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SCOPING REPORT WASTE MANAGEMENT LICENCE APPLICATION FOR THE PROPOSED TAILINGS STORAGE FACILITIES AND MINE WASTE ROCK DUMP SITES AT CRONIMET THABA CHROME MINE, LIMPOPO PROVINCE 11 DECEMBER 2015 NAME OF APPLICANT: Cronimet Chrome Mining SA (Pty) Ltd DMR REFERENCE NUMBER: LP 30/5/1/3/2/1 (115) EM

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Page 1: STANDARD DIRECTIVE - Sazi Environmental … · Web viewEmail: sndlazi@sazienvironmental.co.za/lekau@headwaters.co.za PROJECT INFORMATION PROJECT TITLE : WASTE MANAGEMENT LICENCE APPLICATION

SCOPING REPORT

WASTE MANAGEMENT LICENCE APPLICATION FOR THE PROPOSED TAILINGS STORAGE FACILITIES AND MINE

WASTE ROCK DUMP SITES AT CRONIMET THABA CHROME MINE, LIMPOPO PROVINCE

11 DECEMBER 2015

NAME OF APPLICANT: Cronimet Chrome Mining SA (Pty) Ltd

DMR REFERENCE NUMBER: LP 30/5/1/3/2/1 (115) EM

Page 2: STANDARD DIRECTIVE - Sazi Environmental … · Web viewEmail: sndlazi@sazienvironmental.co.za/lekau@headwaters.co.za PROJECT INFORMATION PROJECT TITLE : WASTE MANAGEMENT LICENCE APPLICATION

STANDARD DIRECTIVE

All applicants for, mining rights, in terms of the provisions of Section 29 (a) and in terms of

Regulation 49 (4) of the Mineral and Petroleum Resources Development Act, are herewith

directed to submit a Scoping Report strictly in accordance with parts G and H of this

guideline, within 30 days of notification by the Regional Manager of the acceptance of such

application.

PREAMBLE

The scoping report contemplated in Regulation 49 is founded on the principle of consultation

with interested and affected parties, which consultation process and its result is an integral

part of the fairness process. The decision to grant a mining right cannot be fair if the

administrator did not have full regard to precisely what happened during the consultation

process in order to determine whether the consultation was sufficient to render the grant of

the application procedurally fair.

The State acknowledges the importance of the involvement of communities where mining is

taking place at the earliest stages of applications for prospecting and mining rights and

permits. This entails the communities being informed and consulted on any mining activities

applied for by mining companies in their area.

Issues around consultation have been problematic in that there have been no guidelines on

how it should be conducted, and as a result there has been resistance on the part of many

landowners and communities against mining activities in their land. This has been

exacerbated by the lack of clarity concerning the relationship between the provisions of

section 10 of the Act and those in sections 16, 22 and 27 regarding the notification of and

consultation with interested and affected parties, and the submission of the results of such

consultation.

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YOUR COMMENTS ON THE DRAFT SCOPING REPORT

Draft Scoping Report (DSR) will be available for comment for a period of 30days from Friday

11 December 2015 to Monday 01 February 2016

Copies of the DSR, are available at the following public places and upon request from the

stakeholder engagement office:

PUBLIC PLACE LOCALITY CONTACT DETAILS

Thabazimbi Public Library 4th Avenue L. Mokwena (014 777 1525)

Thabazimbi LocalMunicipality Office

7 Riebok Street T. Masilo (083 552 9341)

Northam Library 313 Tungsten St Miriam Manyako(014 784 0128)

An electronic version of the DSR can be found at www.sazienvironmental.co.za

The following methods of public review of the DSR are available:

Additional written submissions; and

Comment by email, fax or telephone.

DUE DATE FOR COMMENTMonday 01 February 2016

Please submit comments to the Stakeholder Engagement Officers:

Ms Sandisiwe Ndlazi

Sazi Environmental Consulting

B16 Lone Creek, Waterfall Office Park, Vorna Valley, 1684

Phone: (011) 312 2608/ 079 446 9319

Fax: (011) 312 7208

Email: [email protected]/[email protected]

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PROJECT INFORMATION

PROJECT TITLE: WASTE MANAGEMENT LICENCE APPLICATION FOR THE PROPOSED TAILINGS STORAGE FACILITIES AND MINE WASTE ROCK DUMP SITES AT CRONIMET THABA CHROME MINE, LIMPOPO PROVINCE

.

DATE: DECEMBER 2016

PROPONENT:Company Name: CRONIMET CHROME MINING SA (PTY) LTD

Registration Number: 2003/008407/07

Contact Person: Silvia Costa

Designation: Chief Executive Officer (CEO)

Tel: 011 958 0544

Fax: 011 958 0467

Email: [email protected]

Postal Address: P. O. Box 3319, Witkoppen, 2068

CONSULTANT:Company Name: SAZI ENVIRONMENTAL CONSULTING cc.

Contact Person: Mrs Nonkanyiso Zungu

Designation: Managing Director

Tel: 084 8000 187/ 011 312 2806

Email: [email protected]/

[email protected]

Physical Address: B16 Lone Creek, Waterfall Park, Vorna Valley, Midrand, 1684.

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TABLE OF CONTENTS

STANDARD DIRECTIVE..........................................................................................................ii

PREAMBLE..............................................................................................................................ii

YOUR COMMENTS ON THE DRAFT SCOPING REPORT...................................................iii

PROJECT INFORMATION......................................................................................................iv

EAP EXPERIENCE.................................................................................................................xi

DEFINITIONS.........................................................................................................................xii

1 INTRODUCTION..............................................................................................................1

1.1 PURPOSE OF THE SCOPING REPORT.................................................................1

1.2 SUMMARY OF CONTENT OF DRAFT SCOPING REPORT...................................1

2 PROJECT BACKGROUND..............................................................................................3

2.1 PROJECT LOCALITY................................................................................................4

3 NEED AND DESIRABILITY..............................................................................................6

4 ALTERNATIVES CONSIDERED......................................................................................7

4.1 LOCATION ALTERNATIVES....................................................................................7

4.2 NO GO OPTION......................................................................................................10

5 LAND OWNERSHIP.......................................................................................................12

6 LEGISLATIVE CONTEXT...............................................................................................14

6.1 NATIONAL ENVIRONMENTAL MANAGEMENT ACT............................................14

6.2 NATIONAL ENVIRONMENTAL MANAGEMENT: WASTE AMENDMENT ACT,

2014 (ACT 26 OF 2014).....................................................................................................14

6.3 NATIONAL HERITAGE RESOURCES ACT, 1999 (ACT 25 OF 1999)...................14

6.4 NATIONAL ENVIRONMENTAL BIODIVERSITY ACT, 2004 (ACT 10 OF 2004)....15

6.5 LEGISLATIVE CONTEXT OF THE PROPOSED ACTIVITIES...............................16

7 BASELINE ENVIRONMENT...........................................................................................20

7.1 CLIMATE.................................................................................................................20

7.1.1 Mean Annual Wind Speed And Direction.........................................................20

7.1.2 Mean Monthly Ambient Temperature...............................................................21

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7.1.3 Precipitation......................................................................................................21

7.2 TOPOGRAPHY.......................................................................................................22

7.3 SOILS AND LAND CAPABILITY.............................................................................22

7.3.1 Land Use Categories........................................................................................22

7.3.2 Soil Categories.................................................................................................22

7.3.3 Land Capability.................................................................................................23

7.3.4 Soil Quality and Land Use................................................................................23

7.3.5 Agricultural Potential.........................................................................................24

7.4 GEOLOGY...............................................................................................................24

7.4.1 Faults................................................................................................................26

7.4.2 Iron Rich Pegmatoids.......................................................................................26

7.4.3 Dykes................................................................................................................26

Figure 7:4 Aeromagnetic Map for the Mineral Lease Area.............................................27

7.5 FLORA AND FAUNA...............................................................................................27

7.5.1 Flora.................................................................................................................27

7.5.2 Sensitivity.........................................................................................................28

7.5.3 Fauna...............................................................................................................29

7.6 AIR QUALITY..........................................................................................................31

7.6.1 Mining Operations in the Region......................................................................32

7.6.2 Industrial Operations in the Region..................................................................32

7.6.3 Vehicle Tailpipe Emissions...............................................................................33

7.6.4 Domestic Fuel Burning.....................................................................................33

7.6.5 Agricultural Activities........................................................................................33

7.6.6 Biomass Burning..............................................................................................34

7.6.7 Fugitive Dust Sources......................................................................................34

7.7 NOISE......................................................................................................................35

7.7.1 Measurement Position One..............................................................................36

7.7.2 Measurement Position 2...................................................................................37

7.7.3 Measurement Position 3...................................................................................38

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7.7.4 Measurement Position 4...................................................................................38

7.7.5 Measurement Position 5...................................................................................39

7.7.6 Measurement Position 6...................................................................................39

7.8 ARCHEOLOGY.......................................................................................................40

7.8.1 Late Iron Age Simplex Sites.............................................................................41

7.8.2 Stone Age Sites................................................................................................42

7.8.3 Iron Age Sites...................................................................................................43

7.8.4 Late Iron Age Complex Sites............................................................................43

7.8.5 Cemeteries.......................................................................................................44

7.8.6 European Homestead.......................................................................................45

7.8.7 Historic/Recent Mining......................................................................................45

7.9 WETLANDS.............................................................................................................45

7.9.1 Wetland Delineation and Classification............................................................45

7.9.2 Functional Assessment....................................................................................48

7.9.3 Present Ecological Status.................................................................................49

7.9.4 Ecological Importance and Sensitivity..............................................................49

7.10 AQUATIC.................................................................................................................50

7.10.1 In Situ Water Quality.........................................................................................51

7.10.2 Habitat Assessment..........................................................................................51

7.11 GROUNDWATER....................................................................................................58

7.11.1 Depth of the Water Table.................................................................................58

7.11.2 Presence of Boreholes and Springs and their Estimated Yields......................59

7.11.3 Ground Water Quality.......................................................................................59

7.11.4 Groundwater Quality Distribution and Compliance..........................................60

7.11.5 Groundwater Use.............................................................................................61

7.11.6 Groundwater Zone............................................................................................62

8 INITIAL APPLICATION AND SCOPING PROCESS......................................................64

8.1 APPLICATION PHASE............................................................................................64

8.2 SCOPING PHASE...................................................................................................64

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8.2.1 Stakeholder Review Prior to Submission.........................................................65

8.2.2 Submission and Decision-Making....................................................................65

9 PUBLIC PARTICIPATION UNDERTAKEN TO DATE....................................................66

9.1 INTERESTED AND AFFECTED PARTIES ISSUES AND RESPONSES...............67

10 AN IDENTIFICATION OF THE ANTICIPATED ENVIRONMENTAL, SOCIAL OR

CULTURAL IMPACTS...........................................................................................................72

11 PLAN OF STUDY FOR THE ENVIRONMENTAL IMPACT ASSESSMENT...............74

11.1 TASKS TO BE UNDERTAKEN DURING THE ENVIRONMENTAL IMPACT

ASSESSMENT PHASE......................................................................................................74

11.1.1 Specialist Studies.............................................................................................78

11.1.2 Terms of reference for specialist studies..........................................................78

11.1.3 Stakeholder Review Prior to Submission.........................................................87

11.1.4 Submission and Decision-Making....................................................................87

11.2 IMPACT ASSESSMENT RATING AND ASSESSING SIGNIFICANCE

METHODOLGY..................................................................................................................88

11.2.1 Qualitative Impact Assessment Methodology...................................................88

11.2.2 Quantitative Impact Assessment Methodology................................................88

TABLE OF FIGURES

Figure 2:1 Cronimet Thaba Chrome Mine Locality Map..........................................................5

Figure 4:1 Proposed Tailings Storage Facility and Waste Rock Dump Locality Alternatives. .9

Figure 4:2 Chromium Production and Reserves....................................................................10

Figure 7:1 Period, Daytime and Night-Time Wind Roses For Cronimet For The Period 2006.

...............................................................................................................................................20

Figure 7:2 Monthly Precipitation at Thabazimbi for the Period 2006-2007............................21

Figure 7:3 Regional Geological Map for the Cronimet Study Area (Council For Geosciences)

...............................................................................................................................................25

Figure 7:4 Aeromagnetic Map for the Mineral Lease Area....................................................27

Figure 7:5 Recorded Heritage Artefacts for the Area.............................................................41

Figure 7:6 Delineated Wetlands and Riparian Zones within the Mineral Lease Area............46

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LIST OF TABLES

Table 5:1 Property description...............................................................................................12

Table 5:2 Land ownership details..........................................................................................12

Table 6:1 Description of the listed activities...........................................................................16

Table 6:2 Details of the TSF and WRD sites.........................................................................18

Table 7:1 Land Use Categories and Surface Areas for the Thaba Cronimet Chrome Mine

Mining Lease Area.................................................................................................................22

Table 7:2 Soil Groups and the surface area they cover.........................................................23

Table 7:3 Land Capability Derived From Soil and Land Use Data for the Survey Site..........23

Table 7:4 Vegetation Units Occurring in the Study Area........................................................28

Table 7:5 List of Red Data Birds Potentially Occurring in the Study Area.............................29

Table 7:6 List of Red Data Mammals that may occur in the Study Area...............................30

Table 7:7 Atmospheric Stability Classes................................................................................31

Table 7:8 Recommended Noise Levels SANS 10103:2008..................................................35

Table 7:9 Summary of Noise Monitoring Positions and Results............................................35

Table 7:10 Noise Measurements Taken At Position 1...........................................................37

Table 7:11 Noise Measurements Taken At Position 2...........................................................37

Table 7:12 Noise Measurements Taken At Position 3...........................................................38

Table 7:13 Noise Measurements Taken At Position 4...........................................................38

Table 7:14 Noise Measurements Taken At Position 5...........................................................39

Table 7:15 Noise Measurements Taken At Position 6...........................................................39

Table 7:16 Heritage Site Significance and Mitigation Measures............................................40

Table 7:17 The Hydro-Geomorphic Classification System (Adapted From Brinson, 1993;

Kotze, 1999 And Marneweck And Batchelor, 2002)..............................................................46

Table 7:18 Location, Description and Significance of the Chosen Bio-Monitoring Sites at

Thaba Mine............................................................................................................................50

Table 7:19 Classification of Present State Classes in terms of Habitat Integrity (DWAF,

1999)......................................................................................................................................52

Table 7:20 Intermediate Habitat Assessment Results...........................................................53

Table 7:21 Summary of the Water Levels in External and Monitoring Boreholes in the Study

Area........................................................................................................................................58

Table 7:22 Typical Background Ground Water Quality for the Study Area............................60

Table 7:23 The Current Groundwater Use in the Study Area................................................62

Table 9:1 Summary of Issues raised by Interested and Affected Parties..............................67

Table 11:1 Description of specialist studies...........................................................................78

Table 11:2 Status of the Impact and Ratings.........................................................................88

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Table 11:3 Certainty of Impact and Ratings...........................................................................89

Table 11:4 Frequency Of Impact And Ratings.......................................................................89

Table 11:5 Spatial Extent of Impact.......................................................................................90

Table 11:6 Intensity of Impact And Ratings...........................................................................90

Table 11:7 Duration of Impact and Ratings............................................................................91

Table 11:8 Assessing Significance (Negative Impacts).........................................................91

Table 11:9 Assessing Significance (Positive Impacts)...........................................................92

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EAP EXPERIENCE

The Environmental Assessment Practitioners’ qualifications and CV are attached as

Appendix 1 and Appendix 2 respectively.

Nonkanyiso Zungu is a Professional Natural Scientist (Pr.Sci.Nat) with 10 years’ experience

in the environmental field. She has a Masters Degree in Environmental Management, and

specializes on Water Resource Management. She has extensive experience in obtaining

environmental authorisations (air, water, waste) across sectors that include: power

generation, infrastructure (Construction), transportation (rail), mining, water purification &

sewage works. The projects she has undertaken include: Environmental Impact

Assessments, Basic Assessments, Environmental Feasibility Studies, Environmental

scoping studies, Environmental legal compliance audits, Waste management licences,

Water use licences, and Baseline risk assessments.

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DEFINITIONS

‘consultation’ means a two way communication process between the applicant and the

community or interested and affected party wherein the former is seeking, listening to, and

considering the latter’s response, which allows openness in the decision making process.

‘community’ means a group of historically disadvantaged persons with interest or rights in a

particular area of land on which the members have or exercise communal rights in terms of

an agreement, custom or law: Provided that, where as a consequence of the provisions of

the Act negotiations or consultations with the community are required, the community shall

include the members or part of the community, directly affected by prospecting or mining, on

land occupied by such members or part of the community.

‘Interested and affected’ parties include, but are not limited to; –

(i) Host Communities

(ii) Landowners (Traditional and Title Deed owners)

(iii) Traditional Authority

(iv) Land Claimants

(v) Lawful land occupier

(vi) The Department of Land Affairs,

(vii) Any other person (including on adjacent and non-adjacent properties)

whose socio-economic conditions may be directly affected by the

proposed prospecting or mining operation

(viii) The Local Municipality,

(ix) The relevant Government Departments, agencies and institutions responsible for the

various aspects of the environment and for infrastructure which may be affected by the

proposed project.

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1 INTRODUCTION

1.1 PURPOSE OF THE SCOPING REPORT

The draft Scoping Report (DSR) describes the proposed project, the environment in which

the project is to be located and the specialist studies that will be undertaken as part

of the Impact Assessment Phase. It also aims to solicit inputs and comments from Interested

and Affected Parties (I&AP’s) on the proposed project. I&APs are given the opportunity to

comment on the proposal and scope for the EIA phase by reviewing the DSR.

This DSR is considered preliminary and has been compiled based on desktop analysis and

a literature review of the study area. It will serve as a start point to communicate project

details and further solicit public comments on the project. Specialist studies will be

completed in the meantime, after which the DSR will be updated and then made available for

public comment.

A number of information sessions will take place during the scoping phase of the project.

The comments received on the DSR and information sessions will be captured in an Issues

and Response Report (IRR) which will accompany the Final Scoping Report which is

submitted to DMR for approval.

This initial scope and public inputs guide the authorising authority in determining whether

there are gaps in information and whether additional measures are necessary to assess the

potential impacts of the development on the biophysical and social environment. DMR seeks

such input to support their decision making process and determine whether all potential

issues have been identified or whether further information is required.

1.2 SUMMARY OF CONTENT OF DRAFT SCOPING REPORT

Project background:

Project description and locality,

Alternatives considered,

Land ownership,

Needs and desirability,

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Legislative context,

Baseline environment;

Scoping and Environmental Impact Assessment methodology;

An overview of the EIA process;

Public participation followed to date including a list of interested and affected parties

identified and consulted;

A description of the existing environment within the project area based on desktop

analysis and a literature review;

The potential environmental issues and impacts which have been identified based on

desktop analysis and literature review;

Plan of study for EIA:

The preliminary scope of the specialist studies proposed to be undertaken as part of

this EIA;

Methodology for assessing impact

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2 PROJECT BACKGROUND

Cronimet Chrome Mining SA (Pty) Ltd, a diversified commodity group, contributing

significantly in the sustainable development of South Africa`s economy through mining, is a

holder of a mining right for its existing Cronimet Thaba Chrome Mine granted in terms of

section 23 of the Mineral and Petroleum Resources Development Act, 2002 (Act No. 28 of

2002) (MPRDA). The right involves exploitation of Cr and PGMs contained in the LG6

(including LG6A), LG4-high Cr to Fe ratio) (Lower Groups), MG2 and MG3 (Middle Groups)

of the Critical Zone in the Western Bushveld Igneous Complex using both opencast and

conventional underground mining method on portions of the farms Elandskuil 378 KQ,

Middellaagte 382 KQ, Moddergat 389 KQ, Roodedam 368 KQ, Schildpadness 385 KQ, and

Zwartkop 369 KQ, located within the Magisterial District of Thabazimbi, Limpopo Province.

Current mining activities at Cronimet Thaba Chrome Mine (Thaba Mine) include ML1 and

ML2 opencast pits, tailings storage facility (TSF), return water dams (RWDs), and Cr

processing plant located on the farms Middellaagte 382 KQ and Elandskuil 378 KQ, with

metallurgical chrome concentration as primary product at 40 000 tonnes per month (t/m).

The Thaba Mine plans to increase production through the expansion of the opencast mining

operations and underground mining areas to include the following pits: ZK4, ZK3, ZK2,

ZK1.1, ZK1, ZK4A, ZK3A, ZK1A, ZK4B, ZK3B, ZK1B, ZK1C, ZK4C, ZK5B, EK2, ML3, ML4,

ZK5A, EK1, central and northern underground mining areas. Expansion will cover an area of

approximately 2129 hectares in extent and will include development of additional Cr and

PGMs processing plant on both the remaining extent of the farm Moddergat 389 KQ and

portion 1 of the farm Middellaagte 382 KQ. Thus, an amendment to the 2009 Environmental

Impact Report (EIR) has been submitted to both Limpopo Department of Economic

Development and Tourism (LEDET) and DMR Limpopo Region to meet the requirements of

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

Environmental Impact Assessment Regulations, 2010) and Section 102 of the MPRDA.

The expansion of the opencast and underground mining operations require additional

support infrastructure to be constructed, which includes an expansion of an existing Tailings

Storage Facility (TSF) and construction of new a new TSF as well as Waste Rock Dump

(WRD) sites.

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In accordance with the requirements of the National Environmental Management: Waste

Amendment Act, 2014 (Act No. 26 of 2014) and the Mineral and Petroleum Resources

Development Act (Act 28 of 2004) together with the associated Environmental Impact

Assessment Regulations, 2014 (GNR 984), the proposed support infrastructure require a

Waste Management Licence (WML) from the Department of Mineral Resources (DMR)

through the undertaking of a full Environmental Impact Assessment process, before

construction may commence. According to the Waste Amendment Act, Act 26 of 2014, the

Thaba Cronimet TSF and WRDs are listed in Category A of Schedule 3 as hazardous waste.

This activity requires for the EIA Regulations, 2014, process to be followed.

2.1 PROJECT LOCALITY

Cronimet Thaba Chrome Mine (Thaba Mine) is located on the south-eastern part of the

Limpopo Province. The Limpopo Province is located on the northern border of South Africa

and is bordered by Mpumalanga Province to the south-east, Gauteng Province to the south,

and North West Province to the south-west. The site is located approximately 18 km North of

Northam and 30 km South-West from the town of Thabazimbi. In terms of the current

administrative boundaries, the project area falls within the jurisdictions of the Thabazimbi

Local Municipality which is under the jurisdiction of the Waterberg District Municipality.

Access to Thaba Cronimet Chrome Mine is via a gravel road connected to the R510 main

road, about 2 km North from the Chromedale railway siding.

The project area falls within ward 3, 5, and 8 of Thabazimbi Local Municipality which is under

the jurisdiction of the Waterberg District Municipality. Mining operations are located on

portions of the farm Elandskuil 378 KQ, Middellaagte 382 KQ, Moddergat 389 KQ,

Roodedam 368 KQ, Schildpadness 385 KQ, and Zwartkop 369 KQ, near the village of

Sebilong and Zwartkop, with Rethabile village located south from the mining lease area. The

site is located approximately 18 km north of Northam and 30 km south-west from the town of

Thabazimbi, at geographical coordinates 27.350272° east and -24.755931° South. An

overview of the site locality is indicated on the map below.

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Figure 2:1 Cronimet Thaba Chrome Mine Locality Map

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3 NEED AND DESIRABILITY

The needs and desirability of the proposed support infrastructure (TSF and WRD)

associated with Thaba Mine expansion takes into consideration the principles of NEMA, the

sustainable development objectives, programs and broader community needs within the

Thabazimbi Integrated Development Planning (2013/2014) and the 2008 Spatial

Development Framework (SDF). While the importance of job creation and economic growth

for South Africa cannot be denied, the Constitution calls for justifiable economic

development. The specific needs of the broader community are to be considered together

with the opportunity, costs and consequences of the proposed activities in order to

determine whether or not the development will be socially, economically and environmentally

sustainable.

Mining has been earmarked within the Thabazimbi Local Municipality’s IDP as a significant

contributor of employment and economic growth. Thaba Mine realizes the importance of

programmes to ensure that local communities are sourced for employment opportunities.

Agriculture land use (grazing) can continue on the majority of the mineral lease area as the

largest component of mining will be underground mining, which will minimally affect

agriculture grazing land. In addition, agriculture may recommence once opencast mining is

complete and rehabilitation has taken place.

Furthermore, mining activities are fundamental to national economic growth as outlined in

the NDP and the Medium Term Strategic Framework which states that ‘We need to ensure

growth in the core productive sectors of manufacturing, mining and agriculture and open new

areas of economic growth’. Additionally the proposed project will provide for employment

and skills development, which are of national concern.

In addition, according to the SDF (2008) “larger Thabazimbi area is characterised by many

mining enterprises. The mining sector is the primary pillar of the Thabazimbi economy,

however from a development and environmental perspective it is important that mining takes

place in a responsible manner.” The Thabazimbi mining sector is the key sector towards the

overall economy of the Waterberg District and it also plays an important role in the provincial

economy (contributes 11% to the provincial economy).

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4 ALTERNATIVES CONSIDERED

“Alternatives” are defined in the NEMA EIA Regulations of 2014, as “different means of

meeting the general purpose and requirements of the activity”. The consideration of

alternatives is a key component of an EIA process. While an EIA process should investigate

and comparatively consider all alternatives that have been identified, only those found to be

“feasible” and “reasonable” must be comparatively assessed, in terms of the advantages and

disadvantages that the proposed activity and alternatives will have on the environment and

on the community that may be affected by the activity (DEA&DP, 2011b).

The “feasibility” and “reasonability” of an alternative are measured by:

General purpose and requirements of the activity;

Need and desirability of the activity;

Opportunity costs;

Need to avoid and/or minimize negative impacts;

Need to maximize benefits; and

How it impacts on the community that may be affected by the activity

(DEA&DP, 2011b).

The different types of alternatives that can be considered as part of an EIA process include

the following:

Property on which or location where it is proposed to undertake the activity;

Type of activity to be undertaken;

Design or layout of the activity;

Technology to be used in the activity;

“No-go option”.

4.1 LOCATION ALTERNATIVES

An area of approximately 60ha is required for the storage of 4.5million m3 of tailings for a

period of 20 years on the farm Middellaagte 382 KQ. The only possibility for the location of

the proposed extension to the approved tailings storage facility in close proximity to the

existing tailings facility and processing plant is north of the existing tailings dam up until the

mineral lease boundary. The tailings storage facility cannot be located to the east due to

stockpiled areas and to the west due to demarcated opencast mining areas. It is however to

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be noted that a temporary return water dam will be constructed further south within the

tailings storage facility footprint to allow for opencast mining to take place in the area prior to

constructing the final return water dam further north but still within the proposed footprint for

the tailings storage facility.

The locality alternatives considered for this application are indicated on the Figure below.

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Figure 4:2 Proposed Tailings Storage Facility and Waste Rock Dump Locality Alternatives

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4.2 NO GO OPTION

Chromite is an iron chromium oxide. It is an oxide mineral belonging to the spinel group. It is

an industrially important mineral for the production of metallic chromium, used as an alloying

ingredient in stainless and tool steels and for ferrochromium . As a major source of the

metal chromium, the extracted chromium from chromite is used in chrome plating and

alloying for production of corrosion resistant superalloys, nichrome, and stainless steel.

Chromium is used as a pigment for glass, glazes, and paint, and as an oxidizing agent for

tanning leather (http://www.nationsencyclopedia.com/economies/Africa/South-Africa).

South Africa holds 68% of the world's chromium reserves. The Bushveld Complex, a sill-like

geological feature occupying about 50 000 km2, contains more than half of the world's

chrome ore and platinum. South Africa provides 53 percent of the world’s exports of

ferrochromium, 47 percent of platinum group metals, and 41 percent of chrome ore

(http://www.nationsencyclopedia.com/economies/Africa/South-Africa). Although the demand

for chrome has declined from 2006 due to the steep economic downturn resultant from the

global credit crunch crises, it is estimated that South Africa has the largest chromium

production in the world as illustrated by the figure below.

(http://minerals.usgs.gov/minerals/pubs/commodity/chromium/mcs-2013-chrom.pdf).

Mine production 2011 Mine production 2012 Reserves (shipping grade)

0

50000

100000

150000

200000

250000

IndiaKazakhstanSouth AfricaOther countries

Figure 4:3 Chromium Production and Reserves

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In addition to the large chromium and PGM reserves in South Africa, and in particular, the

Bushveld Complex which has the potential to harness economic growth and beneficiation for

not only the Limpopo Province but for South Africa, the proposed mining and processing

activities at Thaba Mine has numerous advantages as. Should the proposed activities not

proceed, the benefits of such will not be realised. The advantages include the following:

The employment of approximately 800 contractor employees at the steady state of

underground mining;

Thaba Mine has an approved Social and Labour Plan in place which outlines the

Company’s local economic development programmes. The key projects which

Thaba Mine are involved in are outlined below:

- Adult based education and training within the local community (Smash Block)

- Computer classes in the community

- Vegetable gardens in the community

- Sanitation project within the Thabazimbi area, in terms of constructing ablution

blocks

- Assistance in terms of accessing of water within the Smash Block

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5 LAND OWNERSHIP

The table below indicates the property that will be affected by the proposed TSF and WRD.

Table 5:1 Property description

Farm Name:

Portion 1 of the farm Elandskuil 378 KQPortion 1 of the  farm Middellaagte 382 KQRemaining extent of the farm Moddergat 389 KQPortion 8 of the farm Roodedam 368 KQRemaining extent and portion 1 of the Schildpadness 385 KQPortion 17, 18, 21, 26,  and 28 of the farm Zwartkop 369 KQ

Application area (Ha) 2129ha

Magisterial district: Waterberg

Distance and direction from nearest town 30 km North East of Thabazimbi

21 digit Surveyor General Code for each farm portion

T0KQ00000000038200001 (Middelaagte Portion 1)T0KQ00000000038900000 (Moddergat Remaining extent)T0KQ00000000036900018 (Zwartkop Portion 18)T0KQ00000000037800001 (Elandskuil Portion 1)T0KQ00000000036800008 (Roodedam Portion 8)T0KQ00000000038500001 (Schildpadnest Portion 1)T0KQ00000000038500000 (Schildpasnest Remaining extent)T0KQ00000000036900017 (Zwartkop Portion 17)T0KQ00000000036900021 (Zwartkop Portion 21)T0KQ00000000036900026 (Zwartkop Portion 26)T0KQ00000000036900028 (Zwartkop Portion 8)

Cronimet Thaba Chrome Mine is located on portions of the farm Elandskuil 378 KQ,

Middellaagte 382 KQ, Moddergat 389 KQ, Roodedam 368 KQ, Schildpadnest 385 KQ, and

Zwartkop 369 KQ. Most of the property surface rights are held in trust by the Department of

Rural Development and Land Reform, while other properties are privately owned by entities

and individuals. No record of land claim has been made on these properties at this stage.

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Table 5:2 Land ownership details

Property Name Property Number

Registration Divisional

Property Portion Owner of the Surface

Middellaagte 382 KQ Portion 1 Danie Koekemoer

Moddergat 389 KQ RemainingExtent

Cronimet Chrome Mining SA (Pty) Ltd

Zwartkop 369 KQ Portion 18 Trollope Property (Pty) Ltd

Elandskuil 378 KQ 1 Rustenburg Platinum Mines Ltd

Roodedam 368 KQ 8 Mr and Mrs. Moloko

Schildpadnest 385 KQ 1 Baphalane Ba Mantserre Community Development Trust

Schildpadnest 385 KQ Remaining Extent Baphalane Ba Mantserre Community Development Trust

Zwartkop 369 KQ 17 Rustenburg Platinum Mines Ltd

Zwartkop 369 KQ 21 Trollope Property cc

Zwartkop 369 KQ 26 Sebilong Communal Property Association

Zwartkop 369 KQ 28 Sebilong Communal Property Association

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6 LEGISLATIVE CONTEXT

This section provides a brief overview of both the national and international requirements

that must be met by this project.

6.1 NATIONAL ENVIRONMENTAL MANAGEMENT ACT

In terms of the National Environmental Management Act, 1998 (Act No. 107 of 1998)

(NEMA), as amended and the EIA Regulations, 2014, an application for environmental

authorisation for certain listed activities must be submitted to either the provincial

environmental authority, or the national authority (Department of Environmental Affairs,

DEA), depending on the types of activities being applied for.

The current EIA regulations, GN R.982, GN R.983, GN R.984 and GN R.985, promulgated in

terms of Sections 24(5), 24M and 44 of the NEMA and subsequent amendments,

commenced on 08 December 2014. GN R.983 lists those activities for which a Basic

Assessment is required, GN R.984 lists the activities requiring a full EIA (Scoping and

Impact Assessment phases) and GN R.985 lists certain activities and competent authorities

in specific identified geographical areas. GN R.982 defines the EIA processes that must be

undertaken to apply for Environmental Authorisation.

6.2 NATIONAL ENVIRONMENTAL MANAGEMENT: WASTE AMENDMENT ACT, 2014 (ACT 26 OF 2014)

A list of waste management activities which require a Waste Management Licence (WML)

have been published GN 921 and Thaba Mine’s proposed TSF and WRD sites are listed in

Category A of Schedule 3 as hazardous waste. These activities require a Waste

Management Licence from the Department of Mineral Resources (DMR) through the

undertaking of a full Environmental Impact Assessment process, prior to commencement

with the activities.

6.3 NATIONAL HERITAGE RESOURCES ACT, 1999 (ACT 25 OF 1999)

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The National Heritage Resources Act, 1999 (NHRA) protects all structures and features

older than 60 years (Section 24), archaeological sites and material (Section 35) and graves

and burial sites (Section 36). Potential impacts on heritage and archaeological

resources during the construction phase include the likelihood of unearthing of heritage

and archaeological resources especially during the construction phase of the project. The

NHRA thus protects:

Burial sites

Buildings of more than 60 years

Paleontological objects

Special geological features (fossil prints, bushman rock art)

A Heritage Impact Assessment as required in terms of section 38 of the National Heritage

Resource Act (Act 25 of 1999) would be commissioned during the EIA phase of the project

to:

Establish whether any of the type and ranges of heritage resources as outlined in

section 3 of the National Heritage Resource Act(Act 25 of 1999) do occur in or near

the proposed site, and if so, to establish the significance of these heritage resources.

Establish whether such heritage resources will be affected by the proposed activities,

and if so, to determine possible mitigation measures that can be applied to these

heritage resources.

6.4 NATIONAL ENVIRONMENTAL BIODIVERSITY ACT, 2004 (ACT 10 OF 2004)

The purpose of the Biodiversity Act is to provide for the management and conservation of

South Africa’s biodiversity within the framework of the NEMA and the protection of species

and ecosystems that warrant national protection. As part of its implementation strategy, the

National Spatial Biodiversity Assessment was developed.

The list of threatened and protected species issued in terms of Section 56 (1) of the NEMB

would be considered in this application and occurrence of species on site would be

assessed.

South Africa also uses the internationally endorsed World Organisation-International

Union for Conservation of Nature (IUCN) IUCN Red List Categories and Criteria in the Red

List of South African plants.

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6.5 LEGISLATIVE CONTEXT OF THE PROPOSED ACTIVITIES

Thaba Cronimet Chrome Mine plans to increase production through the expansion of the

opencast mining operations and underground mining areas. As part of the expansion,

additional support infrastructure is required.

To service the opencast mining operations, Thaba Cronimet Chrome Mine proposes to

expand the existing Tailings Storage Facility (TSF) located on Middellaagte Farm by

constructing an additional 60ha facility with a 720 000t/annum capacity. On the same farm,

an 8.9ha Waste Rock Dump (WRD) site with a capacity of 100,000t/annum is proposed.

Another WRD is proposed on Portion 18 of the farm Zwartkop 369 KQ, which will cover

10.6ha of land for the 100 000t/annum disposal of waste rock.

Underground mining support infrastructure includes the construction of the TSF and WRD

site on the Remainder of the farm Moddergat 389KG, where 6.9ha of land will be cleared for

the disposal of 120 000t/annum tailings. All tailings from the Cr and PGMs processing will be

pumped into this TSF through a pipe and discharged through spigot outlets. The WRD will

clear 7.4ha of land for the disposal of 1 000 000t/annum of waste rock. Another WRD is

proposed on Portion 18 of the farm Zwartkop 369 KQ, which will cover 8ha for the disposal

of 1 000 000t/annum of waste rock.

According to the Waste Amendment Act, Act 26 of 2014, the Thaba Cronimet Mine’s

proposed TSF and WRD sites are listed in Category A of Schedule 3 as hazardous waste.

These activities require a Waste Management Licence from the Department of Mineral

Resources (DMR) through the undertaking of a full Environmental Impact Assessment

process, prior to commencement with the activities.

A Waste Management Licence application (Ref. No. LP 30/5/1/3/2/ (1115) EM) has been

lodged with the Department of Mineral Resources (DMR) Limpopo Region in terms of the

Waste Amendment Act, Act 26 of 2014. The listings are described on the table below.

Table 6:3 Description of the listed activities

RELEVANT NOTICE

ACTIVITY NUMBER

DESCRIPTION

GNR 921 Category B,

No. 7

The disposal of any quantity of hazardous waste on land.

GNR 921 Category B, The construction of a facility for a waste management

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RELEVANT NOTICE

ACTIVITY NUMBER

DESCRIPTION

No. 10 activity listed in Category B of this Schedule (not in

isolation to associated waste management activity).

A detailed description of the listed activities is provided on the table below.

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Table 6:4 Details of the TSF and WRD sites

Activity Description Capacity Co-ordinates Property Description Applicable Listed Activities and Notice

Tailings storage facility

(expansion)

(60 Ha)

720 000 t/annum

24° 45’ 03.34” S; 27° 20’ 52.52” E

24° 45’ 01.08” S; 27° 20’ 52.05” E

24° 44’ 55.77” S; 27° 21’ 04.87” E

24° 45’ 00.88” S; 27° 21’ 14.51” E

24° 45’ 02.70” S; 27° 21’ 16.17” E

24° 45’ 06.78” S; 27° 21’ 15.29” E

24° 45’ 11.04” S; 27° 21’ 02.59” E

24° 45’ 08.78” S; 27° 20’ 59.57” E

24° 45’ 10” S; 27° 20’ 53” E

24° 45’ 08” S; 27° 20’ 51” E

Portion 1 of the farm

Middellaagte 382 KQ

Government Notice 921 (Category

B): 7 and 10

Tailings storage facility (6.9 Ha)

120 000 t/annum

24° 50’ 02.3” S; 27° 15’ 23.3” E

24° 49’ 57.6”S; 27° 15’ 31.9”E

24° 50’ 04.7”S; 27° 15’ 36.1” E

24° 50’ 09.1” S; 27° 15’ 27.8” E

24° 50’ 02.3”S; 27° 15’ 23.3”E

Remainder of the farm

Moddergat 389 KQ

Government Notice 921 (Category

B): 7 and 10

Waste rock dump 1 (8.9 Ha)

100 000 t/annum

24° 44’ 50.3”S; 27° 21’ 00.4”E

24° 44’ 48.1”S; 27° 21’ 03.6”E

24° 45’ 04.5”S; 27° 21’ 17.3”E

24° 45’ 06.7”S; 27° 21’ 14.0”E

24° 44’ 50.3”S; 27° 21’ 00.4”E

Portion 1 of the farm

Middellaagte 382 KQ

Government Notice 921 (Category

B): 7 and 10

Waste rock dump 2 (7.4 Ha) 24° 49’ 44.3” S; 27° 15’ 28.4” E Remainder of the farm Government Notice 921 (Category

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Activity Description Capacity Co-ordinates Property Description Applicable Listed Activities and Notice

1 000 000 t/annum 24° 49’ 42.3” S; 27° 15’ 32.3” E

24° 50’ 02.1”S; 27° 15’ 44.8” E

24° 50’ 04.2” S; 27° 15’ 40.9” E

24° 49’ 44.3” S; 27° 15’ 28.4” E

Moddergat 389 KQ B): 7 and 10

Waste rock dump 3 (10.6 Ha)

100 000 t/annum

24° 45’ 28”S; 27° 20’ 06.0”E

24° 45’ 31”S; 27° 20’ 14”E

24° 45’ 41”S; 27° 20’ 03.0”E

24° 45’ 43”S; 27° 20’ 12.0”E

Portion 18 of the farm

Zwartkop 369 KQ

Government Notice 921 (Category

B): 7 and 10

Waste rock dump 4 (8.0 Ha)

1 000 000 t/annum

24° 46’ 21”S; 27° 18’ 56”E

24° 46’ 15”S; 27° 19’ 10”E

24° 46’ 10”S; 27° 19’ 06”E

24° 46’ 16”S; 27° 18’ 53”E

Portion 18 of the farm

Zwartkop 369 KQ

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7 BASELINE ENVIRONMENT

The baseline environment refers to the physical and social environment in 2009/2010 which

is pre-mining conditions/prior to the commencement of CCMSA mining and processing

activities in 2011. The information utilised in the section below is obtained from the various

specialist studies that were undertaken in 2009/2010 and 2015. The report provides

information on the conditions in 2015 and provides context with regards to Thaba Cronimet

Chrome Mine’s impact on the physical and socio-economic environment.

7.1 CLIMATE

7.1.1 Mean Annual Wind Speed And Direction

From the data used (January – December 2006), the prevailing winds were spread evenly in

all directions, with slightly more frequent winds from the southeast and less frequently from

the north western sector. During the day time 24 percent of the wind speeds were below

1m/s, with winds prevailing from the southeast at frequency of 10 percent and north-easterly

winds seven percent of the time. The winds from the west were the most infrequent, but

were associated with the highest wind speeds. During the night time, calm conditions were

experienced with wind speeds of less than 1m/s occurring for 28.1 percent of the time. This

is typical of night time conditions and associated with the calm conditions is a reduction in

wind velocity. The predominant wind conditions during the night time were from the

southwest, with a marked decrease to the winds from the northeast.

Figure 7:4 Period, Daytime and Night-Time Wind Roses For Cronimet For The Period 2006.

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7.1.2 Mean Monthly Ambient Temperature

Air temperature is important both for determining the effect of plume buoyancy and in

determining the development of the mixing and inversion layers. The Thaba Cronimet

Chrome Mine has temperatures that are typical to the region; the highest temperatures were

found at mid-day in the summer months of November to January. During the winter months,

the temperatures drop during the night time and the day time temperatures were far lower.

7.1.3 Precipitation

Precipitation is a key factor in air pollution studies as it is an effective mechanism in the

removal of atmospheric pollutants and inhibits dust generation potentials. The Thaba

Cronimet Chrome Mine has summer rainfall with the maximum rainfall in the summer

months and little or no rainfall in the winter months. The annual average rainfall for 2006 was

51mm and 61mm for 2007, with February yielding the highest rainfall month with 294mm of

rain recorded for 2006. October was the highest yielding rainfall month in 2007 with 404mm

rainfall recorded. The figure below shows the monthly rainfall for 2006 and 2007 in

Thabazimbi.

Figure 7:5 Monthly Precipitation at Thabazimbi for the Period 2006-2007

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7.2 TOPOGRAPHY

The majority of the area is characterised by undulating to flat plains with a high of 980 m

above mean sea level (mamsl) to the South West and 960 mamsl to the East, with the

lowest point being the Bierspruit River. This means that the site is generally flat with a slight

gradient towards the Crocodile River. One small hill on the farm Zwartkop 369 KQ is 1058.5

mamsl in height. The area is drained to the north by the Bierspruit River and its associated

tributaries.

7.3 SOILS AND LAND CAPABILITY

Land type data for the site was obtained from the Institute for Soil, Climate and Water of the

Agricultural Research Council. In addition, aerial photographs from Google Earth and

orthophotos from the Directorate Surveys and Mapping in Mowbray were used to interpret

aspects such as land use and land cover, as well as historic land uses. A detailed soil

survey was conducted within the Thaba Cronimet Chrome Mine according to standard

accepted methodology.

7.3.1 Land Use Categories The table below presents the categories as well as the total area they covered in 2009 from

the spatial results of the aerial photograph interpretation.

Table 7:5 Land Use Categories and Surface Areas for the Thaba Cronimet Chrome Mine

Mining Lease Area

Land use Area (ha) Percentage (%)

Extensive grazing 1618.4 82.6

Irrigated agriculture 6.2 0.3

Informal housing 29.7 1.5

Historic mining impacts 266.4 13.6

Current mining impacts 37.5 1.9

Total 1958.2

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7.3.2 Soil CategoriesThe soil survey of the site yielded four main categories of soil namely: Structured and

swelling soils, high base status red soils, soils in drainage canals and shallow and rocky

soils as provided in the table below

Table 7:6 Soil Groups and the surface area they cover

Soil Group Soils Hectares Coverage (%)

Structured and swelling soils Ar/Rg 1184 60.5

High base status red soils Hu/Sd 620 31.7

Soils in drainage canals Oa/Du/Rg/Streambed 50 2.5

Shallow and rocky soils Gs/Ms/R 104 5.3

Total 1958

7.3.3 Land Capability The land capability of the site was identified for the delineated soil areas and the categories

are presented in the table below. Most of the soils were suited to grazing and the structured

swelling and high base status red soils were considered arable but with restrictions. The

area in the drainage canal was strictly speaking considered as a wetland area but then

specifically as a riparian zone due to the regular movement of water through it.

Table 7:7 Land Capability Derived From Soil and Land Use Data for the Survey Site

Soil Group Derived Land Capability

Hectares Mapped

Coverage (%)

Structured and swelling

soils

Grazing/Arable with

restrictions

1184 60.5

High base status red soils Grazing/arable with

restrictions

620 31.7

Soils in drainage canals Wetland (Riparian

zones)

50 2.5

Shallow and rocky soils Grazing 104 5.3

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Total 1958

7.3.4 Soil Quality and Land UseFor most of the mineral lease area, the soils were suited to extensive grazing as they were

not radically disturbed. The areas that have been disturbed by historic mining activities were

not suited to grazing or agriculture as these soils have been degraded significantly due to

disturbance. The land use was changing from grazing to rural dwellings in a large area of the

site and with this change the soil’s quality was also degrading. Low intensity agricultural

activities can be considered for the remaining open areas but the risk of crop failures will be

high if rainfall is erratic and if management is not optimal.

7.3.5 Agricultural PotentialThe structured and swelling soils can be used for the production of crops; however their high

clay content, variable depth and poor internal and external drainage make them very difficult

to manage if irrigated. The quality of irrigation water has to be very good with very low salt

(especially sodium) content as leaching practices cannot be applied to get rid of excessive

salts. Due to climatic constraints (rainfall quantity and distribution) these soils were not

productive under dryland cropping conditions. Their overall agricultural potential was

therefore considered to be medium to low. The high base status red soils were suited to

irrigation agronomic uses as internal and external drainage of water was inherently good.

Although irrigation water quality should still be high these soils could handle slightly higher

salt loads than the structured soils as leaching practices can be applied to flush salts out of

the profile. The rockiness of these soils could pose problems when tilled. The agricultural

potential of these soils were therefore considered to be medium to high, especially if

irrigated. Due to a range of restrictions, the soils in the drainage canals and the shallow and

rocky soils were considered to be of low agricultural potential. Post mining agricultural

potential depends to a very large extent on the rehabilitation efforts by the mining company

but previous experience has shown that it will be low at best.

7.4 GEOLOGY

The study area is situated in the north-western sector of the Bushveld Igneous Complex and

is underlain by the mafic rocks of the Rustenburg layered Suite, which dip at an angle of

between 30 degrees and 15 degrees to the south-east with an average dip of around 22

degrees. The Bushveld Igneous Complex is a layered mafic intrusion which intruded into and

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below the Pretoria Group Sediments (Transvaal Sequence). The resistant quartzites of the

Transvaal Sequence lie to the west and north of the study area, forming the Witfonteinrand

Mountains. The regional geology for CCMSA is discussed with reference to the 1:250 000

Geological Map Series of South Africa – Sheet 2426 Thabazimbi (1974). Figure 10-3 is a

clipped map extract from the above mentioned 1:250 000 Geological Map. The study area is

generally flat and featureless with the underlying geology being covered by a thin layer of

“black turf” soils. The underlying geology at the mine is predominantly confined to the main

and critical zone stratigraphy of the Bushveld Igneous Complex and ranges from Gabbro’s

through to norites, anorthosites and pyroxenites.

Figure 7:6 Regional Geological Map for the Cronimet Study Area (Council For Geosciences)

Due to the nature of the Igneous Complex, which dips towards the south-east, the surface

geology inherently becomes younger from the north-west towards the south-east. The north-

western extent of the study area is underlain by pyroxenites of the upper pyroxenite suite.

The pyroxenites are the oldest lithologies within the study area and are overlain by younger

interlayered norites and anorthosites of the Grasvally Norite-anorthosite formation. The

norites and anorthosites are entirely overlain by anorthosites to the south east. These

anorthosites host the Merensky Reef as well as the three chromitite bands, namely the LG,

MG and UG chromitite layers. These chromitite bands have a large economic potential and

have been further subcategorised and numbered accordingly. The chromitite layers have

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high concentrations of chrome which can be economically mined by open cast methods. The

norites are overlain gabbros of the Mapela Gabbro-Norite formation, which are

predominantly noritic at the base across the south eastern extent of the study area. The

geology of the study area indicates normal contact zones between the layers identified

above, with no localised intrusions.

The Merensky Reef is a pegmatoidal feldspathic pyroxenite, with a strike length of 20km and

average thickness of between 1.0 and 1.5m. In places, relatively minor dip and strike

variations of the Merensky Reef are related to faulting. The major aberration of the Merensky

reef exists within the central parts of the study area, where large scale faulting and an iron

rich pegmatoidal pipe-like body cause a major disruption of the Merensky Reef. Pentlandite

and chalcopyrite are the main base metal sulphides associated with the Merensky reef.

Pyrrhotite is the main iron sulphide which gives rise to troilite in areas where iron-rich

pegmatoids replace the reef (Viljoen et al (1986)). Troilite is simply the iron rich variety of

Pyrrhotite.

7.4.1 FaultsThe main geological features across the study area are two north-west to south-east striking

faults across the central to northern parts of the study area. Aeromagnetic data clearly

justifies and delineates these features. These faults have throws of up to 530m and are

bound by a 2.5 km wide graben structure. These fault zones are geohydrologically

considered as potentially water bearing features at depths greater than 20m.

7.4.2 Iron Rich PegmatoidsThe study area is characterized by the widespread development of iron-rich pegmatoidal

bodies, which appear to be associated with zones of structural. The major iron-rich

pegmatoid, known as the Middellaagte pipe, averages 1.6km in diameter and occurs within

the bounds of the graben structure. Numerous smaller iron-rich ultramafic pegmatoids occur

within the study area. They are generally pegmatoidal pyroxenitic to duntic bodies and are

not identified by the surface geology. These iron-rich ultramafic pegmatoids are however

evidently identified by aeromagnetic data and are delineated by the anomalously light pink

areas in the Figure below.

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7.4.3 DykesFour major and a number of smaller dykes occur across the central and south-western

regions of the study area. They all have a very consistent north-west to south-east trending

strikes, but their widths vary from a few centimetres up to 50m. The dykes are all diabase or

dolerite dykes, are competent lithologies and are related to the same tectonic event, the

Pilanesberg Dyke Swarm. These Pilanesberg Age dykes have a negative magnetic

signature and are identified by the linear blue (to green or yellow) features. Carbonate rich

dykes are also present across the north-eastern sections of the study area. These dykes

have brecciated appearances and contain many inclusions and have kimberlitic affinities.

Figure 7:7 Aeromagnetic Map for the Mineral Lease Area

7.5 FLORA AND FAUNA

7.5.1 FloraThe Thaba Cronimet Chrome Mine lies within the Savanna biome which is the largest biome

in Southern Africa. It is characterised by a grassy ground layer and a distinct upper layer of

woody plants (trees and shrubs). The environmental factors delimiting the biome are

complex and include altitude, rainfall, geology and soil types, with rainfall being the major

delimiting factor. Fire and grazing also keep the grassy layer dominant. The classification of

the area was the microphyllous woodland which is part of the Dwaalboom Thornveld

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vegetation type. The Dwaalboom Thornveld vegetation type had threatened conservation

status, with 14 percent transformed and six percent statutorily conserved.

Vegetation units were identified according to plant species composition, previous land-use,

soil types and topography. The state of the vegetation of the proposed mining site varied

from being natural to completely degraded. The land-use on the different farms in 2009/2010

was as follows:

Farms Zwartkop 369 KQ and Schilpadnest 385 KQ was old mining activities and

tribal land

Middellaagte 382 KQ, Roodedam 368 KQ and Elandskuil 378 KQ was utilised for

livestock farming

Moddergat 389 KQ was managed as two separate game farms.

The vegetation units for the mineral lease area differed in terms of the state of the

vegetation. A species list applicable to each of the units of the woody structure is included.

Purple highlighted areas indicate the presence of the species in 2009/2010

Table 7:8 Vegetation Units Occurring in the Study Area

Vegetation unitsModdergat 389 KQ

Zwartkop 369 KQ, Schildpadsnest 385 KQ Middellaagte 382 KQ

Middellaagte 382 KQ, Roodedam 368 KQ, Elandskuil 378 KQ

Acacia tortilis – Ziziphus

mucronata – Peltophorum

africanum woodland

Acacia mellifera woodland

Acacia tortilis – Acacia nilotica

woodland

Drainage channels &

floodplains

Ziziphus mucronata - Grewia

flava shrubveld / grassland

Rocky outcrops and ridges

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Vegetation unitsModdergat 389 KQ

Zwartkop 369 KQ, Schildpadsnest 385 KQ Middellaagte 382 KQ

Middellaagte 382 KQ, Roodedam 368 KQ, Elandskuil 378 KQ

Degraded bushveld (old mining

dumps; tribal land)

Old fields

Dense Knobthorn Thickets

7.5.2 SensitivityThe classification of the study area into different sensitivity classes and development zones

was based on information collected at various levels on different environmental

characteristics. The mining lease area was low in sensitivity.

7.5.3 Fauna

7.5.3.1 BirdsA survey was conducted on the study site during October 2009 to identify specific bird

habitats, and to compare these habitats with habitat preferences of birds occurring in the

quarter degree grid according to Harrison et al. (1997). The list of red data species

potentially occurring in the area at that time is listed in the Table below.

Table 7:9 List of Red Data Birds Potentially Occurring in the Study Area

English Name Afrikaans Name StatusProbability Of Occurrence On Site

White Pelican Witpelikaan Vulnerable Low

Pinkbacked Pelican Kleinpelikaan Vulnerable Low

Whitebacked Night Heron Witrugnagreier Vulnerable Medium to low

Black Stork Groot swartooievaar Near threatened High

Marabou Stork Maraboe Near threatened High

Yellowbilled Stork Nimmersat Near threatened High

Greater Flamingo Grootflamink Near threatened Low

Lesser Flamingo Kleinflamink Near threatened Low

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English Name Afrikaans Name StatusProbability Of Occurrence On Site

Secretarybird Sekretarisvoël Near threatened Medium

Cape Vulture Kransaasvoël Vulnerable Medium

Whitebacked Vulture Witrugaasvoël Vulnerable Medium

Lappetfaced Vulture Swartaasvoël Vulnerable Medium

Tawny Eagle Roofarend Vulnerable Medium to high

Ayres' Eagle Kleinjagarend Near threatened Medium

Martial Eagle Breëkoparend Vulnerable Medium

African Marsh Harrier Afrikaanse Vleivalk Vulnerable Medium to low

Peregrine Falcon Swerfvalk Near threatened Low

Pallid Harrier Witborsvleivalk Near threatened Low

Lanner Falcon Edelvalk Near threatened Low

Lesser Kestrel Kleinrooivalk Vulnerable Medium to low

Blue Crane Bloukraanvoël Vulnerable Low to zero

African Finfoot Watertrapper Vulnerable Low

Kori Bustard Gompou Vulnerable Medium

Stanley's Bustard Veldpou Vulnerable Medium

Whitebellied Korhaan Witpenskorhaan Vulnerable Medium

Old World Painted Snipe Goudsnip Near threatened Low

Blackwinged Pratincole Swartvlerksprinkaanvoël Near threatened Medium

Yellowthroated Sandgrouse Geelkeelsandpatrys Near threatened Medium

Grass Owl Grasuil Vulnerable Low

Halfcollared Kingfisher Blouvisvanger Near threatened Low

Redbilled Oxpecker Rooibekrenostervoël Near threatened Medium to high

7.5.3.2 MammalsThe table below outlines red data mammal species that could occur according to Friedman

and Daly (2004), in the study area in 2009/2010.

Table 7:10 List of Red Data Mammals that may occur in the Study Area

Scientific Name Vernacular Name Probability Of Occurrence

Status

Acinonyx jubatus Cheetah Low Vulnerable

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Atelerix frontalis South African Hedgehog Marginal Near threatened

Hyaena brunnea Brown hyena Medium Near threatened

Laecon pictus African wild dog Low Endangered

Manis temminckii Pangolin Medium Vulnerable

Mellivora capensis Honey badger Medium Near threatened

Miniopterus

schreibersii

Schreibers’ long fingered bat High Near threatened

7.5.3.3 HerpetofaunaThe Southern African Python (phython natalensis), an International Union for Conservation

of Nature (IUCN) red data species had a moderate to high probability of occurring in the

mineral lease area.

7.6 AIR QUALITY

The baseline study (2009) included the review of the site-specific atmospheric dispersion

potential, relevant air quality guidelines and limits. The dispersion model used namely

ADMS 4, required hourly average meteorological data as input, including wind speed, wind

direction, atmospheric stability, ambient air temperature and mixing height. No on-site

meteorological data was measured, and use was made of simulated data. The US-EPA

CALMET model (which forms part of the CALPUFF suit of models) is a three-dimensional

wind field model using surface and upper air data as well as topography and land-use

information. A three dimensional wind field model was compiled for the region with a point

nearest to the site office extracted for the period January to December 2006.

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Table 7:11 Atmospheric Stability Classes

Designation Stability Atmospheric Conditions

A Very unstable Calm wind, clear skies, hot daytime conditions

B Moderately unstable Clear skies, daytime conditions

C Unstable Moderate winds, slightly overcast daytime conditions

D Neutral High winds or cloudy days and nights

E StableModerate wind, slightly overcast night time

conditions

F Very Stable Low wind, clear skies, cold night time conditions

Particulates represent the main pollutant of concern when assessing open cast mining

operations. Particulates are divided into different particle size categories with Total

Suspended Particulates associated with nuisance impacts and the finer fractions of PM10

(particulates with a diameter less than 10 μm) and PM2.5 (diameter less than 2.5 μm) linked

with potential health impacts. Gaseous pollutants (such as sulphur dioxide, oxides of

nitrogen, carbon monoxide etc.) will be derived from vehicle exhausts but are regarded as

negligible in comparison to particulate emissions.

In characterising the baseline air quality in a region, ambient monitoring data was analysed

and reported on. No ambient monitoring or dust fallout data exists at the proposed Thaba

Mine site and reference was made to the dust fallout data recorded at the neighbouring

Amandelbult Mine. Data were available for the period May 2007 to October 2008. In

addition, existing sources contributing to the current (baseline) air quality in the region were

identified, and the main pollutants associated with these operations reported. Various

components of the bio-physical and socio-economic environment may be impacted by

atmospheric emissions associated with the various phases of the project. These

components include the possible impact on:

Ambient air quality;

The aesthetic environment;

Local residents and neighbouring communities; and,

Employees.

Sources identified in 2009/2010 as possibly impacting on air quality in the region included,

but were not limited to:

Fugitive emissions from mining operations;Page 32 of 108

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Vehicle tailpipe emissions from national and main roads;

Biomass burning (veld fires in agricultural areas within the region); and,

Various miscellaneous fugitive dust sources (agricultural activities, wind erosion of

open areas, vehicle-entrainment of dust along paved and unpaved roads).

7.6.1 Mining Operations in the RegionFugitive dust sources associated with mining activities included drilling and blasting

operations, materials handling activities, vehicle-entrainment by haul vehicles and wind-

blown dust from tailings impoundments and stockpiles. Mining operations were potentially

the most significant sources of fugitive dust emissions (PM2.5, PM10 and total suspended

solids) with small amounts of oxides of nitrogen, carbon monoxide, sulphur dioxide,

methane, and carbon dioxide being released during blasting operations and from mine

trucks. Experience has shown that fugitive dust emissions due to on-site operations are

typically only of concern within three km of the mine boundary, depending on the location of

the mine boundary and the extent of the mining operations. Existing mining operations in the

area included Amandelbult directly east of the proposed Thaba Cronimet Chrome Mine,

Thabazimbi Iron Ore mine located approximately 17km to the north-northeast, Northam

Platinum to the southeast (approximately eight km), and Union mine (approximately 23km to

the southwest).

7.6.2 Industrial Operations in the RegionStack, vent and fugitive emissions from the industrial operations included various criteria

pollutants greenhouse gases, volatile organic compound, semi-volatile organic compounds,

various heavy metals and other toxins such as dioxins and furans. The Rustenburg region

hosts a number of Ferrochrome smelters and Platinum smelters. Ferrochrome operations

include Xstrata (Rustenburg and Wonderkop operations), SA Chrome and Murafe

Ferrochrome. Impala and Anglo are the main platinum operators in the Rustenburg area with

Lonmin Platinum located further to the east. Sources of emission at these operations

typically included stack emissions, including main stack releases which comprised furnace

and converter off-gases, acid plant stack emissions and releases from flash dryer stacks.

7.6.3 Vehicle Tailpipe EmissionsAir pollution from vehicle emissions may be grouped into primary and secondary pollutants.

Primary pollutants are those emitted directly into the atmosphere, and secondary, those

pollutants formed in the atmosphere as a result of chemical reactions, such as hydrolysis,

oxidation, or photochemical reactions. The significant primary pollutants emitted by vehicles

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include carbon dioxide, carbon monoxide, hydrocarbons, sulphur dioxide, oxides of nitrogen,

particulates and lead. Secondary pollutants include: nitrogen dioxide, photochemical

oxidants (e.g. ozone), sulphur acid, sulphates, nitric acid, nitric acid and nitrate aerosols.

Toxic hydrocarbons emitted include benzene, 1.2-butadiene, aldehydes and polycyclic

aromatic hydrocarbons. Benzene represents an aromatic present in petrol, with 85% to 90%

of benzene emissions emanating from the exhaust and the remainder from evaporative

losses. Vehicle tailpipe emissions are also localised sources and unlikely to impact far-field.

The R510, a national road is located next to the mine site.

7.6.4 Domestic Fuel BurningDomestic fuel burning had been identified throughout the various studies as one of the most

significant sources of atmospheric emissions impacting on human health and well-being.

This is due to the level of release of domestic fuel burning emissions within the breathing

spaces of people, with the main pollutants of concern being fine particulates (PM10) and

sulphor dioxide. The extent of household fuel combustion in the region of the Thaba Mine

was not known.

7.6.5 Agricultural ActivitiesThe main economic activities within the region included agriculture, small scale farming,

commercial farming and mining. These activities were widely scattered throughout the

region. Cattle farms (primarily when operated on large scale) are significant sources of

fugitive dust especially when feedlots are used and the cattle trample in confined areas. The

calf-cow sector of the beef industry was found to be the large stemitter of methane

emissions. Where animals are confined densely, the main pollutants of concern include dust

from the animal movements, their feed and their manure, ammonia from the animal urine

and manure, and hydrogen sulphide from manure pits. This was not a likely problem in this

region with farms only located far away and covering large areas.

7.6.6 Biomass BurningCrop-residue burning and general wild fires (veld fires) represent significant sources of

combustion-related emissions associated with agricultural areas. This is typically a concern

in savannah regions where biomass-burning results in incomplete combustion with carbon

monoxide, methane and nitrogen dioxide being emitted during the process.

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7.6.7 Fugitive Dust SourcesFugitive dust emissions may occur as a result of vehicle entrained dust from local paved and

unpaved roads, and wind erosion from open areas, including tailings storage facilities. The

extent of particulate emissions from the main roads will depend on the number of vehicles

using the roads and on the silt loading on the roadways. The extent, nature and duration of

agricultural activities and the moisture and silt content of soils are required to be known in

order to quantify fugitive emissions from this source. The quantity of wind-blown dust is

similarly a function of the wind speed, the extent of exposed areas and the moisture and silt

content of such areas. The pollutants listed above are released directly by sources and are

therefore termed 'primary pollutants'. 'Secondary pollutants' which form in the atmosphere as

a result of chemical transformations and reactions between various compounds include:

nitrogen oxide, various photochemical oxidants (e.g. ozone), hydrocarbon compounds,

sulphur acid, sulphates, nitric acid and nitrate aerosols.

7.6.7.1 Measured Dust FalloutA dust fallout network existed for the Amandelbult Mine located directly east of the proposed

Thaba Cronimet Chrome Mine and data was provided for the period May 2007 to October

2008. The dust fallout varied significantly over the 18 month period and between sites.

During 2007, the highest dust fallout was measured at site one during August with the

second highest recording during July at site two. The most frequent high dust fallout levels

were recorded during the months of August, July and December 2007 with the most

exceedances of the SANS residential limit (600 mg/m²/day) recorded at site two. During

2008, the month with the highest number of dust fallout recordings were March, September

and June. Site two again recorded the highest dust fallout levels. Site two also exceeded the

SANS residential limit and the industrial limit for more than three months in a year and more

than two consecutive months.

7.7 NOISE

The rural environment on which Thaba Mine is situated had typically low levels of

background noise, dominated by the natural sounds of wildlife (primarily birdsong), and man-

influenced sounds such as livestock, farming activities, domestic activity and road and air

traffic, but especially with noise from existing entrenched mining activity in the area. Site

measurements were carried out on 2 and 3 July 2009 in accordance with the procedures

specified in SANS 10103. Measurements were carried out at six positions on or near the

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boundaries of the property and descriptive results as per the table below with summary of

the results as per the Table below.

Table 7:12 Recommended Noise Levels SANS 10103:2008

Type of DistrictEquivalent Continuous Rating Level For Noise (dBA)

Outdoors Indoor with open windows

Day-nightLR,dn

1)

Day-timeLReq,d

2)

Night-timeLReq,n

2)

Day-nightLR,dn

1)

Day-timeLReq,d

2)

Night-timeLReq,n

2)

a) Rural districts 45 45 35 35 35 25

b) Suburban districts with little

road traffic50 50 40 40 40 30

c) Urban districts 55 55 45 45 45 35

d) Urban districts with one or

more of the following:

workshops; business

premises; and main roads

60 60 50 50 50 40

e) Central business districts 65 65 55 55 55 45

f) Industrial districts 70 70 60 60 60 50

Table 7:13 Summary of Noise Monitoring Positions and Results

Positions Results

At the entrance to the northern part of the

section of the site west of the R510 road, in

line with the fence

The area was natural bush with the intrusion of existing

opencast mining activities to the south. The primary

noise sources in the area were remote traffic on the

R510, which was audible and measurable from this

position, and remote plant noise, loading operations, and

haul trucks from other mines already operating in the

area.

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Positions Results

Measurement position two is 20m from the

centerline of the R510 at the 104km post

towards the northern boundary of the site

The noise climate on the site along the R510 corridor

was dominated by traffic noise up to 600m from the road.

The measured values tabulated above area also in

agreement with the calculations using the SANS

recommended method.

Measurement position three is on the

northeast corner of the proposed treatment

plant site at the entrance gate

This was typical of a rural area with little or no man-made

noise, primarily natural noise from birds and insects.

Noise was sometimes audible from remote mining plants

and operations on neighbouring mines, but was not loud

enough or frequent enough to contribute to the

measurements. Noise from the neighbouring mine’s

ventilation fans were not measurable at this position

Perimeter of the dirt road on the eastern

boundary of the Moddergat 389 KQ site and in

line with the axis of the neighbouring mine’s

existing ventilation fans

The noise from the existing mine ventilation fan

completely dominated the noise climate over a large

area of the eastern side of the Moddergat 389 KQ. Note

that this noise was continuous and the measurement

values were highly repeatable and stable

Perimeter of the dirt road on the eastern

boundary of the Moddergat 389 KQ site 150m

from the existing mine ventilation fans on the

neighbouring mine

Noise from this existing mine ventilation fan completely

dominated the noise climate of the area.

Perimeter dirt road on the eastern boundary of

the Moddergat 389 KQ site. It is 350m from

the existing mine ventilation fans on the

neighbouring mine

The noise from the existing mine ventilation fan

completely dominated the noise climate of the area.

7.7.1 Measurement Position OneAt the entrance to the northern part of the section of the site west of the R510 road, in line

with the fence as shown in the following photographs (GPS co-ordinates – S24 46.176,

E27 18.992) Height 943m (4.2m)). The following noise measurements were taken at

position 1 and can be seen below.

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Table 7:14 Noise Measurements Taken At Position 1

Day/Date TimeTC

RH% Wind m/s Leq L90

Fri 03/07/09 08:21-08:31 6.5 66 still 44.5 41

Fri 03/07/09 08:32-08:42 6.5 66 still 43.0 40

Fri 03/07/09 09:17-09:27 11 55 still 40.8 35

Fri 03/07/09 12:35-12:45 19 29 still 35.0 27

Fri 03/07/09 12:46-12:56 19 29 still 35.7 27

Thur 02/07/09 13:53-14:03 21.5 24 <3.2 35.8 27

Thur 02/07/09 14:04-14:17 21.5 24 <3.2 35.6 26

Thur 02/07/09 14:18-14:28 21.5 24 <3.2 38.6 30

Thur 02/07/09 16:15-16:25 19.5 27 still 37.0 28

Thur 02/07/09 16:26-16:36 19.5 27 still 32.1 26

The area is natural bush with the intrusion of existing opencast mining activities to the south.

The primary noise sources in the area are remote traffic on the R510, which is audible and

measurable from this position, and remote plant noise, loading operations, and haul trucks

from other mines already operating in the area.

7.7.2 Measurement Position 2Measurement position two is 20m from the centerline of the R510 at the 104km post towards

the northern boundary of the site. (GPS co-ordinates – S24 45.693, E27 19.504. Height

947m (6m). The following noise measurements were taken at position 2 and can be seen

below.

Table 7:15 Noise Measurements Taken At Position 2

Day/Date TimeTC

RH%Wind m/s

Leq L90

Fri 03/07/09 08:48-08:58 6.5 66 still 64.4 40

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Day/Date TimeTC

RH%Wind m/s

Leq L90

Fri 03/07/09 09:00-09:10 6.5 66 still 61.5 38

Fri 03/07/09 12:08-12:18 19 29 <2.5 65.7 41

Fri 03/07/09 12:19-12:29 19 29 <2.5 64.4 35

Thur 02/07/09 15:24-15:34 21 26 <2.4 64.9 40

Thur 02/07/09 15:36-15:46 21 26 <2.4 65.3 37

Thur 02/07/09 15:48-15:58 21 26 <2.8 65.0 40

Thur 02/07/09 15:59-16:09 21 26 <2.8 64.6 42

The noise climate on the site along the R510 corridor is dominated by traffic noise up to

600m from the road. The measured values tabulated above area also in agreement with the

calculations using the SANS recommended method.

7.7.3 Measurement Position 3Measurement position three is on the northeast at the entrance gate (GPS co-ordinates –

S24 49.323, E27 15.683. Height 987m (5m)).The following noise measurements were

taken at position 3 and can be seen below.

Table 7:16 Noise Measurements Taken At Position 3

Day/Date Time TC RH% Wind m/s Leq L90

Fri 03/07/09 11:23-11:33 18 30 still 35.9 28

Fri 03/07/09 11:34-11:44 18 30 still 32.8 26

Fri 03/07/09 11:45-11:55 18 30 still 32.0 27

This is a typical of a rural area with little or no man-made noise, primarily natural noise from

birds and insects. Noise is sometimes audible from remote mining plants and operations on

neighbouring mines, but is not loud enough or frequent enough to contribute to the Page 39 of 108

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measurements. Noise from the neighbouring mine’s ventilation fans are not measurable at

this position

7.7.4 Measurement Position 4Measurement position four, on the perimeter of the dirt road on the eastern boundary of the

Moddergat site and in line with the axis of the neighbouring mine’s existing ventilation fans

(GPS co-ordinates – S24 50.078, E27 16.138. Height 969m (4.2m)). The following noise

measurements were taken at position 4 and can be seen below.

Table 7:17 Noise Measurements Taken At Position 4

Day/Date Time TC RH% Wind m/s Leq L90

Fri 03/07/09 10:10-10:12 17.5 37 <0.5 71.2 70

Fri 03/07/09 10:22-10:24 17.5 37 <0.5 70.9 69

From the table above, it can be said that the noise from the existing mine ventilation fan

completely dominates the noise climate over a large area of the eastern side of the

Moddergat. Note that this noise is continuous and the measurement values are highly

repeatable and stable.

7.7.5 Measurement Position 5Measurement position four, is on the perimeter of the dirt road on the eastern boundary of

the Moddergat site 150m from the existing mine ventilation fans on the neighbouring mine

(GPS co-ordinates – S24 49.986, E27 16.080. Height 970m (5m)). The following noise

measurements were taken at position 5 and can be seen below.

Table 7:18 Noise Measurements Taken At Position 5

Day/Date Time TC RH% Wind m/s Leq L90

Fri 03/07/09 10:42-10:47 17.5 37 still 54.2 52

From the table above, it can be seen that noise from this existing mine ventilation fan

completely dominates the noise climate of the area.

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7.7.6 Measurement Position 6Noise measurement position six can be found on the perimeter dirt road on the eastern

boundary of the Moddergat site. It is 350m from the existing mine ventilation fans on the

neighbouring mine (GPS co-ordinates – S24 49.909, E27 16.033. Height 972m (6m)).

The following noise measurements were taken at position 6 and can be seen below.

Table 7:19 Noise Measurements Taken At Position 6

Day/Date Time TC RH% Wind m/s Leq L90

Fri 03/07/09 11:02-11:07 17.5 37 still 45.5 43

The above table shows that the noise from the existing mine ventilation fan completely

dominates the noise climate of the area.

7.8 ARCHEOLOGY

The following evaluation criterion was used for determining the significance of archaeological

and heritage sites at Thaba Mine:

The unique nature of a site;

The integrity of the archaeological deposit;

The wider historic, archaeological and geographic context of the site;

The location of the site in relation to other similar sites or features;

The depth of the archaeological deposit (when it can be determined or is known);

The preservation condition of the site;

Uniqueness of the site; and

Potential to answer present research questions.

In addition, site significance classification standards prescribed by the South African

Heritage Resources Agency (2006) and approved by the Association for Southern African

Professional Archaeologists for the Southern African Development Community region, were

used for the baseline conditions.

Table 7:20 Heritage Site Significance and Mitigation Measures

Field rating Grade Significance Recommended Mitigation

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National Significance Grade 1 -Conservation; National Site

nomination

Provincial Significance Grade 2 -Conservation; Provincial Site

nomination

Local Significance Grade 3A High Significance Conservation; Mitigation not advised

Local Significance Grade 3B High SignificanceMitigation (Part of site should be

retained)

Generally Protected A -High / Medium

SignificanceMitigation before destruction

Generally Protected B -Medium

SignificanceRecording before destruction

Generally Protected C - Low Significance Destruction

Cultural resource management surveys, e.g. van Schalkwyk (2004), van der Walt (2010 &

2014) conducted in the area and Huffman (2006) to the north of the area provided a good

basis for understanding the local archaeology. From these studies it was clear that sites and

artefacts dating to the Stone Age, Iron Age, historical cemeteries, farm worker homesteads,

european homesteads and historic/recent mining activities have been recorded and occur in

the larger study area.

For the study area Iron Age activity is concentrated along water courses and rocky outcrops

or hills marked by ceramic clusters or dry stone walling. Material was also found in these

areas especially at the base of hills and along watercourses. Archival documents indicated

that the farms under investigation were established during the 19th century. The Figure

below provides the location of recorded sites for the greater study area. It was noted that

some artefacts occur on farms not part of the CCMSA mineral lease area. These sites

provided an indication of the heritage context of the greater study and placed the sites found

and expected for the area in perspective.

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Figure 7:8 Recorded Heritage Artefacts for the Area

7.8.1 Late Iron Age Simplex Sites Site 6: The site is located on the farm Moddergat 389 KQ. Two enclosures

interpreted as cattle kraals occur around a small hill. Grinding hollows are found on

top of the small outcrop.

Site 8: The site is located on the farm Moddergat 389 KQ. The site consists of a

single cattle enclosure next to a small rock outcrop close to the Bierspruit.

Site 10: The site consists of badly preserved stone walling around a small rock

outcrop on Moddergat 389 KQ.

Site 11: The site consists of badly preserved stone enclosures located in the saddle

of a small hill on the farm Moddergat 389 KQ.

Site 13: Site 13 is located on the farm Moddergat 389 KQ. The site consists of a

cattle enclosure on a low running ridge next to the Bierspruit.

Site 14: Site 14 is located on the farm Moddergat 389 KQ. The site consists of a

cattle enclosure and grinding hollows on a low running ridge next to the Bierspruit.

Site 15: Site 15 is located on the farm Moddergat 389 KQ. The site consists of a

cattle enclosure.

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Site 16: Site 16 consists of the well preserved dry stone walls of a cattle enclosure

next to a rock outcrop.

Site 18: The site is located on the farm Moddergat 389 KQ and consists of a cattle

kraal of approximately 20 meters in diameter.

Site 22: The site is located on the farm Schildpadsnest 385 KQ. The site is

overgrown and consists of a large cattle enclosure.

Site 23: The site is located on the farm Schildpadsnest 385 KQ. The site is

overgrown and consists of a large cattle enclosure.

Site 28: The site is located on the western portion of the farm Moddergat far away

from the river. The site is classified as a find spot, consisting of the undecorated

ceramic fragments of two vessels. No other cultural material is present on site.

Site 30: The site is located on the farm Schildpadsnest 385 KQ and consists of

enclosure of approximately 7meter in diameter. The site is badly preserved and some

of the walling has been robbed.

Site 31: The site is located on the farm Schildpadsnest 385 KQ and consists of a

badly preserved enclosure of approximately seven meters in diameter.

7.8.2 Stone Age SitesThree sites with Stone Age material were on record for areas within the CCMSA mineral

lease area. These sites are all open air sites situated around hills and rock outcrops. The

sites are located on the farms Zwartkop 369 KQ and Moddergat 389 KQ. Diagnostic features

on the tools consist of facets on the striking platform indicating Middle Stone Age

occupation. Raw material consists of igneous rock, Hornfels and possibly Silcrete. Raw

material was found in abundance on the farm Zwartkop 369 KQ consisting of Quartzite,

Chert, Banded Iron Stone and Rhyolite. Details of the sites as follows:

Site 2: the site is located on the farm Zwartkop 369 KQ and consists of a high

concentration of artefacts scattered mostly on the northern side of Mooskop. Raw

material is abundant in this area consisting of Quartzite, Chert, Banded Iron Stone

and Rhyolite. Artefacts consist of diagnostic Middle Stone Age tools and includes

amongst other prepared cores and tools with facets on the striking platform. The

tools are well preserved and do not show much weathering and contain clear

diagnostic features;

Site 7 and site 9 are located on the farm Moddergat and consist of a medium

frequency of artefacts scattered around small hills close to the Bierspruit. Because of

sheet erosion the artefacts are weathered and badly preserved and not much can be

said about them. Diagnostic features on the tools consist of facets on the striking

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platform indicating Middle Stone Age occupation. Raw material consists of igneous

rock, Hornfels and possibly Silcrete

7.8.3 Iron Age SitesTwenty nine Late Iron Age stone walled sites and one “spot find” site market by cultural

material in the form of undecorated ceramics was on record for the farms Zwartkop 369 KQ,

Moddergat 389 KQ and Schildpadsnest 385 KQ. These Late Iron Age remains consist of

cattle kraals and smaller livestock (sheep/goat) enclosures, hut bays, granary platforms, the

remains of huts and other associated features such as ash middens and grinding hollows.

Details as follows:

7.8.4 Late Iron Age Complex Sites Site 1: This site is located on the farm Zwartkop 369 KQ to the east of Mooskop.

Recent mining activities have occurred on site and trace evidence of an Iron Age Site

was found in the vicinity.

Site 2: This site is also located on the farm Zwartkop 369 KQ and is situated on the

north of Mooskop. The site is highly overgrown but fairly well preserved.

Site 4: The site is situated on the farm Moddergat 389 KQ and is located on the

eastern boundary of the farm. The farm road and the construction of power lines

impacted negatively on the site. The site is located on turf soil but several decorated

ceramic fragments were exposed by the impact of the road on the site.

Site 5: The site is situated on the farm Moddergat 389 KQ around a small hill. Finds

include ceramics, cattle enclosures hut bays en grinding hollows.

Site 12: The site is located on the farm Moddergat 389 KQ and consists of several

large cattle enclosures. The site is located on a low running ridge close to the

Bierspruit.

Site 17: The site consists of at least six enclosures of approximately 5 -10 meters in

diameter. The site is located on the farm Moddergat 389 KQ

Site 20: The site is located on the farm Schildpadsnest 385 KQ. The site is highly

overgrown and it is not possible to determine layout. This site is of interest because it

might have an outer enclosing wall that so far has not been documented at the other

complex sites.

Site 21: The site consists of at least five enclosures with an average diameter of

between 5 -10 meters next to a rock outcrop. The natural rock has been included in

the design. The site is located on the farm Schildpadsnest 385 KQ.

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Site 24: The site is located on the farm Schildpadsnest 385 KQ and consist of several

large cattle enclosures.

Site 25: The site is located on a low running ridge at the eastern boundary of the farm

Schildpadsnest 385 KQ and consist of several large cattle enclosures. The farm road

next to fence impacted negatively on the site, destroying several enclosures.

Site 29: The site is located on the farm Schildpadsnest 385 KQ and consists of an

extensive settlement. The site is how ever badly preserved and some of the walling

might have been robbed to construct farm labourer dwellings.

7.8.5 CemeteriesDetails of cemeteries as follows:

Site 19: This is the location of a large overgrown cemetery on the farm Zwartkop. The

graves are aligned east west and the grave dressings consist of stone packed graves

and modern granite headstones. Some of the inscriptions that are visible is of the

family Lehobye and Mpete. The oldest visible date of the deceased is 1921, giving

the impression that some of the graves might be even older. Due to the fact that the

site is so overgrown it was not possible to do an accurate count of the graves but it is

estimated that there are more than 120 graves present;

Site 26: This is the location of a cemetery with a single grave on the farm Moddergat.

The grave is of a child, Danie Groenewald who was born on the 22 June 1938 and

passed away on the 13 July 1938; and

Site 35: This is the location of a large cemetery in Smash Block. The cemetery is

located outside of the impact area of the mine, but is significant because this is

where most of the recently deceased who resided in the study area will be buried.

7.8.6 European HomesteadSeveral modern structures occurred throughout the study area, but these structures were at

most not older than 20 years and were not considered as significant. However, one

structure on the farm Zwartkop 369 KQ was still being used and well preserved. The exact

age of the structure is not certain but based on the architecture it is assumed that the house

could be approaching 60 years and would then be protected by legislation. Details as

follows:

Site 27: This is the remains of the demolished farmhouse of the farm Moddergat. The

house was constructed with red sun dried bricks that were plastered. It is assumed

that the structure is associated with the grave at site 26 and it can be deducted that

the site then must be dating to the 1930’s and therefore older than 60 years and

protected by legislation.Page 46 of 108

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Site 37: This is the location of a farm house on a portion of the farm Zwartkop 369

KQ. The house is still being used and well preserved. The exact age of the structure

could not be determined but based on the architecture it is assumed that the house

could be approaching 60 years

7.8.7 Historic/Recent MiningThe hill on the farm Zwarkop 369 KQ that is called Mooskop was previously mined in the

recent past by other mining entities.

7.9 WETLANDS

7.9.1 Wetland Delineation and Classification

The study area is drained by the Bierspruit and its associated tributaries. Three different

wetland types were identified within the study area, namely:

Channelled valley bottom wetlands;

Unchannelled valley bottom wetlands; and

Seepage wetlands.

In addition, several riparian zones occurred within the study area, while numerous small

dams also occurred within the riparian zones and valley bottom wetlands. Small drainage

lines that displayed no clear wetland or riparian zone characteristics but that are classified as

a watercourse also occurred on site.

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Figure 7:9 Delineated Wetlands and Riparian Zones within the Mineral Lease Area

Table 7:21 The Hydro-Geomorphic Classification System (Adapted From Brinson, 1993;

Kotze, 1999 And Marneweck And Batchelor, 2002).

Hydro-geomorphic type Description

Channelled Valley Bottom

Valley bottom areas with a well defined stream channel but lacking

characteristic floodplain features. May be gently sloped and

characterised by the net accumulation of alluvial deposits or may

have steeper slopes and be characterised by the net loss of

sediment. Water inputs from the main channel and adjacent slopes.

Unchannelled valley bottom

Valley bottom areas with no clearly defined stream channel usually

gently sloped and characterised by alluvial sediment deposition,

generally leading to a net accumulation of sediment. Water inputs

mainly from channel entering the wetland and also from adjacent

slopes.

Riparian zone Riparian habitats (as defined by the NWA) include the physical

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Hydro-geomorphic type Description

structure and associated vegetation of the areas associated with a

watercourse which are commonly characterised by alluvial soils

(deposited by the current river system), and which are inundated or

flooded to an extent and with a frequency sufficient to support

vegetation of species with a composition and physical structure

distinct from those of adjacent areas.

Drainage line

Small, narrow watercourses that display no clear wetland or riparian

zone characteristics yet represent preferential flow paths for water

and convey water intermittently following rainfall events. As

watercourses they are also afforded a degree of protection under the

NWA.

Across the mineral lease area, there were well-developed riparian zones which were

delineated along the Bierspruit and one of its larger, seasonal tributaries. In addition, three

small drainage lines feeding into the Bierspruit were also identified. The tributaries of the

Bierspruit which occurred within the study area were dry at the time of the site visit and were

expected to hold water only for short periods after rainfall events. A narrow riparian zone

was associated with the largest of these tributaries, which was characterised further by a

clearly defined channel, mostly devoid of vegetation, with the exception of an occasional

grass species. The small drainage lines on site represent preferential flow paths within the

landscape with poorly defined channels and vegetation that does not differ from the

surrounding terrestrial vegetation in species composition or structure.

Numerous wetland types and two riparian zones were identified within the mining site, which

together with the six dams identified; covered approximately 162ha of the mining site. Two of

the dams identified on site appear to have been constructed to receive water from the

existing mining activities in the area. Leakage and overflow from these dams appeared to

have been sustaining the seepage wetlands on site. As such, the seepage wetlands could

be labelled as artificial wetlands, though they are nonetheless considered to potentially play

an important role in trapping pollutants and contaminants that might be contained in the

water from the mines.

The large dam constructed across the Bierspruit roughly in the centre of the mining site,

together with the roughly 3.7Ml per day (values for December 2008) of mine water

discharged into the Bierspruit from Amandelbult Mine (quoted

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fromwww.angloplatinum.com/pdf%5C2009%5Cwater.pdf), was believed to have contributed

towards the formation of the wetland conditions along this portion of the river due to the

extended retention and increased flow of water. Further upstream and downstream of the

large dam and the Amandelbult Mine the Bierspruit was again associated with a riparian

zone. The retention of water and the large expanse of openwater and muddy shoreline

provided by the large dam had created an ideal water bird habitat and numerous species of

water birds were recorded on site.

Several smaller tributaries of the Bierspruit associated with riparian zones or channelled

valley bottom wetlands also occurred on site, while an unchannelled valley bottom wetland

occured in the north eastern corner of the site. The unchannelled valley bottom was located

in a broad, flat valley dominated by grasses with little woody vegetation. A small farm dam

hasd been constructed across this wetland, while two excavations located adjacent to the

valley bottom wetland were also likely to have collected water during the rainy season.

7.9.2 Functional Assessment

7.9.2.1 Riparian ZonesRiparian areas can perform a variety of functions that are of value to society, especially the

protection and enhancement of water resources, and provision of habitat for plant and

animal species. The riparian areas on site are expected to play a role in protecting and

enhancing the local water resources through the stabilisation of the river banks as well as

through sediment trapping. Sediment trapping is expected to occur when the river overtops

the channel banks – the water spreading out over a larger surface as well as the resistance

to flow offered by the increased surface roughness provided by the riparian vegetation slows

done the flow velocity, thus creating a depositional environment. In slowing down flow

velocities during flood flows, riparian zones can also contribute to temporary storage of flood

flows and reduce downstream flood damage. The riparian zone also has the potential to

improve water quality through the trapping of nutrients and by acting as a buffer between the

aquatic environment in the river channel and adjacent terrestrial land uses.

7.9.2.2 Channelled Valley Bottom WetlandsWithin the study area, the channelled valley bottom wetland was directly associated with the

large dam built across the Bierspruit. It is likely that the building of the dam has resulted in

the wet land conditions along this section of the Bierspruit replacing the riparian zone that

would have been expected to occur here in the absence of the dam. As such, in assessing

the functions performed by the valley bottom wetland, it is important to alsoPage 50 of 108

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7.9.2.3 Seepage WetlandsAlthough it is assumed that the seepage wetlands on site have formed through artificial

means, i.e. through the seepage and leakage of water out of adjacent mine dams, these

wetlands are nonetheless considered to support various functions of value. Besides their

role in supporting biodiversity through the provision of different habitats, they are also

expected to play a role in improving water quality through the trapping of pollutants and

nutrients that might be found in the water derived from the mining activities.

7.9.3 Present Ecological Status Within the study area past and current mining activities have taken place, numerous dams

have been built, and portions of the site fall within communal land (characterised by

overgrazing and the setting of snares), resulting in extensive impacts on the wetlands and

riparian zones in these areas. The mining activities within and adjacent to the proposed

mining area were expected to have impacted on the riparian zones in two ways, namely by

increasing flows within the Bierspruit through release of water used in the mines/pumped

from the mines and through deteriorating water quality, while the dams have altered the

hydrology supporting the systems. The above activities and their impact on the wetlands

and riparian zones were clearly reflected in the results of the present ecological status

assessment done in 2009. The scores for the wetlands and riparian zones within the study

site ranged from moderately modified to seriously modified.

7.9.4 Ecological Importance and Sensitivity Ecological importance of a water resource is an expression of its importance to the

maintenance of ecological diversity and functioning on local and wider scales. Ecological

sensitivity refers to the system’s ability to resist disturbances and its capability to recover

from disturbance once it has occurred. The Bierspruit, consisting of the riparian zone, the

large dam and the valley bottom wetland, was considered to be of high ecological

importance and sensitivity despite being considered a largely modified system on site, given

its importance in terms of maintaining biodiversity and supporting Red Data species, its

ecological integrity as well as the various functions the riparian zone associated with the

Bierspruit is expected to perform. The remaining wetlands and riparian areas on site varied

from low/marginal ecological importance and sensitivity from the artificially maintained

seepage wetlands to moderate importance and sensitivity for the remaining wetlands and

riparian zones on site. The unchannelled valley bottom wetland was also considered to be of

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moderate importance and sensitivity, despite the impacts of the mining dam located within

the upper reaches of this stream and the small farm dam located onsite.

7.10 AQUATIC

Thaba Mine is situated in the western side of the Limpopo Province and includes the

Waterberg Mountain Range. The availability of water is the most crucially limiting resource

for Province, however, during the high flow sampling season there are a number of running

streams and rivulets occurring in the veld. These include the Bierspruit River and its

surrounding tributaries, which occur in the study area and constitute a part of the catchment

area for the Limpopo River Basin. The Bierspruit River is one of two large tributaries of the

Lower Crocodile River and it joins the Crocodile River south-west of Thabazimbi. There are

no large dams occurring in the study area, however, some smaller dams do occur on the

Bierspruit. Various sites were chosen to conduct the bio-monitoring and the table below

provides a description of each of the chosen sites and their associated significance.

Table 7:22 Location, Description and Significance of the Chosen Bio-Monitoring Sites at

Thaba Mine

Site Description Significance

BS01 Located on the Moddergat farm at

the point where the Bierspruit River

enters the property.

The site indicates the condition of the Bierspruit

upstream of any impacts likely to affect the river as

a result of any activities during the life of the

proposed project. The site serves as a spatial

reference for the BS02 site.

BS02 Located on the Moddergat farm at

the point where the Bierspruit exits

the property.

The site indicates the condition of the Bierspruit

downstream of any impacts occurring as a result of

activities undertaken during the life of the proposed

project and upstream of the Anglo Platinum mining

activities. This site can be compared spatially to

the BS01 site.

BS03 Located at a bridge at the point

where the Bierspruit exits the Anglo

Platinum Mine mining area.

Indicates the level of ecological integrity on the

Bierspruit downstream of the Anglo Platinum Mine

mining activities. The site can be compared

spatially to the BS02 site.

BS04 A dam situated on the Bierspruit on The site serves to support the investigation of the

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Site Description Significance

the Schildpadnest farm before

flowing out into a channelled

wetland along the Bierspruit.

fish and macro-invertebrate diversity in the study

area. Water quality is also indicated.

BS05 Located on downstream of the dam

and wetland on the Schilpadnest

farm.

Indicates the level of ecological integrity on the

Bierspruit River downstream of the dam and

wetland and opencast activities of the proposed

project. The site can be compared spatially to the

BS03 site.

BS06 Located on the Schilpadnest farm at

the point where the Bierspruit exits

the study area.

This site serves to indicate the effect on the

Bierspruit of any impacts occurring as a result of

activities undertaken during the life of the proposed

project.

7.10.1 In Situ Water QualityIn situ water quality is important as it assists in the interpretation of biological results due to

the direct influence water quality has on aquatic life forms. The general water quality

throughout the area can be considered as poor at the time of the assessment as it had:

Relatively high concentrations of dissolved salts. In addition, the Electrical

Conductivity (EC) shows a high variability between sampling points, this level of

change between the sites exceed the DWAF target water qualities for aquatic

ecosystems. It is likely that the osmotic stress due to spikes and drops in EC may

affect the aquatic communities colonising the area;

Fair concentrations of dissolved oxygen were present in the system, however, some

impact from reduced dissolved oxygen may occur preventing sensitive community

members from colonising this section of the Bierspruit; and

The temperature values at the site can be regarded as being natural and any

variations may be attributed to natural diurnal variations. Cognisance must be taken

of the fact that the water quality was determined by hand held equipment.

7.10.2 Habitat AssessmentHabitat assessment can be defined as the evaluation of the structure of the surrounding

physical habitat that influences the quality of the water resource and the condition of the

resident aquatic community. The general habitat integrity of each site is discussed below,

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based on the application of the Intermediate Habitat Integrity assessment for use in rapid and

intermediate habitat assessments. It is important to assess the habitat of each site in order to

aid in the interpretation of the results of the community integrity assessments by taking habitat

conditions and impacts into consideration. This method describes the Present Ecological

State of both the in-stream and riparian habitat at each site. The method classifies Habitat

Integrity into one of six classes, ranging from unmodified/natural (Class A), to critically

modified (Class F). Reference conditions for the area were considered as unmodified/natural

(class A).

Table 7:23 Classification of Present State Classes in terms of Habitat Integrity (DWAF,

1999)

Class Description Score (% of total)

A Unmodified, natural. 90-100

B Largely natural, with few modifications. 80-90

C Moderately modified. 60-79

D Largely modified. 40-59

E Extensively modified. 20-39

F Critically modified. <20

A summary of the results of the Intermediate habitat assessment are included in the table

below and are outlined below:

Habitat structure and diversity are not suitable for supporting a diverse aquatic

macro-invertebrate community at sites BS02, BS03 and BS05, however sites BS01

and BS06 are suitable;

The system as a whole has been largely impacted upon by ever increasing mining

activities in the surrounding areas, as well as the historical impacts from farming;

It is a relatively still and slow flowing system throughout and impacts from in stream

barriers, road crossings and bridges are evident;

Little cover in the form of, aquatic vegetation and undercut root wads and debris were

present in the system as a whole with the exception of some anomalies at sites BS02

and BS06.

Limited spatial variation in habitat is evident at each of the sites; and

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Intermediate habitat assessment was not applied to the BS04 site as the index is

only applicable to riverine environments.

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Table 7:24 Intermediate Habitat Assessment Results

Type Of Result

Mcmillan, 1998 IHAS Description

IHAS Stones Biotopes

IHAS Vegetation Biotopes

IHAS Other Biotopes

IHAS General Stream Characteristics IHAS Score

IHAS Adjustment Score

BS01 Habitat structure

and diversity are

suited to

supporting a

diverse aquatic

macro-invertebrate

community.

There was an

excellent availability

of rocky substrate at

this point suitable for

supporting a diverse

aquatic community.

Good habitat

characteristics present

with dense leafy bankside

vegetation cover

There are

some gravel

and sand

deposits

present at the

site providing

habitat for

suitably

adapted

aquatic macro-

invertebrates.

A wide, still section of stream. The water

was fairly discoloured at the time of

assessment. Riparian vegetation consists

of a mix of grass, trees and reeds which

adequately protect the riparian zone from

erosion.

73 +13

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Type Of Result

Mcmillan, 1998 IHAS Description

IHAS Stones Biotopes

IHAS Vegetation Biotopes

IHAS Other Biotopes

IHAS General Stream Characteristics IHAS Score

IHAS Adjustment Score

BS02 Habitat structure

and diversity are

inadequate for

supporting a

diverse aquatic

macro-invertebrate

community.

No rocky substrate in

or out of current was

present at the time of

assessment.

Good habitat

characteristics present

with dense bankside

vegetation cover and

aquatic vegetation

present. The limited leafy

nature of the aquatic

vegetation and bankside

vegetation reduce the

suitability of the cover for

aquatic macro-

invertebrates.

There was limited gravel,

sand and mud biotopes

present at the site at the

time of the assessment.

A relatively wide, still section

of stream. The water was fairly

discoloured at the time of

assessment and there was

little flow variation at the time

of the assessment. Riparian

vegetation consists of a mix of

grass and trees.

51 +10

BS03 Habitat structure

and diversity are

inadequate for

supporting a

diverse aquatic

maco-invertebrate

There was adequate

rocky substrate

present at the time of

the assessment to

support suitably

adapted macro-

The leafy nature of the

overhanging vegetation

present at this point in the

system was adequate for

supporting a diverse

There is

muddy

substrate

present at the

site along with

A narrow, still section of the stream. The

water was fairly discoloured at the time of

assessment.

62 +17

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Type Of Result

Mcmillan, 1998 IHAS Description

IHAS Stones Biotopes

IHAS Vegetation Biotopes

IHAS Other Biotopes

IHAS General Stream Characteristics IHAS Score

IHAS Adjustment Score

community invertebrate

organisms

community structure. some sandy

deposits in

some areas,

providing

suitable habitat

for suitably

adapted

aquatic macro-

invertebrates.

There was no

gravel present

at the site at

the time of the

assessment.

BS05 Habitat structure

and diversity are

inadequate for

supporting a

diverse aquatic

maco-invertebrate

community

No rocky substrate in

or out of current was

present at the time of

assessment.

There was limited

vegetation present at this

point in the system for

supporting a diverse

aquatic community

structure.

There is

muddy

substrate

present at the

site along with

some sandy

deposits in

some areas,

providing

suitable habitat

A relatively narrow still section of stream

with little variation in flows. The water was

fairly discoloured at the time of

assessment. The riparian zone is severely

impacted on at this point by livestock

trampling.

58 +6

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Type Of Result

Mcmillan, 1998 IHAS Description

IHAS Stones Biotopes

IHAS Vegetation Biotopes

IHAS Other Biotopes

IHAS General Stream Characteristics IHAS Score

IHAS Adjustment Score

for suitably

adapted

aquatic macro-

invertebrates.

BS06 Habitat structure

and diversity are

adequate for

supporting a

diverse aquatic

maco-invertebrate

community

No rocky substrate in

or out of current was

present at the time of

assessment.

There was limited

bankside vegetation

present at this point in the

system. However, a fair

amount of aquatov

vegetation was present

for supporting a diverse

aquatic community

structure.

There were

limited muddy

biotopes

present at the

site at the time

of the

assessment.

A deep relatively still section of the stream

with little depth and flow variation. The was

discoloured at the time of the assessment.

65 +20

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7.11 GROUNDWATER

A drilling program was commissioned by JMA Consulting in March 2009 in order to obtain

geo-hydrological and geological information of the aquifer. The site information, borehole

logs and multi-parameter data of the drilled boreholes are attached in appendices to the

report contained in Appendix B. Geohydrological and hyrdo-chemical information was

collected by JMA Consulting during a hydro-census at the proposed Thaba Cronimet

Chrome Mine study area. The hydro-census was performed in May 2009, covering the total

Thaba Cronimet Chrome Mine area. The census included a compilation of groundwater use

data, owner information, borehole yields and water level measurements. Hydro-chemical

samples were also taken at selected sites. A total of eight boreholes were drilled to cover the

total study area. The borehole logs and geohydrological descriptions can be seen in the

2009 Groundwater report attached in Appendix B.

7.11.1 Depth of the Water TableWater level information was obtained from the hydro census done in 2009 on the CCMSA

mineral lease area. Historical water levels, measured by DWS in the greater study area,

yielded information on 276 boreholes. The database shows initial ground water intersection

on an average of 21.4m, with rest water levels at around 17.1m. The average weathering

depth of Norite/Gabbro units is 24.7m, indicating a poorly-established, saturated shallow

weathered zone aquifer. Ground water level fluctuations of up to 10m over the geo-

hydrological cycle show a distinct seasonal trend.

Table 7:25 Summary of the Water Levels in External and Monitoring Boreholes in the Study

Area

SitesDWS monitoring boreholes

External users identified during hydro census

Newly drilled boreholes for Cronimet

Number of sites 276 19 8 (6dry)

Minimum level (m)

2.9 2.87 8.5

Maximum level 55.2 50.0 17.38

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(m)

Average level (m) 17.1 20.8* ~^

Correlation with topography

Unknown 0.62 ~^

* Average for boreholes currently in use

^ Only two boreholes yielded water levels during the geohydrological investigation. Drawing

statistical conclusions from two points is not representative.

The DWS monitoring boreholes indicated water level distributions from near-surface, to

basically the maximum depth of weathering of the Norite/Gabbro aquifers. Water strikes

deeper than the limit of weathering are extremely rare. The likelihood for deeper water

strikes was given as 1 percent. Given the number of observations in the DWS database, the

average water level recorded (17 m) is viewed as the undisturbed, background ground water

levels of the area. The water level distribution on the farms Zwartkop, Roodedam, Langpan,

Moddergat, Oskuil and Kaalvlakte indicate that some water levels are lowered due to

pumping activities. The water level distribution for the newly drilled boreholes showed values

for only two of the newly drilled boreholes. The very low seepages in the other six boreholes

were not expected. For geohydrological calculations in the shallow weathered

Norite/Gabbro aquifers, the representative depth is taken as 17m below surface.

7.11.2 Presence of Boreholes and Springs and their Estimated YieldsThe depths of water strikes and weathering reported in regional exploration boreholes, as

well as the newly drilled boreholes at the Thaba Mine, were on average 24m. Boreholes with

yield data showed a reportable (blow) yield ranging between 0.69 and 20l/s. The yields

reported by the external users are higher than the average reported for the greater study

area.

7.11.3 Ground Water QualityThe assessment of the current status of the ground water quality distribution is based on the

water quality data generated during the 2009 hydro census. An assessment of all drilled

monitoring boreholes was made to derive a representative background ground water quality

as outlined in the Table below. Previous studies indicate a variable level of nitrates pollution

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due to human and agricultural activities. Nitrates was not used in isolation as an indicator for

mining related impacts.

Table 7:26 Typical Background Ground Water Quality for the Study Area

Variable Minimum Maximum Average

pH 8.1 8.6 8.3

EC (mS/m) 35 101 85

TDS (mg/l) 159 620 455

Ca (mg/l) 5 47 38

Mg (mg/l) 80 180 130

Na (mg/l) 13 38 25

K (mg/l) 1 7 3

T-Alk (mg/l) 135 418 265

Cl (mg/l) 6 88 55

SO4 (mg/l) 2 62 35

F (mg/l) 0.010 0.140 0.022

Al (mg/l) 0.010 0.070 0.030

Fe (mg/l) 0.010 0.030 0.022

Mn (mg/l) 0.010 0.045 0.013

The following conclusions were reached regarding the chosen 2009/2010 background

ground water quality for the study area:

1The background ground water was dominated largely by magnesium bicarbonate.

Elevated magnesium levels were due to geological conditions;

The background ground water quality was alkaline;

Elevated levels of sulphates were not primarily indicative of mining related impacts;

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1Nitrate was excluded from the list, since previous studies indicate impacts due to

human and agricultural activities. However, mining activities can also have an impact

on nitrates. The source of potential nitrates in ground water resources must be clearly

identified;

The chosen background ground water quality was considered as marginal in terms of

total salt load. This was mainly due to natural, geological considerations. Any mining

related impact can clearly be identified, using the above as the pre-impacted quality.

7.11.4 Groundwater Quality Distribution and Compliance1The compliance criteria used to assess ground water quality distribution is the SABS 241

Drinking Water Standard.

1The pH distribution and compliance map alkaline to slightly elevated alkaline values

in the total study area. These include monitoring boreholes and external users falling

in the adjacent Anglo mining area. Previous and current studies have proven that no

mining or metallurgical activities will have an influence in the form of lowered pH

levels;

Total dissolved solids is a representation of the total salinity of a water sample. The

total dissolved solids showed mainly full compliance with respect to the SABS

Drinking Water Standard;

The calcium distribution and compliance showed full compliance. No direct mining

impacts will manifest as calcium, so this element cannot be used as an indicator of

mining related impacts;

The magnesium distribution and compliance showed mainly non-compliance. Given

the naturally elevated levels of magnesium, care should be taken when using

magnesium as an indicator for mining-related impacts;

The sulphates distribution and compliance showed full compliance at all sites. With the

relatively large range in sulphate values for the chosen background ground water

quality, it was evident that sulphates cannot be used in isolation to assess any mining or

agricultural impact. The elevated levels adjacent to the Amandelbult section should be

monitored on a regular basis;

The majority of samples show full compliance for clorine and potassium;

Sporadic marginal compliance for total alkalinity and fluorine is once again due to

geological conditions;

Micro-element analyses showed full to marginal compliance;

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Isolated impacts due to human activities and metallurgical impact in the greater study

area were evident. Total dissolved solids and nitrates (site specific) were the major

parameters that will indicate impacts to the ground water system.

7.11.5 Groundwater UseIn the hydro census performed in 2009, a total of 49 external users’ boreholes were

identified. Approximately 30 percent of all boreholes were currently not in use, or were not

equipped. Extensive use of ground water was taking place, although the majority of the

boreholes were more than two km away from the Thaba Mine activities. The main area of

geo-hydrological concern was the use of borehole water by the Thabazimbi Local

Municipality on the farm Zwartkop 369 KQ. Irrigation also took place on a reported 20ha.

Table 7:27 The Current Groundwater Use in the Study Area

Farm name/ Locality

Number of boreholes in use

Purpose of borehole

Human use

Large stock

Small stock/Other

Zwartkop 18 Extensive >100 >1000

Roodedam 5 35 >100 ~50

Langpan 3 16 >120 ~30

Moddergat 3 45 200 Game

Oskuil 7 170 <200 Game

Kaalvlakte 0 0 0 0

7.11.6 Groundwater ZoneThe geological logs taken in 2009 from the drilled shallow boreholes in the Thaba Mine study

area yielded the following geological/geo-hydrological information:

0m – 2m Dark, brownish clay

2m – 24m Highly weathered to slightly weathered Gabbro and Norite (depending on

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position of geological sequence)

2m – 24m Fresh, occasionally fractured Gabbro and Norite

Ground water movement will essentially be horizontal in the weathered, coarser grained

Norite aquifer. Ground water flow and volumes in the deeper, unweathered Norite aquifer will

be determined by the extent and hydraulic conductivities of individual fractures. Ground

water strike and yield information showed that the deeper, fractured aquifer yields very few

strikes and low volumes of ground water. A non-defined aquifer type at this stage is the two

prominent fracture zones in the northern part of the mineral lease area.

The lateral extent of the aquifer around the mine was important in order to set definable

limits of any potential contaminant transport and lowering of water levels within the shallow

weathered zone Norite aquifer. The shallow weathered zone aquifer at the Thaba Cronimet

Chrome Mine had the following definable boundaries:

The Bierspruit in the centre of the study area (discharge boundary);

The tributaries of the Bierspruit to the north and south (discharge boundaries), a

number of unnamed tributaries;

The two fracture zones in the centre area. These zones can act as no-flow or as

preferential flow boundaries. Dewatering requirements during mining will indicate

the nature of these units.

The major transport zone was the saturated parts of the weathered zone Norite / Gabbro

aquifers. Taking the average depth of ground water for the study area (19m) and the

average depth of weathering into account (24m), the average saturated thickness of the

Norite /Gabbro aquifer is less than 5m. Please note that conditions can change on a regional

scale and that localised saturated aquifer thicknesses can exceed 15m. The average

porosity for Bushveld units was one percent and less, although the porosity in the weathered

zones could increase to five to eight percent. Aquifer effective porosity indicates the volume

of water that can be released from a rock, therefore the volume of connected pores that is

present within an aquifer. Effective porosity is a crucial parameter to determine since it is

used in ground water calculations within the aquifer. The average effective porosity/aquifer

storativity values for shallow Norite / Gabbro aquifers areas is 0.03 and the average for the

deep fractured Norite/Gabbro aquifers is 0.002.

Slug tests performed in the study area yielded transmissivity values for the shallow

weathered aquifers ranging between one and five m2/day. It is important to note that only two

boreholes yielded water levels. The areas concerning the footprint of the approved tailings

storage facility yielded very low seepages during drilling, indicating transmissivity values of Page 65 of 108

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less than 0.5 m2/day. Given the average saturated thickness of this aquifer, hydraulic

conductivity was calculated as ranging between 0.005 and 0.025m/day. The representative

value for ground water calculations was 0.015 m/day. With regards to the CCMSA mineral

lease area, the following aquifer characteristics apply:

The aquifer type was indicated as a minor aquifer region or in other words a

moderately-yielding aquifer system of variable water quality;

The vulnerability, or the tendency or likelihood for contamination to reach a specified

position in the groundwater system after introduction at some location above the

uppermost aquifer, was indicated at least as vulnerable;

Aquifer susceptibility, a qualitative measure of the relative ease with which a

groundwater body can be potentially contaminated by anthropogenic activities and

which includes both aquifer vulnerability and the relative importance of the aquifer in

terms of its classification, was indicated as low.

8 INITIAL APPLICATION AND SCOPING PROCESS

The S&EIR and WUL Application processes for the Proposed Project are being undertaken

as one integrated process comprising of three phases, namely the:

Application phase

Scoping phase

Environmental impact reporting (EIR) phase

This report documents the tasks which have been undertaken as part of the Scoping phase

of the EIA process. These tasks include the public participation process and the

documentation of the issues which have been identified as a result of these activities.

8.1 APPLICATION PHASE

The application phase consists of completing the appropriate application form by the EAP

and the Proponent as well as the subsequent submission and registration of the Proposed

Project with the Competent Authorities.

The competent Authority for the WMLA is the Department of Mineral Resources.

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8.2 SCOPING PHASE

The Scoping phase will be undertaken in accordance with the NEMA, as read with GNR 982

of the NEMA. The objectives of the Scoping phase are to:

Identify the relevant policies and legislation relevant to the activity;

Motivate the need and desirability of the proposed activity, including the need and

desirability of the activity in the context of the preferred location;

Identify and confirm the preferred activity and technology alternative through an

impact and risk assessment and ranking process;

Identify and confirm the preferred site, through a detailed site selection process,

which includes an impact and risk assessment process inclusive of cumulative

impacts and a ranking process of all the identified alternatives focusing on the

geographical, physical, biological, social, economic, and cultural aspects of the

environment;

Identify the key issues to be addressed in the assessment phase;

Agree on the level of assessment to be undertaken, including the methodology to be

applied, the expertise required as well as the extent of further consultation to be

undertaken to determine the impacts and risks the activity will impose on the

preferred site through the life of the activity, including the nature, significance,

consequence, extent, duration and probability of the impacts to inform the location of

the development footprint within the preferred site; and

Identify suitable measures to avoid, manage or mitigate identified impacts and to

determine the extent of the residual risks that need to be managed and monitored.

Scoping is the process for determining issues and concerns related to the Proposed Project

and involves consultation with the stakeholders and authorities. In addition, the Scoping

phase includes the identification of required specialist studies and potential environmental

aspects for further investigation. The Scoping phase outlines the plan of study (PoS) for the

EIR phase and facilitates the input from stakeholders and authorities to inform the EIR

process.

8.2.1 Stakeholder Review Prior to Submission

The Draft Scoping Report (DSR) is made available to all stakeholders and authorities for a

40 day review period. The comments received from stakeholders will be recorded and

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incorporated into the Final Scoping Report (FSR) which will be submitted to DMR as well as

any other relevant commenting authorities.

8.2.2 Submission and Decision-Making

The delegated competent authorities will be allocated 43 days to review the FSR. The FSR

will be placed on stakeholder review for a reasonable time period during the Department’s

final review and decision-making process. Any comments received during this period will be

forwarded to the delegated authority. If the delegated competent authorities must within this

specified timeframe to issue a decision to proceed onto the next phase, the EIR phase.

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9 PUBLIC PARTICIPATION UNDERTAKEN TO DATE

The scoping process has included the activities listed below with further detail on key

aspects discussed in the following sub-sections:

A pre-consultation meeting was held at DMR Offices on the 11 August 2015

Desktop review of available baseline information;

Development of a stakeholder database;

Preparation and distribution of media notices (English adverts were placed in the “Die

Kwevoel” on 25 September 2015;

Placement of BIDs at public places including the Local Municipal Office

Landowners, I & Aps and stakeholders of the proposed development (25 September

2015);

Adjacent landowners were physically delivered a Background Information Document

(BID);

Recording of issues raised by stakeholders and compiling an Issues and Response

Report (IRR);

Collation of comments received during the initial commenting and registration period

into an Issues and Response Report (IRR);

Compilation of a Scoping Report (this document) and submission for a 30 day public

review period;

All comments and concerns raised during this commenting period will be collated and

addressed in the Scoping Report prior to submission to the DMR;

The Environmental Assessment Practitioner (EAP) identifies further investigations required

to investigate the positive and negative impacts identified with input from I&APs and the

relevant authorities;

Terms of Reference was drafted for the relative specialist studies. The main source of

information used to inform the scoping phase of the project is listed below:

Specialist investigations conducted for the mine expansion EIA;

Site visits conducted by the project team;

Regional geological, biodiversity, and land use maps;

Topographic maps (1:50 000 scale); and

Satellite imagery.

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9.1 INTERESTED AND AFFECTED PARTIES ISSUES AND RESPONSES

Table 9:28 Summary of Issues raised by Interested and Affected Parties

Interested and Affected Parties

List the names of persons consulted in this column, and

Mark with an X where those who must be

consulted were in fact consulted.

DateCommentsReceived

Issues raised EAPs response to issues as mandated by the applicant

ConsultationStatus (consensusdispute, notfinalized,etc)

AFFECTED PARTIES

Landowner/s XLandowner of portion 1 of

Middellaagte 382 KQ

(Danie Koekemoer)

X 25

September

2015

07 October

2015

Farm owners were notified of the integrated

waste management and water use licence

application for the proposed construction of

Thaba Mine mine additional tailings storage

facility and waste disposal.

DK indicated that he had been away but all

correspondence has been received. He

further outline that he is aware of the ongoing

project and will comment accordingly.

Landowner of portion 1 of X 25

September

Correspondence was made with the farm

owner notifying him of the integrated waste

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Zwartkop 369 KQ

(Peter Trollope)

2015 management and water use licence

application for the proposed construction of

Thaba Mine mine additional tailings storage

facility and waste disposal. PT indicated he

will contact us should any issues arise.

Lawful occupier/s of the land

Landowners or lawful occupierson adjacent properties

X

Anglo American Kumba Iron

Ore

Municipal councillor XMunicipality X 25

September

2015

Thabazimbi Local Municipality.

Sazi Environmental introduced themselves

and provided information regarding the

proposed project at Thaba Cronimet Chrome

Mine. Notification of the integrated waste

management and water use licence

application for the proposed construction of

Thaba Mine mine additional tailings storage

facility and waste disposal was granted and

the PPO of the Municipality, Mr T. Masilo

indicated that they were already aware of this

project and gave us the go ahead to paste

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site notices there.

Organs of state (Responsible forinfrastructure that may beaffected Roads Department,Eskom, Telkom, DWA e

X 25

September

2015

Formal letters were emailed to the DWS and

DMR to inform them of the proposed project

and to invite them to participate on the

project.

Waterberg Department of

Roads and Transport

(Mabel Makibelo)

Communities

Elinah Phantsi (Smashblock

community)

Miriam Mthiba (Smashblock)

Dept. Land Affairs

Melton Tshililo

Traditional Leaders

Nolizile Gcelu

(Smashblock)

Dept. Environmental Affairs

X 25

September

2015

Formal letters were emailed to the DWS and

DMR to inform them of the proposed project

and to invite them to participate on the

project.

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Other Competent Authorities affected

Thabazimbi Department of

Agriculture

(Charles De Kock)

OTHER AFFECTED PARTIESWard 3 Councillor (Stephen Lerumo) 25

September

2015

Correspondence was provided by Sazi

environmental notifying the councillor of the

integrated waste management and water use

licence application for the proposed

construction of Thaba Cronimet mine

additional tailings storage facility and waste

disposal. SL indicated that they are aware of

the ongoing project and public participation

process however the community is not happy

because they get invited to partake in public

participation process and attend meetings but

their issues are never taken into

consideration or addressed accordingly

especially that of employing locals. S.

Lerumo further indicated that the community

is not pleased with this, and at some point

threatened to boycott the meetings or

demonstrate at the mines because when

construction commences, the mine hires

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people from far off places and disregards

locals.

Ward 5 Councillor (Mr. S Manala) 25

September

2015

Notification of the integrated waste

management and water use licence

application for the proposed construction of

Thaba Cronimet mine additional tailings

storage facility and waste disposal was given.

The councillor acknowledged receipt and

urged me to invite them when a meeting

takes place as they are very much interested

in the socio-economic aspect of the project.

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10AN IDENTIFICATION OF THE ANTICIPATED ENVIRONMENTAL, SOCIAL OR CULTURAL IMPACTS

Geology:

Removal of Ore bodies and overburden

Topography:

Disturbances or changes to the topography area

Waste and hazardous substances:

Potential soil and water contamination;

legal non-compliance; and

lost opportunities for waste recycling

Soil and Land capability:

Soil compaction, soil loss due to wind and water erosion;

Change of land-use from natural to mining:

Soil pollution due to hydrocarbon and cement spillages

sterilisation of the soil resource

Flora and Fauna:

Habitat loss and harm to flora and fauna

Fragmentation of the habitat resulting in harm to flora and fauna;

Fauna mortalities and Habitat degradation

Noise/ Vibrations:

Human discomfort and structural damage;

New total resulting ambient noise levels elevated above pre-development levels; and

the actual increase in ambient noise levels.

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Air Quality:

Cumulative particulate and NO2 emissions.

Surface Water:

Sheet erosion and dust generation;

Potential pollution by hazardous substances; and

Poor sanitation and poor storm water management.

Deterioration in water Quality and decrease in catchment Yield;

Ground Water:

Groundwater Availability and groundwater quality

Wetland:

Increased sedimentation within the wetlands;

Increased turbidity and obstruction of flows; and

Increased risk of erosion and water quality deterioration.

Aquatic:

Destruction / disturbance of the Bierpruit and other rivers in the area.

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11PLAN OF STUDY FOR THE ENVIRONMENTAL IMPACT ASSESSMENT

A full EIA process will be conducted for the proposed project. The Draft and Final EIAR will

be submitted to the competent authority for decision making purposes.

The Scoping Phase is designed to identify impacts and determine whether they require

specialist investigation in the Impact Assessment Phase. The POS for EIA provides an

indication of the tasks to be undertaken during the Impact Assessment Phase of the project,

the impact assessment methodology, the PPP, and when authority consultation will take

place. The purpose of the POS is to layout an effective methodology to be followed during

the assessment of impacts, should this be deemed necessary, in order to meet the minimum

legal requirements.

11.1 TASKS TO BE UNDERTAKEN DURING THE ENVIRONMENTAL IMPACT ASSESSMENT PHASE

Once the FSR and the Plan of Study (PoS) for the EIR phase has been submitted and

accepted by the DMR, the proposed project will proceed into the detailed EIR phase, which

involves the detailed specialist investigations. Sazi will produce a Draft EIR after the

completion of the required specialist studies. The Draft EIR will provide an assessment of all

the identified key issues and associated impacts from the Scoping phase. All requirements

as contemplated in NEMA GNR 982 will be included in the Draft EIR. The Draft EIR will

contain, inter alia, the following:

Details of-

The EAP who prepared the report; and

The expertise of the EAP, including a curriculum vitae;

The location of the activity, including:

The 21 digit Surveyor General code of each cadastral land parcel;

Where available, the physical address and farm name; and

where the required information in items (i) and (ii) is not available, the coordinates of

the boundary of the property or properties;

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A plan which locates the proposed activity or activities applied for as well as the associated

structures and infrastructure at an appropriate scale, or, if it is-

A linear activity, a description and coordinates of the corridor in which the proposed

activity or activities is to be undertaken;

On land where the property has not been defined, the coordinates within which the

activity is to be undertaken;

A description of the scope of the proposed activity, including-

All listed and specified activities triggered and being applied for; and

A description of the associated structures and infrastructure related to the

development;

A description of the policy and legislative context within which the development is located

and an explanation of how the proposed development complies with and responds to the

legislation and policy context;

A motivation for the need and desirability for the proposed development, including the need

and desirability of the activity in the context of the preferred location;

A motivation for the preferred development footprint within the approved site;

A full description of the process followed to reach the proposed development footprint within

the approved site, including:

Details of the development footprint alternatives considered;

Details of the public participation process undertaken in terms of regulation 41 of the

Regulations, including copies of the supporting documents and inputs;

A summary of the issues raised by interested and affected parties, and an indication

of the manner in which the issues were incorporated, or the reasons for not including

them;

The environmental attributes associated with the development footprint alternatives

focusing on the geographical, physical, biological, social, economic, heritage and

cultural aspects;

The impacts and risks identified including the nature, significance, consequence,

extent, duration and probability of the impacts, including the degree to which these

impacts- can be reversed; may cause irreplaceable loss of resources; and can be

avoided, managed or mitigated;

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The methodology used in determining and ranking the nature, significance,

consequences, extent, duration and probability of potential environmental impacts

and risks;

Positive and negative impacts that the proposed activity and alternatives will have on

the environment and on the community that may be affected focusing on the

geographical, physical, biological, social, economic, heritage and cultural aspects;

The possible mitigation measures that could be applied and level of residual risk;

If no alternative development locations for the activity were investigated, the

motivation for not considering such; and

A concluding statement indicating the preferred alternative development location

within the approved site;

A full description of the process undertaken to identify, assess and rank the impacts the

activity and associated structures and infrastructure will impose on the preferred location

through the life of the activity, including-

a description of all environmental issues and risks that were identified during the

environmental impact assessment process; and

An assessment of the significance of each issue and risk and an indication of the

extent to which the issue and risk could be avoided or addressed by the adoption of

mitigation measures;

An assessment of each identified potentially significant impact and risk, including

- Cumulative impacts;

- The nature, significance and consequences of the impact and risk;

- The extent and duration of the impact and risk;

- The probability of the impact and risk occurring;

- The degree to which the impact and risk can be reversed;

- The degree to which the impact and risk may cause irreplaceable loss of

resources; and

- The degree to which the impact and risk can be mitigated;

Where applicable, a summary of the findings and recommendations of any specialist report

complying with Appendix 6 to these Regulations and an indication as to how these findings

and recommendations have been included in the final assessment report;

An environmental impact statement which contains-

A summary of the key findings of the environmental impact assessment:

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A map at an appropriate scale which superimposes the proposed activity and its

associated structures and infrastructure on the environmental sensitivities of the

preferred site indicating any areas that should be avoided, including buffers; and

A summary of the positive and negative impacts and risks of the proposed activity

and identified alternatives;

Based on the assessment, and where applicable, recommendations from specialist reports,

the recording of proposed impact management objectives, and the impact management

outcomes for the development for inclusion in the EMPr as well as for inclusion as conditions

of authorisation;

The final proposed alternatives which respond to the impact management measures,

avoidance, and mitigation measures identified through the assessment;

Any aspects which were conditional to the findings of the assessment either by the EAP or

specialist which are to be included as conditions of authorisation;

A description of any assumptions, uncertainties and gaps in knowledge which relate to the

assessment and mitigation measures proposed;

A reasoned opinion as to whether the proposed activity should or should not be authorised,

and if the opinion is that it should be authorised, any conditions that should be made in

respect of that authorisation;

Where the proposed activity does not include operational aspects, the period for which the

environmental authorisation is required and the date on which the activity will be concluded

and the post construction monitoring requirements finalised;

An undertaking under oath or affirmation by the EAP in relation to:

The correctness of the information provided in the reports;

The inclusion of comments and inputs from stakeholders and l&APs;

The inclusion of inputs and recommendations from the specialist reports where

relevant; and

Any information provided by the EAP to interested and affected parties and any

responses by the EAP to comments or inputs made by interested or affected parties;

Where applicable, details of any financial provisions for the rehabilitation, closure, and

ongoing post decommissioning management of negative environmental impacts;

An indication of any deviation from the approved scoping report, including the plan of study,

including-

Any deviation from the methodology used in determining the significance of potential

environmental impacts and risks; and

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A motivation for the deviation;

Any specific information that may be required by the competent authority; and

Any other matters required in terms of section 24(4)(a) and (b) of the Act.

11.1.1 Specialist Studies

The table below provides a list of the Specialists that are involved in this study and their

areas of expertise.

Table 11:29 Description of specialist studies

Specialist Study Organization responsible for the study

Vibration Impact Assessment RC Kroch

Air Quality Specialist Derek Fletcher

Ecological Impact Assessment Exigo Sustainability

Geochemistry Specialist Study Enviro Resources Management

Groundwater JMA Consulting (Pty) Ltd

Archaeological Impact Assessment Heritage Contracts and Archaeological

Consulting

Noise Study Francois le Roux Malherbe

Socio Economic Study Digby Wells

Soil, Land-use and Land Capability Terra Africa Consultants

Surface water Impact Assessment JR Croucamp

Tailings Water Quality Aquatico Scientific (Pty) Ltd

Visual Specialist Study Newton Landscape Architects cc

Wetland Delineation and Impact Assessment Wetland Consulting Services (Pty) Ltd

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11.1.2 Terms of reference for specialist studies

11.1.2.1 Air Quality assessmentThe Air Quality Impact Assessment TOR must include the following:

The literature review with respect to air quality and climate for the study area must be

done in a radius of 5 km from the project area;

Undertaking of a site inspection to characterise the receiving environment, including

the sensitivity, proximity and direction, and review the suitability of the existing dust

monitoring network with respect to the proposed TSFs and WRDs location;

Assess existing monitoring systems, if available;

Develop an emissions inventory; excluding Greenhouse Gasses and carbon foot

print studies;

Set up and run an air dispersion model for dust and gas that integrates the

information obtained for 3 scenarios with respect to the concentrator plant location

and 3 scenarios with respect to the proposed TSF location and operation;

Identification of all sources of atmospheric emissions that are associated with the

proposed new infrastructure;

Simulations of the ground level PM 2.5, PM 10 concentrations and dust fallout for

highest daily and annual PM concentrations and total daily dust deposition due to

routine and upset emissions from the proposed new infrastructure.

11.1.2.2 Aquatic Assessment

The aquatic assessment must make allowance for the assessment of two

representative aquatic ecological assessment points to characterise a and to define

the Present Ecological State (PES) of aquatic resources at strategic points within on

the system. Allowance has been made for one round of assessment.

The aquatic ecological assessment must focus on, amongst other: On site biota

specific water quality testing (including pH, conductivity, dissolved oxygen and

temperature); Instream habitat integrity and conditions for aquatic macro-

invertebrates (IHAS, HCR and IHIA);

Assessment of the aquatic macro-invertebrate community based on the SASS5

index. Making use of the MIRIA Ecostatus tool to characterise and define the PES

and potential risks to the aquatic macro-invertebrate community; Assessment of the

fish community based on the FRAI11 Ecostatus tool to characterise and define the

PES and potential risks to the aquatic macro-invertebrate community;

Assessment of the riparian vegetation community integrity;

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Findings must be compiled into a report which will highlight the PES, Ecostatus and

Ecological Importance and Sensitivity (EIS) of the system

11.1.2.3 Faunal AssessmentThe faunal assessment will be conducted using the following methods:

Extensive consideration will be given to determining the ecological importance

and sensitivity (EISC) of the subject property according to relevant databases.

The relevant Limpopo Province databases for the QDS will also be consulted and

will serve as the reference data to which field surveys will be compared to;

Visual observations of actually occurring species;

Identification of evidence of occurrence, e.g. call spoor, droppings, etc.;

Capture of fauna by various methods including netting, trapping and

dragging. In this regard special mention is made of the use of pitfall traps and

sweep netting for invertebrates as well as the use of Sherman traps to

determine the composition of the small mammal community on the site. Rope

dragging methods will also be used to flush birds from areas where RDL avifaunal

species are deemed likely to occur;

Nocturnal studies to identify nocturnal animals in the area may take place if it is

deemed necessary;

The reports produced will include sensitive habitat types and impacts from habitat

disturbance, faunal assemblages at risk and an assessment of impacts on migratory

routes;

The RDSIS index will also be considered in order to quantify the importance of the

subject property in terms of RDL faunal conservation;

Based on the findings a detailed impact assessment on all identified significant risks

will take place; and

Recommendations on management and mitigation measures (including opportunities

and constraints) with regards to the construction and operation of the proposed

development in order to manage and mitigate impacts on the faunal assemblage of

the area will be provided.

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11.1.2.4 Flora Assessment The proposed methodology includes both a desktop review and a field work

component.

A desktop review of distribution lists (including Red Data Listed (RDL) species) and

available literature will be conducted to guide the field work component.

The vegetation type of the area will be defined according to sources such as Mucina

& Rutherford (2006). Extensive consideration will also be given to determining the

ecological importance and sensitivity (EISC) of the subject property according to

relevant provincial and national conservation databases. The SANBI and PRECIS

databases for the Quarted Degree Square (QDS) will also be consulted and will

serve as the reference data to which field surveys will be compared to.

The assessment will include a detailed assessment for the entire area to be affected

by mining activities as well as the surrounding zone of influence. The field

assessment will identify:

Various habitat types;

• A description of each habitat type based on conservation importance and

present ecological state;

• Floral species associated with each habitat component:

Focus on sensitive habitat types and impacts associated to them in order to fulfil the

requirements of the study.

Such sensitive areas will be mapped where detail will be given of the ecological

aspect of concern in each sensitivity zone;

Focus on establishing the presence of RDL species and other sensitive species

identified as well as suitable

habitats for any of these species;

Specific focus will also be given to identifying areas of severe weed and alien

vegetation encroachment, which will be mapped;

Medicinal plant species will also be identified and the location of special medicinal

species will be presented on maps;

Veld condition will be quantitatively assessed according to a pre-defined veld

condition index and will also be quantitatively compared to the typical vegetation for

the vegetation type of the area a ccording to Mucina & Rutherford (2006);

Species lists for each habitat unit will be developed;

Based on the findings a detailed impact assessment on all identified significant risks

will take place;

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Recommendations on management and mitigation measures with regards to the

construction and operation of the proposed development in order to manage and

mitigate impacts on the ecology of the area; and

Rehabilitation and closure requirements will be considered.

11.1.2.5 Wetland Assessment The wetland assessment will comprise of detailed desktop assessments of the

National Freshwater Ecosystem Priority Areas (FEPA) database as well as available

regional wetland layers in order to define the wetland features based on existing

desktop data. The wetlands will then be delineated in the field according to the

Department of Water Affairs (DWA) (2005) guideline methodology. Once the wetland

boundary has been defined it will be mapped and the relevant buffers applied.

Delineation of the wetland resources will take place according to the DWAF (2005)

guidelines and an assessment of the wetland Present Ecological State (PES), Index

of Habitat Integrity (IHI), WET-Health, and wetland function and ecoservices will take

place according to DWA approved protocols.

Recommendations for mitigating impacts on the aquatic environment will also be

provided.

Results will be compiled into a report which will include a discussion on the findings.

Specific attention will be given to the impacts associated with the proposed

development with impacts being assessed according to a pre-defined impact

assessment methodology.

Extensive attention will be given to the development of recommendations for

mitigating impacts on the receiving environment. These mitigation measures can

then be incorporated into the EMP for the development to ensure that the wetland

ecology of the area is adequately protected

11.1.2.6 Heritage Assessment The HIA and desktop Palaeontology Assessment must be conducted. The purpose of

the heritage survey is to ascertain if any archaeological or historical remains occur in

the survey area and if they are of aesthetic, architectural, historical, scientific, social,

spiritual, linguistic or technological value. Attention must be given to both tangible

and intangible heritage remains. The Heritage and desktop Palaeontology

Assessment TOR is not limited to, but must include the following:

Liaison with SAHRA and search SAHR Information Systems for existing reports and

information of the survey area;

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Compile detailed maps of the survey area indicating all cultural heritage resources

(Stone Age, Iron Age and Historical Period);

Utilise Geographic Information System (GIS) systems and Google Earth (also

topographic maps and aerial photographs);

Survey of the survey area; reconnoitre larger area with vehicle and foot survey of

sensitive spots and areas;

Random consultation with local people to ascertain aspects of intangible heritage;

Recording and documenting of all sites using standard archaeological field work

techniques;

Recording of site s with a Geographic Positioning System (GPS) and compiling

maps;

Detailed description of all archaeological and historical artefacts, structures (including

graves) and settlements documented in the area (including photographs) will be

included in the phase 1 heritage report;

Establish the level of sensitivity/importance of the archaeological and historical (both

tangible and intangible) remains in the area;

Cultural traditions related by the local communities will be a high priority when

establishing the significance of archaeological and historical remains as well as

graves in formal cemeteries and informal burials;

Provide the relevant authorities with appropriate documents for their review and

decision-making. In particular, copies of the Heritage Report must be sent to SAHRA

and the relevant Provincial Heritage Resource Agency;

The desktop Palaeontology Assessment must include:

- A description of significant fossil occurrences;

- Recommendation on whether a phase 1 Paleontological Impact Assessment

will be required.

11.1.2.7 Noise Assessment The Noise Assessment TOR is not limited to, but must include the following:

o Determine the prevailing noise levels in and around the proposed TSF and

MRD;

o This noise survey from an environmental noise point of view

must be done during the daytime period and the night-time period in order to

evaluate the recommended residual noise levels laid down by SANS 10103:2008 and

to get a representative residual noise level for the areas where the proposed

activities will or takes place;

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The proposed noise survey will consist out of the following:

o Preliminary survey and identification of measuring points;

o All measurements will be done on the boundary of the property;

o Sound pressure readings will also be done at the closest residential area – if

applicable;

Noise survey at the identified measuring sites – Ambient noise measurements;

Calculation of noise propagation;

Analysing of results;

Results of the survey, report and recommendations and mapping of noise contours

for the sites.

11.1.2.8 Soil and Land Capability AssessmentThe Soil, Land Use and Land Capability Assessment TOR are not limited to, but must

include the following:

A detailed soil survey must be conducted at the proposed area where the proposed

development project will be. The maps generated during the desktop study phase

must be used to determine a grid and these areas will be traversed on the pre-

determined transects and auger samples will be studied. In areas of great soil form

variety, more samples points must be evaluated as well as to establish soil form

boundaries;

Observations must be made regarding soil texture, depth of soil, soil structure,

organic matter content and slope of the area. The soil characteristics of each sample

point must be noted and logged with a GPS. The location of these auger points must

be indicated in a Survey Points Map to be included in the final specialist report. Soil

samples for chemical analysis must be taken at 25 sampling points and at each point

both topsoil (0-300mm) and subsoil (300-600mm) will be sampled;

The soils will be described using the S.A. Soil Classification Taxonomic System (Soil

Classification Working Group, 1991) published as memoirs on the Agricultural

Natural Resources of South Africa No.15. Soils will be grouped into classes with

relatively similar soil properties and pedogenesis. A cold 10% hydrochloric acid

solution will be used on site to test for the presence of carbonates in the soil;

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The 24 representative soil samples must be stored in perforated soil sampling plastic

bags on site and sent by courier to SGS Soil Laboratory in Somerset West for

chemical soil analysis;

Samples must be analysed for pH, phosphorus content, cations (calcium,

magnesium, potassium and sodium),

electrical conductivity, organic carbon content and relative fractions of sand, silt and

clay;

The results of the soil survey must be mapped and zones of similar soil forms

indicated. Once soil form groups have been outlined, soil potential and land capability

must be determined using the guidelines developed by the Agricultural Research

Council unless otherwise specified by the client;

The possible impacts of the proposed project on soil, agricultural potential and land

capability must be evaluated.

11.1.2.9 Visual AssessmentThe Visual Impact Assessment (VIA) TOR is not limited to, but must include the following:

The assessment must establish a view catchment area, view corridors, viewpoints

and receptors;

The assessment must indicate the potential visual impacts using established criteria;

The assessment must include amongst other potential lighting impacts at night;

The report must be based upon the WC Guidelines the proposed activities would

require a Level 3 assessment; and must include amongst other:

o Identification of issues raised during the EIA process;

o Undertake a desktop VIA analysis;

o Conduct a site visit to verify the scope of the VIA as well as gain an

understanding of the receiving environment;

o Describe the receiving environment with regards to the various elements

of the project;

o Conduct a viewshed analysis of the proposed expansions, identifying

potential sensitive receptors;

o Identify any potential mitigation measures (including lighting impacts –

should they be raised and potential

o impacts on tourism in the area); and

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o Identify potential alternatives, mitigation measures and monitoring

programmes

o The data required for the project includes, but is not limited to, structural

heights, alignments and footprint areas for the proposed expansions

Once these data are made available the following must be undertaken:

Review of the information based on information supplied;

Perform a desktop analysis to outline the baseline visual aspects of the site and to

identify preliminary sensitive visual receptors – the classification of the landscape’s

visual character and possible receptors to the proposed project;

Consult with the EAP to discuss the project and attend to any questions that may

have arisen from the EIA process;

Liaise with the EAP to obtain any I&APs concerns noted by the EAP regarding the

potential visual impacts the proposed expansions may have; and ·

The data required for the project includes, but is not limited to: structural heights and

footprint areas for the proposed TSFs and MRDs

The viewshed analysis must include the compilation of a preliminary spatial model

(based on the proposed expansions). Tasks will include:

o Compile a preliminary spatial model (based on the plans and contour information)

for the proposed expansions using a GIS three dimensional software modelling

package;

o Compile a set of viewpoints from areas that are deemed to be potentially visually

influenced by the proposed expansions;

o Using these viewpoints in conjunction with a site visit assess the visual impacts of

the proposed expansions;

o Provide descriptions of the possible visual impacts that the proposed expansions

may have on the surrounding landscape using viewshed analysis, including the

identification of potential sensitive viewers / receptors informed by the EIA

process, as well from the viewshed.

11.1.2.10 Surface Water Assessment

The Surface Water Assessment TOR is not limited to, but must include the following:

Water related considerations must be guided by the NWA Regulation 704 and the

DWS Best Practice Guidelines;

The surface water study must consider the following items:

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Assess crossings and diversions against details and visuals where the pipeline

crosses the rivers and identify if there are going to be additional impacts with the

construction of a new pipe crossing;

Identify areas where ponding / restriction of flow is occurring due to structural

restrictions or operational activities;

Assess stability of river banks at crossings and diversions. Relate findings to actual

suspended solids/turbidity data in BRPM's water quality database;

Assess crossings and diversions for potential to be impacted by spills and ability to

handle such spills, with specific reference to tailings and wastewater pipeline

crossings;

Review floodlines and revise as appropriate;

Identify any unauthorised activities within the floodline or 100m of the watercourse

including infrastructure, operations, storage of materials, dumping etc;

Document all erosion controls, energy dissipaters where stormwater releases occur

to the natural environment

Assess watercourses at crossings and diversions for erosion, signs of

current/previous flooding. Review inspection records, if any. Identify areas where

maintenance or rehabilitation have been implemented or are required e.g. energy

dissipation, erosion repairs/controls, removal of accumulated debris to maintain

capacity etc.

Stormwater Management Plan must include the following

o A site audit to understand the existing stormwater layout and the future

stormwater controls;

o Hydrology of the site to indicate the storm volumes emenating from the

various sub catchments within the site (Calculation of the stormwater runoff

based on impervious surface of the site);

o Describe the hydrology in relation to the position of the major pans in the

area;

o Provide layout drawings (3 drawings) of the following elements:

o Indicate the site in relation to watercourses in the area;

o Indicate the existing layout of where the stormwater flows are;

o Detailed property designed layout and demarcation clean and dirty water

areas as well as proposed stormwater controls and monitoring points;

o Describe what stormwater controls are required to ensure that the site will be

environmentally compliant from a stormwater point of view

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11.1.3 Stakeholder Review Prior to SubmissionThe Draft EIR will be made available to stakeholders and authorities for review, prior to

finalisation and submission of the report to authorities for review by the delegated competent

authorities. All stakeholders and authorities will be allocated 30 days to review the Draft EIR

before the Final Report is submitted to the delegated competent authorities for review and

decision making. Furthermore, stakeholders will be afforded an additional timeframe in which

to review the final EIR in parallel to the authority review period.

11.1.4 Submission and Decision-MakingIn accordance with the NEMA, the following process will need to be followed by the decision

making authority in order to process the EA:

Once the Final EIR (including comments received by stakeholders) has been submitted, the

DMR will be allocated 107 days to review the report in which time they may:

Accept the EIR

Notify the Proponent that the EIR has been referred for specialist review

Request the Proponent to make such amendments to the EIR as the delegated

authority may require for acceptance thereof or

Reject the EIR if it does not comply with the content requirements

11.2 IMPACT ASSESSMENT RATING AND ASSESSING SIGNIFICANCE METHODOLGY

11.2.1 Qualitative Impact Assessment MethodologyEach impact identified with regards to the proposed additional mining and processing

activities and associated infrastructure has been qualitatively assessed with and without

mitigation providing context and reasons for the description that has been chosen. In order

to make the EIR easier to read, the following notation format has been used to highlight the

various components of the assessment.

Significance, colour coded as follows:

Red for high negative;

Orange for medium negative;

Yellow for low negative;

Green for high positive Page 91 of 108

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Purple for medium positive

Blue for low positive

Duration will be underlined

Certainty has been typed in bold

Severity/Intensity has been typed in CAPITALS

Frequency has been typed with italics

Spatial has been typed in normal font

11.2.2 Quantitative Impact Assessment Methodology

11.2.2.1 Status of the ImpactThe nature of the impact can be described as negative or positive and can be derived from the

significance rating of the impacts.

Table 11:30 Status of the Impact and Ratings

Rating Description Quantitative rating

Positive A benefit to the holistic environment -1

Negative A detriment to the holistic environment 1

11.2.2.2 Certainty of Impact

The certainty or probability of the impact describes the likelihood of the impact actually occurring.

Table 11:31 Certainty of Impact and Ratings

Rating Description Quantitative rating

Improbable In all likelihood the impact will not occur. Less than 20 percent

probability of a particular fact or of the likelihood of an impact

occurring.

1

Low probability Possibility of the impact to materialise is low. Between 20 and 50

percent probability of a particular fact or of the likelihood of an impact

occurring.

2

Probable A distinct possibility that the impact will occur. Between 50 and 80

percent probability of a particular fact or of the likelihood of an impact

3

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occurring.

Highly probable

Most likely that the impact will occur. More than 80 percent probability

of a particular fact or of the likelihood of an impact occurring.

4

Definite The impact will occur regardless of any prevention measures. 100

percent probability of a particular fact or of the likelihood of an impact

occurring.

5

11.2.2.3 Frequency of Impact

The frequency of the impact refers to the temporal scale of the impact or benefit, in terms of the

period of time that the surrounding environment will be affected or altered by the proposed project.

This is determined by the following scale:

Table 11:32 Frequency Of Impact And Ratings

Rating Description Quantitative rating

Continuous Occurs on a daily basis 4

Frequent Occurs on a weekly basis 3

Infrequent Occurs on a monthly basis 2

Occasional Occurs less than on a monthly basis 1

11.2.2.4 Spatial Extent of Impact

The extent of the impact refers to the spatial scale of the impact or benefit of the proposed project

and the area over which it extends. A description is provided of whether effects are limited in extent

or affects a wide area or group of people.

Table 11:33 Spatial Extent of Impact

Rating Description Quantitative rating

Site specific Effects occur within the mining right boundary 1

Local Effects extend beyond the mining right boundary, up to five kilometres

from the mining right boundary

2

Regional Widespread effect with impacts extending far beyond the mining right

boundary, but within a 50 kilometre radius of the boundary

3

National Within the boundaries of South Africa but further than the Limpopo

Province

4

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International Beyond the boundaries of South Africa 5

11.2.2.5 Intensity of Impact

The severity or intensity of an impact is an attempt to quantify the magnitude of the impacts and

benefits associated with the proposed activities.

Table 11:34 Intensity of Impact And Ratings

Rating DescriptionQuantitative Rating

Very intense Substantial deterioration/substantial improvement or benefit

Irreversible or permanent change/permanent improvement

Negative impacts cannot be mitigated

4

Intense Marked deterioration/improvement

Long term duration

Mitigation for negative impacts is very expensive, difficult or time

consuming

3

Moderately intense

Moderate deterioration/improvement

Medium term to long term duration

Negative impacts are fairly easily mitigated

2

Slight Minor deterioration/improvement

Short to medium term duration

Mitigation for negative impacts is easy, cheap or quick

1

11.2.2.6 Duration of ImpactThe duration of the impact refers to the temporal scale of the impact or benefit, in terms of the

period of time that the surrounding environment will be affected or altered by the proposed project.

Table 11:35 Duration of Impact and Ratings

Rating DescriptionQuantitativ

e rating

Short term The environmental impact identified will be present for less than 10

years

1

Medium

term

The environmental impact identified will be present for life of mine 2

Long term The environmental impact identified will be present beyond the life of 3

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mine

Permanent The environmental impact identified will be irreversible and will remain

post closure

4

11.2.2.7 Assessing Significance

After assessment of an impact in accordance to the preceding six criteria, the significance of an

impact can be determined through a synthesis of the aspects produced in terms of their status,

probability, duration, extent and severity. The significance of an impact is an expression of the cost

or value of an impact to society. The focus must be a judgement as to whether or not impacts are

significant, based upon the value system of society, or groups of people (Thompson, 1988, 1990).

The evaluation of significance is subject to, contingent with values, and dependent upon the

environmental and community context (Sadler, 1996). This subsection presents the criteria used to

define significant effects on the environment. The rankings of each of the different impacts relates

to the maximum and minimum totals that can be achieved for each possible impact. The total of the

criteria’s multiplied by the value of either negative or positive impact value is used to calculate the

threshold “classes” to determine the significance of the impact.

Table 11:36 Assessing Significance (Negative Impacts)

Rating DescriptionThreshold of significance

High Long term or permanent change to the natural and social

environment. Of the highest order possible within the bounds of

impacts which could occur. In the case of adverse impacts, there

is no possible mitigation and/or remedial activity which could offset

the impact. In the case of beneficial impacts, there is no real

alternative to achieving this benefit.

17-22

Medium Impact is real but not substantial in relation to other impacts which

might take effect within the bounds of those which could occur. In

the case of adverse impacts, mitigation and/or remedial activity

are both feasible and possible. In the case of beneficial impacts,

other means of achieving this benefit are feasible but they are

more difficult, expensive, time-consuming or some combination of

these.

11-16

Low Impact is of a low order and therefore likely to have little real

effect. In the case of adverse impacts, mitigation and/or remedial

activity are not required, easily achieved, inexpensive or a

combination of these. In the case of beneficial impacts,

5-10

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Rating DescriptionThreshold of significance

alternative means for achieving this benefit are likely to be easier,

cheaper, more effective, less time consuming, or a combination of

these.

Some impacts have been assessed and proved to be positive and a benefit to the social and

or natural environment. Although these impacts have been rated in accordance with the

methodology provided above, high significance values were obtained. The nature or status

of the impact proved to be the key indicator. Should the nature of the activity, as assessed,

be positive the significance threshold is reversed.

Table 11:37 Assessing Significance (Positive Impacts)

Rating DescriptionThreshold of significance

High A large benefit to the holistic environment 17-22

Medium A benefit to the holistic environment 11-16

Low No real benefit to the holistic environment 5-10

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