undertaken on the

advice of the provincial conservation agency

who must provide the following information:

If needs be a permit must be obtained from the

conservation agency so that the translocations

may be done legally.

SI/ECO Construction phase Moderate

Significance

Limited area of

disturbance.

Dust outfall on flora

outside the

development

footprint area.

Construction activities which create fugitive

dust, such as clearing vegetation, movement

of construction vehicles on unpaved

surfaces.

Low Significance Clearly demarcate the area for clearance of

vegetation and within which construction

activities may take place;

Prohibit activity outside of the demarcated area;

SI Construction and

Decommissioning phase:

Monthly

Insignificance Limited area of

disturbance.





Impact


Significance

Before Mitigation


Party


Significance after

Mitigation

Management

Indicators

Implement dust suppression spraying where

necessary;

Rehabilitate disturbed areas after construction

using indigenous vegetation.

Proliferation of alien

vegetation inside the

footprint area.

Disturbance of natural vegetation and soil

erosion caused by construction activities.

Moderate

Significance

Implement weed eradication programme;

Monitor post construction rehabilitation and

remove weeds where necessary.

ECO Quarterly Low Significance Limited area of

disturbance.

Establishment of

alien vegetation.

Animal Life

Loss of habitat/faunal

diversity.

The animal life will be affected by habitat

removal during construction and by the

disturbance of pathways, which previously

crossed the adit and operational areas.

Traffic on the haul road will disturb animal

life, as will other mining-related activities.

Moderate

Significance

Since the fauna is dependent on the vegetation

it is essential to maintain the best possible

indigenous vegetation cover so as to provide

habitat for the animals. Guidelines for

maintenance of the vegetation have been

provided and are emphasised in the biodiversity

assessment done by Terratest (refer to

Appendix …)

The enclosure fences erected around the

operational areas will prevent domestic livestock

and discourage larger wild animals from

entering the operational sites.

Prohibit activity outside of the demarcated area.

SI Ongoing: Life of mine Low Significance Feedback from

environmental

forum.

Harm to fauna. Poaching, trapping and killing of animals by

construction workers during the

construction activities.

Low Significance Clearly demarcate the construction footprint

area and prohibit movement of workers outside

the footprint;

Prohibit workers from capturing or handling any

animals.

AC

CLO

Ongoing: Life of mine Low Significance Feedback from

environmental

forum.

Surface Water

Contamination of

surface water.

Chemical spills, oil spills and construction

dumping might be picked up by runoff and

contaminate downstream watercourses.

Moderate

Significance

All “dirty” water runoff should be kept on site

and not allowed to mix and contaminate clean

runoff;

SI/ECO Ongoing: Monthly

Low Significance Surface water

quality;

State of the

pollution control

system.





Impact


Significance

Before Mitigation


Party


Significance after

Mitigation

Management

Indicators

The area should be sufficiently bunded, and the

water should be collected at the lowest point of

the site;

Energy dissipaters should be constructed to

prevent erosion;

There should be no mine residue, disposal of

industrial waste on site during the construction

phase;

Hydrocarbon waste and contaminated waste

should be collected for recycling;

Domestic waste should be disposed of at a

registered disposal facility;

Ongoing monitoring of surface water quality.

Decrease of surface

water runoff into the

surrounding

catchment.

Containment of rain water falling onto the

construction site thereby affecting the runoff

that generates stream flow.

Moderate

Significance

Construct clean water diversion structures prior

to the construction to divert clean water away

from the construction area and prevent

damming of clean water.

Water users should be consulted with on a

regular basis. Should the downstream users

suffer a loss of water, the mine should offer an

alternative supply or pay compensation as

agrees by proactive consultation.

SI

CLO

Ongoing: Monthly Low Significance Feedback from the

water monitoring

forum.

Complaints from

downstream water

users.

Disturbance of the bed

and banks of the water

courses running

through the mining

site.

Expansion/upgrade of the five low level

bridges.

High Significance The disturbance footprint should be kept as

small as possible in order to minimize the

impacts on the riparian habitat.

Care must be taken to ensure that watercourses

are not impacted upon at road crossings. Roads

should have adequate drainage to remove

stormwater as rapidly as possible. No drains

should discharge directly into watercourses or

within 15 m of a watercourse.

If a road crosses a watercourse on a low level

causeway that will be inundated from

time to time, then the road should be either

tarred or concreted for a distance of at least 20

AC Construction phase Moderate

Significance

Flow of the stream;

Signs of

sedimentation

around the

structures.





Impact


Significance

Before Mitigation


Party


Significance after

Mitigation

Management

Indicators

m on either side of the watercourse. The

purpose of this guideline is to allow water

dripping off vehicles to run back to the

watercourse without picking up sediment from

the road surface in the process.

Construction waste must be contained and

prevented from entering the watercourse.

The flow of the stream must in no way be

altered or influenced by the upgrading of these

crossings.

Groundwater

Decrease in

groundwater level.

The opening and dewatering of additional

adits.

Moderate

Significance

A Groundwater monitoring program must be

established as soon as possible in order to

generate a database.

Limit groundwater use as much as possible and

measure groundwater abstraction levels.

SI/ECO Quarterly groundwater

monitoring

Low Significance Groundwater

levels;

Complaints from

water users.

Contamination of the

underlying aquifer.

Groundwater seepage flowing into the adit

during excavation.

Spillage from chemical toilets, oil spills and

construction dumping may infiltrate the

groundwater system and contaminate the

groundwater resources.

Dirty storm water collecting in the Pollution

Control Dams (PCD) during the construction

phase has the potential to leach into the

groundwater.

Moderate

Significance

Any groundwater seepage that may flow into the

adit during its excavation will be pumped to the

pollution control dams. This will ensure that

potentially acid generating rocks (specifically

the acid generating shale’s) are not in constant

contact with the water, which will, in turn,

reduce the potential for acid mine drainage

during the construction phase.

There must be no mine residue, disposal of

industrial waste on site during the construction

phase.

Hydrocarbon waste and contaminated waste

should be collected for recycling as

hydrocarbons are a major pollution risk.

Domestic waste must be disposed of at a

registered disposal facility.

Remove any oil or diesel spills as soon as it

occurs and dispose of it at a registered waste

site;

Ongoing monitoring of the groundwater quality;

SI/ECO Ongoing: Construction and

operational phase

Low Significance Groundwater

quality.

Complaints from

water users.





Impact


Significance

Before Mitigation


Party


Significance after

Mitigation

Management

Indicators

Ensure the impermeability of all storage areas

for fuel, lubricants and other chemicals;

Construction vehicles must be kept in a good

working order as to prevent unexpected

leakages of fuels and lubricants (which could be

hazardous substances);

All daily maintenance of construction vehicles

should be carried out in a demarcated area to

limit any possible spills of hazardous materials

(oils and greases);

The oils used by the construction vehicles and

machines should be collected, stored and

transported to an adequate final destination.

Air Quality

Creation of fugitive

dust.

Site establishment operation including

stripping of topsoil and grading of access

roads.

Low Significance Dust from the internal roads will be suppressed

with water and a dust inhibitor.

The disturbed area will be rehabilitated in order

to prevent the generation of dust.

Rationalization of the vehicle and machines

circulation;

SI/ECO Weekly Low Significance Complaints from

the public.

No excessive,

chronic dust

emanating from

the operational

area.

Air quality pollution. Release of emissions into the atmosphere

from the construction vehicles.

Low Significance No mitigation measures possible. SI N/A Low Significance Complaints from

neighbours.


Disturbance of the bed

and banks of a

tributary flowing into

the Annysspruit.

Construction of the fresh water storage dam

and low level bridges and culverts.

High Significance The disturbance footprint should be kept as

small as possible in order to minimize the

impacts on the riparian habitat;

Construction waste must be contained and

prevented from entering the watercourse.

Ideally no new roads may pass through a

wetland. However, if a new road must pass

through a wetland area then care must be taken

to ensure that the flow of water through the

system is kept diffuse. This implies the use of

multiple pipes or culverts and not just a single

unit.

AC

SI

Construction phase Moderate

Significance

Water quality and

volume.

Riparian habitat up

and downstream of

the dam.





Impact


Significance

Before Mitigation


Party


Significance after

Mitigation

Management

Indicators

Decrease in the surface

water runoff into the

downstream wetlands.

Containment of water falling onto the

construction site thereby affecting the runoff

that generates stream flow.

Construction of the fresh water storage dam.

High Significance Construct clean water diversion structures prior

to construction to divert clean water away from

the construction area and prevent damming of

clean water.

Water users should be consulted with on a

regular basis. Should the downstream users

suffer a loss of water, the mine should offer an

alternative supply or pay compensation as

agrees by proactive consultation.

SI Construction phase Moderate

Significance

Water volume.

Feedback from

water users.

Noise

Increase in the ambient

noise level.

The use and movement of machines and the

transportation of materials during

construction.

The reverse sirens of the construction

vehicles and general diesel engine running

noise will add to the industrial noise of the

site.

Low Significance Carry out the noisiest labours as quickly as

possible and during normal working hours

(07:00 – 17:00) or according to applicable legal

criteria.

Follow the equipment’s operation and

maintenance procedures;

All vehicles must undergo periodic maintenance

and inspection;

SI

AC

Construction phase: Weekly Low Significance Complaints from

neighbours.

Visual

Change in the visual


area.

The mining of additional seams through

additional adits and the establishment of the

washing plant and its associated

infrastructure will have an impact on the

visual character of the area.

Lighting from vehicles at night during

construction activities, lighting masts and

security lights.

Moderate

Significance

Demarcate vegetation clearance areas so as to

ensure that the minimum amount of vegetation

is removed;

Remove the minimum amount of topsoil and

store for use in post-construction rehabilitation;

Salvage indigenous vegetation for re-planting

during post-construction rehabilitation;

Removal of vegetation should be done in a

'natural manner', i.e. avoid harsh straight lines;

SI Construction phase:

Monthly

Low Significance Complaints from

local people.





Impact


Significance

Before Mitigation


Party


Significance after

Mitigation

Management

Indicators

Use dark paving materials which blend with the

natural environment for road surfaces;

Slope berms to resemble the natural

surroundings as far as possible;


Where possible, use should be made of down-

lighting and directional lighting. The height of

poles and masts determines how broadly the

light is dispensed. If possible, the existing

overhead lighting method should be phased out

and replaced with an alternative lighting using

closer to source, directed LED technology.

Socio Economic

Additional employment

opportunities.

Refurbishment of the defunct Colliery. Moderate

Significance

(Positive)

Use local workers as far as possible;

Where possible use local companies to supply

construction material.

SI

AC

Construction phase Moderate

Significance

(Positive)

The number of

local jobs created.

The local and regional

road transport network

will suffer additional

pressure from the

haulage trucks.

Transport of construction materials to the

proposed site.

Moderate

Significance

The construction vehicles must remain on site

as far as possible during the construction

period.

SI Construction phase Low Significance Complaints from

road users.

Perception of the IAPs. Refurbishment of the defunct Colliery.

Ongoing rehabilitation of the disturbed area.

Moderate

Significance

Ongoing communication with IAPs must be

conducted and monitoring information must be

made available through the annual audit

reports.

SI/ECO Monthly Low Significance Feedback from

IAPs.

Heritage/Archaeological

Disturbance of heritage

resources

Construction and refurbishment activities. Low Significance The following measures should be taken if a

heritage resource is uncovered during the

construction phase:

All construction within a radius of at least 20m

of the indicator should cease. This distance

should be increased at the discretion of

supervisory staff if heavy machinery or

explosives could cause further disturbance to

the suspected heritage resource.

SI/ECO Construction phase Low Significance N/A





Impact


Significance

Before Mitigation


Party


Significance after

Mitigation

Management

Indicators

This area must be marked using clearly visible

means, such as barrier tape, and all personnel

should be informed that it is a no-go area.

A guard should be appointed to enforce this no-

go area if there is any possibility that it could be

violated, whether intentionally or inadvertently,

by construction staff or members of the public.

No measures should be taken to cover up the

suspected heritage resource with soil, or to

collect any remains such as bone or stone.

If a heritage practitioner has been appointed to

monitor the project, s/he should be contacted

and a site inspection arranged as soon as

possible.

If no heritage practitioner has been appointed to

monitor the project, the head of archaeology at

Amafa’s Pietermaritzburg office should be

contacted.

The South African Police Services should be

notified by an Amafa staff member or an

independent heritage practitioner if human

remains are identified. No SAPS official may

disturb or exhume such remains, whether of

recent origin or not.

All parties concerned should respect the

potentially sensitive and confidential nature of

the heritage resources, particularly human

remains, and refrain from making public

statements until a mutually agreed time.

Any extension of the project beyond its current

footprint involving vegetation and/or earth

clearance should be subject to prior assessment

by a qualified heritage practitioner, taking into

account all information gathered during this

initial heritage impact assessment.




Table 27: Potential impact and mitigation register for the operational phase


Impact


Significance

Before Mitigation


Party


Significance after

Mitigation

Management

Indicators


Altering the geotechnical


geological strata.

The coal mining activity will extract coal

from the geological seams using

conventional bord and pillar underground

mining methods.

High Significance The proportion of coal extracted during mining will be

limited to ensure that the planned factors of safety are

adhered to in the various sections.

No secondary mining such as stoping and goafing must

take place.

AC Operational:

Ongoing

Moderate

Significance

Mining according

to the approved

plan in the EMP.

Topography

Change in existing

topography.

Establishment, moving and growing of coal

and soil stockpiles.

Low Significance Keep the height of the soil and coal stockpiles under 10

meters.

SI/ECO Weekly

Inspection

Low Significance Height of the

stockpiles;

Number of

stockpiles;

Visibility of the

stockpiles.

Soils

Erosion and sedimentation. Stripping of vegetation leaving bare soil

surfaces.

Stockpiling of soils will expose the soil to

elements of erosion such as wind and water

as well as risking the occurrence of

compaction.

Moderate

Significance

The topsoil must be stockpiled separately and used for

the construction of berms: the gradient of the sidewalls

will be such as to prevent excessive wash during

storms. These will be grassed and managed to prevent

soil loss through erosion and excessive dust.

The soils must be stockpiled in the form of a berm not

exceeding 1.5 m in height in a position down slope of

the adit to contain the contaminated rain water run-off

around the area.

Maintain a vegetation layer on the berms.

Construct berms to trap sediment during the

operational phase;

Collect eroded sediment to re-use during post-

construction rehabilitation.

SI/ECO Weekly

Inspection

Low Significance Erosion;

Vegetative growth

on soil stockpiles.

Contamination of soils. Oil and/or diesel spills from operational

vehicles.

Moderate

Significance

Defining routes for the circulation of heavy machinery

and vehicles.

SI Ongoing

Low Significance Visible oil/diesel

spills on the

operational area.





Impact


Significance

Before Mitigation


Party


Significance after

Mitigation

Management

Indicators

Restricting machines’ movement to the strictly

necessary area;

Ensuring the impermeability of all storage areas for fuel,

lubricants and other chemicals.

Clean up any spills immediately and disposed of the soil

at a registered waste site.

Land Use

Reliable water source for

local community.

Accumulating storm water in the fresh water

dam.

Moderate

Significance

(Positive)

The water accumulating in the fresh water dam must be

made available to the community to use for livestock

watering and/or irrigation purposes.

SI Ongoing

Moderate

Significance

(Positive)

Feedback from the

local people.

Vegetation

Dust outfall on flora outside

the development footprint

area.

Operational activities which create fugitive

dust, such as the movement of haulage

trucks on unpaved surfaces.

Low Significance Clearly demarcate the area for clearance of vegetation

and within which operational activities may take place;

Prohibit activity outside of the demarcated area;

Implement dust suppression spraying on access roads

and the operational area;

Rehabilitate disturbed areas during the operational

phase.

SI Weekly Insignificance Limited area of

disturbance.

Establishment of alien

invasive species on the

operational area.

Removal of vegetation and compaction of

soils during the operational phase.

Moderate

Significance

A programme of alien weed control should be

implemented. Most important in this regard is

prevention of the spread of Wattle but effort should also

be made to eradicate the species as far as possible.

A veld burning plan should be drawn up by an

appropriate ecologist and be implemented. Provisionally

the property should be divided into four compartments

with there being two at high altitude and two at low

altitude. Two of each would be burned in each year

with the result that any one is only burned every second

year. The boundaries of the compartments as well

ancillary guidelines on firebreaks and procedures will be

documented in the burning plan. If at all possible, the

plan should be done in collaboration with neighbouring

property owners.

SI/ECO Quarterly Low Significance Limited area of

disturbance.





Impact


Significance

Before Mitigation


Party


Significance after

Mitigation

Management

Indicators

Loss of Sensitive Species Mining activities including washing and

transporting of coal.

Moderate

Significance

Since some animals need to drink from streams or

wetlands, while others require aquatic systems as their

primary habitat, it is essential to ensure that water

quality in those features is maintained at as high a level

as possible. Additionally, environmental water flows

should be maintained. Guidelines for maintenance of

the waterways have been provided by Terratest in the

Biodiversity and wetland assessment report (refer to

Appendix …)..

SI

ECO

Ongoing:

Monthly

Low Significance Presence of

aquatic species in

watercourses.

Surface Water

Contamination of surface

water

The storm water currently falling on the

polluted areas is flowing into the

downstream surface water resources causing

pollution of these streams and wetlands.

Storm water which falls directly onto the

operational areas will be contained in

pollution control dams for use as a dust

suppressant.

Leakages from the pollution control dams

and septic tank could pollute the

surrounding streams and downstream

wetland.

High Significance Since the condition of the watercourses is largely linked

to the condition of the terrestrial vegetation it is

important that the latter be maintained. Guidelines for

maintenance of the vegetation have been provided in

the Biodiversity Assessment done by Terratest and are

emphasised here (refer to Appendix …).

All “dirty” water must be contained in lined pollution

control dams.

No outlets from a pollution control dam or any other

source which may contain coal related substances, may

Discharge into a water course.

No polluted water must be allowed to leave the site or

flow into the surface water system.

Inspect storm water infrastructure, berms, culverts,

channels around operational areas to ensure they are

functioning effectively and are diverting clean water

away from all operational areas and containing “dirty

water”. Especially around the wash plant, stockpile and

discard facilities.

Maintain the septic tank system in good condition to

avoid spillages.

Regular maintenance of the operational vehicles and

machinery to avoid leaks and spillages.

All “dirty” water runoff must be kept on site and not

allowed to mix and contaminate clean runoff;

SI Ongoing:

Monthly

Moderate

Significance

Surface water

quality.

Complaints from

water users.





Impact


Significance

Before Mitigation


Party


Significance after

Mitigation

Management

Indicators

Domestic waste should be disposed of at a registered

disposal facility;

Ongoing monitoring of surface water quality.

Decrease of surface water

runoff into the surrounding

catchment.

All “dirty water” will be contained. No

polluted water will leave the site or flow into

the surface water system.

The fresh water dam will contain storm

water runoff thus reducing the quantity

entering downstream water resources.

Moderate

Significance

The affected area must be minimised to ensure that

effective control of the water balance can be

maintained.

Clean storm water run-off must be diverted around the

operational areas so as to discharge into the natural

surface water courses;

The diversion of storm water will include berms and

channels around the workings.

Construct clean water diversion structures prior to the

construction to divert clean water away from the

construction area and prevent damming of clean water.

Water users should be consulted with on a regular

basis. Should the downstream users suffer a loss of

water, the mine should offer an alternative supply or

pay compensation as agrees by proactive consultation.

Effective surface rehabilitation can influence the quality

and volumes of surface water that can be released from

the site.

SI Monthly Low Significance Surface water

quantity.

Complaints from

water users.

Surface rehabilitation. Surface rehabilitation will start during the

construction phase and continue into the

operational phase thus reducing the

footprint of the colliery.

Low Significance

(Positive)

No mitigation measures needed. SI/ECO N/A Low Significance

(Positive)

Limited disturbed

area.

Groundwater

Decrease in groundwater

level.

Underground mining and dewatering of the

adits.

Potential cracking of the impermeable layers

during mining.

High Significance A groundwater monitoring should be established as

soon as possible in order to generate a database.

Limit groundwater use as much as possible and

measure groundwater abstraction levels.

Should there be a significant reduction in supply of

groundwater to legitimate groundwater users, the

applicant should undertake to supply the affected

groundwater user(s) with water of equal quantity and

quality.

SI Quarterly

monitoring

Moderate

Significance

Groundwater

levels.





Impact


Significance

Before Mitigation


Party


Significance after

Mitigation

Management

Indicators


underlying aquifer.

Water infiltrating into the mine workings will

generate acid mine drainage.

Dirty water contained in the pollution

control dams could contaminate the

underlying aquifer through seepage.

Seepage could also occur on the operational

areas (stockpile and discard facility) if storm

water is allowed to pool.

The potential exists that leakages from the

septic tank system can seep through and

contaminate the underlying aquifer.

High Significance Any groundwater seepage that may collect inside the

underground workings during mining operations will be

pumped to the PCDs for use during dust suppression.

Underground water seepage will further be contained in

designated sumps to avoid uncontrolled flooding of the

workings during the operational phase, and to keep the

contaminated water in the smallest possible area.

Any groundwater seepage into the underground

workings must be re-used and contained on site.

Separate the aquifer from the facility by lining the

pollution control dams with HDPA (2mm) and clay on

top.

Compact the soil of the operational area;

Slope the surface of the stockpile areas to avoid

pooling.

Maintain the septic tank system in good condition to

avoid spillages.

Regular maintenance of the operational vehicles and

machinery to avoid leaks and spillages.

SI Operational

phase:

Ongoing

Moderate

Significance

Groundwater

quality.

Complaints from

water users.

Air Quality

Creation of fugitive dust. Dust will be created during the operational

phase by the activities at the beneficiation

plant, the discard dump and the haulage

trucks driving from the western adit (with

run-of-mine, raw coal) to the plant and

from the plant (with product) along the

district (gravel) road to the R543 (tarred)

road.

Moderate

Significance

Dust from the discard dump and haul roads will be

suppressed as necessary with water bowsers at regular

intervals. The water will be sourced from the pollution

control dams.

Rationalization of the vehicle and machines circulation;

Transport powdered materials in covered trucks.

SI/ECO Weekly Low Significance Complaints from

the public.

No excessive,

chronic dust

emanating from

the operational

area.

Air quality pollution Release of emissions into the atmosphere

from the construction vehicles.

Low Significance No mitigation measures possible.

SI N/A Low Significance Complaints from

neighbours.


Degradation/damage to the

wetlands and streams due to

mining operations.

Operational activities such as washing of

coal, stockpiling, transport of product, and

dirty water handling.

High Significance All “dirty” water must be contained in lined pollution

control dams.

SI/ECO Operational

phase:

Ongoing

Moderate

Significance

Water quality and

volume of





Impact


Significance

Before Mitigation


Party


Significance after

Mitigation

Management

Indicators

Since the condition of the wetlands is largely linked to

the condition of the terrestrial vegetation it is important

that the latter be maintained. Guidelines for

maintenance of the vegetation have been provided in

the Terratest Biodiversity and wetland assessment

report and are emphasised here (refer to Appendix …).

No outlets from a pollution control dam or any other

source which may contain coal related substances, may

discharge into a wetland.

No polluted water must be allowed to leave the site or

flow into the surface water system.

The disturbance footprint should be kept as small as

possible in order to minimize the impacts on the

riparian habitat;

A 500m buffer zone must be maintained around all

wetland areas.

Ensure that the riparian vegetation along the main stream

channel is maintained in its present ecological state in

order to ensure that the services provided by marginal

vegetation such as erosion control, maintenance of

biodiversity and sediment trapping persists.

Clearing of alien vegetation from the riparian zone must

take place.

On-going maintenance of the riparian zone will be

required in order to prevent the re-establishment of an

alien vegetative community.

All effort should be made to ensure that mine process

water does not come in contact with water in the

receiving environment.

downstream

wetlands.

Biodiversity of

wetlands.

Complaints from

landowners.

Noise

Increase in the ambient noise

level.

The washing of coal and transportation of

product during the operational phase.

Moderate

Significance

Mining activities must be carried out during normal

working hours (07h00 – 17h00);

SI/ AC Operational

phase:

Ongoing

Low Significance Complaints from

neighbours.





Impact


Significance

Before Mitigation


Party


Significance after

Mitigation

Management

Indicators

The reverse sirens of the operational

vehicles and general diesel engine running

noise will add to the industrial noise of the

site.

Follow the equipment’s operation and maintenance

procedures;

All vehicles and machines must undergo periodic

maintenance and inspection;

Visual

Change in the visual

characteristics of the area.

The mining of additional seams through

additional adits, coal washing along,

establishment of the discard dump with the

related operational requirements.

Dust pollution through the movement of

haulage trucks.

Lighting from vehicles at night during

operational mining activities, lighting masts

and security lights.

Moderate

Significance

Demarcate vegetation clearance areas so as to ensure

that the minimum amount of vegetation is removed;

Remove the minimum amount of topsoil and store for

use in post-operation rehabilitation;

Salvage indigenous vegetation for re-planting during

post-construction rehabilitation;

Removal of vegetation should be done in a 'natural

manner', i.e. avoid harsh straight lines;

Use dark paving materials which blend with the natural

environment for road surfaces;

Slope berms to resemble the natural surroundings as

far as possible;


Where possible, use should be made of down-lighting

and directional lighting. The height of poles and masts

determines how broadly the light is dispensed. If

possible, the existing overhead lighting method should

be phased out and replaced with an alternative lighting

using closer to source, directed LED technology.

SI Ongoing Low Significance Complaints from

local people.

Socio Economic

Additional employment

opportunities.

Operation of the Kwasa Colliery. Moderate

Significance

(Positive)

Use local workers as far as possible;

Where possible use local companies for transport

services and security.

SI Operational

phase

Moderate

Significance

(Positive)

Number of local

workers employed.

The local and regional road

transport network will suffer

additional pressure from the

haulage trucks.

Transport of product from the proposed

site.

High Significance No mitigation measures possible. SI N/A High Significance The district road

condition.





Impact


Significance

Before Mitigation


Party


Significance after

Mitigation

Management

Indicators

The local community will

have a reliable water resource

to use for irrigation and stock

watering.

The accumulating of storm water in the

fresh water dam.

Moderate

Significance

Make the water in the fresh water dam available to the

local community and farmers for use during irrigation

and livestock watering.

SI/CLO Operational

and after

closure

Moderate

Significance

(Positive)

Feedback from

local people.


Disturbance of heritage

resources

Operational activities such as underground

mining, disposal of discard.

Low Significance The following measures should be taken if a heritage

resource is uncovered during the construction phase:

All construction within a radius of at least 20m

of the indicator should cease. This distance

should be increased at the discretion of

supervisory staff if heavy machinery or

explosives could cause further disturbance to

the suspected heritage resource.

This area must be marked using clearly visible

means, such as barrier tape, and all personnel

should be informed that it is a no-go area.

A guard should be appointed to enforce this no-

go area if there is any possibility that it could be

violated, whether intentionally or inadvertently,

by construction staff or members of the public.

No measures should be taken to cover up the

suspected heritage resource with soil, or to

collect any remains such as bone or stone.

If a heritage practitioner has been appointed to

monitor the project, s/he should be contacted

and a site inspection arranged as soon as

possible.

If no heritage practitioner has been appointed to

monitor the project, the head of archaeology at

Amafa’s Pietermaritzburg office should be

contacted.

The South African Police Services should be

notified by an Amafa staff member or an

independent heritage practitioner if human

remains are identified. No SAPS official may

disturb or exhume such remains, whether of

recent origin or not.


potentially sensitive and confidential nature of

the heritage resources, particularly human

remains, and refrain from making public

statements until a mutually agreed time.

SI Operational

phase

Low Significance N/A





Impact


Significance

Before Mitigation


Party


Significance after

Mitigation

Management

Indicators

Any extension of the project beyond its current

footprint involving vegetation and/or earth

clearance should be subject to prior assessment

by a qualified heritage practitioner, taking into

account all information gathered during this

initial heritage impact assessment.

Table 28: Potential Impact ad Mitigation Register for the Decommissioning Phase

Potential

Environmental Impact


Significance

Before

Mitigation


Party


Significance

after Mitigation

Management Indicators


Altering the

geotechnical


geological strata.

The underground mine will be left

with the pillars intact.

The adits will be plugged.

Low Significance Control the mining to remain within the agreed

parameters of safety (during mining) and stability

(after mining).

AC Operational and

Decommissioning

phase

Low Significance Surface stability: key points will

be surveyed as part of the

monitoring programme.

Extra-ordinary recharge of the

underground workings, caused

by increased infiltration through

cracks to surface: the

groundwater rest levels in the

underground workings will

indicate a deviation from the

predictions of the groundwater

model.

Topography

Altering the

established

topography.

The decommissioning activities will

cause the man-made landscapes to

look more natural and be stable and

free-draining.

Moderate

Significance

(Positive)

The area will be shaped to emulate the pre-

mining topography where practicable-this would

probably take the form of terraces.

Emphasis will be on ensuring that the area is

safe, stable and free draining.

Sloping of remaining structures to ensure that

they blend with the natural topography;

SI Decommissioning

phase: Monthly

Moderate

Significance

(Positive)

Local subsidence.

Noticeable erosion.

Pooling of surface water.

Soils

Replacing of topsoil

and landscaping of the

disturbed area.

The areas to be rehabilitated will have

soils recovered from the stockpiles

and replaced with some compaction

Moderate

Significance

(Positive)

Topsoil will be replaced over the area to

complement the growth medium (subsoil) in

order to meet the two primary criteria, namely:

- topography management (stability) and

SI/ECO Decommissioning

phase: Monthly

Moderate

Significance

(Positive)

Growth of vegetation.

Soil fertility tests.




Potential



Significance

Before

Mitigation


Party


Significance

after Mitigation


Amelioration of Soils. over the cleaned (of carbonaceous

material) and landscaped areas.

- water management (free-draining).

All unrequired mining-related infrastructure

including roads, buildings and conveyor lines will

be demolished on closure.

All rubble on site will be removed to either the

discard dump or the adits and these areas

landscaped, top-dressed with sufficient material

and the appropriate vegetation.

Unrequired roads will be ripped to correct any

compaction created by the heavy traffic utilized

during the mining operation and rehabilitated

with the addition of appropriate fertilizers, lime

and grass seed mixes.

The areas to be planted will need to be

landscaped and engineered to a slope not greater

than 1:6. The replaced soils will then be ripped

to a depth of 20mm to loosen the soil, and all

weeds will be removed. A fertilizer mix if

required (of 3:2:1 at a rate of 200kg/ha) will be

applied at time of planting. In addition, and if

available, chicken litter should be applied to add

bulk (organic matter) to the heavy, clay rich soils.

For areas that are considered too steep, and

where a gradient of 1:6 cannot be achieved, the

use of Vetiver grass (Vetiveria zizanoides) or an

appropriately designed erosion control method is

recommended, and in places will be essential to

prevent erosion, and to stabilize the soils.

If Vetiver is used it must be planted according to

the slope gradient, length of slope, and degree of

erosion potential. A spacing of approximately

one row every five (5m) meters of vertical drop is

recommended. This might alter as the slope

becomes very steep, or very shallow. It is

Abnormal erosion.




Potential



Significance

Before

Mitigation


Party


Significance

after Mitigation


recommended that a specialist be used for the

specific areas of concern.

The top dressed areas will then be rolled and

seeded, preferably in February/March, or as soon

as the soil moisture is sufficient (monitor with

tensiometers) to guarantee that the seed has a

chance of germinating. A suitable seed mix

should be used to stabilize the replaced soils.

Compaction of the sub soils should be carried

out to an 85% Mod AASHTO, and monitored, so

as to achieve the required permeability rate for

the underlying materials, and minimise

infiltration.

The planting will be undertaken with water,

either, by making use of natural rainfall, or by

hydro seeding the seed mix onto the ground, or

having pre-wet the soils prior to planting, with a

weekly watering program (15 to 20mm/week) for

one month after planting, or until germination

has occurred.

A horticulturist will examine the grass stands one

year after planting to ensure that the grass has

established itself satisfactorily. A soil sample will

be taken in the June following planting, and

analysed to determine the required maintenance

fertilizer applications.

The establishment of grass will prevent erosion

and dust. Vegetation and soil rehabilitation will

continue until the land is self-sustainable, well

grassed until closure. The soils have moderate

erosion potential and therefore specific attention

must be paid to the implementation of rigorous

erosion control measures.

Land Capability




Potential



Significance

Before

Mitigation


Party


Significance

after Mitigation


The mining area will be

rehabilitated to an

applied grazing land

capability (actually a

rehabilitated mining

area).

The land capability will be positively

affected during the decommissioning

phase in that the disturbed areas with

a compromised capability will be

rehabilitated and the land capability

returned to a wilderness capability

class (as it was before mining).

Moderate

Significance

(Positive)

The topsoil will be spread over the whole area,

and a grazing potential will be achieved.

SI Monthly Inspections Moderate

Significance

(Positive)

Vegetative cover

Vegetative production.

Plant species diversity.

Land Use

Change in land use The land use will be changed from

mining back to agriculture.

Moderate

(Positive)

The land will be managed and used in such a way

that good farming practice is possible and

implemented.

The unrequired pollution control dams, dam wall,

berms, haul roads and stockpile areas will all be

removed and rehabilitated.

Pollution control dams will be breached and

rehabilitated when the water qualities are such

that the water can be released, or pumped into

the underground workings.

All the temporary facilities, including caravans,

ablutions and workshops will be removed from

the site.

SI/ECO Decommissioning

phase: Monthly

Moderate

(Positive)

Sustainable (applied) farming on

the rehabilitated areas.

Visual assessment of the

stability of rehabilitated areas.

Vegetation

Re-establishment of

indigenous vegetation.

The areas under rehabilitation will be

re-vegetated.

Moderate

Significance

(Positive)

The indigenous flora will be encouraged to re –

establish itself over time as part of the

maintenance programme.

A seed mix will be used to act as a nurse crop to

speed up the vegetation establishment rate to

ensure that erosion does not occur.

Mulching with veld grass (preferably in seed) will

take place during the first spring of the

rehabilitation programme. This will reduce the

potential for erosion from storm water and

SI/ECO

CLO

Decommissioning

phase: Weekly

Moderate

Significance

(Positive)

Soil fertility.

Vegetative (basal & ground)

cover.

Erosion.

Species count (species/m2).

Productivity (tons grass/ha).




Potential



Significance

Before

Mitigation


Party


Significance

after Mitigation


increase the re-seeding of indigenous species in

the area.

While the ideal result would be to have a sward of

indigenous, hardy, palatable, perennial grass

species capable of growing under conditions of

low soil fertility, such species are less easy to

establish on disturbed sites. It is thus planned to

make use of commercial (“artificial” pasture)

species for rehabilitation of the disturbed sites

for use as a pasture. Over time, this will also

enable the establishing of pioneer species and

natural succession of the ecological system.

Animal Life

Habitat and animal re-

establishment.

Domestic livestock will be used to

graze the pastures established on the

disturbed areas.

The larger wild life will be kept out of

these camps by fences.

Low Significance

(Positive)

The pastures will be grazed and maintained

according to a formal pasture management

programme by the future land owner/user to

ensure the organic matter and nutrient build-up

to the target (pre-mining) levels).

No trapping or snaring of wildlife will be

permitted within the area under management.

CLO Ongoing Low Significance

(Positive)

Productivity (Large stock

units/ha)

Surface Water

Maintenance of the

pollution control

structures.

The unrequired surface water

pollution control structures will be

rehabilitated during the de-

commissioning phase.

Moderate

Significance

(Positive)

Pollution control dams that are not needed for

future use will be breached and rehabilitated

when the water qualities are such that the water

can be released, or pumped into the

underground workings.

Carbonaceous material (sediment) will be

returned to the discard dump before it is finally

closed.

The legitimate requirements of the surface water

users will not be infringed upon and will be

addressed through the environmental monitoring

forum and the Authorities.

SI Decommissioning

phase

Moderate

Significance

(Positive)

Surface water quality.

Erosion.




Potential



Significance

Before

Mitigation


Party


Significance

after Mitigation


All legitimate requirements of the downstream

water users will be considered and closure

objectives set in consultation with users.

Mine residue deposits

and disposal facilities.

Rehabilitation of the residue deposits

and removal of disposal facilities

Moderate

Significance

(Positive)

Discard, slurry and any other mine residue

deposits from the clean-up operation during

rehabilitation of the site will be disposed of on

the discard dump, which then will be finally

shaped, capped and vegetated.

Industrial and domestic waste will no longer be

used (and thus no longer disposed of) on site.

The septic tank for sewage disposal will be left if

required for future use.

SI Decommissioning

phase

Moderate

Significance

(Positive)

Vegetative growth.

The surface water run-

off will return to its

pre-mining state

(Positive).

All material used for storm water

diversions and dam walls will be

reused during final rehabilitation

where required for decommissioning.

The rehabilitation of the soils and the

vegetation.

Moderate

Significance

(Positive)

Rehabilitation of the soils and vegetation must be

done such that the surface of the land will

emanate, as far as is practicably possible, the

pre-mining state.

SI Decommissioning

phase and after

closure quarterly

monitoring

Moderate

Significance

(Positive)

Localised settling, especially

along back-filled areas.

Erosion.

Groundwater


underlying aquifer

through Acid Mine

Drainage (AMD).

After mining, the abandoned

underground workings will be left to

fill with groundwater flowing in to the

underground cavity up to the pre-

mining groundwater rest levels.

High

Significance

Accelerated infiltration into the underground

workings will be limited by ensuring stability of

the geological strata above the mine cavity. This

precautionary approach will prevent the surface

rehabilitation required for the underground work.

SI/AC Quarterly monitoring High

Significance

Groundwater quality.

Complaints from water users.

Risk of decant. The rate of recharge to the

underground workings after

rehabilitation has been completed will

determine the risk of decant.

High

Significance

The volume of decant should be confirmed by the

aid of a groundwater model;

Ongoing monitoring of the groundwater level.

SI Quarterly monitoring Moderate

Significance

Erosion.

Ongoing Seepage. The discard dump will (probably)

continue to produce seepage until the

water table stabilizes, after which this

should reduce to an insignificant

volume (the infiltration through the

capping will be very small).

Moderate

Significance

(Positive)

The groundwater modelling exercise will quantify

the volume, quality and phreatic zones where

seepage is expected to occur.

Landscaping (to free-draining) and re-vegetation

of the disturbed areas will minimise infiltration

SI Quarterly monitoring Moderate

Significance

(Positive)

Vegetative growth.




Potential



Significance

Before

Mitigation


Party


Significance

after Mitigation


rates and thus the potential for seepage of

contaminated water.

Air Quality

Creation of fugitive

dust.

Removal of infrastructure.

Stabilising and levelling of the

disturbed area.

Moderate

Significance

Unacceptable dust generated a long haul roads

will be suppressed with a bowser.

The disturbed areas (including unrequired haul

roads) will be rehabilitated in order to prevent

ongoing dust production.

SI Decommissioning

phase: Weekly

Low Significance Feedback through the

monitoring committee.

No excessive, chronic dust

emanating from the

rehabilitated areas.

Air quality pollution. Release of emissions into the

atmosphere from the vehicles and

machines.

Low Significance No mitigation measures possible. CLO N/A Low Significance Complaints from neighbours.

Noise

Increase in the ambient

noise level.

Final landscaping of the disturbed

areas;

Demolition of infrastructure and

machinery used for these activities.

Low Significance Carry out the noisiest labours as quickly as

possible and during normal working hours (07:00

– 17:00) or according to applicable legal criteria.

Follow the equipment’s operation and

maintenance procedures;

All vehicles must undergo periodic maintenance

and inspection;

SI Ongoing Low Significance Complaints from neighbours.

Visual

Visual impact on

adjacent land users.

Rehabilitation of discard dump,

removal of coal waste and ripping of

hard surface areas, re-shaping of

surfaces, and re-vegetation of the

footprint area.

Moderate

Significance

(Positive)

Good housekeeping will mitigate against visual

impacts.

Sloping of remaining structures to ensure that

they blend with the natural topography;

Limit vehicles to established routes as far as

possible;

Re-vegetate disturbed areas with indigenous

vegetation.

SI Ongoing Moderate

Significance

(Positive)

Feedback from local people.

Vegetative cover.

Socio Economic

Unemployment On decommissioning of the mine

various labours will be left without

employment.

Moderate

Significance

A complaints register must be made available at

the mine reception and a toll- free complaints

number made available for the first year after the

operation.

SI Ongoing Moderate

Significance

N/A




Potential



Significance

Before

Mitigation


Party


Significance

after Mitigation


An environmental monitoring committee must be

established.

Perception of the IAPs Rehabilitation of the Colliery.

Ongoing rehabilitation of the

disturbed area.

High

Significance

Ongoing communication with IAP’s will be

conducted where monitoring information will be

made available through the annual audit reports.

A complaints register will be made available at

the security gate and a toll- free complaints

number made available for the first year of the

operation. An environmental monitoring


SI

CLO

Decommissioning

phase: Monthly

Moderate

Significance

Complaints from IAPs.


Disturbance of

heritage resources

Decommissioning activities. Low Significance The following measures should be taken if a

heritage resource is uncovered during the

decommissioning phase:

All activities within a radius of at least

20m of the indicator should cease. This

distance should be increased at the

discretion of supervisory staff if heavy

machinery or explosives could cause

further disturbance to the suspected

heritage resource.

This area must be marked using clearly

visible means, such as barrier tape, and

all personnel should be informed that it is

a no-go area.

A guard should be appointed to enforce

this no-go area if there is any possibility

that it could be violated, whether

intentionally or inadvertently, by

construction staff or members of the

public.

No measures should be taken to cover up

the suspected heritage resource with soil,

or to collect any remains such as bone or

stone.

If a heritage practitioner has been

appointed to monitor the project, s/he

should be contacted and a site inspection

arranged as soon as possible.

SI Decommissioning

phase

Low Significance




Potential



Significance

Before

Mitigation


Party


Significance

after Mitigation


If no heritage practitioner has been

appointed to monitor the project, the

head of archaeology at Amafa’s

Pietermaritzburg office should be

contacted.

The South African Police Services should

be notified by an Amafa staff member or

an independent heritage practitioner if

human remains are identified. No SAPS

official may disturb or exhume such

remains, whether of recent origin or not.


potentially sensitive and confidential

nature of the heritage resources,

particularly human remains, and refrain

from making public statements until a

mutually agreed time.

Any extension of the project beyond its

current footprint involving vegetation

and/or earth clearance should be subject

to prior assessment by a qualified

heritage practitioner, taking into account

all information gathered during this initial

heritage impact assessment.




Probability of Impacts Occurring Pre and Post Mitigation

A summary of the probability (%) of the identified impacts occurring during the construction,

operation and decommissioning phases pre and post mitigation have been given in Table

31 below. The aspects have been divided into biophysical, socio economic, health and safety

and heritage.

Certainty (probability) of occurrence or fact has been assigned five levels or categories,

namely:

Already happened: 100%

Definite: >90% of occurrence or fact

Probable: >70% of occurrence or fact

Possible: >40% of occurrence or fact, and

Unlikely: used also for the groundwater assessment to indicate that it is

not anticipated (through scientific methods) <=40% of occurrence or fact.




Table 29: Probability of Impact Occurring Pre and Post Mitigation

Phase 1

Phase 2

Phase 3

Construction

Operational

Decommissioning

Pre

Mitigation

(%)

Post

Mitigation

(%)

Pre

Mitigation

(%)

Post

Mitigation

(%)

Pre

Mitigation

(%)

Post

Mitigation

(%)

Geology 100 100 100 100 100 100

Topography 100 100 >70 >40 100 100

Soils 100 100 >40 <40 >70 100

Biophysical Vegetation 100 100 >40 <40 >40 >70

Animal life >40 <40 N/A N/A <40 >40

Surface water contamination >40 <40 >70 <40 >70 <40

Decrease in surface water runoff 100 100 100 100 >70 >40

Disturbance of the bed and banks of water

courses 100 100 N/A N/A N/A N/A

Surface Rehabilitation N/A N/A >70 >70 >70 100

Groundwater contamination >40 >40 >40 >40 >70 >40

Decrease in the groundwater level >40 >40 >40 >40 >70 >40

Sensitive landscapes >40 >40 >40 >40 N/A N/A

Socio-Economic

Air Quality >70 >40 >70 >40 >70 >40

Noise pollution 100 100 100 100 100 100

Land capability 100 100 N/A N/A >40 >70

Land use 100 100 100 100 >40 >70




Visual 100 100 100 100 >70 >70

Employment 100 100 100 100 100 100

Damage to regional road network 100 100 100 100 >70 >40

IAPs perceptions 100 >70 100 >70 >70 >40

Reliable water resource for local

community through the fresh water dam >70 >70 >70 100

Sites of

Archaeological

importance Heritage aspects >40 >40 >40 >40 N/A N/A

Archaeological Sites >40 >40 >40 >40 N/A N/A




Environmental Objectives and Goals for Mine Closure

The primary closure objective is to return the area disturbed by mining operations, as closely

as is practicable, to its pre-mining state within the decommissioning phase (three years).

The pre-mining state referred to is defined as the state the environment was found in before

any mining activities took place on the RE of Goedehoop 169 HT.

To achieve this objective, it is critically important to:

Stabilise the affected areas by landscaping and vegetation to the pre-mining

topography and cover, affording a land capability of grazing and wilderness

potential.

Establish a sustainable post closure land use that is ecologically sustainable, and

which would not preclude a nature reserve, eco-tourism or grazing for domestic

livestock.

Manage the surface and groundwater to ensure that the mining activities do not

cause an unacceptable, negative impact on the receiving environment (Inkomati

catchment) nor on the affected groundwater aquifer.

The plant along with its associated infrastructure, Co-Disposal dump site, pollution control

dams and the access roads will be rehabilitated and planted to artificial pastures for grazing.

The whole area would need to be considered for extensive grazing depending on the

involvement of the landowner. The land choice option would have little impact on the

rehabilitation options as any of the potential options would require climax veld that can

sustainably support domestic and wild animals.

Annual environmental reports detailing the progress of the rehabilitation programme will

be submitted to the Authorities and made available to the environmental monitoring

committee.

7.4.1 Geology

Closure objective

An area that has a stable geological foundation.

The impact on geology cannot be prevented, and mitigation by reduction and containment

of the impact through the application of proven and acceptable mining methods, including

a factor of safety that will continue to ensure a stable surface which will accommodate the

planned land uses for the area.


Factor of safety: prevent subsidence – especially to surface.

Acid mine drainage: the surface must be free-draining with no extra-ordinary

infiltration and groundwater make.




7.4.2 Topography

Closure Objectives

An area having slopes and features which emulate the pre-mining topography, and which is

stable and safe to people.

The post-mining, disturbed topography must be similar to the pre-mining topography

where practicable. The area must be free-draining so as not to inhibit the surface water

flow, thus causing excessive infiltration and extra-ordinary erosion.


No pooling of surface water.

No visible erosion.

7.4.3 Soils

Closure Objective

The establishment of a self-sustaining growth medium for grassveld vegetation.

The chemical (pH and nutrient status) and physical (microstructure) status of the replaced

soil must be stable (dynamic equilibrium) and not susceptible to erosion to ensure that the

residual impact of mining-related activities on the soil and consequently the land

capability is effectively mitigated.


Growth of vegetation, and

Stability of soil nutrient levels.

7.4.4 Land Capability

Closure Objectives

A land capability that will sustain an applied and controlled grazing programme.

The land should be suitably rehabilitated to sustain the planned post closure use with a

stocking rate of one large stock unit per ten hectares per annum.


Vegetative bio-diversity;

Vegetative cover;

Vegetative production.




7.4.5 Land Use

Closure Objectives

Establish an area that can be used for the sustainable grazing of domestic and wild animals.

The pre-mining land use on the undisturbed areas was one of grazing, while that of the

disturbed area was mining. The pre-mining undisturbed land use will revert back after

mining to what it was, while the rehabilitated, disturbed area will be able to be used as an

area for the grazing of artificial pastures.

Management indicators

Land use records;

Sustainability of land uses.

7.4.6 Vegetation

Closure objectives

Maintain the species diversity and productivity of the undisturbed areas. On the rehabilitated

areas, establish a vegetation cover which will stabilize the soil cover.

The re-establishing natural vegetation in the adit area will be assisted by a “nurse crop” of

artificial pastures grasses, while the operational area including the plant and discard dump

will be vegetated with artificial pasture grasses and managed as such.

While the ultimate goal should be to have indigenous, hardy, palatable, perennial grass

species capable of growing under conditions of radical disturbance and low soil fertility,

such species are generally commercially unavailable and less easy to establish on disturbed

sites. It is thus preferable to make use of commercial species to help the site to become

stable. This provides for pioneer growth, which allows the natural succession of the

ecological system to encourage indigenous growth. The objective is to establish a variety of

species that will produce cover at a variety of growth forms and which would occur during

as much of the growing season as possible. This is especially relevant to the

decommissioned adit and associated infrastructure areas further up the slope, as opposed

to the operational below on the flatter ground.

Management indicators

The vegetation of the rehabilitated areas will be monitored during the maintenance phase to

determine:

soil fertility;

vegetation ground/basal cover;

erosion potential; and

the possible need for revision of the rehabilitation programme to increase stability

through the bio-diversity.




7.4.7 Animal Life

Closure objectives

A non-aggressive environment, suitable to the natural re-habitation of indigenous and

domestic animal life.


Visual survey of an increase in faunal bio-diversity.

7.4.8 Surface Water

Closure objectives

The objective regarding surface water after the decommissioning phase is to:

ensure that not only the surface water remaining on the site, but also the surface

water leaving the site is of acceptable quality, and

to enable through landscaping, as much as possible of the storm water runoff to flow

off the rehabilitated site without undue delay, so as to minimise infiltration without

causing unacceptable erosion;

accumulate storm water runoff in the fresh water dam in order to supply the

landowner and local community with a more reliable source of fresh water.

Management Indicators:

Surface water quality and hydrological yield.

Maintenance of pollution control structures and fresh water dam

The surface water pollution control facilities along with the fresh water dam will either be

maintained or decommissioned as required by the post-mining land users during the de-

commissioning phase. All unrequired pollution control facilities will be rehabilitated by the

end of the maintenance phase.

Legitimate requirement of surface water uses on affected water courses.

Requirements of the downstream water users will be addressed through the environmental

monitoring forum and the DWS. All legitimate and reasonable requirements of the

downstream water users will be considered during the catchment reserve determination

process and closure objectives will be set in consultation with users during the water use

registration / licence application process.




7.4.9 Groundwater

Closure Objectives

The mine will ensure that private water users, if affected by mine dewatering, have a reliable

alternative source of water.

An ongoing, three-monthly monitoring programme will be implemented during operations.

The data obtained from the programme will be used to verify the predictions made in this

report.

The adits will be rehabilitated according in order to minimise the risk of acid mine drainage.

Carbonaceous material will be replaced at the bottom of the decommissioned adit, and

where possible, beneath the groundwater rest level, to ensure early flooding and the

limitation of oxidation processes.

Surface rehabilitation strategies to minimise groundwater impacts

Reference is made Table 30 the sections on Topography and Soils for supplementary

rehabilitation and remediation strategies.

Requirements of legitimate groundwater users in affected zones

The legitimate requirements of downstream water users will be used to determine the

closure objectives. This will be determined by the Reserve Determination process and

finalised during the water use licence application process.


Water quality;

Groundwater rest levels.

7.4.10 Air Quality

Closure objective

Restore ambient air quality to pre-mining levels.

The rehabilitation of the disturbed areas must be of such a standard that the level of dust

generated from (decommissioned) mining activities is insignificant. The generation of dust

will be adequately minimised through vegetative cover. This is both a health and aesthetic

aspect.


Visual detection by the IAP’s of unacceptable levels of particulate matter generated

from the site;

Visual assessments;

Feedback via the environmental monitoring committee.




7.4.11 Noise

Closure objectives

Restore the ambient noise levels to the pre-mining levels.

Once the decommissioning phase has been completed, the activities associated with mining

area would have ceased, and thus there would be no sources of noise. The typical noise

level for rural areas is 40dB.


Reports of incidents from the environmental monitoring committee.

7.4.12 Sites of Archaeological and Cultural Interest

Sites of archaeological importance

Closure objectives

There are no recorded sites of archaeological importance within the area planned to be

disturbed.

It is considered important to ensure that the IAP’s associated with post-mining land use

have an adequate awareness of any significant sites in the study area.


Feedback through the monitoring committee.

7.4.13 Sensitive Landscapes

Closure objective

No further damage to sensitive landscapes.

Where wetlands have been damaged by past agricultural activities there is opportunity to

rehabilitate some systems so as to mitigate for any new impacts which might arise as a

consequence of the mine operations. The systems which would be most amenable for

rehabilitation are those at the far north of the property. Depending on the degree of

rehabilitation it might be possible to trap a large part of the contaminants from the mine.

The sensitive landscapes outside the areas of disturbance should continue to be conserved

by the post closure land users as do the measures implemented by the mine.


Feedback from the monitoring committee;

Maintenance of the bio-diversity status quo.




7.4.14 Visual Aspects

Closure Objectives

There will be no unacceptable impact on the aesthetic nature of the site.

Many of the pre-mining disturbances of the study area are no longer responsible for causing

a negative visual impact as they have become effectively grassed. Certain of these disturbed

sites will again be disturbed by mining activities: these will be mitigated from a visual impact

point of view by the rehabilitation thereof (landscaping and vegetating the area). There will

be no unrequired mining super-structures left on the property for future use, except for the

access road.


Visual assessments;

Environmental Monitoring Forum.

7.4.15 Regional Socio-economic Structure

Closure objectives

Ensure that both the rehabilitated, (previously disturbed) mining area develops and retains

a positive and sustainable economic dynamic for the benefit of the community.


Continued economic growth in the community associated with the mine;

Feedback from the forum.

7.4.16 Interested and Affected Parties (IAP’s)

Closure objectives

To reach consensus on the achievement of closure objectives for the mine, and consequently

have a satisfied collective of IAP’s that would again consider a coal mine in their area to be

a positive opportunity.

Ongoing communication with IAP’s is of cardinal importance. For example, monitoring

information will be made available through the annual audit reports and the environment

monitoring committee, which will continue to facilitate communication with the IAP’s. The

complaints register will continue to be available throughout the decommissioning phase.


Dynamics of the environmental monitoring committee.

Interested and Affected Parties feel they have been adequately and meaningfully

involved throughout the life of mine and the rehabilitation/maintenance phase.

Feedback from the forum.




7.4.17 Infrastructure areas

Adequately rehabilitate all unwanted infrastructure.

All buildings will be removed unless identified for post closure use and an agreement with

the post closure user drawn up whereby the end user takes full responsibility for the use,

maintenance and liabilities associated with the said building/ infrastructure.


Reach consensus on the achievement of closure objectives for the mine;

Ongoing communication with IAP’s;

Stability of rehabilitated areas.

7.4.18 Mine residue deposits

The following six categories are included below under the environmental objectives for

mine closure:

Disposal facilities;

Ongoing seepage and control of rain water;

Long term stability;

Final rehabilitation in respect of erosion and dust control;

Sealing of underground workings and of rehabilitation of dangerous excavations;

Final rehabilitation of opencast mine haul ramps, roads and final voids (not

applicable).

7.4.19 Disposal facilities

Closure objective

There will be no operating disposal facilities other than the rehabilitated Co-Disposal

Dump site.

The septic tank for sewage disposal may be required for post-mining use.


No latent impacts;

No residual visual impacts.

7.4.20 Ongoing seepage, control of rainwater

Closure objective

Any ongoing seepage will be pro-actively identified and adequate measures implemented

before or during the decommissioning phase.

The clean rain water falling on to the (previously disturbed) rehabilitated site will not be

contaminated by residual carbonaceous (and other) pollutants remaining on the surface.





Effective clean-up, landscaping and re-vegetation of former operational areas to

reduce the infiltration and contamination of rain water falling on, and flowing over

the area.

The storm water run-off should flow along the landscaped water courses to ensure

free drainage from the site once rehabilitation has been completed and the

topography has been landscaped to the levels envisaged in the rehabilitation

programme.

The re-vegetation of the area (and especially the landscaped water courses) will

minimise soil erosion.

The re-vegetation of the area will assist in reducing infiltration rates.

Monitor the rest water level in terms of flows and water quality. Proactively

determine if the predictions that the groundwater rest table is at a sufficient depth

to ensure that seepage on surface will not occur from the old workings.

7.4.21 Long-term stability

Closure objective

Ensure that the planned secondary mining safety factors are adhered to during the end of

mining and landscape the disturbed areas with slopes that are stable.


No localised settling or subsidence;

No (extra-ordinary, visible) erosion.

7.4.22 Final rehabilitation in respect of erosion and dust control

Closure objective

Landscape the disturbed areas with slopes that are stable and an effective vegetative cover.


No (extra-ordinary, visible) erosion;

No dust generated from mining-related activities.

The mixture of grass species will be determined in conjunction with the Department of

Agriculture (Resource Conservation), Mpumalanga Parks Board and the post-mining land

user(s). It has been planned in this EMP to establish the rehabilitated areas to artificial

pastures, to be used and managed as separate units to the areas that will not be disturbed.

7.4.23 Sealing of underground workings and rehabilitation of dangerous

excavations.

Closure objective




The underground workings are to be plugged and made safe. Any dangerous excavations

are to be sloped or terraced.


No access to defunct underground workings;

No accessible slopes that are dangerous to people or animals.

7.4.24 Final rehabilitation of mine haul ramps.

Closure objective

Only roads required by the post-mining land users will remain on the property.

Roads not required will be rehabilitated (ripped, top soiled and vegetated).


No unrequired roads remaining;

Rehabilitated areas to be stable.




8 Public Participation Process

Stakeholder Participation is a legal requirement, where the potential exists for individuals

and /or parties to be affected by a proposed activity.

According to the principles of Integrated Environmental Management (IEM), these individuals

and/or parties should be involved in the decision-making process from an early stage in the

project, with regard to any relevant issues and concerns complementing the information on

which the Regulating Authorities would base their decision.

The decision would entail either,

proceeding to the next phase in the project,

supplementing inadequate information, or

not approving the project.

The decision for the project application is made on the basis of adequate information. The

decision-making framework will - in practice, comprise the Authorities and the Proponent.

This facilitation of effective communication between the Authorities, the Public and the

Applicant, forms the primary role of the Stakeholder Participation Process. Certain key

terminology needs to be clarified from the outset.

“Stakeholders” and “the Public”

“Stakeholders” refers to all individual(s) and institutions that are (potentially) associated with

the project including:

the Applicant, namely Siphiwo Investments(Pty) Ltd;

regulating (“Competent”) Authorities namely DMR (Witbank), DEDET

(Ermelo), Department of Water Affairs (DWS), Gert Sibande District

Municipality;

“Commenting” Authorities, namely the Mkhondo Local Municipality, IUCMA,

DWS, DMR;

Neighbouring and downstream communities (potentially affected parties);

Other interested and affected parties (IAPs).

It is the right of the IAP to decide whether or not she/he will participate in the process.

The “Public”, more specifically, refers to the last two categories described above, namely:

surface owners and residents;

Catchment Water Forum;




neighbouring and downstream (water users) communities (potentially

affected parties);

other interested and affected parties (IAPs).

Consultation – a level of Participation

“Participation” refers to a broad term of communication between parties, and includes

various levels of intensity in joint decision-making across a continuum, namely:

inform,

consult,

involve,

collaborate,

empower.

The specific level is dependent on the requirements of the project and its Stakeholders.

The Stakeholder Participation process intends to include the following actions to ensure that

the various individuals and parties will be included in the process, namely:

Stakeholder scan (inclusive and will be ongoing during the scoping

process);

Distribution of Stakeholder letters;

Individual discussions as may be necessary with

neighbouring landowners;

surface rights holders;

officials administering the application procedure;

Interested and Affected Parties (IAPs).

The focus of the public participation process will be to:

Identify and register potential Interested and Affected Parties (IAPs);

Empower the IAPs as to their participative process rights as “registered

IAPs”;

Define roles and responsibilities in the scoping process, namely to raise

concerns through response to a project notice placed in the press, public

meetings and reports;

Access to documentation, including:

Accessibility of the reports and clarity of the reports;

Access to information on decisions made by the Authorities and

Proponent;

Elicit comments in response to the decisions;

Raise issues and/or concerns for further investigation.




Notification Criteria

The Regional Manager or designated agency must make known to Stakeholders and

Interested and Affected Parties by way of a notice, that an application has been accepted in

respect of the land. This notice must be placed on a notice board that is accessible to the

public at the office of the Regional Manager or designated agency.

In additional to the notice, the Regional Manager or designated agency must also make

known the application by at least one of the following methods:

Publication in the applicable Provincial Gazette;

Notice in the Magistrate’s Court in the magisterial district applicable to the

land in question; or

Advertisement in a local or national newspaper circulating in the area where

the land to which the application relates is situated.

A publication, notice or advertisement must include:

An invitation to members of the public to submit comments in writing on

or before a date specified in the publication, notice or advertisement, which

date may not be earlier than 30 days from the date of such publication,

notice or advertisement;

The name and official title of the person to whom any comments must be

sent or delivered, and

The work, postal and street address and, if available, an electronic mail

address;

Work telephone number, and

Facsimile number, if any, of the contact person.

In addition, key Stakeholders will need to be individually informed of the application, with

communication via fax, e-mail or telephonically.

Creating Public Awareness

8.1.1 Site Notice

A site notice was placed at the entrance of the defunct Kwasa Colliery informing the local

people that an application for environmental authorisation has been lodged with DEDET

(Ermelo) and inviting them to form part of the public participation process (Refer to Appendix

A.1.1).

8.1.2 Newspaper Adverts

The key stakeholders were notified personally of the 1st public participation meeting that

was held on the 25th of February 2014. A press notice was placed in the local newspaper




(Excelsior) notifying the public of the intention of Siphiwo Investments (Pty) Ltd to apply for

environmental authorisation and inviting participation at a public meeting and / or directly

with the Public Participation office (refer to Appendix A.1.2.1).

The registered IAPs were personally invited to the 2nd public participation meeting that was

held on the 05th of December 2014 specifically to discuss the Water Use License application.

A press notice was placed in the local newspaper (Excelsior) notifying the public of the

intention of Siphiwo Investments (Pty) Ltd to apply for a Water Use License and inviting

participation at a public meeting and / or directly with the Public Participation office (refer

to Appendix A.1.2.2).

8.1.3 Background Information Document

A Background Information Document was handed out at the public meeting and given to

Foster Attorneys during the meeting in Ottosdal. The BID gave a background description of

Siphiwo Investments involvement and future plans for the mine. The BID further explained

the different development alternatives as well as a preliminary development plan (refer to

Appendix A.3.1 for a full copy of the BID).

Public Meetings

8.2.1 Public Meeting

The 1st public meeting was held on the 25th of February 2014 at 5pm in the Annysspruit

Farmers Association Hall. At the public meeting Siphiwo Investments explained that the

purpose of the meeting was to inform the key stakeholders that Siphiwo Investments had

started the process to apply for environmental authorisation in keeping with their plans to

resume mining at the defunct Kwasa Colliery. It was further explained that a formal process

has been initiated under Section 11 of the MPRDA for the transfer of ownership of the mine.

Background on the mine, the process followed to date, and context for the planned activity

was given, including the background and details of the due diligence and remediation plans.

uKhozi Environmentalists presented a presentation explaining what environmental

authorisations are needed as well as the preliminary plan of development.

The main concerns raised at the public meeting were (refer to the issues and response report

for detailed concerns raised by each stakeholder):

Livestock & crops: there is a concern that profitability of agriculture would be

compromised by mining activities;

Environmental provision: there is a concern about whether there would be enough

funds –and control thereof, for rehabilitation and pollution control;




Traffic and maintenance: stakeholders are concerned about the expected increased

traffic, especially large trucks, in terms of safety, and who would be responsible for

the much needed maintenance and upkeep of the roads;

Profitability of mine: stakeholders are concerned that the mine would not be

financially feasible, and would thus like to see the mining model;

Labour – has a big effect on the social and financial security of the community. If the

mine fails it would have a pronounced negative effect on those aspects of the

community.

The 2nd public meeting was held on the 05th of December 2014 at 5pm in the Annysspruit

Farmers Association Hall. At the public meeting uKhozi explained that the purpose of the

meeting was to discuss the WULA and to obtain issues and concerns specifically relating to

the proposed water uses at the colliery.

uKhozi Environmentalists presented a presentation explaining the WULA as well as the

process. The following main points were dealt with in the presentation (refer to Appendix

A.3.5 for the full presentation):

Background of the proposed project;

Property Description;

Project description (Planned activities for the Construction, Operational and

Decommissioning phases);

Section 21 Water uses that will be applied for;

The water balance;

Potential Biophysical and Socio Economic Impacts;

Management/ Mitigation measures;

Planned Specialist studies;

The way forward in terms of the WULA and Environmental Authorisation process.

The main concerns raised at the public meeting were (refer to the issues and response report

for detailed concerns raised by each stakeholder):

The construction of the in stream fresh water storage dam will reduce the surface

water runoff significantly and could result in the streams and wetlands downstream

of this dam drying up;

The planned product stockpile area at the entrance of the colliery is too close to the

wetland. It was requested that this stockpile area is moved further south away from

the wetland.

Environmental provision: there is a concern about whether there would be enough

funds –and control thereof, for rehabilitation and pollution control;




8.2.2 Focus Group Meetings

A target group meeting was held with the key stakeholders on the 5th of September 2014 to

discuss the intention of Siphiwo Investments to resume mining at the defunct Kwasa Colliery

and to get preliminary input from them. (Refer to Appendix A.6.1 for the Note for the

Record). The main concerns raised at this meeting were:

The costs to rehabilitate the footprint and to establish pollution control measures.

The available reserve is not big enough to justify carrying all these costs;

Storm water runoff into the surrounding water resources. At the moment coal waste

from the disturbed footprint is ending up in the surrounding rivers during rain events;

Erosion;

Health and Safety issues. There is an open power line on site that can result in serious

injury or death.

A target group meeting was held with the local community on the 6th of December 2014 to

discuss the intention of Siphiwo Investments to resume mining at the defunct Kwasa Colliery.

Authority Meetings

The Department of Water Affairs conducted a site inspection on the 21st of May 2013. The

site visit convinced the department that Kwasa Colliery has water uses that are unlawful.

Following this the DWA issued a letter of non-compliance to Kwasa Mining Services

requesting them to make a written representation if they believe that there are compelling

reasons for the department not to issue a directive.

Siphiwo Investments responded to the above mentioned letter addressing the issues raised

by DWA as follows (refer to Appendix A.4.2 for copies of the letters).

As per the requirements the letter received from the Dept. Water Affairs on the 24th June

2013, the following has reference:

There are several non-compliances at the mine, as noted during the visit by Officials

of the Department in May 2013.



Rescue manager to apply to the DMR to transfer the Mining Right to Siphiwo, who is

able and willing to take this over, together with the environmental liabilities.

Siphiwo recognises the urgency of the pollution control measures needed on the site.

uKhozi Environmentalists prepared an application for a Water Use Licence which was

submitted to Kwasa Collieries in March 2010. Siphiwo is currently following up to

determine the date and office to which this application was submitted. The

Department is requested to indicate if a copy of this application can be made

available.




Siphiwo recognises the need for a coal washing plant to beneficiate the Run-of-Mine

coal to an acceptable product specification, and this implies the need for a discard

dump.

Siphiwo has accepted a proposal from uKhozi Environmentalists to do the following

in order to become environmentally compliant:

Water Use Licence in terms of the National Water Act, 1998 – revision and amendment

as per the requirement for a washing plant and discard dump;

Environmental Authorisation in terms of the Mineral and Petroleum Resources

Development Act, 2008 – revision and amendment;

Environmental Authorisation in terms of the National Environmental Management Act,

1998– as may be relevant.

The DWA did not issue a directive.

The Department of Water Affairs and Sanitation (DWS) met with uKhozi on the 22nd of

September 2014. uKhozi presented the WULA to them. The department raised the

following main points (refer to the minutes of the meeting in Appendix A.6.4):

Good clarification is needed regarding the separation of the clean and dirty water on

site. Details must be given on how this will be done;

Proof of public participation must be included in the report. This includes Note for

the Records of meetings held, proof of newspaper notices, proof of site notices,

issues and response report etc.

S27 motivations must be done in detail especially the investments already made by

the applicant. It must indicate every cent spent to date on the proposed project.

The impacts of granting of WULA and not granting WULA must be assessed.

The current Infrastructure on site as well as the planned infrastructure must be

described.

The PCDs must be lined with HDPA (2mm) and if possible with clay on top;

All facilities on site must be fenced;

Overflow scenarios must be assessed if the PCDs don’t have 0.8m freeboard. If

according to the civil engineer designs all PCDs will have a freeboard of 0.8m then

the overflow scenarios don’t need to be assessed.

The Inkomati-Usuthu Catchment Management (IUCMA) Agency conducted a site visit on the

17th of November 2014 in order to advise on the way forward with regards to the Water Use

License application. On the 25th of February 2015 a meeting was held with the Inkomati-

Usuthu Catchment Management Agency (IUCMA) and the DMR to discuss a collective way

forward as to who is liable to rehabilitate or to contain the pollution at Kwasa Colliery.




Register of IAPs

Table 30: IAPs Register

Surname First name Organisation / Department Tel Nr Cell Nr Fax Nr Postal/

E-mail address

Mtshali BH Ward Councillor

(Mkhondo Municipality)

0176048484 0823623952 0178268127 [email protected]

Nkosi Bob Siphiwo Investments 074 104

0662

[email protected]

Dane Greg STA/Siphiwo 082 8549848 [email protected]

Nhlapho Shadrack Community Development

Worker

0822696907 [email protected]

Trebble Mike Goedehoop 0824184347 0178241131 [email protected]

Trebble Bruce Goedehoop 0825712624 [email protected]

Van Wyk Miranda Land Owner 0125473289 0822569383 [email protected]

Prigge Sven Land Owner 0825608179 [email protected]

Prigge Erich Goedehoop 0178262478 0823874031 [email protected]

Boshoff Reinette

Lawyer

(Guillaume Foster)

Land Owner 018 571

0031

018 571

0036

[email protected]

Roodewald Ralf Goedehoop 0836610465 [email protected]

Weber Werner Land Owner 0846529164 [email protected]

















E-mail address

Beneke Heinz Land Owner 0828252828 [email protected]

Zeelie Vlakhaas Land Owner 0827845816 [email protected]

Gary Day Land Owner 0823784610 [email protected]

Loubser Gudrun Land Owner/

Community Activist

0721108928 P O Box 682, Piet Retief 2380

[email protected]

Meyer Jenny Driehoek 082 686

8079

[email protected]

Fourie Manie Private 082 404

7404

[email protected]

Weber Ewald Land Owner 082 371

4713

[email protected]

Gibbons Bradley Endangered Wildlife Trust 082 568

5803

[email protected]

Mathavha Lutendo Environmental Liaison Officer

Kiepersol Colliery

087 310

2952

076 424

1381

086 668

4799

12 A Theo Mocke Street.

Piet Retief,

2380

South Africa

[email protected]

Mthembi Golden IUMCA Environmental Office:

Resource Protection and Waste

013 753

9000

083 825

8894

086 668

8681

[email protected]















E-mail address

Rasiuba Thabo IUMCA Environmental Office:

Resource Protection and Waste

013 753

9000

N/A 086 668

8681

[email protected]

Ramovha Matshilele Department of Mineral Resources

(Mpumalanga)

013 653

0500

[email protected]






Issues Raised

Issues identified should be recorded and the assessment based on:

The participation of IAPs as an indication of the success of the scoping exercise,

The perceived significance of the issues, and

A measure of the sustainability of the outcome/solution.

The overriding objective during this consultative process is to create an atmosphere

conducive to sharing knowledge between all Stakeholders to ensure that issues

identified are used in a positive and constructive manner.

All parties will be given the opportunity to raise their issues – be they fact or

perception. The number and frequency with which issues are raised, and the intensity

and extent to which they are debated gives a direct indication of the following:

The success of the process;

The perceived significance of the issues; and

A measure of the sustainability of the outcome/solution.

The primary objectives of the scoping exercise include:

Identification and evaluation of existing relevant information;

Identification of a broad range of issues of concern to the Stakeholders through a

consultative process, and

Identification of alternatives accommodating a wide range of criteria, and falling into

three broad categories, namely:

Social,

Biophysical / “Environmental”

Economic.

Consultation with the relevant Authorities, on a formal basis as to their requirements

for administration of the issues and concerns provisionally raised during scoping.

Identification of additional Interested and Affected Parties (IAPs) and the recording of

their issues of concern in response to information in local newspapers, consultation

with local associations and other key community representatives.

Discussion of the comments raised at scoping meetings with focus groups.




Issues and Responses

The issues and concerns recorded during the public participation process to date are tabled below along with the response from the

Environmental Assessment Practitioner (EAP) and/or Siphiwo Investments.

Table 31: Issues and Responses

Name: Capacity: Issues & Concerns: Responses:

Gudrun Loubser Private At the key stakeholder meeting that was held on the

5th of September 2013 Mrs Loubser had the following

comments and concerns:

(1) Coal lying around on site.

The coal lying around on site would need to

be cleaned up before operations start. Who is

going to remove this coal and who would

profit from this?

Some of the coal on site has already been

removed. Who was responsible for this?

The profit made from the coal removed from

site must go to community and rehabilitation

of the area.

(2) Job opportunities

(1) The area will be cleaned and storm water

control measures will be implemented during

the construction phase to contain the current

sources of pollution.

Siphiwo Investment started to remove the

coal.

What the mining company must do is:

Firstly make money available upfront to clean

up the area before mining starts.

Secondly during operations for every ton coal

sold the mining company need to put money

aside for rehabilitation.

(2) The applicant’s representative Mr Bob

Nkosi should speak to the local people and

uKhozi consult with the Ward Councillor

during the public participation process.





When the mine operated under Kwasa

Collieries Chief Mathetwa’s people were given

the available jobs and the closer community

felt that they were being neglected.

Advised that the closer community needs to be

involved in discussion in order to avoid

conflict.

(3) Life of Mine

Why is Siphiwo Investments interested to do all

the environmental studies and take over the

liability just to mine for 1.5 years

(4) Criminal Case against Kwasa Collieries

Siphiwo Investments must be aware that there

is still a criminal case against the mine. Should

Kwasa Collieries be found guilty they will need

to pay the legal and environmental costs to the

concerned residents of Mkhondo.

(5) Extent of Kwasa’s footprint

(3) The life of mine is not 1.5 years as

previously indicated. It is estimated to be

between 6 – 10 years including the closure

phase.

(4) Noted.

(5) A hydrosensus and groundwater study

will be done using previous work. A

hydrology study will also be done using civil

engineers.

(6) Noted.

(7) Noted.

(8) The Section 11 was the ownership

transfer from the previous owner to the new

mine owner. Operations may begin under a

contract mining arrangement before the

s.11had been granted and the ownership

transferred, and the coal would be sold as

Run-of-Mine.

(9) The relationship between Siphiwo, STA

and Jindal were explained as follows:





Siphiwo Investments must determine the

footprint of Kwasa by taking water and soil

samples to see how far seepage has occurred.

(6) Environmental Impact Assessment

The EIA baseline information from before

mining must be used for the new studies. Not

after the damage has occurred.

(7) Sensitivity of the area

No mining should take place in the Piet

Retief/Wakkerstroom area. The area is too sensitive

with regards to water resources and because of this

there are no mitigation measures, just damage control

measures. Due to the water resources found in the

area it is a strategic important area for the country.

(8) What is a Section 11 Transfer?

(9) Relationship between Siphiwo Investments and

Jindal

Requested clarity regarding the collaboration

between Siphiwo and Jindal.

Is Siphiwo or their mining contractor involved

in any illegal mining? According to Mrs Loubser

Bob Nkosi is a shareholder in STA;

Siphiwo is owned by Bob, but

financing is done through STA;

Jindal has an arm’s length contract

mining arrangement with STA.

Jindal had wanted to purchase Kwasa,

but this had not been successful. The

coal in the stockpile area at Kwasa

was sold to Jindal to cover costs and

to remove this pollution source.

With regards to Kwasa they have complied

with all the DMR requirements, and with

regards to the Dundas seem at Jindal they

were told to go ahead and as a contractor

they did their job.

(10) Siphiwo have capital and overseas

investments, and have made sure everything

is in order to make sure the funding is

adequate. The project team know the area

and know what needs to be done to mine the

reserve at Kwasa successfully. For example

they plan to establish a washing plant at the

mine which was not done in the past and this





Jindal is mining the Dundas seam illegally and

as a contractor STA is also then conducting an

illegal activity.

(10) Rehabilitation of the area

Siphiwo might also fail like previous mining

company’s attempting to mine at Kwasa

successfully. This would mean that the area

would stay un-rehabilitated and continue to

pollute the surrounding environment.

What security can be shown to ensure the

same mistake won’t happen again.

(11) Sustainability of Kwasa Colliery

Siphiwo want to mine at Kwasa for profit and

to recover revenue – making the prime reason

business.

She requested honesty in what the venture is

truly about, which in her opinion was to make

money. A concern was voiced that if the land is

damaged then they cannot move forward with

other opportunities (such as renewable

energy).

is considered critical to ensure successful

production.

Siphiwo have already appointed uKhozi to

conduct the EIA and Water Use

Licence application as part of the

environmental authorisation process. This

was not done by previous companies.

Siphiwo are waiting for the Section 11

process to be completed after which they will

go ahead and do a proper Social and Labour

Plan (SLP) to ensure it addresses the

community and their best interests, and

submit it to the DMR. The whole process will

take time but that it is needed in order to do

it properly.

(11) There is always a qualitative element to

business. Siphiwo realises that the world is a

finite resource and that they have to look

after each other. They do have to make

money, but also have to put aside the funds

to rehabilitate to make sure the activity is

sustainable.

It was suggested that a separate fund is put

together which would be open to the public





It was requested that Siphiwo come back to the

stakeholders with their business proposal to

satisfy them that the planned operation is

feasible.

to show the money that is available for

environmental provision.

Bruce Trebble Landowner Goedehoop Mr Bruce Trebble had the following comments and

concerns:


He is not necessarily concerned about the

reopening of the colliery because the area was

left in such a bad state that it is currently

polluting the surrounding water resources.

However he is concerned about what they leave

behind after the remaining reserve is mined

out.

From his experience mines never tidy up

afterwards because it is not in their interest.

How much coal there is at Kwasa, and if there

will be enough money to cover the cost of

rehabilitation?

(1) What the mining company must do is:

Firstly make money available upfront to clean

up the area before mining starts.

Secondly during operations for every ton coal

sold the mining company need to put money

aside for rehabilitation.

The amount of tons would be difficult to

state off hand, but there would be enough

for STA to conservatively mine 1.5 Million

tons and perhaps more beyond the barriers

(subject to the necessary permits). The only

way the mine can really function is to bring in

an operator to mine at cost to ensure capital

for environmental provisions, and have

money at the DMR for the environmental

liability. STA and Siphiwo feel confident





What happened to the money set aside for

rehabilitation by the previous mine?

The rehabilitation after the mining was the

main concern. Money should be put aside for it

and should be managed by a committee which

would keep track of where the funds are used

and how they are used.

It would be advantageous to get people from

the community to work with the mine who

would use the capital efficiently to rehabilitate.

It was suggested that the Annysspruit Farmers

association Chairman and Vice Chair should

form part of the rehabilitation fund and be two

of the signatories.

How many signatories is required for the

rehabilitation fund?

It was suggested that the Annysspruit Farmers

Association will have the majority of the

control (65%) over the funds.

(2) Discard Disposal

about increasing the provision because they

know they will get a higher price for the coal.

Not sure what happened to that money but

most probably nothing had been set aside.

Each mine should have an environmental

provision fund and Siphiwo believes that the

stakeholders should be privy to that

information. It is unacceptable for a mine to

come in, rape the land, and then leave it for

the community to handle.

In terms of mine closure, it would be the

responsibility of the mine, but it would be

important to get the stakeholders into the

process. They could get an independent

company to do the rehabilitation, but

rehabilitation would remain their (the mine’s)

responsibility ultimately. It would be perfectly

feasible to get people such as Mkhondo

Green in to assist with the rehabilitation.

The request to have signatories on the

rehabilitation trust fund was noted and will

be discussed with the applicant.





Siphiwo know they want to mine and sell the

product but don’t know what to do with the

discard. Will Siphiwo start mining if they don’t

find an appropriate place to dispose of the

discard?

(3) The in stream fresh water dam

The proposed fresh water dam must rather be

constructed off-stream as the stream plays a

major role for the watering of livestock and the

health of the wetlands especially during the

dry winter months.

The wetland downstream of the proposed fresh

water dam is used for grazing and is very

important for the local community. If the dam

is constructed in-stream, the stream will not

flow which will result in the wetland drying up.

This will have a major impact on the local

community. The wetland also forms part of a

breeding site for water fowl and crested

cranes, blue cranes and a number of game

species (Reedbuck).

(4) Ground and Surface water monitoring

The number of signatories for a rehabilitation

trust fund usually ranges from 3-5.

(2) Department of Water Affairs (DWA) will

not issue a water use license if there isn’t an

appropriate plan to dispose the discard,

which would mean they may only start

mining without the updated WUL through the

Jindal adit into a block within their Mining

Rights area and the coal would be sold as

Run of Mine.

(3) This is the reason for applying for a

Section 21(c&i) water use. The DWA will

assess the impact of the dam on the surface

water runoff and if it is decided that the

impact will be too severe on the downstream

water uses they will not grant the Water Use

License for the construction of the in stream

fresh water dam. The dam would then be

moved to an off stream location.

The location of the dam will be discussed

with the applicant and the engineer.

According to the engineer the amount of

water which will be stored in the dam is 90

000m3/annum and the total amount of





Who will do the ground and surface water

monitoring at the proposed mine?

Who will pay for monitoring after the operation

has seized and what will happen after the two

year monitoring that is needed after the

operation has seized?

(5) Water Use License Application

Who is the representative from DWS to contact

regarding the proposed project?

(6) Job Creation

No unrealistic promises regarding job creation should

be made as this will create expectations.

runoff from the catchment area is 670

000m3/annum.

(4) The applicant will decide who to appoint

to do the water monitoring at the colliery but

that there is a good chance that uKhozi will

do the monitoring. The colliery must

continue with monitoring for two years after

the operation has ceased and they need to

make provision for this in their financial

provision for rehabilitation. The outcome of

the water monitoring results will determine

the way forward.

(5) It was Zethu Makwabasa from the Durban

office and now it is Golden Mthembi from

IUMCA (DWS Nelspruit office). Nelspruit DWS

is the regulating authority for the

Usutu/Inkomati Catchment.

(6) This was noted and agreed to on behalf of

the applicant.

Erich Prigge Landowner Mr Prigge raised the following comments and

concerns:


(1) A meeting should be had regarding the

Social and Labour Plan (SLP), to see what

commitments were made by the previous

company.





In principle mines need to put money aside for

rehab but no one does.

The IAPs should have a guarantee that the

mine can deal with the environmental

Liability.

Money set aside for rehabilitation could be

squandered on other things, where individuals

or organisations would benefit instead of the

environment.

(2) Environmental Authorisations and adhering to the

laws

Previously Kwasa Colliery did not have the

necessary environmental authorisations.

The stakeholders are weary of anyone wanting

to mine – which is because they have heard the

same story before. However at least Siphiwo is

starting with an environmental process and are

having environmental studies done.

He is concerned about corruption. Most mining

companies have government connections and

according to him they get away with doing

(2) uKhozi have already been appointed by

the applicant to conduct the EIA as well as

the Water Use Licence Application for the

refurbishment of the colliery. The

construction phase will only go ahead once

the necessary environmental authorisations

have been obtained.

Siphiwo will take small steps to build up

trust, and this would be aided by working

together.

(3) Noted.

(4) A portion of the discard will be sold.

There will be an element of discard

remaining on site and the correct procedures

will be followed to dispose of it.

(5) Siphiwo has people that know how to run

a mine. It must be run ‘lean’ with the right

amount of money being spent on the right

things (not luxuries). Siphiwo is a South

African company, and they already have a

market for the coal within South Africa, which

will generate a cash flow for STA.





what they want without having proper

environmental studies done.

Mining can’t be stopped however the mine

must follow the rules and commitments made

in the EIAR, EMPR and WUL in order to

minimise the environmental impacts.

(3) Access Road

Siphiwo Investments must use a different

access road. The Jindal road can’t take any

more traffic.

(4) Discard Disposal

What will happen to the discard?

(5) Feasibility of Kwasa Colliery

How are Siphiwo going to make money when

surrounding mines were struggling?

Siphiwo and STA are professional miners, and

since STA has been contracted to Jindal they

(Jindal) have had more tons of coal mined

than ever before.

Mike Trebble Landowner Mr Mike Trebble had the following comments and

concerns:

(1) Dust Pollution

(1) Noted. Mitigation measures will be

described in the EIAR. It would make sense

for Jindal (Goedehoop) and Kwasa to work

together.





He is concerned about dust pollution that will

be caused by the additional haulage trucks on

the Jindal access road.

The applicant should get the extension of the

road tarred passed the entrance to Kiepersol to

Kwasa.

(2) Erosion

During previous operations Kwasa dug out

ditches to allow water to flow out in order to

continue mining. These ditches are becoming

dongas now and influencing the boundary

fences.

(3) Involvement of local communities

Local people do not see the broader picture.

The local people do not care about

environmental issues like the water quality or

air pollution they are only thinking about job

opportunities.


(2) Noted.

(3) Noted.

(4) Noted. This is what Siphiwo is planning to

do.

(5) The life of mine is approximately 6 – 10

years, based on a figure of 20 000 to 30 000

tons planned to be mined per month.

(6) There were no environmental policies in

place in the past, and that now they are

trying to correct all that and trying to sort

things out. Siphiwo have said the water use

licence must be in place first before mining

starts. Siphiwo will implement proper

mitigation measures to avoid or limit the

pollution caused by Kwasa Colliery. Siphiwo

have already started removing the coal that

was lying around at Kwasa.

The location of the product stockpile will be

investigated and if necessary it will be able to

move it south. The specific location was

chosen for the easy access for the

transporting of the product but it could be





If DWA can’t get the money from Kwasa

Collieries to rehab the mine it would be a good

alternative if a company comes in, mine the

remaining reserve and rehabilitate the area

when they leave.

Mkhondo Green does a lot of good work and

has necessary skills. They should sit on the

committee and assist the mine in managing

the environmental rehabilitation process.

(5) Life of Mine

What is the expected life of mine?

(6) Contamination of surrounding water resources by

Kwasa Colliery

Mr Erich Prigge had lost 8 calves and another

farmer lost 11 pigs after they drank water from

a stream running below Kwasa Colliery – which

was the source of their anger towards mining

in that it affects their people and livelihood.

The location of the product stockpile area at

the entrance of the colliery is located very

close to the wetland on his farm. It was

suggested that it is moved further south.

moved further up the access road if

necessary to reduce the risk of impacting the

wetland.

(7) Noted. The use of the main access road

and maintenance thereof will be discussed

with Jindal. The internal roads at Kwasa

Colliery will be upgraded.

(8) Water found underground in the

underground workings would be used as

make up water, and based on the current

estimates there will be enough water. Water

from pollution control dams will be reused,

and in dry cycles water from boreholes will

be used as make up water for the washing

plant.

(9) According to the title deeds, the

remaining extent refers to portion 0.

(10) Siphiwo plans to buy the whole farm.

The plan is to allow the current activities on

the farm to continue.





(7) Increased Traffic and Safety on the roads

The stakeholders are concerned about the

increased traffic expected on the roads due to

mine operations and the transport of coal.

They have wives and children using the roads,

and would like to ensure their safety.

The maintenance of the roads would be crucial

with increased use. Currently, the Kwasa road

is badly eroded and there are cattle on the

road that gain access through the gaps in the

fences created by the erosion. Safety on the

roads is a concern.

(8) Water availability

Will there be enough water for a washing plant.

(9) What portion of Goedehoop is involved the RE or

portion 0?

(10) Does Siphiwo plan to buy the whole farm or only

the area where the coal reserve is and what will





happen to the current lease agreements that are in

place for Goedehoop portion 0. ?

Sven Prigge Landowner

(1) Storm water runoff

He is concerned about storm water runoff from

the mountain. People don’t realise how much

water comes off the mountain during rainfall

events and because of this proper measures

are not put in place to manage these events.

He is concerned that Kwasa do not have access

to enough land to build proper pollution

control dams. He said Kwasa has 30 ha and

according to him it is difficult to put in

pollution control measures in such a small

area.

(1) Kwasa has two options with regards to

screening:

Do screening out at the old

Goedehoop footprint;

Do screening at the mine;

Both these options will be included in the EIA

and WULA in order to compare the different

environmental and socio economic impacts

to determine which of the two the better

option is.

(2) Noted. A mine manager will be on site

permanently.





He suggested that Kwasa must consider doing

screening off site.

(2) Oversee and Control

From previous experience the mine owner is

never on site only a contractor. There is

nobody accountable on site when there is a

problem.

(3) Coal Washing Plant

If coal washing is going to take place at the old

Goedehoop site then the road there needs to be

tarred. The current state of the road will not allow

trucks or even normal bakkies to drive on it when it

rains.

(4) Pollution Control Dams

What are the function of the four pollution

control dams?

What will the water from these dams be used

for?

Will the water undergo treatment before being

utilised for dust suppression?

(3) Noted.

(4) The PCDs will contain contaminated water

from the site in order to prevent it from

entering the surrounding streams. The water

from the PCD’s will be recycled and used for

dust suppression as well as make-up water

in the washing plant.

The water will not be treated (other than the

settling out of solid particles), and this is why

a Section 21(g) water use is applied for.

(5) The dam will be constructed with an

overflow or an outlet of sorts. The dam will

be located close to the community on the

eastern side of the access road into Kwasa.

One must look at the proportion of water

coming from the mining area catchment

which will be stored in the dam. The in-

stream construction will result in less

operating costs for the local community and

farmers in the future because the water

stored in the dam will be available to be used

by the community and farmers for stock

watering and irrigation. The DWS will assess

the impact of the dam on the surface water

runoff and if it is decided that the impact will





(5) In stream Fresh Water Dam

Where will the freshwater dam be located and

will it have an overflow or some sort of outlet?

If too much water is used, the dam will not be

able to overflow and therefore the stream and

wetland downstream of the dam will dry up.

The stream flowing into this dam is the only

stream in the area that has not been polluted

yet, and therefore the dam should rather be

constructed off-stream because during the

winter months there will be no runoff, and

therefore the stream won’t be flowing.

(6) Goedehoop’s proposed conveyor belt

Does the proposed conveyor of the Goedehoop

Project form part of the Kwasa project.

Kwasa must consider making use of the

conveyer belt to transport the ROM to

Kiepersol and do the washing there. This will

mean that no wash plant or discard facility

would be needed at Kwasa and therefore the

impacts on the environment will be minimised.

be unacceptable (too severe) on the

downstream water uses the department will

not grant the Water Use License for the

construction of the in stream fresh water

dam. The dam is also being considered at an

off-stream location.

The location of the dam will be discussed

with the applicant and the engineer.

According to the engineer the amount of

water which will be stored in the dam is 90

000m3/annum and the total amount of

runoff from the catchment area is 670

000m3/annum.

(6) No the conveyor only forms part of the

Goedehoop project. Kwasa has nothing to do

with the conveyor.

This suggestion was noted. It does make

sense to do it that way from the

environmental (and economic) perspective

and that Ken Smith would continue to

encourage discussions between Siphiwo and

Jindal to try to reach an agreement.

(7) The applicant would like to sort out the

current pollution but have to wait for the WUL





(7) When do the applicant want to start operation?

(8) Job Creation

If there are any meetings with the communities no

promises should be made if they cannot be kept.

to be granted and Environmental

Authorisation. This could take up to a year.

However DWS has been on site and would

support actions to sort out the current

pollution.

(8) This was noted and it was agreed on

behalf of the applicant.

Jenny Meyer Landowner Mrs Meyer raised the following comments and

concerns:

(1) Storm water runoff

What would happen to runoff water from the

plant?

(2) Dust Pollution

What will be done to minimise dust pollution

from stockpiles during windy conditions.

(3) What will happen to the rehabilitation funds if the

mine is bankrupt?

(4) The landowners would like to be part of the trust

fund controlling body. There should be at least two

signatories from the community for the fund.

(1) Water will be directed to pollution control

dams. Berms and trenches will be

constructed to separate clean water from

dirty water and direct the dirty water to

pollution control dams thus protecting the

surrounding environment. A civil design

engineer will be appointed to design the

storm water management plan.

The intensity of rainfall is important, and the

engineer that will be used, knows the area

well, and will take all aspects into account

when designing the pollution control dams

and storm water management. Regulation

704 governs how those dams are designed,

so it will be according to that. The current

dam was designed for a smaller area, so the

new design will need to be larger.





(2) Dust suppression would be undertaken on

stockpiles to minimise dust pollution. The

water used for dust suppression will mainly

be sourced from the PCD’s.

(3) The money for pollution control and

rehabilitation should be dedicated to a

specific mine and should be used to

rehabilitate the specific area, but that in

practice the funds could be allocated by the

DMR to other higher priority mining areas

(4) This was noted.

Guillaume Foster

(attorney)

Representative of Reinette

Boshoff

Mr Foster had the following comments and concerns:

(1) Previous Environmental Impact Assessments

(1) A previous Mining Right had been granted

in terms of the Mineral and Petroleum

Resources Development Act, 2002. The

current EIA is to fulfil the terms under the





Haven’t there been previous EIA’s done at the

Kwasa Colliery?

(2) Business Rescue Process

Ms. Boshoff had a land use and rental

agreement with Kwasa Mining Services for the

lease of the farm house on the property.

Currently, Kwasa Mining Services are in debt to

Ms. Boshoff in the amount of approximately

R412 500.00, plus escalation at 15.5% p.a.

Ms. Boshoff was not informed about the

business rescue application or plan, and thus

was not initially registered as a creditor in the

process.

Foster Attorney wrote a letter to the business

rescue practitioner, and in response was sent

documentation and a claim form with the

regret that they were unaware that the

property owner had a claim. Ms. Boshoff is

concerned over her recognition of a claim,

should the Section 11 (transfer of Mining

Right) go ahead, and if there are sufficient

funds to meet her claim.

National Environmental Management Act,

1998 newest amendments, together with the

Water Use

Licencing programme.

(2) Mr. Ken Smith, as representative of

Siphiwo Investments, acknowledged the

points made, and expressed his intentions to

discuss them with Siphiwo and its strategic

partner, STA.

(3) Noted. These potential impacts will be

assessed in the EIAR.





Foster Attorney highlighted irregularities

within the business rescue plan (additional

details of which can be sourced directly from

Mr. Guillaume Foster).

As a result of the frustration caused through

this process, Ms. Boshoff has decided not to

allow anyone onto the property until the

situation is resolved. Ms. Boshoff has an

appeal pending with the

Department of Mineral Resources, against the

Section 11 application from Kwasa Mining

Services (Pty) Ltd to Siphiwo.

Foster Attorney requested Siphiwo Investments

to make a reasonable offer to compensate Ms.

Boshoff, which takes into account the past rent

with interest that was not paid, the value of the

farm in terms of the coal reserves, the

agricultural value, and environmental liability

causing the depreciation of her property.

(3) Environmental Considerations

There is a concern that the mining operation

will prove too costly for Kwasa Colliery to be

successful, and specifically that the





rehabilitation will prove too costly to complete

since Ms. Boshoff has doubts regarding the

amount set aside (of R2 000 000.00) as the

rehabilitation guarantee with the Department

of Mineral Resources.

Extensive erosion has occurred through poor

management of the previous mining area,

which will need to be addressed.

Coal discard is polluting the wetland and river

areas, which will require clean up.

Bradley Gibbons Endangered Wildlife Trust (1) Who will do the ground and surface water

monitoring at the proposed mine?

(2) What will happen if the applicant is unable to

rehabilitate the area due to a lack of funding?

(3) What specialist studies are planned?

(4) People from the outside will come in to look

for jobs, which will change the culture of the

local community. For example new people can

introduce AIDS in the area.

(5) The specialist doing the wetland delineation

should take the weather into account as the

(1) The applicant will decide who to

appoint to do the water monitoring at

the colliery but that there is a

possibility that uKhozi will do the

monitoring.

(2) Siphiwo will need to make provision

for rehabilitation. It would not make

sense for Siphiwo to take over the

liability of the area if they did not

have the financial ability to

rehabilitate.





wetlands will look different during the dry

season.

(6) Who will be in control of the re-vegetation

during the rehabilitation process?

(3) The following specialist studies are

planned:

Hydrogeological and Geochemical

Study;

Hydrology Study (still needs to be

commissioned)

Fauna and Flora studies as well as the

Bio monitoring and Wetland

Delineation (Terratest)

Soil Specialist Study (uKhozi

Environmentalists)

Visual Impact Assessment (uKhozi

Environmentalists)

Heritage Impact Assessment

(eThembeni Cultural Heritage)

Integration of the Social and Labour

Plan with the Socio Economic

Assessment (uKhozi

Environmentalists)

(4) There is a section in the WULA which

focusses on the socio-economics of





the area. These issues will also be

addressed during the integration of

the Social and Labour Plan with the

Socio Economic Assessment.

(5) This was noted. The specialists will be

able to delineate the wetlands based

on soils as well as vegetation.

(6) A vegetation specialist will be

involved in order to ensure the

correct vegetation is used to re-

vegetate the areas. The farmers will

also be included during this process.

Ralf Rodewald Landowner (1) Will the proposed conveyor from Goedehoop

miss the Kwasa operation?

(1) The preferred location of the

conveyor has not been finalised yet

but according to the conceptual plans

for Goedehoop the conveyor will run

through Kwasa’s mining right area to

the north of the operational area.



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9 Methodology

The report has been compiled through the analysis of various sets of data and

reports, a desk-top analysis, site visits and discussions with mine management. The

planned future operations are described and the related proposed commitments

listed. Updated information regarding predicted impacts on the bio-physical

(specifically - ground and surface water) environment will be made available from

specialist studies which are in the process of being undertaken at the Kwasa Colliery.

The following specialist studies will be incorporated in the final EIA/EMPr upon

completion:

Hydrogeological and Geochemical Study;

Hydrology Study;

Fauna and Flora studies as well as the Bio monitoring and Wetland Delineation;

Soil Specialist Study;

Visual Impact Assessment;

Heritage Impact Assessment;

Integration of the Social and Labour Plan with the Socio Economic Assessment.

The current state of the environment and the proposed construction, operation and

decommissioning activities are described in the report.

Desktop Analysis

A desktop analysis of various sets of information has been conducted during the

compilation of this report. Documents which had been reviewed include the

following:

Addendum to the approved EMPR (March 2010);

Water Use Licence Application report (December 2014);

Specialist groundwater assessment reports all of the above from the previous

Protea Colliery;

Jindal Mining: Africa (Pty) Ltd: Kiepersol Colliery, approved EMPr compiled by

uKhozi Environmentalists;

Various sets of legislation had further been taken into consideration during the

compilation of the report such as:



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The National Environmental Management Act, 1998 (Act No 107 of 1998) (As

amended) (NEMA);

Mineral and Petroleum Resources Development Amendment Act 49 of 2002

(MPRDA);

The National Water Act, 1998 (Act No 36 of 1998)(NWA);

Mpumalanga Nature Conservation Act, 1998 (10 of 1998) and the South

African Biodiversity Institute (SANBI);

Conservation of Agricultural Resources Act, 1983 and Section 28 of the

National Environmental Management Act, 1998);

National Environmental Management Waste Amendment Act, 2014 (Act No.

26 of 2014);

National Environmental Management: Air Quality Act, 2004 (Act No. 39 of

2004); and

National Veld and forest Fire Act, 1998 (Act No. 101 of 1998).

Guiding Principles

Several crucial guiding principles govern the environmental impact assessment

exercise, and have been summarised below to give the reader an informed

perspective of this process.

9.2.1 Balanced sustainable approach

The primary objective of arriving at a sustainable solution is to ensure that an

acceptable trade-off is determined, developed and maintained between three

categories of criteria namely;

Social (individual and corporate rights, consultation),

Bio-physical (“environmental”) – no significant compromise in the

ecosystems within the zone of influence, and

Economic factors (feasibility).

The approach of Integrated Environmental Management (IEM) is used as a guiding

principle.

9.2.2 Best Practicable Environmental Option (BPEO)

The activities and processes for the proposed project are influenced by the following

issues, namely;



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Affording the most benefit to the broadest spectrum of the community;

Causing the least (“ecological”) damage;

Catering for both short and long term impacts;

Identification and evaluation of practicable mitigation alternatives, and

Optimisation of the cost: benefit ratio.

9.2.3 Precautionary Principle

Where risk and/or uncertainty exist, the precautionary principle will be applied,

whereby additional measures are proactively implemented to prevent an occurrence

rather than to have to remedy the consequences of such risk becoming manifest.

Assumptions and limitations

The following assumptions and limitations are relevant to this study:

The report is based on project descriptions from the EMPR that was done

for Kwasa Mining Services in March 2010 and these are likely to undergo a

number of iterations and refinements before it can be regarded as definite.

A project description based on the final design would be provided if

changes occur.

It is assumed that all planned construction activities will use the existing

footprint and related infrastructure where possible;

It is assumed that new adits will be excavated from the existing adit

complex for future planned mining of all the mine-able coal seams.



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10 Environmental Impact Statement

Kwasa Colliery is an abandoned small underground coal mine located on the farm

Goedehoop 169 HT in the Piet Retief district. The colliery was left in an un-

rehabilitated state by the previous owners, Kwasa Mining Services (Pty) Ltd. The

surrounding environment, mainly the surface and groundwater resources are

currently being polluted. The abandoned Kwasa Colliery is a significant point source

of surface and groundwater pollution of the receiving environment. The polluted

water also flows into the sensitive wetlands located in close proximity to the mine.

The Mining Right for Kwasa Colliery has recently been applied to be transferred to

Siphiwo Investments (Pty) Ltd., for which a S.11 transfer of ownership is required, and

has been submitted to the DMR. Discussions are currently being in held in this regard

with the surface owner. Once the Mining Right is transferred to Siphiwo Investments

(Pty) Ltd, they will be responsible for the environmental liabilities. Siphiwo

Investments have committed to implement a designed storm water management

system in order to contain the source of pollution and to rehabilitate the mine at the

end of life. The construction activities can only start once environmental authorisation

is received and the Water Use License is granted by the Department of Water Affairs.

The most significant negative biophysical and socio economic impacts identified in

this report will mainly occur during the construction and operational phases of the

mine and are listed below (some of these impacts are already occurring and will

continue until the mine is rehabilitated):

Surface and groundwater contamination (currently occurring, high

significance);

Groundwater seepage and lowering of the groundwater levels could lead to

springs and fountain drying up (operational phase, high significance)

Reduction in the surface water runoff (construction and operational phase,

moderate significance);

Degradation of sensitive landscapes (currently occurring, high significance)’

Air pollution (construction and operational phases, moderate significance);

Increase traffic which could lead to further degradation of the district roads

(construction and operational phases, moderate significance)

The main positive biophysical and socio economic impacts identified in this report

are:

Containment of the pollution source (construction phase, high significance)

Rehabilitation of the disturbed area during and after mining (decommissioning

phase, high significance)



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Increase in employment opportunities (construction and operational phases,

high significance)

When comparing the environmental impacts that will occur if the Kwasa Colliery is

recommissioned to those that is currently occurring due to the state the environment

was left in, the recommissioning of the Kwasa Colliery should not have unmanageable

additional impacts. Some of the impacts that are currently occurring especially those

pertaining to the contamination of the surface and groundwater will be reduced if

proper mitigation measures are installed.

Considering the above the option of mining out the remaining reserve and then using

the funds to rehabilitate the area should be assessed further by undertaking the

specialist investigations identified in Section 10 and incorporating these findings in

the Final EIA and EMP for further consideration by the key stakeholders and

authorities.

The following recommendations are made:

The Authorities (formally) and Stakeholders should provide comments on the

Draft EIA/EMPr in order for an objective and relevant impact assessment to be

finalised, and for informed decisions to be made on the basis thereof.

The decision-making process should proceed to the next step, namely

completion and submission of the Final EIA/EMP Report supplemented by all

the relevant documentation and based on inputs from the specialist studies.

11 Appendices

Appendix A: Public Participation

Appendix B: Historical Data

Appendix C: Motivation for the consideration of the Wakkerstroom Wet Grasslands

Appendix D: Layout Plan

Appendix E: Site Photographs

Appendix F: Specialists Studies

Appendix G: Environmental Awareness Plan

Project Manager: Tommy Olivier Alternate: Inus de Wit

uKhozi Environmentalists uKhozi Environmentalist