PO Box 22014 | Helderkruin | 1733 [email protected]082 412 1799 086 551 5233 Dwarsrivier Chrome Mine (Pty) Ltd FINAL Basic Assessment Report and Management Plan for the Expansion of the Low Grade Met Plant Stockpile area, and Discard Dump with Ancillary Infrastructure Report Purpose DMR Submission Report Status FINAL Report Reference EnviroGistics Ref.: 21714 Departmental Ref.: 30/5/1/3/2/1(179) EM Mining Right Ref: 30/5/1/3/2/1(179) EM Report Author Tanja Bekker MSc. Environmental Management Certified EAPSA; PrSci. Reg. 400198/09 12 October 2017
FINAL Basic Assessment Report and Management Plan for the Expansion of the Low Grade Met Plant Stockpile area, and Discard Dump with Ancillary Infrastructure
Dwarsrivier Chrome Mine: Basic Assessment Report and Management Plan for the Expansion of the Met Grade Chrome Stockpile and Discard Dump with Ancillary Infrastructure Mining Right Ref: 30/5/1/3/2/1(179) EM Project Ref: 21714 Version: FINAL
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Author
Tanja Bekker is registered as a Professional Natural Scientist with the South African Council of Natural Science Professional Board and is also a Certified Environmental Assessment Practitioner (EAP) with the Interim Certification Body of Environmental Practitioner Association of South Africa (EPASA), a legal requirement stipulated by the National Environmental Management Act, 1998. She is further certified as an ISO 14001 Lead Auditor. Her qualifications include a BSc. Earth Sciences (Geology and Geography), BSc. Hons. Geography, and a MSc. Environmental Management. In addition to her tertiary qualifications, she obtained a Certificate in Project Management, and completed the Management Advance Programme at Wits Business School.
With more than 14 years' experience in environmental management and the consulting industry she follows a methodical and practical approach in approaching environmental problems and a holistic approach towards approaching environmental solutions throughout the project planning, initiation, operation and decommissioning or closure of projects.
Disclaimer
The findings, results, observations, conclusions and recommendations given in this report are based on the author’s best scientific and professional knowledge, as well as available information. Information utilised and contained in this
report is based on data/information supplied to EnviroGistics (Pty) Ltd by the client and other external sources (including previous site investigation data and external specialist studies). EnviroGistics (Pty) Ltd exercises due care and diligence in rendering services and preparing documents, however it has been assumed that the information provided to EnviroGistics (Pty) Ltd is correct and as such the accuracy of the conclusions made are reliant on the accuracy and completeness of the data supplied. No responsibility is accepted by EnviroGistics (Pty) Ltd for incomplete or inaccurate data supplied by the client and/or other external sources. Opinions expressed in this report apply to the site conditions and features that existed at the time of the start of the relevant investigations and the production of this document. For this reason EnviroGistics (Pty) Ltd accepts no liability, and the client by receiving and therefore accepting this document, indemnifies EnviroGistics (Pty) Ltd and its directors against all actions, claims, demands, losses, liabilities, costs, damages and expenses arising from or in connection with the services rendered, directly or indirectly.
The document may not be altered or added to without the prior written consent of the author. This also refers to electronic copies of the report which are supplied for the purposes of inclusion as part of other reports.
Copyrights
Copyright on all documents, drawings and records, whether manually or electronically produced, which form part of the submission and any subsequent report or project document, shall vest in EnviroGistics (Pty) Ltd.
Should the Client wish to utilise any part of, or the entire report, for a project other than the subject project, permission must be obtained from EnviroGistics (Pty) Ltd to do so. This will ensure validation of the suitability and relevance of this report on an alternative project.
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Quality Control
Report Title
DWARSRIVIER CHROME MINE: BASIC ASSESSMENT REPORT AND MANAGEMENT PLAN FOR THE EXPANSION OF THE MET GRADE CHROME STOCKPILE AND DISCARD DUMP WITH ANCILLARY INFRASTRUCTURE
Report Ref. No.
21714F
Report Status
FINAL
Report Purpose
Stakeholder Review
Signature
Date
Report Co-Author Tanja Bekker 12 October 2017
Report Review and Second Author
Diana Verster 30 August 2017
Client Signoff
Amendments
Report Ref:
Nature of Amendment Date Report Output Ref:
21714D1 Client Comments 8 September 2017 21714FD
21714FD Updated Engineering Designs 5 October 2017
Distribution
Distributed To:
Purpose: Date Format/Amount
Pieter Schoeman Client review 31 August 2017 Electronic
Tanja Bekker Client Comments 7 September 2017 Electronic
Registered Stakeholders Stakeholder Review 11 September 2017 Electronic
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Executive Summary
Introduction
Dwarsrivier Chrome Mine (Pty) Ltd (hereafter referred to as “Dwarsrivier”) is situated approximately 60km northwest of Lydenburg, 25km south of Steelpoort and 63km northeast of Roossenekal in the Limpopo Province. The mine currently holds the mining rights for Portion 1 (Remaining Extent) and Portion 0 (Remaining Extent) of the farm and surface rights for the said portions, as well as Portion 4 portion of Portion 3 of the farm de Grootteboom 373KT.
The operation is located in the Greater Tubatse Local Municipality, within the boundaries of the Sekhukhune District Municipality and is wholly owned by Assore Ltd.
Project Description
It is the intention of the mine to initiate certain additional activities on site. These will include the expansion of the
Discard MRD and the expansion of Met Grade Product Stockpile within the existing mining right area. The existing
Discard are included into the approved Environmental Management Programme (EMP) approved under the Mineral
and Petroleum Resources Development Act, 2002 (Act No. 28 of 2002) (MPRDA) and also in the 2008 Water Use
License (WUL). The Met Grade Product Stockpile is an existing facility on the southern border of the Dwarsrivier Plant
area.
The Discard MRD Expansion Project: The mine produces two types of mine residue as part of the beneficiation
process. This includes tailings material and discard waste. The mine has an existing authorisation in terms of the
MPRDA and the NWA for the existing unlined, Discard MRD and it is therefore deemed a lawful facility. This facility
is located on the Remainder Portion of the farm Dwarsrivier 372KT. As part of the mines expanding underground
mining operations (approved), the need to increase the Discard MRD has become evident.
The area required for the expansion of the Discard facility is approximately 16ha within the existing mining rights
towards the north-west.
The Metallurgical Plant Stockpile Expansion:
The existing Met Grade Stockpile located on the Remainder of Portion 1 of the farm Dwarsrivier 372KT has been
established during the year 2016. Since the initial establishment the applicant has experienced the need to further
increase the footprint of this project stockpile area. This area will require an increase of approximately 0.8ha in a
south-easterly direction.
The latter project, will generally not require environmental authorisations, however, due to the fact that the mine is
located in the Steelpoort Valley, which is characterised as a Critical Biodiversity Area (CBA), listing Notice 3 activities
apply.
In addition to the two extension projects, the mine also plans to establish certain ancillary activities, which forms part of the optimisation of the mines footprint around the plant area, which includes:
Establishment of fences; Establishment of a new Sewage Treatment Facility; Establishment of a new Workshop; and Establishment of a new load out area.
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Application area (Ha)
Discard MRD Extension: The area required for the expansion of the Discard facility is approximately 13ha within the existing mining rights towards the north-west. Metallurgical Grade Product Stockpile (Met Grade Product Stockpile) Extension: This area will require an increase of approximately 0.7ha in a south-easterly direction. New Sewage Treatment Plant: This area will encompass and area of approximately 0.06ha, north of the proposed Met Grade Chrome Stockpile Extension. New TMM Workshop: This area will encompass and area of approximately 0.2ha towards the south east of the Met Grade Chrome Stockpile Extension. New Loadout Area: This area will be located around the east and southern perimeter of the Met Grade Chrome Stockpile Extension and will encompass and area of approximately 0.9ha Fences: No clearance required. Overall Site Clearance: Approximately 15ha
Listed Activities
Section 16 of the Mineral and Petroleum Resources Development Act, 2002 (Act No. 28 of 2002) requires, upon
request by the Minister that an Environmental Management Plan be submitted and that the applicant must notify
and consult with Interested and Affected Parties (I&APs). Section 24 of the NEMA requires that activities, which may
impact on the environment must obtain an environmental authorisation from a relevant authority before
commencing with the activities. Such activities are listed under Regulations Listing Notice 1 Government Notice
Regulation 326, 324 and Regulation 327 (dated April 2017) of NEMA. The proposed operations at Dwarsrivier
triggers the following activities:
NEMA Government Notice 327, Listing Notice 1:
Activity 27: The clearance of an area of 1 hectares or more, but less than 20 hectares of indigenous
vegetation, except where such clearance of indigenous vegetation is required;
Activity 34: The expansion of existing facilities or infrastructure for any process or activity where such
expansion will result in the need for a permit or licence or an amended permit or licence in terms of national
or provincial legislation governing the release of emissions, effluent or pollution, excluding— (i) where the
facility, infrastructure, process or activity is included in the list of waste management activities published in
terms of section 19 of the National Environmental Management: Waste Act, 2008 (Act No. 59 of 2008) in
which case the National Environmental Management: Waste Act, 2008 applies.
NEMA Government Notice 324, Listing Notice 3:
Activity 12: The clearance of an area of 300 square metres or more of indigenous vegetation except where
such clearance of indigenous vegetation is required for maintenance purposes undertaken in accordance
with a maintenance management plan.
Considering the NEM: WA, the Regulation 921, dated 29 November 2013 as amended makes provision for lists of waste management activities that have, or are likely to have a detrimental effect on the environment. The amendments of the list of waste management activities dated 24 July 2015 makes provision for the inclusion of
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Residue Stockpiles or Deposits. The Discard Dump extension will also trigger a waste activity in terms of the National Environmental Management: Waste Act, 2008:
Category A, Activity 13: “The expansion of a waste management activity listed in Category A or B or this Schedule which
does not trigger an additional waste management activity in terms of this Schedule.
Aim and Motivation of the Project
Currently Dwarsrivier is serviced by 1200 permanent and 800 contractor employees. The majority of the employees are locals drawn from Lydenburg and villages around DWR, including Steelpoort Park, Kalkfontein and Buffelshook. The aim of the proposed activities are to improve the logistics on site, ensure suitable supply of chrome for markets, as well as to ensure a suitable waste rock disposal strategy, whilst a long term strategy is investigated:
The mine has an approved footprint for the Discard Dump. The capacity of this footprint is not suitable to maintain the underground mining operations waste volume production. The capacity of the footprint is being reached and the footprint has to be expanded. According to the production department, the expanded facility can provide a much longer timespan if the angle of the Discard Dump is designed at 35 degrees (approximately 24 years), however to design and operate the facility at a 1:3 slope for closure a life of facility of approximately 10 years will be available. It should be noted, that for the long term, an additional facility will still be required. The purpose of the Discard Dump expansion is therefore to provide the mine with an additional 10 years of life, during which time a detailed investigations will be undertaken to determine a suitable site for a long term Discard Dump facility.
According to an article by S&P Global Plats, 6 March 2017 (https://www.platts.com/latest-news/metals/tokyo/strong-chrome-demand-to-hold-but-views-divided-26678512), “strong demand for chromite feedstock of ferrochrome will continue to hold on the back of robust Chinese stainless steel output, but views are divided on whether global supply will move into deficit due to constraints of South African production to meet that demand, industry sources told S&P Global Platts Monday”. According to the article, “sources said there are two possible scenarios arising from South Africa trying to meet Chinese demand amid stagnated output: the market will be short on chrome ore supply as other global suppliers will not be able to fully meet China's demand; or China will reduce dependency on South African chromite supply and diversify to other resources.” According to the Mining Weekly Online (http://m.miningweekly.com/article/strong-outlook-for-recovering-ferrochrome-industry-merafe-2017-03-08/rep_id:3861): “The Chinese economy, on which the ferrochrome and chrome ore markets are heavily dependent, grew by 6.7% year-on-year, underpinning pleasing growth in stainless steel production. Ferrochrome-using stainless steel production is projected to grow by 3.5% in 2017 and by 3.8% in 2018, which should be followed by increased ferrochrome demand.” The Met Grade Plant Stockpile and load out facility allow the mine to sell additional grades to the market. The market demand has increased and therefore a greater size stockpile is required to meet the supply requirements.
The ancillary infrastructure (sewage treatment plant and workshops) are required to fulfil the operational requirements of the mine. The location of these facilities in proximately to the plant will assist in the operational logistics.
Alternatives Considered
The following considerations were taken in terms of alternatives:
The capacity of the existing facilities (Sewage Treatment Plant, Workshops) have been reached on site. The ancillary infrastructure will be placed at the closest available open space located near the Plant area, for this reason no alternatives were investigated.
The Met Grade Plant Stockpile is an existing facility and therefore the expansion of the facility is based on available space around the existing site. For this reason no alternatives are available for the stockpile or the load out facility.
In terms of the Discard Dump certain considerations were made in terms of the location of the facility which included backfilling, expansion to the existing area, and a new disposal area. To address the current needs of the applicant and to ensure a sound level of compliance, the best alternative is to utilise the existing area of the Discard Dump and extent this facility in the interim, whilst a suitable long term alternative is found
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(please refer to Section 3h for a detailed discussion). In the interim the applicant will continue with their investigations for the most effective and practical manner in which to implement the waste management hierarchy, with the aim to reduce waste (optimise mining practices), or reuse the waste (assess avenues to use the discard as aggregate or alternative uses).
Application and Consultation Process
The application for the Basic Assessment Project was submitted to the Department of Mineral Resources (DMR) on
21 July 2017 (delivered at 9h00). A letter of acknowledgement from the DMR was received on 23 August 2017.
In terms of the Environmental Authorisation Process a detailed stakeholder consultation process was also undertaken
notification of I&APs commenced on 07 July 2017. The notification process was undertaken by means of the
following:
Newspaper advertisements;
Site Notices;
Direct Notifications through a Background Information Document.
Five (5) site notices were erected on site (on 4-7 July 2017) and at visible locations close to the site. The formal announcement of the proposed project was done by placing an advert in the Steelburger News on 07 July 2017 to invite all I&APs to register on the project database.
The draft report was made available to stakeholders from 11 September 2017 to 11 October 2017 for review, where after all the comments received would have been incorporated. To date no comments have been received from stakeholders, however, ongoing assessment in terms of the optimisation of the available footprint has allowed for the inclusion of an updated design for the Discard Dump footprint. The final report is presented with this information and submitted to the Department of Mineral Resources (DMR) for review. It should be noted that a formal application will be lodged with the Department of Water and Sanitation (DWS) for the expansion of the approved Discard Dump as an amendment to the approved Section 21(g) water use.
Impact Statement
Positive Impacts
The demand for chrome has increased globally due to the increase in China Markets. No allowing the expansion of the Met Grade Plant Stockpile will result in a restriction on the volume of this material to be produced. This will result in restricting the mine to market supply available reserves, and could impact on the economics of scale of the mining operation. The load out facility is an ancillary infrastructure to this product stockpile and is required to allow for the movement of the product off site. Not allowing this facility will restrict the logistics of supply to the various markets.
The Discard Dump is a key component to the mining operation, with all Discard from the Plant deposited on this site. The capacity of the Discard Dump is fast reaching its capacity and for this reason additional capacity is required. The Discard Dump extension will provide approximately ten (10) years of life of facility, however, by not allowing this extension the opportunity to assess a new site in terms of detailed specialist studies are lost, as the requirement for capacity is immediate.
Increased sustainability of mining operations in this area will have a multiplier effect in terms of employment and economic activities in the region.
Negative Impacts
It should be noted that impacts associated with the proposed project will be significantly lower than a Greenfields project, as activities are located within the existing mining right area and mostly within already disturbed or impact environments.
The activities proposed by the applicant, have not indicated any significant impact in the long term. The main concern of the project was the potential impact of the Discard Dump on the groundwater resources, which has indicated that limited impact is foreseen. Refer to the following key areas which were considered.
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Cultural and Heritage Sites
Based on existing studies conducted as part of the overall mine site, no sits of cultural and heritage importance are present on site.
Sensitive Ecosystems
Although the site is located in a CBA, an ecological study was undertaken to determine the presence of sensitive plant and tree species in the area. A detailed study of each of the species were undertaken to determine the location and to obtain a removal certificate from the Department of Agriculture, Forestry, and Fisheries (Ref: LP-SDM-201-06-06-B).
NFEPA Wetlands
Three NFEPA wetlands are indicated around the proposed project area. After consideration of these areas, it was found that these sites are in fact the mines internal Return Water Dams and not wetlands.
Another study was undertaken to determine whether a wetland is present to the west of the existing Discard Dump. The study concluded that no wetland is present in this area.
Based on this assessment, no wetlands are located within 500m of the activities considered for this application.
River Systems
The activities will remain outside of the 1:100 year flood lines for both the Springkaanspruit to the east of the proposed developments and the Groot Dwarsrivier towards the south of the proposed developments.
Groundwater Resources
The hydrogeological study stated that the impact of the expansion will not contribute to any significant increase in impact not already foreseen in the study. Modelling results further indicated that full rehabilitation at mine closure will limit the spread of contamination from the site.
The outcome of the waste classification study completed for the site indicate that the discard material is a Type 4 waste. According to Regulation 636 of the NEM: WA: Type 4 wastes may only be disposed of at Class D landfill sites (see diagram below), designed in accordance with Section 2(1) and (3) of these Norms and Standards, or, subject to Section 3(4) of these Norms and Standards, may be disposed of at a landfill site designed in accordance with the requirements of a GLB- landfill as specific in the Minimum Requirements for Waste Disposal by Landfill (2nd Ed., DWAF, 1998).
The outcome of the numerical groundwater modelling completed as part of the study indicates that groundwater in the vicinity of the expansion to the Discard Dump is already contaminated. This contamination will continue to impact on groundwater quality in this area during the operational phase and in the long-term. Scenarios tested with the model suggest that lining of the Discard Dump extension will not eliminate the existing contamination and that the latter will continue to affect groundwater quality even if liners are constructed. If the Discard Dump extension is lined, nitrate concentrations and the area of contamination will be slightly reduced, but nitrate concentrations will continue to exceed the license conditions in future. The impact of the expansion will have a limited addition to the already expected scenario.
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Leach tests undertaken on the discard material furthermore suggests that the discard is not a source to nitrate contamination, with nitrate concentrations below the mine’s WUL conditions. In the long-term the source of nitrate contamination associated with the site is expected to be reduced as very little nitrates will leach from the site. The source of nitrate pollution is therefore still under investigation. At the current time the following potential sources are considered as part of this study and will therefore require management measures in terms of the engineering design, further studies are however required to assess this in more detail:
1. Runoff from upstream sources (i.e. historic opencast area and historic overflows of the North Return Water Dam) which reached the boreholes and infiltrated the groundwater resources;
2. Leachate of ammonia from fines during initial deposition of the existing Discard Dump.
Based on the available information, it is therefore recommended that the following be implemented:
1. To understand the water as part of the shallow aquifers, test pits are recommended. Any water intercepted should be analysed to determine the quality of the water. The quality will indicate whether surface water runoff may be a resulting cause of nitrate contamination.
2. The base of the site is prepared with a suitable base preparation layer as recommended by a registered Engineer to reduce the rate of infiltration to the underlying aquifers.
3. Development of a shallow trench around the facility to avoid the infiltration of upstream runoff and also the discharge of surface seep from the facility;
4. Development of berms around the facility to separate clean and dirty water; 5. Allowance for a sump within the dirty water catchment of the Discard Dump expansion to capture shallow
seep and runoff and pump this water back to the closed water circuit of the mine from where it will be treated through the water treatment plant and reused.
6. Upon closure, the site must be sloped and rehabilitated to reduce the rate of recharge to near-natural conditions. Focus must be placed on developing more detailed rehabilitation plans to facilitate this scenario.
In the long-term, contamination from the Discard dump will migrate towards the Dwarsrivier and may reach this stream within a 100 years after closure. Only a small section of the Dwarsrivier may be affected (<100m in length). Contamination associated with the extension to the Discard Dump will however migrate in a northerly direction towards the Dwarsrivier. It is not expected that this plume will reach the river 100 years after mining ceases.
Gaps
1. Although waste classification has been undertaken and the results are presented in this report, further samples have been taken from the Discard Dump Facility to assess the quality of the Total Concentrations and Leachable Concentrations in more detail. This information has been initiated to further contribute to the development of the numerical model.
2. Designs in terms of the depth of the trenches proposed around the Discard Dump have not been finalised. The final designs will be submitted to the DWS for approval where after the facility may only be constructed.
3. An existing groundwater pollution plume is present, which has higher nitrate concentrations than presented by the Leach Tests of the Discard Dump. This indicates the presence of a secondary source of pollution, may be historic, which is not as yet fully understood. Further studies are required to determine the exact source of this pollution and the necessary management measures are required to manage this pollution path.
Concluding Statement
Based on the outcomes of the study it is the opinion of the Environmental Assessment Practitioner that the Environmental Authorisation should be awarded, with the following conditions:
An independent Environmental Control Officer must be appointed to assess the construction activities, at least once a month to ensure that all components of the EMP are addressed.
Tree removal permits to be applied for where required, after the current permits have lapsed. No activities may be established within either 100m of a river or within the 1:100 year flood line. The numerical model must be updated at least once every two years. The maximum volume of topsoil is to be removed from construction activities. New monitoring boreholes, identified as a requirement in the numerical groundwater model, should be
implemented within 24 months from the date of approval of the Environmental Authorisation.
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Tests pits must be developed around the Discard Dump expansion to provide further information on the quality of water seep in this area.
Geophysical and Geotechnical assessments on the footprint of the facility should be conducted.
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Contents Page
1 Important Notice ........................................................................................................................................................ viii
2 Objective of the Basic Assessment ............................................................................................................................ viii
3 Contact Person and Correspondence Address ........................................................................................................... 9
3.a.i Details of the EAP ............................................................................................................................................ 9
3.a.ii Expertise of the EAP ........................................................................................................................................ 9
3.a.iii Details of the Applicant ................................................................................................................................. 10
3.b Location of the Activity ...................................................................................................................................... 11
3.b.i Location of the Mine ..................................................................................................................................... 11
3.b.ii Ownership of Land ......................................................................................................................................... 12
3.b.iii Listed Activity Location and Size ................................................................................................................... 15
3.d.ii Expansion of the Discard Dump .................................................................................................................... 20
3.i.ii Stakeholder Identification and Notification ................................................................................................. 36
3.i.iii Site Notices .................................................................................................................................................... 37
3.i.iv Background Information Documents ........................................................................................................... 37
3.i.vii Summary of Issues raised by the I&APs ....................................................................................................... 38
3.i.ix The Environmental Attributes associated with the Alternatives ................................................................ 39
3.i.ix.1 Baseline Information ............................................................................................................................................... 39
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3.i.ix.2 Type of Environment Affected by the Proposed Activity ...................................................................................... 80 3.i.ix.3 Description of the Current Land Uses .................................................................................................................... 80 3.i.ix.4 Description of Specific Environmental Features and Infrastructure on Site ........................................................ 83 3.i.ix.5 Environmental and Current Land Use Map ............................................................................................................ 83
3.i.x Methodology used in determining and ranking the Nature, Significance, Consequences, Extent, Duration and Probability of potential Environmental Impacts and Risks ............................................................... 84
3.i.x.1 Criteria of assigning significance to potential impacts .......................................................................................... 84 3.i.xi Impacts and Risks identified including the Nature, Significance, Consequence, Extent, Duration and Probability of the Impacts, including to which these Impacts ................................................................................. 86
3.i.xii The Positive and Negative Impacts that the Proposed Activity (in terms of the Initial Site Layout) and Alternatives will have on the Environment and the Community that may be affected ....................................... 144
3.i.xiii The Possible Mitigation Measures that could be applied and the Level of Risk ...................................... 144
3.i.xiv Motivation where no alternative sites were considered .......................................................................... 145
3.i.xv Statement Motivating the Alternative Development Location within the overall Site ........................... 145
3.j Full Description of the Process undertaken to Identify, Assess and Rank the Impacts and Risks the Activity will Impose on the preferred Site (In respect of the Final Site Layout Plan) through the Life of the Activity ......... 145
3.k Assessment of Each Identified Potential Significant Impact and Risk ........................................................... 146
3.l Summary of Specialist Reports........................................................................................................................ 147
3.m.i Summary of the Key Findings of the Environmental Impact Assessment ................................................ 149
3.m.i.1 Direct Impacts during Construction ..................................................................................................................... 151 3.m.i.2 Direct Impacts during the Operational Phase ...................................................................................................... 152 3.m.i.3 Direct Impacts during Decommissioning and Closure ......................................................................................... 152
3.m.ii Direct Cumulative Impacts .......................................................................................................................... 153
3.m.iii Final Site Map .............................................................................................................................................. 154
3.m.iv Summary of the Positive and Negative Impacts and Risks of the Proposed Activity and Identified Alternatives............................................................................................................................................................... 154
3.n Proposed Impact Management Objectives and the Impact Management Outcomes for inclusion in the EMPr 155
3.o Aspects for Inclusion as Conditions of Authorisation .................................................................................... 156
3.p Description of any Assumptions, Uncertainties and Gaps in Knowledge ..................................................... 157
3.q Reasoned Opinion as to Whether the Proposed Activity should or should not be authorised................... 157
3.r Period for which the Environmental authorisation is required ..................................................................... 159
3.t.ii Confirm that this amount can be provided for from Operating Expenditure .......................................... 162
3.u Specific Information Required by the Competent Authority......................................................................... 162
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3.u.i Compliance with the Provisions of Section 24(4) (a) and (b) read with Section 24(3) (a) and (7) of the National Environmental Management Act (Act 107 of 1998) The EIA Report must include the:- ...................... 162
3.u.i.1 Impact on the Socio-Economic Conditions of any Directly Affected Person...................................................... 162 3.u.i.2 Impact of any National Estate referred to in Section 3(2) of the National Heritage Resources Act. ................ 162
3.v Other Matters Required in terms of Section 24(4) (a) and (b) of the Act .................................................... 162
1.a Details of the EAP ............................................................................................................................................. 163
1.a.i Expertise of the EAP .................................................................................................................................... 163
1.b Description of the Aspects of the Activity ...................................................................................................... 164
2.a The correctness of the Information provided in the Reports ....................................................................... 367
2.b The inclusion of Comments and Inputs from Stakeholders and I&APs ........................................................ 367
2.c The inclusion of Inputs and Recommendations from the Specialist Reports where relevant .................... 367
2.d That the Information provided by the EAP to I&APs and any Responses by the EAP to Comments and Inputs made by I&AP are correctly reflected herein .................................................................................................. 367
List of Figures
Figure 1: Local and Regional Setting ................................................................................................................................. 13 Figure 2: Cadastral Information ........................................................................................................................................ 14 Figure 3: Location of Activities)......................................................................................................................................... 18 Figure 4: Discard Dump Slope from North to South ........................................................................................................ 43 Figure 5: Discard Dump Slope from East to West ............................................................................................................ 43 Figure 6: Met Grade Stockpile and Ancillary Infrastructure Slope from North to East ................................................. 44 Figure 7: Met Grade Stockpile and Ancillary Infrastructure Slope from South to West ................................................ 44 Figure 8: Geology of the project area................................................................................................................................ 46 Figure 9: Soils map.............................................................................................................................................................. 47 Figure 10: Topsoil Stockpile Locations ............................................................................................................................. 51 Figure 11: Vegetation ......................................................................................................................................................... 52 Figure 12: Management Units ........................................................................................................................................... 53 Figure 13: CBAs .................................................................................................................................................................. 56 Figure 14: An aerial photograph depicting the location of the study area in relation to surrounding areas................ 57 Figure 15: Quaternary Catchments .................................................................................................................................. 60 Figure 16: The cross sections representative parts of the rivers/streams ...................................................................... 61
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Table 1: Details of EAP ......................................................................................................................................................... 9 Table 2: Experience of EAP .................................................................................................................................................. 9 Table 3: Details of Applicant ............................................................................................................................................. 10 Table 4: Landownership .................................................................................................................................................... 12 Table 5: Property Location ................................................................................................................................................ 15 Table 6: Coordinates.......................................................................................................................................................... 15 Table 7: Met Grade Chrome Stockpile Design ................................................................................................................. 19 Table 8: Discard Dump Design .......................................................................................................................................... 21 Table 9: Sewage Facility Design ........................................................................................................................................ 26 Table 10: Loadout Area Design ......................................................................................................................................... 26 Table 11: Workshop Facility Design .................................................................................................................................. 27 Table 12: Listed Activities .................................................................................................................................................. 29 Table 13: Policy and Legislative Context ........................................................................................................................... 33 Table 14: Stakeholder Comments received ..................................................................................................................... 38 Table 15: Rainfall Summary ............................................................................................................................................... 40 Table 16: Evaporation Summary ........................................................................................................................................ 41 Table 17: Extreme Weather Conditions. ........................................................................................................................... 42 Table 18: Soil forms and Families ...................................................................................................................................... 45 Table 19: Soil forms as a percentage of the area surveyed. ............................................................................................ 48 Table 20: Soil forms as a percentage of the area disturbed ............................................................................................ 48 Table 21: Soil Chemistry ..................................................................................................................................................... 48 Table 22: Soil Erodibility ..................................................................................................................................................... 49 Table 23: Topsoil balance (presented in m3) .................................................................................................................... 49 Table 24: Dominant Species within the Dwarsrivier Mine. .............................................................................................. 50 Table 25: Management units within the Dwarsrivier Mine ............................................................................................. 50 Table 26: Specific Biodiversity Targets .............................................................................................................................. 54 Table 27: Dominant, Threatened and Invasive Plant Species .......................................................................................... 54 Table 28: Threatened Animal Species ............................................................................................................................... 59 Table 29: Surface Water Monitoring Location ................................................................................................................. 63 Table 30: Surface Water (Instream) Chemical Analyses Results – March 2017............................................................. 65 Table 31: Groundwater abstraction volumes .................................................................................................................. 66 Table 32: Groundwater Monitoring Points ....................................................................................................................... 68 Table 33: Groundwater Quality ........................................................................................................................................ 69 Table 34: Nitrate concentrations in monitoring boreholes in mg/l ................................................................................ 70 Table 35: Nitrate concentrations derived from monitoring data ................................................................................... 70 Table 36: Dust Monitoring Points ..................................................................................................................................... 73
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Table 37: Employment Status ........................................................................................................................................... 77 Table 38: Employment Sectors ......................................................................................................................................... 78 Table 39: Monthly Income Distribution ........................................................................................................................... 78 Table 40: Agricultural Production (Departmental Report 2013) .................................................................................... 79 Table 41: Status of Impact ................................................................................................................................................ 84 Table 42: Extent of Impact ................................................................................................................................................. 84 Table 43: Duration of Impact ............................................................................................................................................. 85 Table 44: Probability of Impact .......................................................................................................................................... 85 Table 45: Intensity of Impact ............................................................................................................................................. 85 Table 46: Impact Magnitude and Significance Rating ...................................................................................................... 85 Table 47: Planning and Construction Phase Impact Assessment and Management Measures (Significance before
Mitigation –SbM; Significance after Mitigation – SaM) ................................................................................................... 87 Table 48: Operational Phase Impact Assessment and Management Measures (Significance before Mitigation –SbM;
Significance after Mitigation – SaM) ............................................................................................................................... 106 Table 49: Decommissioning and Closure Phase Impact Assessment and Management Measures (Significance before
Mitigation –SbM; Significance after Mitigation – SaM) ................................................................................................. 125 Table 50: Specialist Study Findings ................................................................................................................................. 147 Table 51: Summary Input Data ....................................................................................................................................... 160 Table 52: Annual Escalation of DMR Published Rates ................................................................................................... 160 Table 53: Closure Cost ..................................................................................................................................................... 161 Table 54: Details of EAP .................................................................................................................................................. 163 Table 55: Experience of EAP ........................................................................................................................................... 163 Table 56: Construction Phase Impact Table with Management Measure, Objectives and Standards ....................... 167 Table 57: Operational Phase Impact Table with Management Measure, Objectives and Standards......................... 187 Table 58: Decommissioning and Closure Phase Impact Table with Management Measure, Objectives and Standards
........................................................................................................................................................................................... 205 Table 59: Rehabilitation Plan .......................................................................................................................................... 225 Table 60: Proposed new boreholes ................................................................................................................................ 233 Table 61: Current Monitoring Network Summary .......................................................................................................... 233 Table 62: Additional Surface Water Points Summary .................................................................................................... 233 Table 63: Proposed Ground Water Monitoring Programme ........................................................................................ 235 Table 64: Monitoring points for Biomonitoring at Dwarsrivier Mine ........................................................................... 237 Table 65: Monitoring Compliance during Construction Phase ..................................................................................... 240 Table 66: Monitoring Compliance during Operational Phase ....................................................................................... 283 Table 67: Monitoring Compliance during Decommissioning and Closure Phase ........................................................ 322 Table 68: Environmental Training and Awareness Schedule .......................................................................................... 365
List of Diagrams
Diagram 1: Process Flow of Sewage Package Plant ......................................................................................................... 25 Diagram 2: Education Level in comparison to other Municipalities and South Africa (Quantec Regional Economic
Database) ............................................................................................................................................................................ 77 Diagram 3: Economic Active Population (Quantec Regional Economic Database) ....................................................... 77 Diagram 4: Class D Landfill Liner ..................................................................................................................................... 150
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List of Annexures
Annexure 1: DMR Acknowledgment of Receipt Annexure 2: EAP Curriculum Vitae Annexure 3: List of Environmental Authorisations Annexure 4: Title Deeds Annexure 5: Met Grade Plant Stockpile & Discard Dump Design Annexure 6: Leach Study Results Annexure 7: Tree Removal Permit and Supporting Study Annexure 8: Stakeholder Consultation Documentation Annexure 9: Wetland Assessment Annexure 10: Topsoil Management Plan Annexure 11: Groundwater Study Annexure 12: Fence Risk Assessment
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BASIC ASSESSMENT REPORT
And
ENVIRONMENTAL MANAGEMENT PROGRAMME REPORT
SUBMITTED FOR ENVIRONMENTAL AUTHORIZATIONS IN TERMS OF THE NATIONAL
ENVIRONMENTAL MANAGEMENT ACT, 1998 AND THE NATIONAL ENVIRONMENTAL
MANAGEMENT WASTE ACT, 2008 IN RESPECT OF LISTED ACTIVITIES THAT HAVE BEEN
TRIGGERED BY APPLICATIONS IN TERMS OF THE MINERAL AND PETROLEUM RESOURCES
DEVELOPMENT ACT, 2002 (MPRDA) (AS AMENDED).
NAME OF APPLICANT: Dwarsrivier Chrome Mine (Pty) Ltd
FILE REFERENCE NUMBER SAMRAD: Mining Right Reference Number: LP 30//2/3/2/1(179) EM
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1 IMPORTANT NOTICE
In terms of the Mineral and Petroleum Resources Development Act (Act 28 of 2002 as amended), the Minister must grant a prospecting or mining right if among others the mining “will not result in unacceptable pollution, ecological degradation or damage to the environment”.
Unless an Environmental Authorisation can be granted following the evaluation of an Environmental Impact Assessment and an Environmental Management Programme report in terms of the National Environmental Management Act (Act 107 of 1998) (NEMA), it cannot be concluded that the said activities will not result in unacceptable pollution, ecological degradation or damage to the environment. In terms of section 16(3) (b) of the EIA Regulations, 2014, any report submitted as part of an application must be prepared in a format that may be determined by the Competent Authority and in terms of section 17 (1) (c) the competent Authority must check whether the application has taken into account any minimum requirements applicable or instructions or guidance provided by the competent authority to the submission of applications.
It is therefore an instruction that the prescribed reports required in respect of applications for an environmental authorisation for listed activities triggered by an application for a right or a permit are submitted in the exact format of, and provide all the information required in terms of, this template. Furthermore please be advised that failure to submit the information required in the format provided in this template will be regarded as a failure to meet the requirements of the Regulation and will lead to the Environmental Authorisation being refused.
It is furthermore an instruction that the Environmental Assessment Practitioner must process and interpret his/her research and analysis and use the findings thereof to compile the information required herein. (Unprocessed supporting information may be attached as appendices). The EAP must ensure that the information required is placed correctly in the relevant sections of the Report, in the order, and under the provided headings as set out below, and ensure that the report is not cluttered with un- interpreted information and that it unambiguously represents the interpretation of the applicant.
Please refer to Annexure 1 for the proof of submission of the Application Form and Acknowledgment of Receipt by the DMR.
2 OBJECTIVE OF THE BASIC ASSESSMENT
The objective of the basic assessment process is to, through a consultative process─
a) determine the policy and legislative context within which the proposed activity is located and how the activity complies with and responds to the policy and legislative context;
b) identify the alternatives considered, including the activity, location, and technology alternatives; c) describe the need and desirability of the proposed alternatives, d) through the undertaking of an impact and risk assessment process inclusive of cumulative impacts which
focused on determining the geographical, physical, biological, social, economic, heritage, and cultural sensitivity of the sites and locations within sites and the risk of impact of the proposed activity and technology alternatives on these aspects to determine:
a. the nature, significance, consequence, extent, duration, and probability of the impacts occurring to; and
b. the degree to which these impacts— i. can be reversed; ii. may cause irreplaceable loss of resources; and
iii. can be managed, avoided or mitigated; c. through a ranking of the site sensitivities and possible impacts the activity and technology
alternatives will impose on the sites and location identified through the life of the activity to— i. identify and motivate a preferred site, activity and technology alternative; ii. identify suitable measures to manage, avoid or mitigate identified impacts; and
iii. Identify residual risks that need to be managed and monitored.
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PART A
SCOPE OF ASSESSMENT AND BASIC ASSESSMENT REPORT The application for the Basic Assessment Project was submitted to the Department of Mineral Resources (DMR) on 21 July 2017 (delivered at 9h00). A letter of acknowledgement from the DMR was received on 23 August 2017.
Please refer to Annexure 1 for the submitted application form and proof of submission.
The following table presents a summary of the EAPs experience:
Table 2: Experience of EAP
Name Position Qualification Professional Registrations Experience
Tanja Bekker Principal Practitioner
M.Sc. Environmental Management (RAU), now Johannesburg University)
Certified member of the Environmental Assessment Practitioners Association of South Africa (October 2013) Registered with the South African Council of National Scientific Professions (SACNASP: Pr.Sci.Nat. Reg No. 400198/09) Member of International Association of Impact Assessors Member of the Environmental Law Association of South Africa
14 Years
Please refer to Annexure 2 for the EAPs Curriculum Vitae.
Education B.Sc. Earth Sciences (Geography & Geology) – RAU (University of Johannesburg) B.Sc. Geography Honours - RAU (University of Johannesburg) M.Sc. Environmental Management - RAU (University of Johannesburg) Career Enhancing Courses ISO 14000 Lead Auditors Course (WTH Management) Certificate in Project Management (Pretoria University) Management Advance Programme (MAP 81) (Wits Business School) Professional Affiliations Certified member of Environmental Assessment Practitioners Association of South Africa Certified ISO 14001 Environmental Management System Auditor Registered as a Professional Natural Scientist, Member of the South African affiliate of the International Association for Impact Assessment Member of the Environmental Law Association of South Africa (ELA).
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Summary of the EAP’s past experience
Ms. Bekker is registered as a Professional Natural Scientist with the South African Council of Natural Science Professional Board and is also a Certified Environmental Assessment Practitioner (EAP) with the Interim Certification Body of Environmental Practitioner Association of South Africa (EPASA), a legal requirement stipulated by the National Environmental Management Act, 1998. She is further certified as an ISO 14001 Lead Auditor. Her qualifications include a BSc. Earth Sciences (Geology and Geography), BSc. Hons. Geography, and a MSc. Environmental Management. In addition to the tertiary qualifications, she obtained a Certificate in Project Management, and completed the Management Advance Programme at Wits Business School.
With more than 14 years' working experience in environmental management and the consulting industry and managing various Large Account Clients, she understands the South African Regulatory System, and can advise client with due diligence on their environmental regulatory requirements and offer a solution driven service to their project life cycle. She is equipped with exceptional project management and coordination skills, which especially enhances the service she offers clients within the environmental permitting system.
Her key focus is environmental management and compliance with extensive experience in the mining industry. Project Management and Coordination of projects form a critical component of her duties, which include project planning, initiation of projects, client, authority and stakeholder consultation, specialist coordination, budget control, process control, quality control and timeframe management. Her interest lies in a client advisory capacity, being involved during due diligence investigations, pre-project development and assist the client and engineering team in adding value to develop the project in and environmental sustainable manner, considering client costs and liabilities, as well as consider the implication of environmental authorisation conditions and requirements on project deliverables. Her involvement in projects has spanned over the project life cycle from Due Diligence Investigations, Pre-Feasibility Investigation’s, Prospecting Right Applications, Mining Right Applications, Environmental Reporting and implementation and auditing of Environmental Management Plans and Authorisations.
3.a.iii Details of the Applicant
Dwarsrivier Chrome Mine (Pty) Ltd (hereafter referred to as “Dwarsrivier”) is wholly owned by Assore Ltd.
According to information obtained from the official Dwarsrivier Web Page, the origin of the mine resulted as a result of neighbouring properties to the north and south of Dwarsrivier, which had existing chrome mining operations at the time of purchase in 1998. The owners of Dwarsrivier, therefore invested in a feasibility study for the Plant, old Tailings Storage Facility (hereafter referred to as the “old TSF”) and the mining of chrome. The designs for the opencast- and underground mines then commenced. Approval to proceed with the final design and construction of work was given in July 1999 (http://www.assmang.co.za/chrome.asp). The mine ceased opencast operations in 2006 and is currently operating as an underground (trackless, board and pillar operation) mine, producing chromite ore, with a Dense Medium Separation and Spiral Beneficiation Plant. Dwarsrivier currently produces approximately 200 000t of chromite ore per month.
The mine was previously owned by Assmang (Pty) Ltd with a 50% share. This results from the approval by the Department of Mineral Resources (DMR) of the Section 11 Transfer in terms of the Mineral and Petroleum Resources Development Act, 2002 (Act No. 28 of 2002) (MPRDA) of Dwarsrivier Mine from African Rainbow Minerals (ARM) to Assore. The change of ownership officially came into effect on 1 August 2016.
Physical address: The mine is situated 25km outside of Steelpoort on Portion 1 (Remaining Extent) and Portion 0 (Remaining Extent) of the farm Dwarsrivier 372 KT and Portion 4 (a Portion of Portion 3) of the Farm De Grootteboom 373 KT
Dwarsrivier Chrome Mine: Basic Assessment Report and Management Plan for the Expansion of the Met Grade Chrome Stockpile and Discard Dump with Ancillary Infrastructure Mining Right Ref: 30/5/1/3/2/1(179) EM Project Ref: 21714 Version: FINAL
8 MPRDA Approval for Three Plants LP30/5/1/3/2/1 (179)EM 11 January 2012
9 NEM:WA Waste Licence – Temporary General Waste Storage Facilities
12/4/10-A/1/GS3 29 March 2012
10 NEMA Construction of a Low-Level Bridge over the Groot Dwarsrivier
12/1/9/1-GS22 11 June 2012
11 NEMA Environmental Permission for Construction of a Bridge over the Springkaanspruit River
12/1/9/1-GS62 19 September 2013
12 NWA Water Use Licence – River Crossings 04/B41G/CI/2240 4 October 2013
13 NEMA Section 24G Rectification 12/1/9-7/S24G/7-GS1 26 August 2014
The activities relating to the expansion is covered under the Plant Infrastructure and Discard Dump as presented in the approved EMP, 2010 and the Discard Dump also in the WUL (see highlights above).
Refer to Annexure 3 for the list of relevant (highlighted in table) Authorisations.
3.b Location of the Activity
3.b.i Location of the Mine
Dwarsrivier is situated approximately 60km northwest of Lydenburg, 25km south of Steelpoort and 63km northeast of Roossenekal in the Limpopo Province. The mine currently holds the mining rights for Portion 1 (Remaining Extent) and Portion 0 (Remaining Extent) of the farm and surface rights for the said portions, as well as Portion 4 portion of Portion 3 of the farm de Grootteboom 373KT.
The operation is located in the Greater Tubatse Local Municipality, within the boundaries of the Sekhukhune District Municipality.
The R577 that connects to the R555 (Lydenburg-Roossenekal road), is situated to the north of the plant and mine offices. The overall area is characterised by intensive mining development. Various servitudes are present which traverse the site, which includes gravel roads, telephone lines, and electricity lines. Please refer to the following figures illustrating the location and cadastral setting of the mine.
Dwarsrivier falls in Quaternary catchment B41G and B41H in the Olifants Water Management Area (WMA) (WMA B4). The confluence of the Groot- and Klein Dwars Rivers is located on the north-western border of the property. All surface water draining from the properties ultimately flows into the Groot Dwars River and the Klein Dwars River, the confluence of which is located on the property. The Dwarsrivier flows northwards into the Steelpoort River. Dwarsrivier has an exemption (Reference Number 16/2/7/B400/C83/1) from the then Department of Water
1 Note, that the licence holder has not, and will not be commissioning the activity. The Environmental Authorisation has therefore not been
implemented on site. The License Holder is not in contravention to the Environmental Authorisation.
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Affairs (DWA), now the Department of Water and Sanitation (DWS), which allows the operation to undermine the Groot Dwars River.
Several of the neighbouring farms, Tweefontein 380 JT, Thorncliffe 374 KT, De Grooteboom 373 KT and Dwarsrivier 372 KT are owned by mining houses with existing and operational chrome and platinum mines. On the remainder of the neighbouring farms, agricultural activities take place, in the form of stock grazing and the production of vegetables, Lucerne and cotton.
Refer to the following two figures for the settling and surrounding landowners.
3.b.ii Ownership of Land
Dwarsrivier has been mining chromite ore from the LG6 seam since 1999. Between 1999 and 2005, ore was mined using opencast methods. The six (6) pits have subsequently been mined out and backfilled with the exception of the South and North Pit portals from which access is gained to the underground workings. The current mine plan extends the life of the operations to the year 2042.
Assmang bought the farm Dwarsrivier 372KT (Portions 1 and the Remaining Extent), including all surface and mineral rights, in October 1998 for R163 million. In 2002, the mine purchased a portion of the farm De Grootteboom 373KT, subdividing this portion into Portion 4 (a portion of Portion 3).
The mine currently holds the mining rights for Portion 1 (Remaining Extent) and Portion 0 (Remaining Extent) of the farm Dwarsrivier 372KT and surface rights for the said portions, as well as Portion 4 (portion of Portion 3) of the farm de Grootteboom 373KT.
The property details are presented in the following table:
Table 4: Landownership
Farm Name Portion Title Deed Number Property Size Ownership
Dwarsrivier 372KT RE of Portion 1 T129310/1998 489.1915ha Assmang Ltd
De Grootteboom 373 KT Portion 4 a Portion of Portion 3 T78889/2002 52,1993ha Assmang Ltd
A Section 11 transfer in terms of the Mineral and Petroleum Resources Development Act, 2002 (Act No. 28 of 2002) has been applied for whereby Assore takes over all administrative and technical services, as well as the sales and marketing function. This application has been successful and therefore Assore is now 100% owners of Dwarsrivier Mine in terms of the mining right. Surface rights are currently still being held by Assmang Ltd.
Refer to Figure 2 for the cadastral setting of the mine.
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Figure 1: Local and Regional Setting
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Figure 2: Cadastral Information
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3.b.iii Listed Activity Location and Size
The activities in question and a brief location description is presented in the following table:
Discard MRD Extension: The area required for the expansion of the Discard facility is approximately 16ha within the existing mining rights towards the north-west. Metallurgical Grade Product Stockpile (Met Grade Product Stockpile) Extension: This area will require an increase of approximately 0.7ha in a south-easterly direction. New Sewage Treatment Plant: This area will encompass and area of approximately 0.06ha, north of the proposed Met Grade Chrome Stockpile Extension. New TMM Workshop: This area will encompass and area of approximately 0.2ha towards the south east of the Met Grade Chrome Stockpile Extension. New Loadout Area: This area will be located around the east and southern perimeter of the Met Grade Chrome Stockpile Extension and will encompass and area of approximately 0.9ha Fences: No clearance required. Overall Site Clearance: Approximately 18ha (17.86ha)
Magisterial district: The mine falls within the Greater Tubatse Local Municipality, within the boundaries of the Sekhukhune District Municipality.
Distance and direction from nearest town Dwarsrivier mine is situated approximately 25km southwest of Steelpoort and 60km from Lydenburg on the border between Limpopo and Mpumalanga Provinces. The mine itself falls under the jurisdiction of the Limpopo Province.
21 digit Surveyor General Code for each farm portion
Applicable to authorization application: Farm Dwarsrivier 372KT RE of Portion 1 - T0KT00000000037200001 Farm Dwarsrivier 372KT Portion 1: T0KT00000000037200001 Title Deeds attached in Appendix 2.
Refer to Annexure 4 for the title deeds.
The following table presents the coordinates for each of the respective activities involved in this application:
Dwarsrivier Chrome Mine: Basic Assessment Report and Management Plan for the Expansion of the Met Grade Chrome Stockpile and Discard Dump with Ancillary Infrastructure Mining Right Ref: 30/5/1/3/2/1(179) EM Project Ref: 21714 Version: FINAL
Dwarsrivier Chrome Mine: Basic Assessment Report and Management Plan for the Expansion of the Met Grade Chrome Stockpile and Discard Dump with Ancillary Infrastructure Mining Right Ref: 30/5/1/3/2/1(179) EM Project Ref: 21714 Version: FINAL
The following figure presents the location of the listed activities within the approved mine surface rights.
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Figure 3: Location of Activities)
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3.d Description of the Scope of the Proposed Activity
It is the intention of the mine to initiate certain additional activities on site. These will include the expansion of the Discard Dump and the expansion of the Met Grade Product Stockpile area within the existing mining right area. The existing Discard area is included into the approved Environmental Management Programme (EMP) approved under the Mineral and Petroleum Resources Development Act, 2002 (Act No. 28 of 2002) (MPRDA) and also in the 2008 Water Use License (WUL). The Met Grade Product Stockpile is an existing facility on the southern border of the Dwarsrivier Plant area, which is approved under the mines 2010 EMP.
In addition to the two extension projects, the mine also plans to establish certain ancillary activities, which forms part of the optimisation of the mines footprint around the plant area.
3.d.i Metallurgical Grade Chrome Stockpile
The Met Grade Chrome is pumped from the Minerals Separation Plant (MSP) at the existing Plant area, to the stockpile in the form of a slurry. The product is "de-watered" at the discharge point to the stockpile using a dewatering cyclone.
Thereafter product is discharged onto the stockpile at a moisture content not exceeding 10%, with the overflow water from the cyclone being pumped back to the MSP using a recirculation pump.
The product is stored on the stockpile area and any residual moisture in the product is drained off the stockpile and collected in a recirculating drain and pumped back to the plant.
The product is then loaded via trucks for the various markets. As part of this project, it is the mines’ intention to establish a new load out facility on the perimeter of the stockpile to assist in optimising the logistics of transporting this material off site.
Currently the site is about 0.9ha, located on the southern perimeter of the Plant area. Due to the market requirements the need has arisen to further expand this area by 0.7ha, which will make the overall project act 1.6ha.
The site is currently and will continue to be bounded by a berm and a concrete trench which will lead to a silt trap, before any runoff water will report via a concrete trench to the down-gradient return water dam (Upper Return Water Dam).
The design of the facility is presented in the following table:
Table 7: Met Grade Chrome Stockpile Design
Centre Coordinate Footprint Size Height Specific Design Requirements
24°55'54.39"S
30° 7'6.29"E
Current: 0.9ha
Extension: 0.7ha
Overall: 1.6ha
20m The base will be 200mm thick concrete on a compacted terrace of 1500mm thick discard dump rock
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Photo 1: Met Grade Chrome stockpile
Please also refer to Annexure 5 for the proposed layout design of this facility.
3.d.ii Expansion of the Discard Dump
Three types of mineral residue are generated at Dwarsrivier Mine:
Waste rock – from mining of non-ore bearing sections, for access, vent shafts, etc. (this goes direct from the mining operation to the waste rock dumps on site);
Discard rock – reject rock from the plant, early in the plant process, that goes to the discard dump; and Tailings – fine reject from the plant in slurry form, at the end of the plant process.
The waste rock and discard rock are of the same rock types, namely:
Anorthosite; Pyroxenite; Chromite pyroxenite; and Gabbro.
Feed from the underground mining operations is fed to the plant Run of Mine (ROM) stockpile via a single overland conveyor. Separate feeder breakers underground and in the open pits reduce the ore to -300mm. The plant ROM stockpile has a two (2) day live capacities of 10 000t to enable weekend work if necessary and provide buffer capacity in the event of no feed from the mine.
Conveyer feed from the ROM stockpile is then subjected to a crushing and screening process, whereby the size of the material is reduced, such that it can either be suitably fed into either the cyclone or dense medium separators within the plant. Alternatively, the crushed and screened material will be conveyed to a mill feed stockpile, from where it will be subjected to milling, in order to further reduce particle size for entry into the plants spiral separation units.
Crushed and screened material that enters either the cyclone or dense medium separation units within the plant is then effectively separated into small chrome lumpy and conventional chrome lumpy, as well as discard. This separation process results, in both instances, in the development of discard rock, which is subsequently conveyed to a discard bin that is emptied to the site’s waste rock discard dump by a tractor drawn trailer as required.
The mine has an existing authorisation in terms of the MPRDA and the NWA for the existing Discard Dump and it
is therefore deemed a lawful facility. As part of the mines expanding underground mining operations (approved),
the need to increase the Discard Dump has become evident. The plant process and source of Discard will not
change. The project purely involves the expansion of the existing facility in terms of the existing design
philosophy.
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The current area is about 4.5ha and will be expanded by a further 16ha, rendering an overall area of 20.5ha within
the existing mining rights towards the north-west.
The design of the facility in this report is presented as the final footprint for closure, i.e. to allow for the shaping
of a 1:3 degree slope upon final rehabilitation. The following additional measures will be designed by a suitably
qualified engineer to manage clean and dirty water around the site:
1. The base of the site is prepared with a suitable base preparation layer as recommended by a registered Engineer to reduce the rate of infiltration to the underlying aquifers.
2. Development of a shallow trench around the facility to avoid the infiltration of upstream runoff and also the discharge of surface seep from the facility;
3. Development of berms around the facility to separate clean and dirty water; 4. Allowance for a sump within the dirty water catchment of the Discard Dump expansion to capture
shallow seep and runoff and pump this water back to the closed water circuit of the mine from where it will be treated through the water treatment plant and reused.
The expansion of the Discard Dump will require the relocation of Eskom owned, electricity lines (33kV) which
feeds from the existing Eskom substation located to the north –west of the existing Discard Dump. The mine has
initiated discussions with Eskom regarding the relocation of these lines.
Table 8: Discard Dump Design
Centre Coordinate Footprint Size Height Slope Capacity (m3) Specific Design Requirements
24°55'26.07"S
30° 6'50.44"E
Current: 4.5ha
Extension: 16ha
Overall: 20.5ha
45m 1:3 Current Volume: 660 000
Expansion Capacity: 816 673
Proposed Capacity: 1 472 322
The design will follow the current design and structure of the existing Discard Dump. Engineers have been appointed by the mine to assess the specific design specifications (i.e. in terms of footprint compaction, liners, etc.) This will be based on the final outcomes of the waste classification study and the associated numerical model. At this time it is not foreseen that the facility will be lined as per the existing Discard Dump Design. Compaction may however be undertaken. Clarification on this will be provided in the final Basic Assessment Report, due in October 2017.
It is currently foreseen that the site will be unlined, but designed with the necessary base preparation for a Type 4 waste, due to the following conclusion from leach tests conducted during 2009 on the Discard material (refer to Annexure 5):
The existing Discard Dump is not lined; The Discard material is classified as a Type 4 waste; The groundwater numerical model (2017) indicate that lining of the extension to the Discard Dump may
only have a limited effect on long-term contamination associated with the site, compared to the scenario if the area over which the Discard Dump will be extended is not lined. This is due to the fact that a liner will to not reduce the existing historical impact on groundwater quality that is already present in this
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area. The installation of a liner is however expected to reduce the area of the plume associated with the Discard Dump in the long-term. The model however indicates that lining the site would not reduce nitrate concentrations to below the concentrations specified in the exiting water use licence for the operations;
Aggregate tests for use in concrete (and pre-stressed concrete) revealed that the anorthosite, pyroxenite and chromite pyroxenite are all suitable for aggregate;
Values for chloride, sulphate/sulphide and soluble salts are all below any level of concern for the three above rock types;
The chromium content of the discard rock is high (>1%), but the chromium is in chromite, an inert oxide mineral – leaching and acid-base-accounting tests have confirmed that negligible chromium will move into groundwater or surface water;
Acid-base accounting indicates the discard rock is relatively inert and has low levels of potential acid generation or neutralising potential, but the neutralising potential exceeds the acid generating potential in all cases and in most cases is several times more;
In the long-term, neutral conditions are expected and these will preclude any significant quantities of metals from going into solution from the discard rock and therefore dissolved metal concentrations will remain low in surface and groundwater; and
Sulphides are present, but in extremely minor quantities and in highly competent, impermeable rock and hence sulphate concentrations in surface and groundwater will remain low.
Subsequent to the 2009 studies another round of analysis were conducted, based on the NEM: WA Waste Regulation 634. The results from this study indicated that the total Cu and Ni concentrations in the discard samples exceeded TCT0 (total concentration) levels. However, the leachable concentrations of all constituents (including Chromium, and Nitrates) were <LCT0 (leachable concentrations) levels (see information box below).
The photo below presents the current Discard Dump, with the arrow indicating the direction of expansion.
Wastes with any element or chemical substance concentration above LCT3 or TCT2 limits (LC>LCT3 or TC>TCT2) are Type 0 Wastes; Wastes with any element or chemical substance concentration above the LCT2 but below or equal to the LCT3 limits, or above the
TCT1 but below or equal to the TCT2 limits (LCT2<LC<LCT3 or TCT1<TC<TCT2), are Type 1 Wastes; Wastes with any element or chemical substance concentration above the LCT1 but below or equal to the LCT2 limits, and all
concentrations below or equal to the TCT1 limits (LCT1<LC<LCT2 or TC<TCT1), are Type 2 Wastes; Wastes with any element or chemical substance concentration above the LCT0 but below or equal to the LCT1 limits, and all
concentrations below or equal to the TCT1 limits (LCT0<LC<LCT1 or TC<TCT1), are Type 3 Wastes; or Wastes with all elements and chemical substance concentration levels for metal ions and inorganic anions below or equal to the
LCT0 and TCT0 limits (LC≤LCT0 and TC≤TCT0), and with all chemical substance concentration levels also below the relevant concentration limits for organics and pesticides, are Type 4 Wastes (no organics or pesticides are included in the waste rock material and therefore that requirement is not applicable);
If a particular chemical substance in a waste is not listed with corresponding LCT and TCT limits in the norms and standards, and the waste has been classified as hazardous in terms of regulation 4(2) of the Regulations based on the health or environmental hazard characteristics of the particular element or chemical substance, the waste is considered to be Type 1 Waste (not applicable to this study);
If the TC of an element or chemical substance is above the TCT2 limit, and the concentration cannot be reduced to below TCT2 limit, but the LC for the particular element or chemical substance is below the LCT3 limit, the waste is considered Type 1 Waste;
Wastes listed in item (2)(b) of Annexure 1 to the regulations are considered to be Type 1 Waste, unless assessed and determined otherwise in terms of the Norms and Standards;
Wastes with all element or chemical substances leachable concentration levels for metal ions and inorganic anions below or equal to the LCT0 limits are considered to be Type 3 Waste, irrespective of the total concentration of elements or chemical substances in the waste provided that: o The concentration levels are below the relevant limits for organics and pesticides; o The inherent waste and chemical character of the waste is stable and will not o change over time; and o The waste is disposed of to landfill without any other waste.
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Photo 2: Discard Dump
3.d.iii Ancillary Infrastructure
3.d.iii.1 Fences (not a NEMA listed activity)
The mine is also in the process of initiating a Water Use License Authorisation process for the three (3) fences present on site.
Two of these fences crosses unnamed tributaries of the Groot Dwarsrivier, whereas Fence 3 crosses the Groot Dwarsrivier.
The first two fences are security control fences, whereas the last fence, Fence 3, serve to keep animals from entering the site.
Photo 3: Fence 1: Upstream site situated on an unnamed tributary of the Groot-Dwars River at the point where the stream enters the Dwarsrivier complex
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Photo 4: Fence 2: A point further downstream on the unnamed tributary of the Groot-Dwars River at the point where the stream exits the Dwarsrivier complex
Photo 5: Fence 3: Located on the Groot-Dwars River at the point of the proposed fence crossing. Surrounding area is unimpacted at this point by surface mining activities.
Although the fences are not a NEMA listed activity, and requires no environmental authorisation, it is incorporated into the Basic Assessment Report and Management Programme to ensure that a management programme is available for ongoing maintenance.
3.d.iii.2 Sewage Treatment Facility
The satellite sewage treatment plant will comprise of a rotating biological contactor (RBC). This is essentially a fixed media biological treatment process, which utilizes a rotating shaft surrounded by plastic media discs. The micro-organisms (biomass) attaches to the media, which is approximately 50%, submerged in the wastewater. The rotation of the shaft exposes the biomass to the wastewater and then with the oxygen in the atmosphere.
The process includes the following consecutive process stages: (Please refer Figure 12 for the existing installation process flow diagram).
Step 1: Inlet screening
Although no inlet screen could be depicted at the location of the satellite sewage treatment plant, it is assumed that upstream screening of the raw sewage is done.
Step 2: Primary phase separation via septic tanks
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The septic tank (anaerobic zone) allows for an estimated 20 – 30% removal of organic material by settlement and anaerobic oxidation. The septic tank makes provision for the accumulation of this material and has design features typically incorporated to ensure that this activity does not cause unnecessary blockages across the tank. All septic tanks do require servicing and desludging at some stage since the rate of sludge accumulation exceeds the slow growth rate of the anaerobic bacteria and hence their capacity to break down organic material.
Step 3: Aerobic treatment via RBC
The settled sewage from the septic tank is then discharged under gravity to the RBC stage where further organic reduction and ammonia nitrification is achieved under aerobic conditions. RBC’s are fixed-bed reactors consisting of stacks of rotating disks mounted on a horizontal shaft.
The aerobic conditions are achieved by the rotation of the discs, on which the micro-organisms are attached and growing. The rotational speed is approximately 3 to 4 RPM. The discs are manufactured from a polyurethane based material and are 1.5 – 2 m diameter discs assembled onto a 60mm steel shaft. The discs typically are of a high density and impermeable, and tend to float in the RBC basin, reducing the load imposed on the shaft. The shaft rests and is secured to end bearings which is bolted down onto the sides of the RBC basin.
The energy requirement of rotor is estimated to be 0.75 kW. The rotor is estimated to contain 130 discs, providing the surface area on which the micro-organisms is attached. The photograph depicted in Figure 9 was taken during the site inspection and shows the rotors referred to in the text above.
Step 4: Secondary settlement
A secondary settling tank, or typically called the humus tank, treats the effluent from the RBC basin. It is required for the removal of suspended solids (humus) from the treated wastewater. The collected (settled) humus is typically returned to the septic tank for anaerobic digestion. This method is typically employed and effectively eliminates the need for sludge drying beds. It is unclear from the existing satellite sewage treatment plant whether the sludge underflow is returned to the septic tank.
Step 5: Disinfection
The clarified effluent is stored in the disinfection tank or channel. The purpose of the disinfection tank is to allow adequate residence time in which the pathogens can be effectively destroyed. Calcium hypochlorite (also known as HTH; Ca(OCl)2) chips is dosed into this tank and acts as the oxidizing agent.
Diagram 1: Process Flow of Sewage Package Plant
The table hereafter provides a concise summary of the plant:
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Table 9: Sewage Facility Design
Centre Coordinate Footprint Size Capacity
24°55'52.43"S
30° 7'7.63"E
0.06 120m3/week
3.d.iii.3 Load Out Area
A new load out facility is planned. The purpose of this facility will be used to park trucks during which period the material from the Met Grade Stockpile will be loaded for transport to the various markets.
The facility will entail the following:
A weighbridge Control room Parking for trucks.
The facility will be operated similar to the existing dispatch facility on site, with loading taking place by utilizing Front End Loaders (FELs) only. The road trucks once loaded will report to a new weighbridge area which includes a weighbridge for mass measurement. There will be a new control room, but local mass indication will be provided at the scale.
The area will be compacted, but not surfaced. The surface of the area will be sloped towards a spillage sump; with any excess water recycled back to the Plant or will report to the Upper Return Water Dam via concrete channels.
The table below provides a concise summary of the facility:
Table 10: Loadout Area Design
Centre Coordinate Footprint Size Footprint Design
24°55'56.85"S
30° 7'6.83"E
0.9 Compacted sloped surface to a spillage sump.
3.d.iii.4 Workshop
The mine intents to establish a new Trackless Mobile Machinery (TMM) Workshop. The purpose of the workshop will be to provide a dedicated area for the repair and maintenance of TMM machines that service the Beneficiation Plant.
Vehicles will also be parked in this area during off shift periods. The area will provide an impermeable surface as well as an oil separator to manage any potential hydrocarbon spills.
The TMM workshop is critical to improve the maintenance and management of the TMM vehicles in the area and will reduce the travelling distance as TMM machines currently need to be serviced at the South Shaft TMM area.
The facility will comprise of the following:
Concrete Surface Roof Structure Collection sump Oil separator Wash bay Chemical store Office area Vehicle parking area
No additional bulk diesel storage will be required in this area.
This facility will be self-contained with berms and sumps to contain any possible spills the area.
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Table 11: Workshop Facility Design
Centre Coordinate Footprint Size Footprint Design
24°55'56.85"S
30° 7'6.83"E
0.9 Concrete surface, with a slope towards a central sump.
3.d.iv Listed and Specified Activities
National Environmental Management Act, 1998 (NEMA)
In terms of the NEMA, there are three listing notices which should be considered for this application. These listing notices were amended during April 2017. Listing Notice 1 and/or Listing Notice 2 and/or Listing Notice 3 of Regulation 982 (known as the 2014 EIA Regulations). Listing Notice 1 (Regulation 327) activities requires a Basic Assessment Process, whereas, Listing Notice 2 (Regulation 325) activities requires a full EIA Process; Listing Notice 3 (Regulation 324 of 2017) requires a Basic Assessment Process if the area falls within certain geographic zones. The area is located in a Critical Biodiversity Area, and therefore Notice 3 is applicable when considering activities planned on site.
Considering the above, the following listed activities may be triggered:
NEMA Government Notice 327, Listing Notice 1:
Activity 27: The clearance of an area of 1 hectares or more, but less than 20 hectares of indigenous vegetation, except where such clearance of indigenous vegetation is required;
Activity 34: The expansion of existing facilities or infrastructure for any process or activity where such expansion will result in the need for a permit or licence or an amended permit or licence in terms of national or provincial legislation governing the release of emissions, effluent or pollution, excluding— (i) where the facility, infrastructure, process or activity is included in the list of waste management activities published in terms of section 19 of the National Environmental Management: Waste Act, 2008 (Act No. 59 of 2008) in which case the National Environmental Management: Waste Act, 2008 applies.
NEMA Government Notice 324, Listing Notice 3:
Activity 12: The clearance of an area of 300 square metres or more of indigenous vegetation except where such clearance of indigenous vegetation is required for maintenance purposes undertaken in accordance with a maintenance management plan.
National Heritage Resources Act, 1999 (NHRA)
According to Regulation 38 of the National Heritage Resources Act, 1999, any development or other activity which will change the character of a site exceeding 5 000 m2 in extent requires notification to the South African Heritage Resources Agency. Due to the fact that the site has been subjected to heritage studies, heritage studies are currently not foreseen.
National Environmental Management: Waste Act, 2008 (NEMWA)
Considering the NEM: WA, the Regulation 921, dated 29 November 2013 and as amended makes provision for lists of waste management activities that have, or are likely to have a detrimental effect on the environment. The amendments of the list of waste management activities dated 24 July 2015 makes provision for the inclusion of Residue Stockpiles or Deposits.
Category A, activity 13 states: “The expansion of a waste management (Lawful activity in terms of the EMP, 2010) activity listed in Category A or B or this Schedule which does not trigger an additional waste management activity in terms of this Schedule.
National Water Act, 1998
Chapter 4 of the NWA specifically addresses the use of water and is a tool for an authority to ensure the implementation of the principle that National Government has overall responsibility over water resource management, including the equitable allocation and beneficial use of water in the public interest, a person can only be entitled to use water if the use is permissible under the Act. In general a water use must be licensed
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unless it is listed in Schedule I, is an existing lawful use, is permissible under a general authorization, or if a responsible authority waives the need for a license. Section 21 of the NWA identifies eleven (11) consumptive and non-consumptive water uses which must be authorized.
The activities associated with this project should not trigger any WULs, due to the following:
The extension of the Discard MRD will result in amendments to the approved Section 21(g) approved facility in the 2008 WUL, which will subsequently be updated.
Product Stockpiles have in the past not been authorised in the Dwarsrivier WUL, it is therefore assumed that the Met Grade Product Stockpile will not require approval as a Section 21g water use
A General Authorisation, Government Notice 509 of 2016 has been published in terms of Section 21(c) and (i) water uses. This Regulation states that any landowner may erect fences provided that the fence will not in any way impede or divert flow or affect resource quality in the short, medium or long term. The fences on site, crossing watercourses will be included into the Water Use License (WUL) amendment.
Please refer to Annexure 3 for a copy of the WUL.
Please refer to the table overleaf for the details in terms of the listed activities.
3.d.v Description of the Activities to be undertaken
The activities that will form part of the proposed project will include the following:
Planning Phase: o Ensure the implementation of Legal Requirements (Environmental Permits) o Development of test pits to monitor shallow water seep with the aim of understanding the
pollution sources in the area o Geophysical and Geotechnical investigations to ensure that the stability factors and
groundwater flow source paths are understood Construction Phase:
o Land and Footprint Clearance; o Topsoil Stripping and Stockpiling; o Establishment of Surface Infrastructure o Waste Management
Operational Phase: o Operation of Discard Dump and Met Grade Product Stockpile o Transportation (Load out area, roads) o Operation of Workshop and Sewage Plant o Waste Management
Closure Phase: o Ensure the implementation of Legal Requirements (Environmental Permits) o Rehabilitation of Waste Rock Dumps o Dismantling and decommissioning of infrastructure and buildings, including product stockpiles o Earth Moving, shaping and ripping of ground o Cessation of Labour Contracts o Waste Management.
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Table 12: Listed Activities
Name of Activity Aerial extent (ha) Listed Activity Applicable Listing Notice Waste Management Authorization
Discard Dump Expansion
The mine has an existing authorization in terms of the MPRDA and the
NWA for the Discard Dump and it is therefore deemed a lawful facility.
However, the facility has reached its approved footprint area and
needs to be expanded. The area required for the expansion of the
Discard facility is approximately 16ha on existing mining rights.
The expansion of the discard site will require a Waste License. The
expansion of the Discard Dump will fall under NEM: WA (Category A,
Activity 13) as a new facility is not required, merely the expansion of
an existing approved facility.
Current: 4.5ha
Extension: 16ha
Overall final footprint: 20.5ha
- - NEM:WA: (Waste activities):
Category A, Activity 13:
“The expansion of a waste
management activity listed in
Category A or B or this Schedule
which does not trigger an additional
waste management activity in terms
of this Schedule.
Update of the approved WUL will be
required to change the capacity of
the Discard Dump approved.
The changes to the Discard MRD will require amendments to the
approved 2008 WUL, but as a Waste License is triggered Activity 34 of
Listing 1 will not be triggered.
N/A GN327, Listing 1, Activity 34: The
expansion of existing facilities or
infrastructure for any process or activity
where such expansion will result in the
need for a permit or license or an
amended permit or license in terms of
national or provincial legislation governing
the release of emissions, effluent or
pollution, excluding— (i) where the
facility, infrastructure, process or activity
is included in the list of waste
management activities published in terms
of section 19 of the National
Environmental Management: Waste Act,
2008 (Act No. 59 of 2008) in which case the
National Environmental Management:
Waste Act, 2008 applies.
Clearance of the footprint of the Discard dump is located in a Critical
Biodiversity Area according to the Limpopo Conservation Plan, 2012
(refer to Section 3.i.ix.1.f).
GN324, Listing 3, Activity 13
The clearance of an area of 300 square metres or more of indigenous vegetation except where such clearance of
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Name of Activity Aerial extent (ha) Listed Activity Applicable Listing Notice Waste Management Authorization
GN327, Listing 1, Activity 27
indigenous vegetation is required for maintenance purposes undertaken in accordance with a maintenance management plan The clearance of an area of 1 hectares or
more, but less than 20 hectares of
indigenous vegetation, except where such
clearance of indigenous vegetation is
required;
Metallurgical Grade Plant Stockpile Expansion
The Metallurgical Grade Plant Stockpile is an existing product
stockpile from where product will be loaded for the various markets.
This is an existing facility on the southern perimeter of the site, which
is now required to be expanded.
Current: 0.9ha
Extension: 0.7ha
Overall: 1.6ha
GN324, Listing 3, Activity 13
The clearance of an area of 300 square metres or more of indigenous vegetation except where such clearance of indigenous vegetation is required for maintenance purposes undertaken in accordance with a maintenance management plan
N/A
Sewage Treatment Plant
Sewage Treatment Plant will be a package plant with a throughput of
120m3/week.
0.06 N/A GN327, Listing 1, Activity 27: The development and related operation of facilities or infrastructure for the treatment of effluent, wastewater or sewage with a daily throughput capacity of more than 2 000 cubic metres but less than 15 000 cubic metres.
No dry beds will be established as
part of the facility – No Waste
Management Authorization
Required.
No dry beds will be established,
process will be internally circulated
– No Water Use License Required.
Roads
Existing roads will be utilized in and around this project area. None, if required
these will be
limited, and only
for access – no
N/A GN327, Listing 1, Activity 24: The development of a road— (i) [a road] for which an environmental authorisation was obtained for the route
N/A
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Name of Activity Aerial extent (ha) Listed Activity Applicable Listing Notice Waste Management Authorization
listed activity
trigger.
determination in terms of activity 5 in Government Notice 387 of 2006 or activity 18 in Government Notice 545 of 2010; or (ii) [a road] with a reserve wider than 13,5 meters, or where no reserve exists where the road is wider than 8 metres; but excluding a road— (a) [roads] which [are] is identified and included in activity 27 in Listing Notice 2 of 2014; (b) [roads] where the entire road falls within an urban area; or (c) which is 1 kilometre or shorter.
Fences
Three fences crosses watercourses on site. Max of 30m2
combined over
watercourse
N/A GN327, Listing 1, Activity 12: The development of— dams or weirs, where the dam or weir, including infrastructure and water surface area, exceeds 100 square metres; or infrastructure or structures with a physical footprint of 100 square metres or more; where such development occurs— (a) within a watercourse; (b) in front of a development setback; or (c) if no development setback exists, within 32 metres of a watercourse, measured from the edge of a watercourse.
N/A
Workshop
Establishment of a new workshop. 0.2 N/A - N/A
Loadout facility
Establishment of a Loadout Facility at the Met Grade Stockpile area. 0.7ha GN324, Listing 3, Activity 13
The clearance of an area of 300 square metres or more of indigenous vegetation except where such clearance of indigenous vegetation is required for maintenance purposes undertaken in
N/A
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Name of Activity Aerial extent (ha) Listed Activity Applicable Listing Notice Waste Management Authorization
accordance with a maintenance management plan
Overall Site Clearance (cumulative removal of indigenous vegetation)
Overall clearance:
Discard dump Extension;
Met Grade Stockpile Extension;
Workshop;
Loadout;
Sewage Treatment Plant.
18ha GN327, Listing 1, Activity 27
GN324, Listing 3, Activity 13
The clearance of an area of 1 hectares or more, but less than 20 hectares of indigenous vegetation, except where such clearance of indigenous vegetation is required. The clearance of an area of 300 square metres or more of indigenous vegetation except where such clearance of indigenous vegetation is required for maintenance purposes undertaken in accordance with a maintenance management plan
N/A
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3.e Policy and Legislative Context
Table 13: Policy and Legislative Context
Applicable Legislation And Guidelines Used To Compile
The Report
Reference Where Applied
How Does This Development Comply With And Respond To The Legislation And Policy Context
Specific Environmental Management Acts (SEMAs)
National Department of Agricultures, Forestry and Fishery
Relevant for tree removals within the CBA area.
The operation has an approved License to authorise actions and activities affecting the Protected Trees (Ref: LP-SDM-2017-06-06-B). The Permit is valid up until 26 June 2018. (Refer to Annexure 6)
National Heritage Resources Act, 1999
Potential presence of heritage sites during construction and excavation studies.
A heritage assessment and paleontological was undertaken as part of the initial EMPs conducted for the mine. No sites of heritage value was identified in this area.
National Water Act, 1998 Establishment of facilities containing waste or water continuing waste.
A Water Use License is currently being updated, the changes in the approved facilities will be incorporated into this process.
Na t io nal Leg is la t ion
National Environmental Management Act, 1998
This Basic Assessment Report & EMP
The BAR Application fee of R3000 was paid to the DMR on 19 July 2017. An Application for Environmental Authorisation was couriered to the DMR on 21 July 2017.
The DMR acknowledged the application on 23 August 2017. (Refer to Annexure 1)
Mineral and Petroleum Resources Development Act, 2002
Existing Right The project does not entail any additional authorisation for mining rights in terms of the MPRDA. The surface infrastructure will be located within the approved mining area with Dwarsrivier Chrome Mine as the surface owners. No changes to the Mining Works Programme is required
Munic ipa l P lans
Integrated Development Plan (IDP) (Draft 2015/2016)
Economic Development
The IDP states a number of mission statements, which includes:
Accountable through active community participation Economic enhancement to fight poverty and
unemployment Render accessible, sustainable and affordable service Municipal transformation and institutional
development Sustainable livelihoods through environmental
management
The IDP further states that although there are several mines in
the area, the existing resources remain unexploited. Investment in this sector is important as it brings with it investment in infrastructure, results in creation of job opportunities and generates many other economic spin-offs. The lack of economic growth in the region warrants special attention and support to optimize the available opportunities. However, cognizance should be taken of the outflow of money from the mines in Greater Tubatse to other regions
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3.f Need and Desirability of the Proposed Activities
Currently Dwarsrivier is serviced by 1200 permanent and 800 contractor employees. The majority of the employees are locals drawn from Lydenburg and villages around DWR, including Steelpoort Park, Kalkfontein and Buffelshook. The aim of the proposed activities is to improve the logistics on site, ensure suitable supply of chrome for markets, as well as to ensure a suitable waste rock disposal strategy, whilst a long-term strategy is investigated:
The mine has an approved footprint for the Discard Dump. The capacity of this footprint is not suitable to maintain the underground mining operations waste volume production. The capacity of the footprint is being reached and the footprint has to be expanded. According to the production department, the expanded facility can provide a much longer timespan if the angle of the Discard Dump is designed at 35degrees (approximately 24 years), however to design and operate the facility at a 1:3 slope for closure a life of facility of approximately 10 years will be available. It should be noted, that for the long terms, an additional facility may still be required. The purpose of the Discard Dump expansion is therefore to provide the mine with an additional 10 years of life, during which time a detailed investigations will be undertaken to determine a suitable site for a long term Discard Dump facility.
According to an article by S&P Global Plats, 6 March 2017 (https://www.platts.com/latest-news/metals/tokyo/strong-chrome-demand-to-hold-but-views-divided-26678512), “strong demand for chromite feedstock of ferrochrome will continue to hold on the back of robust Chinese stainless steel output, but views are divided on whether global supply will move into deficit due to constraints of South African production to meet that demand, industry sources told S&P Global Platts Monday”. According to the article, “sources said there are two possible scenarios arising from South Africa trying to meet Chinese demand amid stagnated output: the market will be short on chrome ore supply as other global suppliers will not be able to fully meet China's demand; or China will reduce dependency on South African chromite supply and diversify to other resources.” According to the Mining Weekly Online (http://m.miningweekly.com/article/strong-outlook-for-recovering-ferrochrome-industry-merafe-2017-03-08/rep_id:3861): “The Chinese economy, on which the ferrochrome and chrome ore markets are heavily dependent, grew by 6.7% year-on-year, underpinning pleasing growth in stainless steel production. Ferrochrome-using stainless steel production is projected to grow by 3.5% in 2017 and by 3.8% in 2018, which should be followed by increased ferrochrome demand.” The Met Grade Plant Stockpile and load out facility allow the mine to sell additional grades to the market. The market demand has increased and therefore a greater size stockpile is required to meet the supply requirements.
The ancillary infrastructure (sewage treatment plant and workshops) are required to fulfil the operational requirements of the mine. The location of these facilities in proximately to the plant will assist in the operational logistics. The TMM workshop in specific will assist the mine to improve maintenance of the machines and thereby reduce breakdowns and related hydrocarbon spillages. It will also ensure that the machines are maintained in a sound state, reducing emissions and vibration noise generated by the machines during operation. The location of the workshop will further reduce travelling distances currently experience on site, with vehicles having to be maintained and services at the South Shaft TMM Workshop.
3.g Motivation for the Overall Preferred Site, Activities and Technology Alternative
The only alternative relevant to this project will be the location of the sites, as the project involves the expansion of existing facilities on site.
In terms of project alternatives, the following should be considered:
The capacity of the existing facilities has been reached on site. The ancillary infrastructure will be placed at the closest available open space located near the Plant area, for this reason no alternatives were investigated.
The Met Grade Plant Stockpile is an existing facility and therefore the expansion of the facility is based on available space around the existing site. For this reason no alternatives are available for the stockpile or the load out facility.
In terms of the Discard Dump certain considerations were made in terms of the location of the facility which included backfilling, expansion to the existing area, and a new disposal area. To address the current needs of the applicant and to ensure a sound level of compliance, the best alternative is to utilise
Dwarsrivier Chrome Mine: Basic Assessment Report and Management Plan for the Expansion of the Met Grade Chrome Stockpile and Discard Dump with Ancillary Infrastructure Mining Right Ref: 30/5/1/3/2/1(179) EM Project Ref: 21714 Version: FINAL
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the existing area of the Discard Dump and extent this facility in the interim, whilst a suitable long term alternative is found (please refer to Section 3h for a detailed discussion). In the interim the applicant will continue with their investigations for the most effective and practical manner in which to implement the waste management hierarchy, with the aim to reduce waste (optimise mining practices), or reuse the waste (assess avenues to use the discard as aggregate or alternative uses). Please refer to the following section for the discussion on these options.
3.h Full Description of the Process followed to reach the proposed Preferred Alternative within the site
3.h.i Details of the Development Footprint Alternatives Considered
Please refer to the earlier section (3.f) presenting the discussion on the alternatives. The only alternative considered was that of the Discard Dump. It should be noted that the expansion to the facility is considered a medium term measure, whilst a long term final disposal area to cater for the required capacity is sourced.
In terms of the Discard Dump certain considerations were made: o The current Discard Dump has reached its capacity. The options the applicant have is either to
backfill discard into old pits, extend the existing footprint or develop a new facility: o The opencast pits present on site has been backfilled in terms of the EMP and the only voids
available are those of the underground adit accesses, therefore no further backfilling is possible; o The applicant would prefer to optimally utilise existing and available land in close proximity to
the approved facilities. Surface area is available around the existing Discard Dump, the size available is however constraints between the access road to Two Rivers on the west, the Sekhukhune Regional Road on the east, and various Mine and Eskom Powerlines on the North and East. For this reason an areas of 17ha has been allocated for the current expansion.
o The current expansion of 13ha could provide a life of facility of approximately 24 years with a slope angle of 35% (angle of repose). However, the mine is committed to design and operate the facility with closure in mine, and for that reason is committed to a 1:3 slope, which reduces the available capacity, in terms of the available footprint to approximately 10 years.
o The current expansion of the Discard Dump is therefore regarded as a medium term solution to a present capacity constraint. During the following four (10) years, the operation will enter into a detailed site selection process during which time a suitable site for a new long term Discard Dump will be assessed.
o The applicant will continue with their investigations for the most effective and practical manner in which to implement the waste management hierarchy, with the aim to reduce waste (optimise mining practices), or reuse the waste (assess avenues to use the discard as aggregate or alternative uses).
o The current preferred alternative is therefore to utilise the existing surface area around the existing Discard Dump, whilst the operation investigate the preferred location for a long term site in terms of specific environmental studies and impact assessments.
Should the project not be approved (No Go Option) the following implications may arise:
As mentioned before (Section 3f) the demand for chrome has increased globally due to the increase in China Markets. No allowing the expansion of the Met Grade Plant Stockpile will result in a restriction on the volume of this material to be produced. This will result in restricting the mine to market supply available reserves, and could impact on the economics of scale of the mining operation. The load out facility is an ancillary infrastructure to this product stockpile and is required to allow for the movement of the product off site. Not allowing this facility will restrict the logistics of supply to the various markets.
The Discard Dump is a key component to the mining operation, with all Discard from the Plant deposited on this site. The capacity of the Discard Dump is fast reaching its capacity and for this reason additional capacity is required. The Discard Dump extension will provide approximately four (10) years of life of facility, however, by not allowing this extension the opportunity to assess a new site in terms of detailed specialist studies are lost, as the requirement for capacity is immediate.
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Saying the above, specialist studies have been undertaken on both the expansion sites, and no areas of concern have been raised. Although the site is located in a CBA, the mine has already received the required tree removal permits to relocate and remove sensitive tree species.
3.i Details of the Public Participation Process Followed
The Comments and Responses Report (C&RR) includes the comments received during the Public Participation Process undertaken to date. The Comments and Responses Section has the following objectives:
1. To provide a formal and integrated record of all the issues raised by Interested and Affected Parties (I&APs) to date and the responses provided by the EIA Study Team.
2. To provide a mechanism that allows all parties participating in the process (including the environmental authorities) to verify whether the issues raised have been considered and where appropriate, adequately addressed by the EIA Study Team.
Issues have been raised and recorded through a variety of mechanisms. These include:
Comments sheets received by fax, and/or e-mail; Comments sent to the public participation office via e-mails; Comments received telephonically; and Comments received during the announcement phase when adjacent landowners were visited.
The PPP during the Basic Assessment Application of the project consisted of the following activities:
Consultation with regulatory authorities and municipal authorities;
Consultation with surrounding landowners;
The identification and engagement with the general public;
Placement of notifications and advertisements in local newspapers;
Placement of posters and notifications on site and in close proximity to the site;
The PPP will be an ongoing activity and will only be concluded once the authorisation for the water use licence has been issued. All I&APs will be informed as to the final decision taken by the Department.
3.i.i Stakeholder Identification
The current Stakeholder Database on the mine was utilised as a basis for the development of the consultation register for this project. In addition, relevant government departments, municipalities and affected ward councillors were contacted to inform them of the proposed project and to obtain their issues and comments in this regard. The following stakeholders were consulted as part of the project:
DWS; DMR; LDEDET; Local Municipality; Districts Municipality; Ward Councillor; Surrounding Landowners; and Other Identified Stakeholders.
Please refer to Annexure 8 for the list of stakeholders consulted.
3.i.ii Stakeholder Identification and Notification
Notification of I&APs commenced on 07 July 2017. The notification process was undertaken by means of the
following:
Newspaper advertisements;
Site Notices;
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Direct Notifications through a Background Information Document.
Please refer to Annexure 8 for copies of these notifications. Proof of email submissions can be requested from the EAP.
3.i.iii Site Notices
In order to inform surrounding communities and adjacent landowners of the proposed project, five (5) site notices were erected on site (on 4-7 July 2017) and at visible locations close to the site.
Site Notices were place at the following locations:
Discard Dump Entrance from the Richmond Road; Mine Main Entrance; North Mine Entrance; and Plant Entrance.
Main Entrance Entrance to Discard Dump from Richmond Road
North Mine Entrance Plant Entrance
3.i.iv Background Information Documents
Background Information Documents were distributed via email to all parties on the database on 7 July 2017. Please refer to Annexure 8 for a copy of this document.
3.i.v Advertisements
The formal announcement of the proposed project was done by placing an advert in the Steelburger News on 07 July 2017 to invite all I&APs to register on the project database. The objective of this newspaper advertisement was to:
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Inform I&APs of the proposed project; Inform I&APs of the Environmental Impact Assessment procedure and the way in which I&APs could
lodge any objections to the proposed development and provide comments; and Invite I&APs to become involved in the proposed project by registering as I&APs.
Please refer to Annexure 8 for a copy of these adverts.
3.i.vi Document Review
All registered stakeholders were informed of the availability of the draft BAR on 11 September 2017 for the opportunity to review this document. A second notification was submitted to registered stakeholders via email as a reminder of the commenting period on 2 October 2017. The commenting period ended on 11 October 2017. No comments outside of those presented in the draft reports were received.
3.i.vii Summary of Issues raised by the I&APs
To date the following comments have been received.
Table 14: Stakeholder Comments received
NO. THEME: GENERAL COMMENTS / ISSUES
ISSUE RAISED DATE AND HOW ISSUE WAS
RAISED
COMMENTATOR RESPONSE
1.1 We acknowledge receipt. Please
register the following entities as
interested and affected parties.
De Groote Pomp (Pty) Ltd. (owner
of portion 8 of De Grooteboom 373
KT), an immediate neighbour.
DGB Joint Venture (operator of the
chrome mine on portion 7 of De
Grooteboom 373 KT
Junobix (Pty) Ltd., owner to be of
portion 10 of De Grooteboom
373KT
24 August 2017 via e-mail Mr Henk Moen: Adjacent
Property Owner Farm De
Grootboom 373KT (Portion 3)
and Farm Thornciffe 374KT
(Portion 3)
The mentioned parties were registered
on the project database and will be kept
informed as to when the draft report
becomes available.
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3.i.ix The Environmental Attributes associated with the Alternatives
As no significant changes in the location of infrastructure have been undertaken, the environmental attributes associated with the current site location is presented.
3.i.ix.1 Baseline Information
3.i.ix.1.a Climate
3.i.ix.1.a.1 Temperature
The Mine is situated in the Highveld Climate Region of South Africa. The annual rainfall is approximately 721mm per annum, mostly in the form of intense thunderstorms during the months of October to April. The average daily maximum temperature for summer (January) is 27 degrees Celsius (°C) and for winter 17°C. The average daily minimum temperatures vary between 13°C in January and 0°C in July.
3.i.ix.1.a.2 Rainfall and Evaporation
Mean Annual Precipitation (MAP) is representative of the average rainfall that occurs over an area during any given year. This rainfall is obtained by taking the total rainfall received over time at a specific point including any extreme periods and/or events and averaging it. The site MAP was obtained from the DRUP (Smithers & Shultze 2002) and is estimated at 601 mm. The data set that is used to represent this MAP is obtained from the WR2005 database (WRC, 2008). The graph below describes total annual rainfall received over an 85 year record period over quaternary catchment area B41G which the site area falls in.
Graph 1: Total Annual Rainfall
Average normal annual rainfall is representative of the average rainfall that is expected over an area during a normal rainfall year. This rainfall is expected to occur at least 50% of the time (most of the time). This rainfall is not likely to occur during years where extreme rainfall periods or events take place (extreme rainfall events that are rare and not so common like El Nino, or La Nina, or many high intensity storm events). This rainfall is obtained by looking at the statistical distribution of rainfall over time of a specific area. WR2005 (WRC, 2008) data for quaternary catchment area B41G (as in the case of MAP analyses) is used for this analyses.
Average monthly wet and dry rainfall periods are representative of rainfall that is expected to occur only during above and below normal rainfall conditions respectively. These values are derived statically and are represented by different percentile values of a specific rainfall data set taken over time. Average monthly wet and dry rainfall periods are expected when rainfall figures are at 30% and 70% respectively of the total rainfall (i.e. 20% above or
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below normal average of 50%). WR2005 (WRC, 2008) data for quaternary catchment area B41G (as in the case of MAP and average normal annual analyses) is used for this analyses.
The graph below shows the average monthly wet and dry rainfall periods together with the normal average (50%) rainfall period as a reference.
Graph 2: Average Monthly Rainfall Distribution
Storm rainfall is critical in the estimation of peak flows. Peak flows are then used for flood line and SWM analyses. The table below summarizes all the different rainfall figures that hydrological study derived for the site area.
Table 15: Rainfall Summary
Type of Rainfall Amount (mm)
MAP 618
Average Normal Annual 590
Average Wet Monthly 61
Average Dry Monthly 38
24 hour 1:50 151.6
24 hour 1:100 171.8
3.i.ix.1.a.3 Evaporation
As in the case of rainfall and runoff it is also necessary to analyses evaporation over the following periods:
Mean Annual Evaporation (MAE); Average annual normal evaporation; and Average monthly wet and dry evaporation.
The graph below indicates the average monthly evaporation data for quaternary catchment area B41G that is used in the analyses.
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Graph 3: Average Monthly Evaporation
Because limited data is available only very basic statistics are performed on the data in order to obtain required figures. Percentage values of 50%, 40%, and 60% of the MAE respectively are assumed and adopted for normal, wet, and dry averages.
The table below summarizes all the different evaporation figures that SWS derived for the site area.
Table 16: Evaporation Summary
Type of Rainfall Amount (mm)
Mean Annual Evaporation 1677
Average Normal Annual 839
Average Wet Monthly 56
Average Dry Monthly 84
The MAP is less than the MAE and therefore the site is classified as a water deficit site (B). Due to the high evaporation there should not be significant leachate generation on account of the climate. The climatic water balances were taken into consideration for all designs associated with the current TSF.
3.i.ix.1.a.4 Wind
Wind can play an important factor in the potential distribution of fugitive dust resulting from the sites. The mine is situated in the Dwarsrivier valley. This factor gives rise to winds that are variable in terms of both speed and direction. Wind is mostly light. The wind rose (presented in the figure hereafter) of the closest weather station recording wind is Lydenburg (W0554816). According to this information the dominant winds are south-easterly and north-westerly winds.
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Graph 4: Wind data.
3.i.ix.1.a.5 Extreme Weather Conditions
The incidents of extreme weather conditions for this area are included in the following table.
Table 17: Extreme Weather Conditions.
# of Days With
Jan Feb March Apr May Jun Jul Aug Sep Oct Nov Dec Days Per Yr.
The farm Dwarsrivier, on which the mine is located, is traversed by the Dwars River and the Klein Dwars River. The confluence of these rivers is also located on the property. The eastern portion of the property, where the chrome reserves outcrop, generally slopes in a westerly to south westerly direction, towards the Dwars River. Adjacent to the river, slopes are gentle, in the order of 3°. Further upslope from the river, slope angles increase to as much as 40°.
However, the slopes are not always gradual with frequent small to relatively large koppies or hills formed from more resistant materials. Elevations on the farm Dwarsrivier vary from 900 – 1,200 m. The area generally drains in a northerly direction, via the Dwars and Klein Dwars Rivers. There are, however, a number of small westerly flowing, non-perennial tributaries of the Dwars River in the vicinity of the old open cast sections. There is approximately 40m elevation change across the mine site, with elevations between 940 – 975 metres above mean sea level (mamsl). Refer to the following figure for the topography of the area.
The area associated with the Discard Dump is characterised by an overall decreasing slope towards the north, as well as the west – i.e. in the direction of the Dwarsrivier. Please to the following two figures.
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Figure 4: Discard Dump Slope from East to West
Figure 5: Discard Dump Slope from East to West
Based on the figures below it is evident that the site slopes from south to north and east to west in a decreasing slope. The site is however located on an already established plant site, which has altered the topography significantly.
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Figure 6: Met Grade Stockpile and Ancillary Infrastructure Slope from North to East
Figure 7: Met Grade Stockpile and Ancillary Infrastructure Slope from South to West
3.i.ix.1.c Geology
Dwarsrivier Mine is situated in the eastern limb of the 2052 Ma (million year old) Bushveld Igneous Complex, the world’s largest layered intrusion, comprising the emplacement of at least 7 x 105 cubic kilometres (km3) of magma into the sediments of the Transvaal Supergroup. The chrome ore deposits form part of the Critical Zone of the Bushveld Complex. The chrome horizon that gets mined is referred to as the LG 6 (Lower Group 6) horizon. The chrome layer is overlain by anorthosite and pyroxinite. The layers have a regional dip of 13 degrees west in this area, towards the centre of the Bushveld Igneous Complex. However, local variations in dip are common.
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The Dwarsrivier ore body represents an open-ended structural synform, with a north-south orientated axis that plunges gently to the south. The mine is situated on the eastern limb of this synform. The geology overlying the chromite generally comprises pyroxenite and anorthosite.
3.i.ix.1.d Soils
3.i.ix.1.d.1 General Description
The soils of the area were mapped using standard procedures. A 1:500 scale contour plan of the area together with 1: 10 000 scale aerial photographs were used to provide an overview of the area as well as forming the base map for the detailed soil survey (Figure 9). The field work was undertaken during the TSF North EMP study (2013) comprised traversing of the areas on a staggered grid with a grid spacing of approximately 200 - 300 m, using a conventional 1.25m bucket auger to investigate and log the soil profiles. A limited number of soil samples were also taken to aid in the classification of the soils and to determine the nutrient status of the soils. The identification and classification of soils was carried out in terms of the Soil Classification, “A Taxonomic System for South Africa” (MacVicar et al, 1991 edition).
This is a relatively simple system that has two levels of classification, an upper, fairly general level comprising Soil Forms and a lower, more specific level comprising Soil Families. Each of the Soil Forms in the classification is defined by a specific, unique vertical sequence of diagnostic horizons. All forms are further divided into two or more Families, which have the same vertical sequence of diagnostic horizons, but are differentiated within the Form on the basis of certain physical and/or chemical properties.
The soil forms that were identified in the area are predominantly a close association of the Glenrosa and Mispah Form soils together with scattered rock outcrop. Within these soils there are also small pockets of Hutton Form soils. On the lower, gentler slopes adjacent to the rivers and streams traversing the site, soils identified include those of the Hutton, Clovelly and Augrabies Forms. The soils immediately adjacent to the streams and drainage lines are Katspruit Form soils. Where gully erosion has occurred adjacent to some of the streams, Valsrivier Form soils are found. The corresponding Soil Families and diagnostic horizons are summarised in the following table, whilst the areas covered by the various soils and percentages of the total area are summarised in Table 19.
Table 18: Soil forms and Families
Soil Form Soil Family Code Diagnostic Horizons
Glenrosa Tsende Gs –1211 Orthic A1
Lithocutanic B2
Mispah Myhill Ms –1100 Orthic A1
Hard Rock
Hutton Stella Hu –3100 Orthic A1
Red Apedal B2
Clovelly Setlagole Cv –3100 Orthic A1
Yellow Brown Apedal B2
Augrabies Khubus Ag –1210 Orthc A1
Neocarbonate B2
Katspruit Lammermeer Ka –1000 Orthic A1
G
Valsrivier Alice Va –2111 Orthic A1
Pedocutanic B2
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Figure 8: Geology of the project area.
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Figure 9: Soils map
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Table 19: Soil forms as a percentage of the area surveyed.
Soil Form Area (ha) Percentage (%)
Glenrosa / Mispah 113,29 41
Hutton 132,29 48
Clovelly 6,9 2.5
Augrabies 5,56 2
Katspruit 16,58 6
Valsrivier 5,56 0,5
Total 276,34 100,00
Table 20: Soil forms as a percentage of the area disturbed
Soil Form Area (ha) %
Glenrosa / Mispah 26 74.3
Hutton 8 22.9
Clovelly 0.5 1.4
Augrabies 0.5 1.4
Total 35 100
The Hutton and the Glenrosa/Mispah Form soils are generally the dominant soils in the area of the discard dump and the associated plant. They are frequently associated with rock outcrop. The Glenrosa and Mispah Form soils are not bleached in the A horizon and are non-calcareous with no signs of wetness. The Clovelly and Hutton Form soils are eutrophic and non-luvic. That is, little leaching has taken place, and there is not a marked increase in clay content with depth. The Augrabies Form soils are red, not bleached in the A horizon and are non-luvic. The Katspruit and Valsrivier Form soils are associated with streams and may be saturated with water for long periods of time.
3.i.ix.1.d.2 Soil Fertility
From the laboratory testing carried out on representative samples taken from the area, it is apparent that the Hutton, Clovelly and Katspruit Form soils are all non-saline and non-sodic. They have very low levels of sodium and potassium, moderate to occasionally low levels of calcium and very high levels of magnesium. They have high pH (are alkaline). As such, these soils are suitable for cultivation, provided adequate levels of fertiliser are applied. The results of the chemical analyses carried out are summarised in the following table.
Table 21: Soil Chemistry
Position and Depth AH 19
(0-0,45) AH 19
(0,45-0,8) AH 39 (0-0,2)
AH 39 (0,2-0,8)
AH42 (0-0,2)
AH 42 (0,2- 0,4)
AH 47 (0-0,4)
AH 47 (0,4-0,8)
PH 7,7 8,1 7,2 7,2 8,3 8,5 8,0 7,7
Na (mg/100g) 0,15 0,28 0,08 0,15 0,11 0,22 0,09 0,23
K (mg/100g) 0,29 0,15 0,15 0,17 0,29 0,22 0,27 0,79
Ca (mg/100g) 12,90 16,20 5,00 7,00 10,45 6,40 5,20 11,85
S Value 37,44 48,23 19,83 33,12 31,60 32,04 15,16 44,22
T Value (CEC) 30,60 37,20 19,80 33,10 20,80 20,10 15,10 31,60
CEC/100g clay 118 109 99 144 139 118 101 93
3.i.ix.1.d.3 Soil Erodibility
The erodibility of the soils occurring on the site is given in the following table. The erodibility index was calculated using the Exchangeable Sodium Percentage (ESP), where possible, as well as the physical properties of the soils.
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Table 22: Soil Erodibility
Soil Form Erodibility Index
Glenrosa Moderate
Mispah Moderate
Hutton Low
Clovelly Low
Augrabies Low
Katspruit Moderate
Valsrivier High
Soil Depth
The Glenrosa and Mispah Form soils are generally less than 0.30m deep, but may be as much as 0.60m deep. The Hutton, Clovelly, Augrabies, Katspruit and Valsrivier Form soils are generally in excess of 0.60m deep to as deep as 1.50m, but shallower examples occur, especially adjacent to the Glenrosa Form soils.
3.i.ix.1.d.4 Dryland Production Potential
The soils in the four broad categories have varying dryland production potential. The shallow soils have poor cultivation potential:
Glenrosa and Mispah Form soils and small portions of the other soil Forms; The Hutton and Clovelly Form soils of the area are generally of fair to good cultivation potential; The Augrabies Form soils are of fair to poor cultivation potential; and Katspruit and Valsrivier Form soils are associated with valley lines and streams and should not be
cultivated.
3.i.ix.1.d.5 Irrigation Potential
The irrigation potential of the Hutton and Clovelly Form soils is generally good where these soils are deep, particularly due to the availability of water from the Dwarsrivier. Very shallow soils and rock outcrop, resulting in a very low irrigation potential predominantly cover the remainder of the area.
3.i.ix.1.d.6 Topsoil Balance
A topsoil balance study was conducted by GCS (Pty) Ltd during 2016. The locations of topsoil stockpiles and the current surface infrastructure at the Mine can be seen in in the following figure. The areas occupied by surface infrastructure are part of the sites that will need rehabilitation during the post-mining or closure phase of the Mine.
The volume of topsoil required for future rehabilitation is indicated to be 110 309.1m3 and this volume is in excess of the available topsoil volume which stands at 104651.6m3. This means 5 657.5m3 of additional topsoil is required to meet all rehabilitation obligations at the mine as shown in the following table:
Table 23: Topsoil balance (presented in m3)
Available Topsoil Required Topsoil Topsoil Balance
104 651.6 110 309.1 -5 657.5
The topsoil deficit could be attributed to loss of topsoil from stockpiles through water erosion. The Mine’s final rehabilitation, decommissioning and closure plan, points out the possibility of conversion of brick buildings and infrastructure currently serving as offices to other beneficial use upon closure of the mine (GCS, 2016). If the aforementioned plan is finally implemented, the available topsoil will be sufficient for post closure rehabilitation since the area occupied by the brick buildings will no longer need any rehabilitation.
3.i.ix.1.e Land capability
Land capability classification was determined using the Chamber of Mines Classification System (Chamber of Mines, 1981). In general, the arable land comprises the Hutton and Clovelly Form soils, the grazing land comprises the Augrabies and some of the Glenrosa Form soils and the wetland comprise the Katspruit and Valsrivier Form
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soils. The wilderness land on the site comprises the very steep areas and the other areas of particularly shallow Glenrosa and Mispah Form soils, with associated rock outcrop.
3.i.ix.1.f Ecological Footprint
Scientific Aquatic Services was requested to develop a Biodiversity Action Plan for the Dwarsrivier Mine. Upon initial assessment, it was identified that there were significant gaps in the baseline information available on the faunal and floral aspects of the biodiversity of the area. In depth investigations of the faunal and floral ecology of the subject property were undertaken during two site visits in November 2009 and January 2010. The assessments also looked at the regional faunal ecology and comparisons of the subject property were made to information gathered on the general area.
3.i.ix.1.f.1 Plant Communities
Based on the findings of these studies it was identified that several Red Data Listed (RDL) faunal and floral species occur in and around the study area, as well as several floral species endemic to Sekhukhune land. Specific ranking of RDL species and their probability of occurrence was made using the Red Data Sensitivity Index Score (RDSIS) index. Important floral species encountered on the study area can be are included in the following table. The current Vegetation of the area can be seen in Figure 11.
Table 24: Dominant Species within the Dwarsrivier Mine.
Important habitat for RDL faunal species was also identified in the form of wetland and riparian zones and ridges. It was deemed important that these areas play the focal role in the management of the biodiversity of the subject property. The study area was divided into five management units, listed in the following table. The project area is located in Management unit 3.
Table 25: Management units within the Dwarsrivier Mine
Management unit Definition
Management unit 1 Ridges
Management unit 2 Mixed Bushveld
Management unit 3 Mining footprint comprising of:
• Shafts • Access roads • Waste rock dumps • Conveyors • Return water dams • Administrative buildings
Management unit 4 Old agricultural land
Management unit 5 Riparian habitat
Based on the outcome of the identification of RDL species, impacts and impacting mechanisms on the faunal and floral ecology of the area were identified. Biodiversity action plans with management and mitigation measures were then defined for each management unit in order to manage the ecological assets of the Dwarsrivier Mine. Specific biodiversity targets were defined for each management unit in order to optimise biodiversity value as indicated in the following table.
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Figure 10: Topsoil Stockpile Locations
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Figure 11: Vegetation
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Figure 12: Management Units
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Table 26: Specific Biodiversity Targets
Management unit Target
Management unit 1 (Ridges) Conserve ridges while optimising biodiversity value by
rehabilitating disturbed areas and alien and invasive control
and ensuring faunal migratory connectivity
Management unit 2 (Mixed Bushveld) Conserve remaining mixed bushveld, with special mention of the
Grootboom Farm, by establishing a biodiversity reserve.
Rehabilitate disturbed areas and control alien and invasive
species.
Management unit 3 (Mining Footprint Areas) Increase biodiversity value by removing waste, alien and invasive
species and establishing indigenous/endemic floral species as
part of general rehabilitation and landscaping features.
Management unit 4 (Old Agricultural Lands) Increase biodiversity value by removal of alien and invasive
species, rehabilitation of disturbances and optimisation of land-
use
Management unit 5 (Riparian Areas) Conservation of riparian areas by establishing no-go areas
below the 1:100 year flood lines, removal of alien and invasive
species and rehabilitation of disturbed areas.
A monitoring program was then defined in order to allow for ongoing monitoring of the faunal and floral assets on the subject property, which, along with the action plans, will address knowledge gaps still present which are deemed necessary to fill to ensure that all important aspects of the ecology of the subject property are adequately understood and managed.
3.i.ix.1.f.2 Threatened Species
Species that are potentially or actually present in the project area, and which are considered to be threatened, are highlighted for consideration (refer to the following table).
Table 27: Dominant, Threatened and Invasive Plant Species
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Please refer to the next section detailing site specific information.
3.i.ix.1.f.3 Critical Biodiversity Areas
Critical Biodiversity Areas are areas required to meet biodiversity targets for ecosystems, species and ecological processes, as identified in a systematic biodiversity plan. Ecological Support Areas are not essential for meeting biodiversity targets but play an important role in supporting the ecological functioning of Critical Biodiversity Areas and/or in delivering ecosystem services. Critical Biodiversity Areas and Ecological Support Areas may be terrestrial or aquatic.
The overall project area is located in a Critical Biodiversity Area (CBA21) as proclaimed as part of the 2012 Limpopo Biodiversity Conservation Plan, for this reason specially management tools are required in terms of the management of biodiversity in these areas (see the figure overleaf).
A CBA 1 area is defined as the following:
Maintain in a natural or near-natural state that maximizes the retention of biodiversity pattern and ecological process:
Ecosystems and species fully or largely intact and undisturbed. These are areas with high irreplaceability or low flexibility in terms of meeting biodiversity pattern
targets. If the biodiversity features targeted in these areas are lost then targets will not be met. These are biodiversity features that are at, or beyond, their limits of acceptable change.
An ESA 2 is defined as the following:
Maintain as much ecological functionality as possible (generally these areas have been substantially modified):
Maintain current land use or restore area to a natural state. Ecosystem NOT in a natural or near-natural state, and has been previously developed (e.g. ploughed). Ecosystems significantly disturbed but still able to maintain some ecological functionality. Individual species or other biodiversity indicators are severely disturbed or reduced and these are areas
that have low irreplaceability with respect to biodiversity pattern targets only. These are areas with low irreplaceability with respect to biodiversity pattern targets only. These areas
are required to maintain ecological processes especially landscape connectivity.
.
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Figure 13: CBAs
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Discussion
During November 2016 a study on the floral species of conservation in the current project area was undertaken by SASS. Four focus areas, namely Area A, B, C and D (hereafter collectively referred to as the “study area’) were identified where possible future activities may occur and were investigated for the presence of any Species of Conservation Concern (SCC).
For the purposes of this project, Area B and C is important and therefore discussed further.
Figure 14: An aerial photograph depicting the location of the study area in relation to surrounding areas
The total number of protected trees identified for the overall study area was 349. This number includes Sclerocarya birrea subsp. caffra (Marula) and Catha transvaalensis (=Lydenburgia cassinoides) (Sekhukhune Bushman’s Tea) and Elaeodendron transvaalense (Bushveld Saffron). All the aforementioned are protected under the NFA (1998). In terms of this act, protected tree species may not be cut, disturbed, damaged or destroyed and their products may not be possessed, collected, removed, transported, exported, donated, purchased or sold - except under license granted by the Department of Water Affairs (DWA) (or a delegated authority).
E. transvaalense is also listed as Near Threatened by the South African National Biodiversity Institute (SANBI). Another species, namely Jamesbrittenia macrantha, listed as Near Threatened by the SANBI, was also encountered throughout the study area, especially in disturbed areas where norite-rich soils have accumulated. Due to this species being herbaceous and not all plants flowering due to the late rain, it was not marked using dangertape due to practical reasons. Furthermore, due to its abundance within the study area, no necessary permitting requirements on a provincial or national level and its perceived preference for disturbed areas, it is assumed that this species will continue to persist within the study area and as such it was not marked by GPS. The following section provides details on the species and number of SCC for each Area (B and C) and the figures indicate the localities of the floral SCC as marked during the assessment. Appendix 7 contains the coordinates for each species listed for each area.
Area B: Sclerocarya birrea: 2 individuals Catha transvaalensis: 275 individuals
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The operation has an approved License to authorise actions and activities affecting the Protected Trees (Ref: LP-SDM-2017-06-06-B). The Permit is valid up until 26 June 2018. (Refer to Annexure 7)
3.i.ix.1.g Animal Life
The project area in question, has been subjected to mining activities for many years and therefore the animal life has adapted to this setting. The projects only include the expansion of existing operational facilities and limited supporting infrastructure and should not pose a significant impact on the animal life.
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Animal life in the project area is dependent on the soil, plant, and water resources of the project area. It is these basic biophysical resources that afford suitable habitat and food to the range of fauna that exist there. The lists do not reflect surveys conducted specifically within the project area, but are based on existing databases for the area in general (see table below).
1 Rare species 1 Rare species 8 Endemic; 1 Vulnerable species
Amphibians Butterflies Birds
Green-veined Emperor Bateleur (V)
Koppie Emperor Martial Eagle (V)
White-barred Emperor House Martin (C)
Pearl-spotted Emperor
Bushveld Emperor
0 Threatened species 5 Protected species 2 Vulnerable; 1 Candidate species
Discussion
According to the draft EMP Consolidation report, of all the threatened fauna species listed in the table above, only the avifauna (birds) and the fish are confirmed to have been seen on Dwarsrivier 372KT. The potential presence of threatened reptiles and butterflies has not been confirmed. The large number of endemic reptile species potentially present in the project area may warrant a more intensive on-site investigation by a specialist.
3.i.ix.1.h Hydrological Setting
The Mine is located in Water Management Area (WMA) 4: Olifants and the greater part of the mine in Quaternary Catchment Area B41G. Water drainage on site is in different directions as follows:
Some water drains toward the Sprinkaan Spruit; Some water drains to the Klein Dwars River; Some water drains toward the Groot Dwars River; and Predominant flow direction of natural drainage of water on site is in a western direction.
The non-perennial stream on the southern side of the proposed opencast area drains into the Klein Dwars River, which has its confluence with the Tubatse (Steelpoort) River about 10km downstream of the site. The Steelpoort River joins the Olifants River approximately 60km north.
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Figure 15: Quaternary Catchments
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The Groot Dwars River has its origin on the farm, De Berg 71 JT some 33.75 Km (measured in a straight line) to the south of the confluence of the Groot Dwars River with the Klein Dwars River. The Klein Dwars River has its origin on the farm, Uysedoorns 47 JT, approximately 25.3 km (measured in a straight line) to the south of this river’s confluence with the Groot Dwars River. The Springkaanspruit enters the Groot Dwars River from the east some 1.6 km upstream from the confluence of the Groot and Klein Dwars Rivers, and has its origin on the watershed between the farms Zwakwater 377 KT and Schuins 378 KT, some 15.4 km (measured along its longest collector) to the east of its confluence with the Groot Dwars River.
After the confluence of the Groot Dwars River, with the Klein Dwars River, the river continues as the Dwars River for another 15.3 km (measured along the course of the river) up to its confluence with the Steelpoort River on the farm, Kennedy’s Vale 361 KT. The Steelpoort River is a tributary of the Olifants River, which ultimately leaves the Republic of South Africa and flows into the Limpopo River in Mozambique before the latter river discharges its contents into the Indian Ocean near Xai-Xai. The Limpopo River is approximately 1,750 km long (compared to the Dwars River’s 33.75 km) and has a drainage basin of 415,000 square kilometres (km2). Its mean annual discharge is some 174.288 cubic metres per second (m3/s) at its mouth making it the second largest river in Africa discharging eastwards into the Indian Ocean, the Zambezi River being the largest.
The following figure presents the various rivers on site, and the associated 100 year flood line.
Figure 16: The cross sections representative parts of the rivers/streams
3.i.ix.1.h.1 River Diversion
No river diversions will occur within the mining area. All activities are planned outside of the 1:100 year flood line and must not be located within 100m from river (see figure above).
3.i.ix.1.h.2 Surface Water Quality
Aquatic health and water quality at the upstream and downstream points of the mine is undertaken by SAS. The monitoring locations are indicated on the figure below:
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Figure 17: Surface Water Monitoring
When considering the November 2011 results:
Water quality at the S1 point has improved slightly since the previous assessment in March 2016 with a decrease in EC of 15.9%. The latter exceeds the DWS (formerly DWAF, 1996) Target Water Quality Requirements (TWQR) for aquatic ecosystems, which advocates an increase of no more than 15%. At the S2 site, the EC decreases by 20.0%, which slightly exceeds the DWS TWQR. However, both these short term changes are deemed positive and are considered to be a change towards more natural conditions. See Figure below:
Since the baseline assessment in July 2009, the EC has increased by 21.7% at the S1 site and by 4.2% at the S2 site. The EC is somewhat variable along this section of the Dwars River over time and some seasonal variation is evident.
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pH observed at both points may be regarded as natural in the current assessment and the spatial change falls within the DWS guideline recommendations.
Dissolved Oxygen concentrations have improved at both points since the previous assessment in March 2016 by 23.8% and 15.7%, respectively at the S1 and S2 sites; Temperature fluctuations, flow variations as well as increased dissolved salts concentrations in the current assessment are likely to play a role. Percentage saturation at both sites exceed 80% and complies with DWS guideline recommendations;
Other surface water monitoring positions are indicated in the following figure:
Figure 18: Monitoring Location
The table below presents the location of these sites:
Table 29: Surface Water Monitoring Location
Sample ID Location Sampling Technique Co-ordinates
Latitude Longitude
SP1 Springkaanspruit at the
main road bridge
Grab Sampling
24°56'0.52" 30° 7'26.08"
SP2 Springkaanspruit,
upslope of the main sewage plant
24°56'0.60" 30° 7'13.59"
SP3 Springkaanspruit,
downslope of the main sewage plant
24°56'0.04" 30° 7'0.97"
S1 Through mining area in
Dwars River 240 55’41.7” 300.07’20.0”
S2 Old helipad bridge, north
of Landing strip 240 55’45.3” 300.06’03.4”
S3 Clinic Bridge in the Groot
Dwars 240 55’22.9” 300.06’13.3”
S4 Dwarsrivier Bridge, Tar
road at entrance 240 54’32.6” 300.06’20.4”
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Sample ID Location Sampling Technique Co-ordinates
Latitude Longitude
*S5 First stream next to
DRM6
Not sampled
240 56’35.4” 300.07’20.7”
*S6 Corner Dam at T-Junction 240 55’42.5” 300.06’46.6”
**S7 Southern Dam 240 55’50.7” 300.06’54.5”
*S8 Run-off of S7 dam, next
to DRM5 240 55’53.2” 300.06’52.6”
*S9 East of S6, Next to DRM4 240 55’42.5” 300.06’48.4”
The laboratory analyses results for March 2017 of the surface water resources samples and the compliance/non-compliance of the constituents to the water quality limits (WQL) specified in the water use licences are tabulated in the following table. All the constituents exceeding the WQL (non-compliance) have been indicated in red.
No volatile petroleum hydrocarbons were detected in all the seven surface water samples.
Overall the water quality in the system if fairly compliant with the conditions of the WUL.
It should be noted that the Dwarsrivier is considered a Flagship River. The River Freshwater Ecosystem Priority Area Database provide biodiversity targets for river ecosystems, threatened/near threatened fish species, and identified in rivers that are currently in a good condition (A or B ecological category). The FEPA status indicates that they should remain in a good condition in order to contribute to national biodiversity goals and support sustainable use of water resources. The Dwarsrivier mining area is located in one sub - quaternary catchment (674). The sub – quaternary catchment is classified as a FEPA which is situated in B41G quaternary catchment (identified on the BGIS (2016) website).
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Table 30: Surface Water (Instream) Chemical Analyses Results – March 2017
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3.i.ix.1.i Hydrogeological Setting
There are three main aquifers found in the area (iLEH, 2017). These include:
A shallow weathered aquifer present in the upper 20m of the geological succession. A fractured rock aquifer consisting of fractured pyroxenites, anorthosites and norites. The depth to
weathering in this aquifer varies from 0 – 32m, but is on average 8 – 10m below surface. Pockets of deeper weathering are associated with faulting and/or jointing. The intersection of fractures in exploration boreholes suggests that the majority of fractures occur within the upper 60m of the geological succession. Deeper fracturing is however found to a depth of 200m. Information from monitoring boreholes suggests that water-bearing fractures typically occur to a depth of 40m. For the purpose of this study, the floor of the LG6 chromitite seam will be assumed as the depth of the fractured rock aquifer.
An alluvial aquifer present in the floodplains of the Groot- and Klein Dwars Rivers. In this aquifer, the lithology varies from large boulders to fine silty material. Monitoring boreholes drilled into this aquifer suggests that it is 20m thick on average.
Dwarsrivier monitors 17 boreholes around the operations, of which 16 are stated in the WULs. The boreholes are indicated on the following figure.
Groundwater is used as water supply to the operations. Groundwater is abstracted from six boreholes. Their locations are indicated on the following figure. Past and current groundwater abstraction patterns are summarised in the following table. This information represents average volumes from the mine’s monitoring database.
Table 31: Groundwater abstraction volumes
Boreholes 2016 Average abstraction volume (m3/d) Long-term average abstraction volume (m3/d)
BHD1 149 113
BHD2 0 82
BHE 143 107
BHA+B to tank 118 139
BHA+B to MRC 110 291
Extraneous mine water is pumped via a series of underground dams from both the South and North Pit Portals. This water is pumped to the Clarifier and then channelled to Dam 26 for re-use in the mine water circuit. The dewatering volume declined since monitoring thereof started in 2008. Initially the volume of water pumped to surface varied between 2000 and 8000m3/month. Since April 2010, the volume of water pumped to surface has decreased to between 2000 and 3000m3/month. This could be attributed to reduced groundwater seepage rates after the gradients to towards the pits have been reduced/lowered as a result of the initial mine dewatering. During the evaluation period, the average volume of water pumped from underground is below 1500 m3/d.
Dewatering from the North Pit portal commenced during November 2011 and fluctuates between 0 and 3200m3/d. The volume dewatered remains under 700m3/d on average for this area.
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Figure 19: Groundwater Monitoring Points
There are no springs present within the mining area.
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An assessment of the rate of recharge to the aquifers was undertaken as part of the 2015 modelling study using the SVF method. The results indicate that for larger storage coefficients (S), the recharge rate is calculated as 6% of the Mean Annual Precipitation (MAP). For lower values of S, the rate of recharge is estimated to be around 5% of MAP.
3.i.ix.1.i.1 Priority contaminants used during current Groundwater Model and Water Quality
Sixteen boreholes specified in the two licences for the monitoring of the impact of the mining and water use
activities on the groundwater environment were sampled during the March 2017 monitoring run. The details of
these points are tabulated below.
Table 32: Groundwater Monitoring Points
Sample ID Location Sampling Technique Co-ordinates
Latitude Longitude
DRM1 Left of T-junction
Purging before sample collection
24.92853 30.11103
DRM2 Along the main road to Two
Rivers 24.92779 30.11110
DRM3 Gate to quarry and mining 24.92461 30.11224
DRM4 Inside the plant 24.92791 30.10965
DRM5 Below upper return water
dam 24.93133 30.11147
DRM6 Behind magazine stores 24.94293 30.12280
DRO4 Along Groot Dwars Rivier 24.92791 30.10965
ASDW BH1 South of Proposed Pit 24.92811 30.12359
ASDW BH2 North-east of proposed TSF 24.9178 30.12349
ASDW BH3 Down gradient at North pit
proposed tailing dump 24.9255 30.11942
ASDW BH4 Up gradient at North pit proposed tailing dump
24.92402 30.12402
ASDW BH5 Down-gradient to Dam 26 24.93514 30.11694
ASDW BH6 Up-gradient to Dam 26 24.93551 30.11807
ASDW BH8 Down gradient at north pit
decline shaft Not
sampled/Destroyed 24.92900 30.12007
ASDW BH9 Between lower return and
tailings Purging before sample
collection
24.92848 30.1133
ASDW BH10 Up Gradient of discard dump
at quarry and mining 24.9259 30.11621
ASDW BH11 Up gradient of South Pit 24.93493 30.12356
The laboratory analyses results of these water samples and the compliance/non-compliance of the constituents
to Class II Water Quality Target are tabulated in the following table. All the constituents that exceeded the WQL
(Class II Water Quality Limits for 2008 Licence and WUL-WQL for 2011 Licence) are indicated in green or orange
(depending on WUL) on the table below. No volatile petroleum hydrocarbons were detected in all the sixteen
groundwater samples.
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The priority contaminant identified for the investigation is nitrate, based on monitoring data.
The mine maintains an extensive groundwater quality-monitoring database over the period November 2000 to present date. Nitrate has been identified as the priority contaminant for the operations, as mentioned above. Average long-term and 2015/6 nitrate concentrations are presented in the following table for comparison.
Table 34: Nitrate concentrations in monitoring boreholes in mg/l
BH ID Long-term average NO3
2014
average NO3
2015/6 average NO3
Past and current possible sources of NO3
Future possible sources of NO3
DRM1 176 510 125 URWD, Old TSF, plant area, UG mining, North Pit, old TSF, URWD
DRM2 207 404 NA URWD, Old TSF, plant area UG mining, North Pit, old TSF, URWD
DRM3 189 337 382 Northern Waste Rock Dump area
UG mining, North Pit, old TSF
DRM4 578 869 999 Plant area UG mining, North Pit, plant area
DRM5 302 435 581 LRWD LRWD, OC pits
DRM6 10 14 14 Waste rock dump, South Pit, UG mining
UG mining, South Pit
DRO4 31 169 39 URWD, Old TSF, plant area UG mining, North Pit, old TSF, URWD
ASDW1 275 260 315 North Pit, waste rock dump North Pit
ASDW2 197 100 363 New TSF, OC pits New TSF, OC pits
ASDW3 587 924 795 North Pit, North Pit RWD UG mining, North Pit
ASDW4 50 23 96 North Pit, waste rock dump North Pit, new TSF
ASDW5 97 16 21 Dam 26, waste rock dump, UG mining
Dam 26, UG mining, South Pit
ASDW6 99 18 35 Dam 26, waste rock dump, UG mining
UG mining, South Pit
ASDW8 510 456 NA North Pit: Destroyed during mining
North Pit
ASDW7 4 1 4 Waste rock dump Upstream borehole
ASDW9 451 436 580 Old TSF, plant area UG mining, North Pit, old TSF
ASDW10 347 276 379 Northern Waste Rock Dump area
UG mining, North Pit, old TSF
ASDW11 2 1 2 Upstream borehole Upstream borehole
The concentrations are compared to possible past, current and future sources of nitrate contamination to groundwater in the table. It is shown that historical impacts associated with the old TSF, the plant area and North Pit have the most significant impact on groundwater quality in terms of nitrate concentrations. This is further illustrated in the nitrate classed post map presented in the following table.
Table 35: Nitrate concentrations derived from monitoring data
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All but three of the monitoring boreholes indicate an increase in nitrate concentrations from the 2014 average value reported in the 2015 modelling study. These are indicated in red in Table 34. Monitoring borehole DRM1, down gradient of the URWD, old TSF and plant area show a significant decrease from an average concentration of 510mg/l in 2014 to 125mg/l in 2015/16. Borehole DRO4 further down gradient of these sources also show a reduction in average nitrate concentration. ASDW3, down gradient of the North Pit RWD also show reduced nitrate concentrations, from 924mg/l in 2014 to 795mg/l in 2015/2016.
The remainder of the monitoring boreholes show an average increase of just under 100mg/l over the 2-year period. This is considered a significant increase in the context of the conceptual model, especially in the fractured rock aquifer formed by igneous rock formations. These rocks have fairly low permeabilities. Such a large increase in concentration in these boreholes therefor suggests that the plumes associated with the various historical sources of groundwater contamination are increasing at a rate of around 50mg/l per year. This is fairly rapid in the context of the site.
It is shown that nitrate concentrations in boreholes ASDBH7 and 11 comply with the water use license condition of 6mg/l. Boreholes ASDWBH5 and 6 and DRM6 have nitrate concentrations between 7 and 20 mg/l. Borehole ASDWBH4 falls in the nitrate concentration class of 21 – 50 mg/l. Nitrate concentrations in all other boreholes exceed 100mg/l, with the highest concentrations observed in DRM4 at the plant and ASDWBH3, situated down gradient of the North Pit RWD.
3.i.ix.1.j Sensitive Sites or Wetlands
The National Freshwater Ecosystem Priority Areas (NFEPA), 2011 indicates a number of wetlands on site (refer to the Figure 15 for the location of the wetlands). However, these identified areas are in fact the mine’s return water dams (Dam 26, Upper Return Water Dam, Lower Return Water Dams).
A concern was raised on a possible wetland system to the north of the existing Discard Dump (see figure below), where the expansion is planned. To ensure that clarity on this system is obtained, a specialist study was commissioned during 2016 by GCS (Pty) Ltd. The study stated the following:
Figure 20: Potential Wetland Area
The site in question is situated on the south western side of a hill, on a downward slope towards the Groot Dwars River (see following photo).
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Photo 6: Hill adjacent to site (east)
Historically an earth dam was constructed by the farmer, which also falls into the site. This dam is fed by storm water runoff from the adjacent catchment, before it can enter the Groot Dwars River (see following figure). At the time of the survey, this dam was completely dry. No drainage line, river or wetland could be identified during the site assessment.
Photo 7: Dam that was constructed by farmer
The field investigation was undertaken during October 2016 to assess and delineate the Wetland zones present on the proposed development site. The field procedure for the wetland delineation was conducted according to the Guidelines for delineating the boundaries of a wetland set out by the Department of Water Affairs and Forestry (DWAF 2005).
The site was traversed on foot. A soil auger was used to auger holes, enabling to see if any wetland soils are present within the study site. Several holes were augured. No wetland soils could be characterised during the site investigation. No wetland vegetation was identified on site.
The study concluded that:
“During the site visit conducted in October 2016 no wetland characteristics could be identified within the study area adjacent to the discard dump. During the site visit, no wetland soils or wetland vegetation could be identified.
Based on this assessment, no wetlands are located within 500m of the activities considered for this application.
Refer to Annexure 9 for the report.
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3.i.ix.1.k Air Quality
Sources of potential air emissions and/or pollution significance:
Transfer of ore from underground to ROM stockpiles by belt conveyor (wind entrained particulate matter);
Vehicle exhaust gasses – both on and off site; Dust generated from vehicles driving on unpaved roads within mine boundary; The reclamation of the tailings dam and the rock dump will produce dust; and Dumping of the processed material from the tailings into the north and south old pit will also produce
dust.
Five monitoring points are assessed for dust fallout by the mine. These are indicated in the following table:
Table 36: Dust Monitoring Points
Sample Point Sample Point Name
DWR 001
School
DWR 002
Far North Point
DWR 003 Parking Lot South Shaft
DWR 004 Discard Dump South Shaft
DWR 005 North Shaft
The figure below illustrates the location of these
Figure 21: Dust Monitoring Locations
As mentioned before, there are five Dust Watch units installed and operational at Assmang Chrome Dwarsrivier Mine, the DWR 001 unit, DWR 002 unit, DWR 003 unit, DWR 004 unit, and the DWR 005 unit.
The fall-out dust standards from National Dust Control Regulations, 2013.
Based on the monitoring results available the dust fall out remains within the standards of 1 200 mg/m2/day.
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3.i.ix.1.l Noise
A noise impact assessment was conducted by dBAcoustics in May 2009 and this revealed the following sources of noise along the boundaries of the mine:
Traffic noise – both light motor vehicles and heavy-duty trucks; distant mine noise; mine activity noise; industrial noise; and Ventilation noise.
No additional noise assessment was undertaken as the activities in question is located within the existing mining footprint and will be a pure expansion of existing facilities.
Of particular significance is the presence of the R577 regional road from Sekhukhune land to Lydenburg that transects the mine property and is adjacent to the main mining activities on Dwarsrivier Mine, most importantly the processing plant, conveyor and workshops. Also important is the presence of four other mining operations in the vicinity of Dwarsrivier Mine.
These contribute noise directly to the ambient noise levels, but also indirectly through the presence of heavy duty and other traffic on the R577 and minor access roads to the mines. The area cannot be classified as rural according to Table 2 of SANS 10103 due to the above factors.
The following conclusions were drawn from the results of the noise impact assessment:
The prevailing ambient noise levels along the boundary of the mining area are lower than the recommended noise level for an industrial area;
The prevailing ambient noise levels are largely caused by emissions from a combination of noise sources; The significance of the noise impact from the activities at the proposed mine on the existing immediate
environment will be medium according to the standardised risk matrix; and According to Table 5 of SANS 10103 of 2008, the community response to the industrial type noise will
be medium due to the higher prevailing ambient noise levels already experienced in this area from other mining activities.
No changes to the ambient conditions have resulted since the last study.
3.i.ix.1.m Cultural and Heritage Setting
According to the draft EMP Consolidation Report and approved EMP, a heritage investigation was done by the Department of Archaeology from the University of the Witwatersrand. The University of the Witwatersrand recorded two archaeological sites on the mining area. These consisted of a historic mine and a Middle Stone Age scatter.
Site 1: This site consists of an abandoned chrome mine and associated building foundations located at the south-eastern base of the koppie in the far north eastern corner of the mining area. One mineshaft had been sealed with stone and mortar. This area will be mined through by the open cast mine. The remains of at least 20 circular hut platform foundations and three sub-rectangular room block foundations stood to the east of the sealed mineshaft. No additional cultural material, such as refuse deposits, was located.
Site 2: A light concentration of Middle Stone Age material lay scattered in a deflated ploughed field, just south of the gravel track to the farmhouse on Dwarsrivier. Cultural material included lithic blades, points and flakes fashioned from dolerite. The material was rolled and weathered, indicating that it is not in primary context.
Two graves have been demarcated on site. Please refer to the following figure. None of these are located in proximity of the proposed activities.
No other sites have been identified.
3.i.ix.1.n Socio-Economic Setting
According to the 2011 Stats SA information, the total population of the municipality is approximately 335 767 with 83 19 households. These makes the Greater Tubatse Local Municipality (GTM) the municipality with the
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highest population in the District. It also appears from 2007 community survey and the 2011 Stats SA results that there has been a population decline in most of the local municipalities.
The population in the municipality is constituted by 97, 8% black African, 1, 6% white people, with other population groups making up the remaining 0, 7. The sex ratio in the municipality is 88, meaning that for every 100 women there are 88 men. Languages spoken in the municipality include Sepedi (78, 6%), Tsonga (6, 9%), isiNdebele (3, 8%), isiZulu (2, 1%) and other languages make up 8, 6%. Of those aged 20 years and older, 22, 6% have completed matric and 6, 6% have some form of higher education.
The age group below 18 years comprises approximately 51% of the population, resulting in a largely young population. The female ratio is almost equal at the age of between 0 and 17 years. This substantially changes when comparing male-female distribution in the economically active age cohorts, i.e. 19-65 years where there are more women.
The GTM is populated by people who originates from Limpopo province, only 6 of the population in the municipality originates from outside Limpopo and bout 2% of the population originates outside South Africa.
The following information has been obtained from the 2015/2016 Draft IDP of the GDM.
Education
The Limpopo province’s education achievements lag behind those of other provinces. For example, the literacy rate of the Limpopo province was 73.6% in 1991, while average literacy in South Africa was 82.2%. Population Development Program (PDP) indicators suggest that, in 1991 nearly one in every ten children of a school going age did not attend school.
Based on the diagram below the GTM has the highest secondary schooling of the municipalities. 10% of the population has however no schooling and only 5% complete primary school.
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Figure 22: Grave Locations
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Diagram 2: Education Level in comparison to other Municipalities and South Africa (Quantec Regional Economic Database)
Employment Status & Economic Active Population
The following table presents the employment status by gender.
Table 37: Employment Status
Male Female Total
Employed 32 840 16 682 49 522
Unemployed 20 618 29 603 50 220
Discouraged work seekers
4 034 6 571 10 605
Other not economically active
39 072 53 304 92 376
Age less than 15 years - - -
Not applicable 63 834 69 119 132 952
Total 160 398 175 278 335 676
Based on the labour force projections, it is foreseen that the unemployment percentage will increase form 41% in 2011 to 56% in 2030.
The table below illustrates the economic active population within the municipality. Based on this diagram the municipality has the lowest number of economic active population for the age group 20-24 years, and the highest for the 25-64 age group.
Diagram 3: Economic Active Population (Quantec Regional Economic Database)
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Employment Sector
The 2015/2016 IDP presents that mining & quarrying and wholesale & retail trade, catering and accommodation are the two major economic activities in the Greater Tubatse region, accounting for 50% and 15.8% of the economic activity in the area respectively. Community, Social and Personal services follows by 8.3% of the economic activity in the area. The IDP further states that although there are several mines in the area, the existing resources remain unexploited. Investment in this sector is important as it brings with it investment in infrastructure, results in creation of job opportunities and generates many other economic spinoffs. The lack of economic growth in the region warrants special attention and support to optimise the available opportunities.
Table 38: Employment Sectors
Indicator 2009 2010 2010%
Agriculture 1 457 1 184 2.2%
Mining and quarrying 20 740 26 610 50.0%
Manufacturing 1 841 1 902 3.6%
Electricity, Gas and Water 57 56 0.1%
Construction 2 232 2 252 4.2%
Wholesale and Retail trade, Catering and Accommodations 8 363 8 414 15.8%
Transport, Storage and Communication 1 611 1 648 3.1%
Finance, Insurance, Real estate and Business services 2 679 2 649 5.0%
Community, Social and Personal Services 4 741 4 440 8.3%
General Government 3 870 4 063 7.6%
Income Levels
According to the 2011 Census, the municipality has a weak economic base and high poverty levels. The Burgersfort town in the municipality has been identified as a growth point in the province because of its mining activities. A potential to grow the economic base in the municipality, through tourism, has been brought by the availability of natural resources. Poverty alleviation projects implemented by the municipality have improved the socio economic conditions.
The following table presents the monthly income of individuals in the municipality:
Table 39: Monthly Income Distribution
Monthly income Male Female
No income 69 361 91 242
R1-R400 39 653 40 537
R401-R800 3 376 4 834
R801-R1 600 12 704 19 715
R1 601-R3 200 6 815 3 332
R3 201-R6 400 9 925 2 916
R6 401-R12 800 5 785 2 137
R12 801-R25 600 2 611 1 253
R25 601-R51 200 930 253
R51 201-R102 400 81 40
Economic Development Sectors
Tourism
Tourism in GTM is underdeveloped as most tourist attraction places are found beyond the boundaries of GTM, particularly the worlds famous Blyde River Canyon and a couple of game farms e.g. Kruger National Park, Malamala Game Reserve, etc. are found on the east of the municipal area. GTM municipal area has a potential to develop tourism industry by way of adopting two different strategies as indicated in the GTM LED strategy.
Agriculture
Farming is an important economic resource as a wide range of products are cultivated owing to good soil conditions, the sub-tropical climate and reasonable access to water. The following type of products is produced: fruit, vegetables, grain, cotton, citrus, maize, tobacco and meat. The main resources that encourage agricultural production are the Olifants, Steelpoort and Spekboom Rivers, which provide water to the region. These sources of natural water are essential for present and long term irrigation of crops.
Table overleaf indicates Agricultural production areas.
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Table 40: Agricultural Production (Departmental Report 2013)
Production Total Tons Total (ha)
Maize (ha) 3 022.9 30 144.59
Sorghum 2 575 8 638
Wheat 2 464 13 945
Sunflower 59 728.1
Groundnuts 13.6 14.9
Soya beans 152.4 3 060.9
Canola 0 50
Bambara nuts 0 633.6
Dry beans 1 560.2 3 092.2
Potatoes 107.7 1 975.3
Cabbage 104 957.6
Butternuts 21.9 200.1
Tomatoes 135.7 340.3
Citrus 1 430.5 10 073
Cotton 0 901.1
Tobacco 21 2222.7
Lucerne 515.8 1760.9
Table grapes 7.1 1390.2
Potential land for agricultural purpose is found on the river banks of three above mentioned rivers, however some of the land is not used optimally e.g. the land at Penge on the river bank of Olifants River and others.
Good agricultural land (Tswelopelo agricultural land) near Praktiseer and Bothashoek is invaded by illegal squatters leaving agricultural activities with no enough land for cultivation. The Tswelopele agricultural scheme in Praktiseer was a very good initiative and has been abandoned by the department of agriculture leaving the entire infrastructure vulnerable to theft.
No other region in the GTM reveals a higher potential for desertion, resultant from overgrazing over a prolonged period by a highly impoverished rural population that struggles to plan and control their area. Their lack of skills prevents them from managing their resource for long-term production. This type of farming makes the region vulnerable to periodic droughts that affect both the regional resources and the potential to generate work opportunities for the unemployed.
Mining
The intrusion of the Volcanic Bushveld Igneous Complex into the sedimentary rock of the Transvaal system resulted in great metamorphism, which caused the introduction of many minerals including chrome, vanadium, platinum, asbestos and magnetite in the area.
Chrome is mined extensively at Dilokong, Dwars-river, Dooringbosch, Tweefontein, Lannex Mine, Magareng, Thorncliffe, Helena, Mooihoek and the product is exported by rail and sea to overseas destinations.
The following chrome mine is still under prospection; Lwala Mine. Vanadium is mined and smelted at only one mine and this product caters for most of the demand in the
country. Platinum is found in the well-known Merensky Ridge and this resource accounts for more than 50% of
all platinum resources on earth and is mined at Mototolo (XSTRATA), Marula Mine, Twickenham Mine, Modikwa Mine, Two- rivers Mine and Phokathaba Mine.
The following platinum mines are still under prospection or at project stage Spitzkop Mine, Grootboom Mine, Nkwe Platinum Mine, Booysendal, Debrochen and Tjate Mine.
Two Andalusite mines exist in the areas of Segororng and Modubeng, which are Rhino minerals and Annesley havecroft Mines.
Granite is mined at Elephant’s river mine near Tjate village. Clay is mined at Atta clay mine and most of the product is used in the process of platinum production. Asbestos was mined at Penge and Taung, but because asbestos products have been banned worldwide,
the mines were closed down and areas are to be rehabilitated. Slate is mined at Saringa Mine near Kgautswane village and is used to manufacture roof and floor tiles. Silica is mined for the production of sand and stone aggregate, and serves as a flux in the chrome smelting
process.
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Magnetite is an iron-ore mined at Goede Hoop and transported to Witbank for the production of steel in the Highveld Steel Plant.
Magnisite was mined extensively in the Burgersfort area, but as it does not meet the required standard anymore, mining operations were ceased.
There are currently three chrome smelters operating in the area, Lion Ferrochrome (XSTRATA), ASA Metals at Ga-Maroga village and Tubatse Ferrochrome in Steelpoort.
Although there are several mines in the area, the existing resources remain unexploited. Investment in this sector is important as it brings with it investment in infrastructure, results in creation of job opportunities and generates many other economic spin-offs. The lack of economic growth in the region warrants special attention and support to optimize the available opportunities. However, cognizance should be taken of the outflow of money from the mines in Greater Tubatse to other regions.
Clay is mined at Atta clay mine and most of the product is used in the process of platinum production. Asbestos was mined at Penge and Taung, but because asbestos products have been banned worldwide,
the mines were closed down and areas are to be rehabilitated. Slate is mined at Saringa Mine near Kgautswane village and is used to manufacture roof and floor tiles. Silica is mined for the production of sand and stone aggregate, and serves as a flux in the chrome smelting
process. Magnetite is an iron-ore mined at Goede Hoop and transported to Witbank for the production of steel
in the Highveld Steel Plant. Magnisite was mined extensively in the Burgersfort area, but as it does not meet the required standard
anymore, mining operations were ceased.
There are currently three chrome smelters operating in the area, Lion Ferrochrome (XSTRATA), ASA Metals at Ga-Maroga village and Tubatse Ferrochrome in Steelpoort.
Although there are several mines in the area, the existing resources remain unexploited. Investment in this sector is important as it brings with it investment in infrastructure, results in creation of job opportunities and generates many other economic spin-offs. The lack of economic growth in the region warrants special attention and support to optimize the available opportunities. However, cognizance should be taken of the outflow of money from the mines in Greater Tubatse to other regions.
3.i.ix.2 Type of Environment Affected by the Proposed Activity
Please refer to the preceding section detailing the environmental setting in which the mine is located. The proposed activities will be located in already disturbed areas but will still necessitate the following:
Clearing of Vegetation Removal and stockpiling of soils; Shaping of the landscape; and Establishment of infrastructure.
These activities may therefore impact on the following:
Groundwater Setting (establishment of waste related activities); Water Setting (establishment of waste related activities and the change in runoff patterns); Ecological Settling (removal of ecology and potential spread of invasive species); Soils (removal of soils for stockpiling); and Topography (shaping).
3.i.ix.3 Description of the Current Land Uses
Dwarsrivier has been mining chromite ore from the LG6 seam since 1999. Between 1999 and 2005, ore was mined using opencast methods. The six pits have subsequently been mined out and backfilled with the exception of the South and North Pit portals from which access is gained to the underground workings. The current mine plan extends the life of the operations to the year 2042 (27 years). DCM indicated that the mine plan has not changed since the 2015 numerical modelling was undertaken (iLEH, 2015).
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The abstraction of groundwater for potable use was included in the assessment presented in this report. Five boreholes are used for groundwater abstraction, namely BHA, B, C, D1, D2 and E.
All opencast mining has ceased and the pits have been backfilled and partially rehabilitated. The extent to which this rehabilitation was completed, is shown on Figure 1. These areas were delineated as part of the annual rehabilitation plan, completed by GCS in 2016. Access to the underground workings is gained from both North and South Pits. The two decline shafts are constructed in the high walls of the pits.
Tailings material was backfilled into both North and South Pits. The majority of the tailings material was backfilled into North Pit while the construction of the Northern TSF was completed. A return water dam (RWD) was constructed in the north-western part of North Pit during this period. The RWD was excavated into backfilled tailings and lined with HDPE.
The old TSF situated west of the Plant is partially reprocessed. Tailings are currently deposited in the Northern TSF, which was commissioned in 2012. The life of the Northern TSF is estimated to be around 12 years.
Several dams are used on site to contain and transfer dirty water around the operations. These include two pollution control dams, the Upper Return Water Dam (URWD) and Lower Return Water Dam (LRWD), situated adjacent to the old TSF. Both dams are lined with HDPE. Extraneous water is pumped from the underground workings to the Clarifier. From here, water is transferred to Dam 26. Approximately half of the extraneous water is pumped back underground for reuse.
Several waste rock dumps (WRD) are situated around the operations. The locations of these are indicated on Figure 1. Some of these dumps have been rehabilitated, as indicated. The operational waste rock dumps are situated east of South Pit, west of North Pit and north of the old TSF (the northern WRD). DCM is in the process of applying to extend the northern WRD in a northerly direction, as indicated. The impact of this activity on groundwater quality forms part of the assessments presented in this report.
Pre-Mining Land Use
Prior to the sale of the land for mining purposes, a portion of the property was used for agriculture under irrigation, the dominant crops being maize, Lucerne, cotton and vegetables. The remainder of the property was used for grazing and wilderness land. The valley lines and wetland areas were left uncultivated.
Historical Potential
The estimated dryland production potential of the area is 4 tons per hectare (t/ha). The grazing capacity is approximately seven large stock units per hectare (Adcock’s, 1988). The irrigated land potential is in the order of 6 - 10 t/ha for maize.
Evidence of Misuse
The only evidence of misuse is erosion gullies in some areas and the presence of borrow pits where the soils and underlying soft rock materials have been removed.
Current Land Use
The current land use for the area is for mining operations, with the Two Rivers and Glencore Thorncliffe Mines operating in the adjacent farm portions. Refer to the following figure.
.
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Figure 23: Land use map
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3.i.ix.4 Description of Specific Environmental Features and Infrastructure on Site
The following specific environmental features are present on site:
Three, identified NFEPA wetlands, which are in fact not wetlands but rather the mines’ internal Return Water Dams (refer to Section 3.i.ix.1.j);
The site is located in a CBA and ESA. These areas have been assessed and the required tree removal permits have already been obtained (refer to Section 3.i.ix.1.f).
The Dwarsrivier is considered a Flagship River in terms of the NFEPA, and therefore all activities will be located outside of the 1:100 year flood line (refer to Section 3.i.ix.1.i).
3.i.ix.5 Environmental and Current Land Use Map
Please refer to Figure 23.
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3.i.x Methodology used in determining and ranking the Nature, Significance, Consequences, Extent, Duration and Probability of potential Environmental Impacts and Risks
The following section presents the criteria used to assess the potential impacts presented in the previous section.
3.i.x.1 Criteria of assigning significance to potential impacts
The evaluation of impacts is conducted in terms of the criteria detailed in Table 41 to Table 46. The various environmental impacts and benefits of this project are discussed in terms of impact status, extent, duration, probability, and intensity. Impact significance is regarded as the sum of the impact extent, duration, probability and intensity and a numerical rating system has been applied to evaluate impact significance. Therefore, an impact magnitude and significance rating is applied to rate each identified impact in terms of its overall magnitude and significance (Table 46).
In order to adequately assess and evaluate the impacts and benefits associated with the project, it was necessary to develop a methodology that would scientifically achieve this and to reduce the subjectivity involved in making such evaluations. To enable informed decision-making it is necessary to assess all legal requirements and clearly defined criteria in order to accurately determine the significance of the predicted impact or benefit on the surrounding natural and social environment.
3.i.x.1.a Impact Status
The nature or status of the impact is determined by the conditions of the environment prior to construction and operation. A discussion on the nature of the impact will include a description of what causes the effect, what will be affected and how it will be affected. The nature of the impact can be described as negative, positive or neutral.
Table 41: Status of Impact
Rat i ng De s cr i pt i on Qua nt i t a t i ve r a t i ng
Positive A benefit to the receiving environment. P
Neutral No cost or benefit to the receiving environment. -
Negative A cost to the receiving environment. N
3.i.x.1.b Impact Extent
The extent of an impact is considered as to whether impacts are either limited in extent or if it affects a wide area or group of people. Impact extent can be site specific (within the boundaries of the development area), local, regional or national and/or international.
Table 42: Extent of Impact
Rating Description Quantitative rating
Low Site Specific; Occurs within the site boundary. 1
Medium Local; Extends beyond the site boundary; Affects the immediate surrounding environment (i.e. up to 5 km from the Project Site boundary).
2
High Regional; Extends far beyond the site boundary; Widespread effect (i.e. 5 km and more from the Project Site boundary).
3
Very High National and/or international; Extends far beyond the site boundary; Widespread effect. 4
3.i.x.1.c Impact Duration
The duration of the impact refers to the time scale of the impact or benefit.
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Table 43: Duration of Impact
Rating Description Quantitative rating
Low Short term; Quickly reversible; Less than the project lifespan; 0 – 5 years. 1
Medium Medium term; Reversible over time; Approximate lifespan of the project; 5 – 17 years. 2
High Long term; Permanent; Extends beyond the decommissioning phase; >17 years. 3
3.i.x.1.d Impact Probability
The probability of the impact describes the likelihood of the impact actually occurring.
Table 44: Probability of Impact
Rating Description Quantitative rating
Improbable Possibility of the impact materialising is negligible; Chance of occurrence <10%. 1
Probable Possibility that the impact will materialise is likely; Chance of occurrence 10 – 49.9%. 2
Highly Probable It is expected that the impact will occur; Chance of occurrence 50 – 90%. 3
Definite Impact will occur regardless of any prevention measures; Chance of occurrence >90%. 4
Definite and Cumulative
Impact will occur regardless of any prevention measures; Chance of occurrence >90% and is likely to result in in cumulative impacts
5
3.i.x.1.e Impact Intensity
The intensity of the impact is determined to quantify the magnitude of the impacts and benefits associated with the proposed project.
Table 45: Intensity of Impact
Rating Description Quantitative rating
Maximum Benefit Where natural, cultural and / or social functions or processes are positively affected resulting in the maximum possible and permanent benefit.
+ 5
Significant Benefit Where natural, cultural and / or social functions or processes are altered to the extent that it will result in temporary but significant benefit.
+ 4
Beneficial Where the affected environment is altered but natural, cultural and / or social functions or processes continue, albeit in a modified, beneficial way.
+ 3
Minor Benefit Where the impact affects the environment in such a way that natural, cultural and / or social functions or processes are only marginally benefited.
+ 2
Negligible Benefit Where the impact affects the environment in such a way that natural, cultural and / or social functions or processes are negligibly benefited.
+ 1
Neutral Where the impact affects the environment in such a way that natural, cultural and / or social functions or processes are not affected.
0
Negligible Where the impact affects the environment in such a way that natural, cultural and / or social functions or processes are negligibly affected
- 1
Minor Where the impact affects the environment in such a way that natural, cultural and / or social functions or processes are only marginally affected.
- 2
Average Where the affected environment is altered but natural, cultural and / or social functions or processes continue, albeit in a modified way.
- 3
Severe Where natural, cultural and / or social functions or processes are altered to the extent that it will temporarily cease.
- 4
Very Severe Where natural, cultural and / or social functions or processes are altered to the extent that it will permanently cease.
- 5
3.i.x.1.f Impact Significance
The impact magnitude and significance rating is utilised to rate each identified impact in terms of its overall magnitude and significance.
Table 46: Impact Magnitude and Significance Rating
Impact Rating Description Quantitative rating
Positive High Of the highest positive order possible within the bounds of impacts that could occur.
+ 1 2 – 1 6
Medium Impact is real, but not substantial in relation to other impacts that might take effect within the bounds of those that could occur. Other means of achieving this benefit are approximately equal in time, cost and effort.
+ 6 – 1 1
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Impact Rating Description Quantitative rating
Low Impacts is of a low order and therefore likely to have a limited effect. Alternative means of achieving this benefit are likely to be easier, cheaper, more effective and less time-consuming.
+ 1 – 5
No Impact No Impact Zero impact. 0
Negative Low Impact is of a low order and therefore likely to have little real effect. In the case of adverse impacts, mitigation is either easily achieved or little will be required, or both. Social, cultural, and economic activities of communities can continue unchanged.
- 1 – 5
Medium Impact is real, but not substantial in relation to other impacts that might take effect within the bounds of those that could occur. In the case of adverse impacts, mitigation is both feasible and fairly possible. Social cultural and economic activities of communities are changed but can be continued (albeit in a different form). Modification of the project design or alternative action may be required.
- 6 – 1 1
High Of the highest order possible within the bounds of impacts that could occur. In the case of adverse impacts, there is no possible mitigation that could offset the impact, or mitigation is difficult, expensive, time-consuming or a combination of these. Social, cultural and economic activities of communities are disrupted to such an extent that these come to a halt.
- 1 2 - 1 6
3.i.xi Impacts and Risks identified including the Nature, Significance, Consequence, Extent, Duration and Probability of the Impacts, including to which these Impacts
The following table presents the list of impacts, and indicates the nature, extent, duration, probability and significance, as well as whether these impacts can be avoided, are reversible or will result in residual impacts.
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Table 47: Planning and Construction Phase Impact Assessment and Management Measures (Significance before Mitigation –SbM; Significance after Mitigation – SaM)
Name of Activity
Impact Area
Potential Impacts Rating Prior to Measures Mitigation Type Rating Post Measures
Activities Potential Impacts Aspect
Stat
us
Exte
nt
Du
rati
on
Pro
bab
ility
Inte
nsi
ty
SbM
Reversible (R),
Irreplaceable Damage (ID)
or Can be Avoided
(CbA)
Mitigation Measures
Stat
us
Exte
nt
Du
rati
on
Pro
bab
ility
Inte
nsi
ty
SaM
Planning Phase
Legal Requirements (Environmental Permits)
Legal Compliance
Unlawful water and waste (mine residue) activities, which could lead to NWA Directives and Section 24G Rectification fines.
Legal Compliance
N -4 -3 -2 -5 -14 CbA
A legal assessment of all activities and future planned activities must be undertaken annually to ensure that all activities are authorised.
P 4 3 5 5 17
The mine must familiarise themselves with the NEM:WA Regulations for the management of Mine Residue Deposits. Those included in previous approved EMPs are considered lawful under the NEM:WA, however where reworking, rehabilitation, stockpiling is taking place, not included into the previous EMP, these activities are unlawful and may require a Waste License.
All legally appointed personnel responsible or involved in water use activities and activities associated in the Environmental Authorisations on site must receive training on the requirements of the Environmental Authorisations and relevant Environmental Legislation.
Quarterly (construction); Biannually (after construction) integral audits must be undertaken during the construction phase, where after biannual audits can be undertaken, on the lawful implementation of the Environmental Authorisation
Water Use Licence must be available on site at all times.
The legal register must be updated to indicate all activities associated with Environmental Authorisations.
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Name of Activity
Impact Area
Potential Impacts Rating Prior to Measures Mitigation Type Rating Post Measures
Activities Potential Impacts Aspect
Stat
us
Exte
nt
Du
rati
on
Pro
bab
ility
Inte
nsi
ty
SbM
Reversible (R),
Irreplaceable Damage (ID)
or Can be Avoided
(CbA)
Mitigation Measures
Stat
us
Exte
nt
Du
rati
on
Pro
bab
ility
Inte
nsi
ty
SaM
Relocation of Eskom Powerline
Socio-Economic
The relocation of the Eskom 33kV powerlines feeding towards the Two Rivers Mine could temporarily disrupt Economic Activities in the area which the powerline supplies.
Electricity disruptions.
N -3 -1 -4 -4 -12 CbA
The mine should obtain approval from Eskom and affected parties regarding the relocation of the powerlines.
- -2 -1 -1 5 1 The mine should enter into discussions with Eskom and the affected parties to develop an operating procedure and time line for the removal of the powerlines.
The powerlines may not be removed without the required approvals by Eskom.
Development of Test Pits and additional investigations (geophysics and geotechnical investigations).
Ecology Removal of vegetation. Clearance of footprints.
N -1 -2 -2 -1 -6 CbA Restrict clearance to demarcated areas within the area of disturbance.
- -1 -1 -1 -1 -4
Construction Phase
Land and Footprint Clearance Topsoil Stripping and Stockpiling
Geology No direct impact - Activities will not be constructed over future planned mining areas.
- - - - - - - - - - - - - - -
Topography
Direct impact: Alteration of topography. Removal of vegetation and the associated shaping of the area will lead to change in topographical characteristics of the area. The impact is not considered significant due to the fairly flat nature of the topography and the location of the activities in the immediate vicinity of the existing plant area.
Footprint clearance
N -1 -3 -3 -2 -9 R
Construction areas must be clearly demarcated to control movement of personnel and vehicles, providing clear boundaries for construction sites in order to limit the spread of impacts. Markers and pegs will be erected and maintained along the boundaries of the working areas, access roads, haul roads and paths before commencing any work. If proved insufficient for control, these shall be replaced by fencing.
N -1 -1 -2 -1 -5
Designs of the facilities (Stockpile and Discard Dump) must be undertaken by a registered Engineer.
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Name of Activity
Impact Area
Potential Impacts Rating Prior to Measures Mitigation Type Rating Post Measures
Activities Potential Impacts Aspect
Stat
us
Exte
nt
Du
rati
on
Pro
bab
ility
Inte
nsi
ty
SbM
Reversible (R),
Irreplaceable Damage (ID)
or Can be Avoided
(CbA)
Mitigation Measures
Stat
us
Exte
nt
Du
rati
on
Pro
bab
ility
Inte
nsi
ty
SaM
Draw up a procedure clearly reflecting the method and phases of clearance of vegetation only in areas where construction will take place.
Removal of vegetation must be undertaken in a phased approach to limit surface exposure.
Erosion control measures must be implemented early in the construction phase.
Clean and dirty water separation must be implemented early in the construction phase, especially down-gradient of construction areas to ensure that the natural runoff patterns are impacted as little as possible.
Where possible existing roads must be utilised.
Linear infrastructure must follow for as far as practically possible the natural contours of the area.
Soil, Land Use and Land Capability
Direct impact: The removal and stockpiling of topsoil may lead to a loss of soil resource and land capability through erosion of the stockpiles and chemical and physical degradation. This impact is considered important due to the fact that the mine may be operating on a negative topsoil balance and therefore the retaining of suitable
Footprint clearance
N -1 -3 -5 -4 -13 CbA
Adhere to Soil Stripping, Soil Stockpiling and Soil Management Plan as part of the original EMP (Soil Utilisation Guideline). Prior to construction of the road the soil will be stripped and placed on a soil stockpile. Remove at least 30cm of soil or until hard rock is reached. Topsoil should be stockpiled on designated topsoil stockpiles, unless around linear
N -1 -1 -2 -1 -5
ENVIROGISTICS (PTY) LTD 10/12/17
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Name of Activity
Impact Area
Potential Impacts Rating Prior to Measures Mitigation Type Rating Post Measures
Activities Potential Impacts Aspect
Stat
us
Exte
nt
Du
rati
on
Pro
bab
ility
Inte
nsi
ty
SbM
Reversible (R),
Irreplaceable Damage (ID)
or Can be Avoided
(CbA)
Mitigation Measures
Stat
us
Exte
nt
Du
rati
on
Pro
bab
ility
Inte
nsi
ty
SaM
topsoil is important for successful rehabilitation.
infrastructure, where the topsoil could be stockpiled next to the linear structure. The topsoil management plan, 2016 should be implemented on all topsoil’s immediately to ensure that the integrity of the soils are maintained. Any new topsoil stockpiles should not exceed the recommended height in terms of the Topsoil Management Plan, 2016 of 2-4m. Where exceedance is present on existing facilities, erosion control measures should be implemented and vegetation establishment should be encouraged to assist in maintaining the structure of the soils for rehabilitation.
Direct impact: Soil compaction
Footprint clearance
N -1 -4 -2 -2 -9 CbA
The contractor will ensure that all activities, material and equipment storage and personnel movement take place within the designated area.
N -1 -1 -2 -1 -5
A site plan must be developed, indicating the following: Location of all approved activities; 1:100 year buffer around all watercourses; Location of the CBA and mark this as a no-go zone; All vegetation management zones as per the Biodiversity Action Plan.
All contractors must receive induction. The induction should be updated on site, to make provision for the site plan and a detailed explanation on the purpose of the no-go zones, presence of protected species, presence of the CBA and ESAs and the meeting thereof.
ENVIROGISTICS (PTY) LTD 10/12/17
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Name of Activity
Impact Area
Potential Impacts Rating Prior to Measures Mitigation Type Rating Post Measures
Activities Potential Impacts Aspect
Stat
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Exte
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Inte
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ty
SbM
Reversible (R),
Irreplaceable Damage (ID)
or Can be Avoided
(CbA)
Mitigation Measures
Stat
us
Exte
nt
Du
rati
on
Pro
bab
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Inte
nsi
ty
SaM
The management of topsoil stockpiles should be undertaken in terms of the Topsoil Management Plan, 2016 to ensure that the topsoil stockpiles maintain its integrity and are not subjected to compaction.
A fine system/disciplinary system must be implemented on site for all significant or recurring environmental non-compliances.
Site clearance and activities should be restricted to the approved footprint. Contractor’s areas should be established on already disturbed footprints.
Direct impact: Clearing vegetation will result in the exposure of soil, which may in turn lead to soil erosion. This impact is considered important due to the fact that the mine may be operating on a negative topsoil balance and therefore the retaining of suitable topsoil is important for successful rehabilitation.
Footprint clearance
N -1 -3 -5 -4 -13 CbA
Adhere to Storm water Management Plan, developed by SWS, 2016 or any approved update thereafter.
N -1 -2 -2 -1 -6
Ensure that all design drawings include effective erosion control measures.
Ensure the required erosion protection measures are monitored and corrected where necessary.
Natural vegetation establishment (self-succession) will be encouraged on cleared areas, topsoil stockpiles and the Discard Dump slopes.
If natural succession of vegetation is not established within one rainy season after the 1:3 slope of the Discard Dump has been achieved, hydro seeding will be undertaken.
The mine will investigate an appropriate seed mix for the rehabilitation purposes should self-succession not establish on rehabilitated sites.
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Name of Activity
Impact Area
Potential Impacts Rating Prior to Measures Mitigation Type Rating Post Measures
Activities Potential Impacts Aspect
Stat
us
Exte
nt
Du
rati
on
Pro
bab
ility
Inte
nsi
ty
SbM
Reversible (R),
Irreplaceable Damage (ID)
or Can be Avoided
(CbA)
Mitigation Measures
Stat
us
Exte
nt
Du
rati
on
Pro
bab
ility
Inte
nsi
ty
SaM
Areas of construction must be clearly demarcated.
No construction or project related activities may be undertaken outside of the demarcated areas.
Clean and dirty water systems must be established prior to construction.
Where vegetation cannot be established during the life of construction and operations, appropriate measure will be taken to control erosion. These will include grading of surfaces to prevent rapid run-off of storm water and / or the use of energy dissipaters.
The mine will ensure that erosion controls are included in the designs of all linear infrastructure (roads, conveyors, pipelines or open channels) and points of water discharge (where required).
Terrestrial Ecology (Fauna & Flora)
Direct & Cumulative impact: Unplanned loss of floral and faunal species of conservation importance is an important activity to assess and manage due to the fact that the planned activities are located within a CBA. The activity is regarded as a direct and cumulative impact as the loss of species will restrict the purpose and philosophy of the Regional Biodiversity Management Plans. However, saying this it is important to understand that the planned activities are not
Footprint clearance
N -3 -3 -5 -5 -16 CbA
Prior to the removal of plant species, the mine should appoint an ecologist to monitor and oversee the removal of all identified protected species, which should be removed under tree removal permits. All such species should be demarcated by signage or tape.
N -2 -1 -1 -2 -6 Natural vegetation establishment (self-succession) will be encouraged on cleared areas, topsoil stockpiles and the Discard Dump slopes.
If natural succession of vegetation is not established within one rainy season, after the 1:3 slope of the Discard Dump has been achieved, hydro seeding will be undertaken.
ENVIROGISTICS (PTY) LTD 10/12/17
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Name of Activity
Impact Area
Potential Impacts Rating Prior to Measures Mitigation Type Rating Post Measures
Activities Potential Impacts Aspect
Stat
us
Exte
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Du
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on
Pro
bab
ility
Inte
nsi
ty
SbM
Reversible (R),
Irreplaceable Damage (ID)
or Can be Avoided
(CbA)
Mitigation Measures
Stat
us
Exte
nt
Du
rati
on
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bab
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Inte
nsi
ty
SaM
located within pristine environments, but rather directly adjacent to the approved and operational plant, stockpiles and Discard Dump.
Obtain tree removal permit prior to the removal of any protected species, in the event that the existing permit (valid until 26 June 2018) has lapsed.
A fine system/disciplinary system must be implemented on site for all significant or recurring environmental non-compliances.
Site clearance and activities should be restricted to the approved footprint. Contractor’s areas should be established on already disturbed footprints.
All employees, or contractors on site, involved in this project, should receive a detailed induction on the expectations for the protection of fauna and flora on site.
Weed eradication should be implemented on site.
Direct impact: Displacement of faunal species and human/animal conflict. Due to the fact that the site is located within an existing operation mining footprint, and directly adjacent to the plant and perimeter of the existing water management facilities, the impact is not regarded to be as significant as it would have been for a green field’s site.
Footprint clearance
N -1 -2 -4 -3 -10 CbA
A record of any animal fatalities should be kept on site. The reason for the fatality and action to avoid such in the future (if possible) should be stated.
N -1 -1 -3 -1 -6
Construction and site clearance should be undertaken in a systematic approach to allow animals to relocate from the site where construction will take place.
All employees, or contractors on site, involved in this project, should receive a detailed induction on the expectations for the protection of fauna and flora on site.
Clearance of vegetation must be undertaken in such a manner as to provide sufficient time for animals to relocate.
Direct impact: Loss of ecological connectivity and ecosystem functioning. Due
Footprint clearance
N -1 -2 -4 -3 -10 R No construction or project related activities may be undertaken outside of the demarcated areas.
N -1 -1 -1 -1 -4
ENVIROGISTICS (PTY) LTD 10/12/17
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Name of Activity
Impact Area
Potential Impacts Rating Prior to Measures Mitigation Type Rating Post Measures
Activities Potential Impacts Aspect
Stat
us
Exte
nt
Du
rati
on
Pro
bab
ility
Inte
nsi
ty
SbM
Reversible (R),
Irreplaceable Damage (ID)
or Can be Avoided
(CbA)
Mitigation Measures
Stat
us
Exte
nt
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Inte
nsi
ty
SaM
to the fact that the site is located within an existing operation mining footprint, and directly adjacent to the plant and perimeter of the existing water management facilities, the impact is not regarded to be as significant as it would have been for a green field’s site.
The construction area can be isolated by means of a chain link fence in order to prevent animals on local migrations entering the area and being killed.
In the establishment of fences, erect fences in such a manner as to limit the potential of animals to enter the plant and silo areas. This could involve the placement of rocks and materials at on the surface of the fences.
Direct impact: The disturbance of the cleared areas may allow the establishment of alien invasive vegetation. Increased prevalence of exotic invasive species: The fact that the area will be cleared for construction creates niches that can be colonised by exotic and/or invasive species. This is compounded by the fact that trucks and other heavy machinery often act as vectors for seeds of these species.
Footprint clearance
N -2 -4 -5 -1 -12 CbA
Weed eradication should be implemented on site.
N -1 -1 -2 -1 -5
Areas of construction must be clearly demarcated.
No construction or project related activities may be undertaken outside of the demarcated areas.
Direct impact: Increased vibration and noise will have a significant effect mainly on fauna species in the immediate vicinity of the development, due to the heavy machinery utilised, and the presence of the activities towards the Springkaanspruit
Footprint clearance
N -1 -2 -3 -2 -8 CbA
Equipment will be well maintained to reduce excessive noise creation.
N -1 -2 -2 -1 -6
Activities should remain within the demarcated sites.
Activities will be restricted to the day time.
ENVIROGISTICS (PTY) LTD 10/12/17
Dwarsrivier Chrome Mine: Basic Assessment Report and Management Plan for the Expansion of the Met Grade Chrome Stockpile and Discard Dump with Ancillary Infrastructure Mining Right Ref: 30/5/1/3/2/1(179) EM Project Ref: 21714 Version: FINAL
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Name of Activity
Impact Area
Potential Impacts Rating Prior to Measures Mitigation Type Rating Post Measures
Activities Potential Impacts Aspect
Stat
us
Exte
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Du
rati
on
Pro
bab
ility
Inte
nsi
ty
SbM
Reversible (R),
Irreplaceable Damage (ID)
or Can be Avoided
(CbA)
Mitigation Measures
Stat
us
Exte
nt
Du
rati
on
Pro
bab
ility
Inte
nsi
ty
SaM
and Dwarsrivier. Direct impact: Vibration can also affect a number of subterranean fauna taxa, such as burrowing mammals, reptiles and arthropods. Vibration affects these animals by causing the collapsing of burrows, and causing these animals to leave the area due to the vibration. Direct impact: Noise will also affect a wide range of taxa including avifauna, mammals, reptiles, amphibians and arthropods.
Direct and Cumulative Impact: Habitat degradation due to dust: Increased dust will occur in all areas where vegetation is cleared. Dust will be caused by excavation, and construction. Dust in the area will be greatly increased due to the dry weather conditions and the nature of the soil in the area. Dust settling on plant material can reduce the amount of light reaching the chlorophyll in the leaves, thereby reducing photosynthesis, which in turn
Dust dispersion
N -2 -2 -3 -2 -9 CbA
Maintain the current air quality monitoring stations that determine fallout and implement respirable dust (PM10) monitoring that could arise from the mining activities. Implement dust suppression in and around the construction area where required.
N -1 -1 -2 -1 -5
ENVIROGISTICS (PTY) LTD 10/12/17
Dwarsrivier Chrome Mine: Basic Assessment Report and Management Plan for the Expansion of the Met Grade Chrome Stockpile and Discard Dump with Ancillary Infrastructure Mining Right Ref: 30/5/1/3/2/1(179) EM Project Ref: 21714 Version: FINAL
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Name of Activity
Impact Area
Potential Impacts Rating Prior to Measures Mitigation Type Rating Post Measures
Activities Potential Impacts Aspect
Stat
us
Exte
nt
Du
rati
on
Pro
bab
ility
Inte
nsi
ty
SbM
Reversible (R),
Irreplaceable Damage (ID)
or Can be Avoided
(CbA)
Mitigation Measures
Stat
us
Exte
nt
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bab
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Inte
nsi
ty
SaM
reduces plant productivity, growth and recruitment.
Direct Impact: Increased erosion can eventually lead to the loss of vegetation and habitats for further species. Soils in the area are prone to erosion in areas where vegetation is cleared, this is further compounded by the fact that precipitation in the area occurs through heavy rainfall events in in the form of thundershowers in summer. Furthermore large areas will be cleared before construction leaving these areas prone to erosion.
Footprint clearance
N -3 -3 -5 -5 -16 CbA
Ensure the required erosion protection measures are monitored and corrected where necessary.
N -1 -1 -2 -2 -6
Storm water management plan should be implemented prior to construction to ensure that runoff does not lead to the formation of erosion gulleys.
Where vegetation cannot be established during the life of construction and operations, appropriate measure will be taken to control erosion. These will include grading of surfaces to prevent rapid run-off of storm water and / or the use of energy dissipaters.
An erosion monitoring and mitigation plan should be put in place.
Wetland
No direct impact. The National Freshwater Ecosystem Priority Areas (NFEPA) wetlands present on site, is in fact the mines' dirty water RWDs and not wetlands. No activities will be undertaken within 500m of any wetland system based on the NFEPA sites, if the RWDs are not considered.
- - 0 0 0 0 0 - - - 0 0 0 0 0
Riparian Habitat
The Sprinkaan Spruit is located just 100m to the south of the proposed infrastructure construction (workshops, loadout and sewage facilities). The Dwarsrivier is located to the
Footprint clearance
N -3 -2 -2 -3 -10 CbA
Remain at all times outside of the 1:100 year flood line of the watercourses. Ongoing Biodiversity Monitoring should be undertaken at the upstream and downstream points.
N -1 -1 -1 -2 -5
ENVIROGISTICS (PTY) LTD 10/12/17
Dwarsrivier Chrome Mine: Basic Assessment Report and Management Plan for the Expansion of the Met Grade Chrome Stockpile and Discard Dump with Ancillary Infrastructure Mining Right Ref: 30/5/1/3/2/1(179) EM Project Ref: 21714 Version: FINAL
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Name of Activity
Impact Area
Potential Impacts Rating Prior to Measures Mitigation Type Rating Post Measures
Activities Potential Impacts Aspect
Stat
us
Exte
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Du
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Pro
bab
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Inte
nsi
ty
SbM
Reversible (R),
Irreplaceable Damage (ID)
or Can be Avoided
(CbA)
Mitigation Measures
Stat
us
Exte
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Inte
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ty
SaM
west of the proposed loadout facility (520m) and Discard Dump (220m).
Ongoing surface water monitoring should be undertaken at the upstream and downstream monitoring points. The storm water management plans should be implemented in and around the facilities to ensure that dirty water runoff or water with high sediment loads do not enter the existing watercourses.
Hydrology
Direct impact: The removal of vegetation can lead to increased surface runoff, which may in turn alter natural surface water flows and increase siltation of watercourses as well as pollution control facilities.
Footprint clearance
N -3 -2 -2 -3 -10 CbA
Rehabilitate open areas as soon as practically possible. Self-succession should be encouraged.
N -1 -1 -1 -2 -5
The storm water management plans should be implemented in and around the facilities to ensure that dirty water runoff or water with high sediment loads do not enter the existing watercourses.
Limit the areas to be cleared to the demarcated sites.
Geohydrology No direct impact during the construction phase.
- - 0 0 0 0 0 - - - 0 0 0 0 0
Heritage
No direct impact is foreseen in this area. However, due to the nature of heritage sites, graves may be uncovered during the clearance activities.
Footprint clearance and foundation excavation.
N -3 -3 -3 -4 -13 CbA
In the event that heritage artefacts or graves are encountered during the excavation activities, all activities must cease and the SAHRA should be contacted to determine the way forward before construction may continue.
N -1 -1 -2 3 -1
Visual Direct impact: soil stripping and footprint clearance
Footprint clearance
N -1 -2 -1 0 -4 CbA Stripping of vegetation and soils should be undertaken within the demarcated areas.
N -1 -1 -1 0 -3
Air Quality Direct impact: Dust-fallout Footprint clearance
N -2 -2 -3 -2 -9 CbA
Utilised the existing monitoring network to monitor dust fall out in and around the construction area. N -1 -1 -2 -1 -5 Strictly enforced speed limits on all roads
Limit site clearance to designated areas.
Noise The area is located within the mining area. Noise impacts
Removal of topsoil.
N -1 -2 -1 -1 -5 CbA Equipment will be well maintained to reduce excessive noise creation.
N -1 -1 -1 -1 -4
ENVIROGISTICS (PTY) LTD 10/12/17
Dwarsrivier Chrome Mine: Basic Assessment Report and Management Plan for the Expansion of the Met Grade Chrome Stockpile and Discard Dump with Ancillary Infrastructure Mining Right Ref: 30/5/1/3/2/1(179) EM Project Ref: 21714 Version: FINAL
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Name of Activity
Impact Area
Potential Impacts Rating Prior to Measures Mitigation Type Rating Post Measures
Activities Potential Impacts Aspect
Stat
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Exte
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Du
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Pro
bab
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Inte
nsi
ty
SbM
Reversible (R),
Irreplaceable Damage (ID)
or Can be Avoided
(CbA)
Mitigation Measures
Stat
us
Exte
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Inte
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ty
SaM
are not considered to be significant but can occur during excavation and construction activities.
Activities will be restricted to the day time.
Social No direct impact - - 0 0 0 0 0 - - - 0 0 0 0 0
Establishment of Surface Infrastructure
Geology No direct impact - Activities will not be constructed over future planned mining areas.
- - - - - - - - - - - - - - -
Topography
During the site clearance activity, the required storm water management systems and shaping of land would have been completed. Therefore no further impact on the topography is expected
- - - - - - - - - - - - - - -
Soil, Land Use and Land Capability
No further impact on soil compaction is expected as all soils would have been removed during the site clearance activities.
- - - - - - - - - - - - - - -
Direct impact: Construction activities with surrounding exposed soil may in turn lead to soil erosion.
Active construction
N -1 -2 -3 -4 -10 CbA
Ensure that all design drawings include effective erosion control measures and that these are implemented during the establishment of the infrastructure.
N -1 -1 -2 -1 -5
Ensure the required erosion protection measures are monitored and corrected where necessary.
Vegetation established as part of the site clearance activities, will be monitored and assessed to ensure that these remain well established.
Areas of construction must be clearly demarcated. No construction or project related activities may be undertaken outside of the demarcated areas.
ENVIROGISTICS (PTY) LTD 10/12/17
Dwarsrivier Chrome Mine: Basic Assessment Report and Management Plan for the Expansion of the Met Grade Chrome Stockpile and Discard Dump with Ancillary Infrastructure Mining Right Ref: 30/5/1/3/2/1(179) EM Project Ref: 21714 Version: FINAL
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Name of Activity
Impact Area
Potential Impacts Rating Prior to Measures Mitigation Type Rating Post Measures
Activities Potential Impacts Aspect
Stat
us
Exte
nt
Du
rati
on
Pro
bab
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Inte
nsi
ty
SbM
Reversible (R),
Irreplaceable Damage (ID)
or Can be Avoided
(CbA)
Mitigation Measures
Stat
us
Exte
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Inte
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ty
SaM
Clean and dirty water systems must be established prior to construction and must be maintained throughout the life of mine.
Where vegetation cannot be established during the life of construction and operations, appropriate measure will be taken to control erosion. These will include grading of surfaces to prevent rapid run-off of storm water and / or the use of energy dissipaters.
Where erosion gulley are formed, these will be recorded on the IsoMetrix system for immediate action.
Terrestrial Ecology (Fauna & Flora)
All impacts are assessed under Footprint Clearance.
- - 0 0 0 0 0 CbA - - - - - - -
Wetland No direct impact - - 0 0 0 0 0 - - - 0 0 0 0 0
Hydrology All impacts are assessed under Footprint Clearance.
- - 0 0 0 0 0 CbA - - - - - - -
Geohydrology
Direct impact. The use of waste rock in the compaction of the Discard Dump should not lead to an impact on the groundwater resources as the material is not considered a pollutant. According to Ivusi [Ivusi 2009] the outcome of acid-base accounting (ABA) leach tests results undertaken on tailings and waste rock samples at Dwarsrivier in 2006 was that the material is relatively inert.
Active construction
- -2 -3 -1 -3 -9 CbA
In order to reduce long-term impacts associated with the Discard Dump extension, it is recommended that the base of the facility is compacted and that the site is rehabilitated to reduce the rate of recharge to near-natural conditions upon closure. The design of the Discard Dump Footprint should be undertaken in terms of signed of engineering drawings. The correct compaction of the footprint should be undertaken to ensure that the liner is fit for purpose.
N -1 -2 -1 -1 -5
ENVIROGISTICS (PTY) LTD 10/12/17
Dwarsrivier Chrome Mine: Basic Assessment Report and Management Plan for the Expansion of the Met Grade Chrome Stockpile and Discard Dump with Ancillary Infrastructure Mining Right Ref: 30/5/1/3/2/1(179) EM Project Ref: 21714 Version: FINAL
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Name of Activity
Impact Area
Potential Impacts Rating Prior to Measures Mitigation Type Rating Post Measures
Activities Potential Impacts Aspect
Stat
us
Exte
nt
Du
rati
on
Pro
bab
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Inte
nsi
ty
SbM
Reversible (R),
Irreplaceable Damage (ID)
or Can be Avoided
(CbA)
Mitigation Measures
Stat
us
Exte
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bab
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Inte
nsi
ty
SaM
Exemption in terms of GN704 (Regulation 5) should be obtained from the DWS for the use of the Waste Rock in the construction of the facility. Groundwater monitoring should be undertaken to ensure that the facilities are operated in a manner as not contributed to the current and historic pollution plumes - this should include the implementation of the two new monitoring boreholes as proposed in the numerical model.
Heritage No direct impact - - 0 0 0 0 0 - - - - - - - -
Visual Direct impact: Establishment of infrastructure.
Active construction
N -1 -1 -1 0 -3 CbA Activities should be restricted within the approved footprints.
N -1 -1 -1 0 -3
Air Quality All impacts are assessed under Footprint Clearance.
- - 0 0 0 0 0 CbA - - - - - - -
Noise All impacts are assessed under Footprint Clearance.
- - 0 0 0 0 0 CbA - - - - - - -
Social No direct impact - - 0 0 0 0 0 CbA - - - - - - -
Waste Management and Handling Hydrocarbon spills within the Mining Area and the management of Domestic and Hazardous Waste
Geology No direct impact. - - - - - - - - - - - - - - -
Topography No direct impact. - - - - - - - - - - - - - - -
Soils Contamination of soil resources due to hydrocarbon spills.
Spills and Release of Contaminants.
N -1 -2 -4 -4 -11 CBA
Storage of fuels and oils, the refuelling of vehicles and equipment maintenance must be limited to designated, bunded (bunds to be 110% of volume of the materials stored) areas.
N -1 -2 -1 -1 -5
All fuels and soils must be stored in appropriate containers.
Chemicals and hazardous material must be stored in suitable containers, fit for purpose and in line with SDS requirements.
Where drip trays are too small, specially prepared, non-pervious bunds with
ENVIROGISTICS (PTY) LTD 10/12/17
Dwarsrivier Chrome Mine: Basic Assessment Report and Management Plan for the Expansion of the Met Grade Chrome Stockpile and Discard Dump with Ancillary Infrastructure Mining Right Ref: 30/5/1/3/2/1(179) EM Project Ref: 21714 Version: FINAL
P a g e 101 | 393
Name of Activity
Impact Area
Potential Impacts Rating Prior to Measures Mitigation Type Rating Post Measures
Activities Potential Impacts Aspect
Stat
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Exte
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Du
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bab
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Inte
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SbM
Reversible (R),
Irreplaceable Damage (ID)
or Can be Avoided
(CbA)
Mitigation Measures
Stat
us
Exte
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bab
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Inte
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SaM
solution trenches must be used to capture spillages
Oils and potentially hazardous materials must be disposed of at a licensed facility and waste certificates obtained.
A spill kit must be provided to be used in the event of a spill.
If a spill occurs, the contaminated soil must be removed immediately. Contaminated soil must be stored according to best practices until it can be disposed of at a suitably licensed facility.
Safety signage must be used at designated storage areas.
All workers must undergo an induction which includes environmental awareness training to make them aware of the environmental incident management procedures as well as the importance of complying with management measures.
Ecology
The unmanaged disposal of waste, could result in the spread of invader species, as well as the influx of opportunistic species.
Loss of Ecology and the influx of Opportunistic Species.
N -2 -3 -3 -4 -12 CbA
Develop dedicated waste handling areas; prevent access to rodents and opportunistic species; prevent the spread of waste. N -1 -1 -2 -1 -5 Develop dedicated waste handling areas, fit for purpose and prevent the spread of waste.
Wetlands No direct impact. - - - - - - - - - - - - - - -
Riparian Habitat
The Sprinkaan Spruit is located just 100m to the south of the proposed infrastructure construction (workshops, loadout and sewage facilities). The Dwarsrivier is located to the west of the proposed loadout
Airborne littering
N -3 -2 -2 -3 -10 CbA
Remain at all times outside of the 1:100 year flood line of the watercourses. Ongoing Biomonitoring Monitoring should be undertaken at the upstream and downstream points. Ongoing surface water monitoring should
N -1 -1 -1 -2 -5
ENVIROGISTICS (PTY) LTD 10/12/17
Dwarsrivier Chrome Mine: Basic Assessment Report and Management Plan for the Expansion of the Met Grade Chrome Stockpile and Discard Dump with Ancillary Infrastructure Mining Right Ref: 30/5/1/3/2/1(179) EM Project Ref: 21714 Version: FINAL
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Name of Activity
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Potential Impacts Rating Prior to Measures Mitigation Type Rating Post Measures
Activities Potential Impacts Aspect
Stat
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Pro
bab
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Inte
nsi
ty
SbM
Reversible (R),
Irreplaceable Damage (ID)
or Can be Avoided
(CbA)
Mitigation Measures
Stat
us
Exte
nt
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Inte
nsi
ty
SaM
facility (520m) and Discard Dump (220m). The presence of littering could enter the watercourses in the area if not managed.
be undertaken at the upstream and downstream monitoring points. The storm water management plans should be implemented in and around the facilities to ensure that dirty water runoff or water with high sediment loads do not enter the existing watercourses. Develop dedicated waste handling areas, fit for purpose and prevent the spread of waste.
Surface Water
Handling of Hazardous Waste within workshops and general mine area could contaminate the dirty water storage areas. The water is then reused in the system and could have impacts on the integrity of the storm water system and also the production.
Spill and Release of Waste Material and Contaminated Water.
N -3 -2 -2 -4 -11 CbA
Clean and Dirty water separation systems should be incorporated in terms of the 2016 SWMP or any approved update thereafter.
N -1 -1 -2 -2 -6
A detailed waste management strategy will be established and implemented, which will clearly demarcate the containments for different waste streams.
Waste management training must be implemented on site.
Clear signs informing staff of waste management practices must be implemented on site.
Hazardous waste handling should only take place within bunded and/or lined areas.
Hazardous waste should be removed by a licenced removal company and taken to a suitable and licenced landfill site.
Documentation of removal and safe disposal must be available on site.
The mine will adopt a cradle-to grave approach to ensure that the waste is
ENVIROGISTICS (PTY) LTD 10/12/17
Dwarsrivier Chrome Mine: Basic Assessment Report and Management Plan for the Expansion of the Met Grade Chrome Stockpile and Discard Dump with Ancillary Infrastructure Mining Right Ref: 30/5/1/3/2/1(179) EM Project Ref: 21714 Version: FINAL
P a g e 103 | 393
Name of Activity
Impact Area
Potential Impacts Rating Prior to Measures Mitigation Type Rating Post Measures
Activities Potential Impacts Aspect
Stat
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Exte
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Du
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Pro
bab
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Inte
nsi
ty
SbM
Reversible (R),
Irreplaceable Damage (ID)
or Can be Avoided
(CbA)
Mitigation Measures
Stat
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Inte
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SaM
removed and disposed of in a legally compliant manner.
Weekly inspections of Storm Water Management Systems must be undertaken. Any blockages or maintenance requirements must be documented and an action plan developed.
Handling and Storing of Domestic Waste should have no impact on the surface water resources due to the location of the facility. However, incorrect disposal of waste could hamper the integrity of the storm water system.
Spill and Release of Waste Material and Contaminated Water.
N/A -1 -2 -3 -3 -9 CbA
Clean and Dirty water separation systems should be incorporated in terms of the 2016 SWMP or any approved update thereafter.
N -1 -1 -2 -1 -5
Waste management training must be implemented on site.
Weekly inspections of Storm Water Management Systems must be undertaken. Any blockages or maintenance requirements must be documented and an action plan developed.
Clear signs informing staff of waste management practices must be implemented on site.
Access control must be strictly enforced.
The berm around upstream of the facility must be maintained.
Recycling practices must be investigated and implemented on site.
Groundwater Large scale hydrocarbon spills could be present at the mining area
Spill and Release of Waste Material.
N -1 -1 -4 -4 -10 R
Clean and Dirty water separation systems should be incorporated in terms of the 2016 SWMP.
N -1 -1 -2 -1 -5 No activities associated with hydrocarbons and/or chemicals may be undertaken outside of an effectively designed and contained area.
ENVIROGISTICS (PTY) LTD 10/12/17
Dwarsrivier Chrome Mine: Basic Assessment Report and Management Plan for the Expansion of the Met Grade Chrome Stockpile and Discard Dump with Ancillary Infrastructure Mining Right Ref: 30/5/1/3/2/1(179) EM Project Ref: 21714 Version: FINAL
P a g e 104 | 393
Name of Activity
Impact Area
Potential Impacts Rating Prior to Measures Mitigation Type Rating Post Measures
Activities Potential Impacts Aspect
Stat
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Exte
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Du
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Pro
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Inte
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SbM
Reversible (R),
Irreplaceable Damage (ID)
or Can be Avoided
(CbA)
Mitigation Measures
Stat
us
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Inte
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SaM
All used oils must be removed from site by a licensed company and disposed of at a suitably licensed site.
Any spills occurring during the collection process must be cleaned up immediately.
Any significant spills must be captured in the incident reports and must be reported to the relevant department (LDEDET, Catchment Management Agency/DWS).
All equipment and machinery should be kept in good working order.
A clean up procedure (i.e. Works Instruction) must be in place.
Handling or Hazardous Waste within workshops and general mine area.
Spill and Release of Waste Material and Contaminated Water.
N -2 -2 -2 -4 -10 CbA
Clean and Dirty water separation systems should be incorporated in terms of the 2016 SWMP or any approved update thereafter.
N -1 -1 -2 -2 -6
The workshop should be designed with the suitable waste containment measures (berms, sumps, oil separators).
Waste management training must be implemented on site.
Clear signs informing staff of waste management practices must be implemented on site.
Hazardous waste handling should only take place within bunded and/or lined areas, with a capacity of at least 110% of the volume stored.
Hazardous waste should be removed by a licenced removal company and taken to a suitable and licenced landfill site.
Documentation of removal and safe disposal must be available on site.
Handling and Storing of Domestic Waste
Spill and Release of
N -3 -3 -3 -3 -12 CbA Clean and Dirty water separation systems should be incorporated in terms of the
N -2 -3 -2 -2 -9
ENVIROGISTICS (PTY) LTD 10/12/17
Dwarsrivier Chrome Mine: Basic Assessment Report and Management Plan for the Expansion of the Met Grade Chrome Stockpile and Discard Dump with Ancillary Infrastructure Mining Right Ref: 30/5/1/3/2/1(179) EM Project Ref: 21714 Version: FINAL
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Name of Activity
Impact Area
Potential Impacts Rating Prior to Measures Mitigation Type Rating Post Measures
Activities Potential Impacts Aspect
Stat
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Exte
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Du
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Pro
bab
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Inte
nsi
ty
SbM
Reversible (R),
Irreplaceable Damage (ID)
or Can be Avoided
(CbA)
Mitigation Measures
Stat
us
Exte
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Inte
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SaM
Waste Material and Contaminated Water.
2016 SWMP or any approved update thereafter.
Waste management training must be implemented on site.
Clear signs informing staff of waste management practices must be implemented on site.
All waste must be removed by licensed contractors and disposed of at a licensed landfill site.
As a duty of care and the cradle to grave principles, the mine should regularly inspect disposal site to ensure that best practices are implemented.
Recycling practices must be investigated and implemented on site where practical.
Groundwater monitoring must be undertaken in such a manner as to ensure that any potential impacts from the landfill site can be detected.
Air Quality No direct impact - - - - - - - - - - - - - - -
Heritage No direct impact - - - - - - - - - - - - - - -
Noise No direct impact - - - - - - - - - - - - - - -
Visual No direct impact - - - - - - - - - - - - - - -
Social No direct impact - - - - - - - - - - - - - - -
ENVIROGISTICS (PTY) LTD 10/12/17
Dwarsrivier Chrome Mine: Basic Assessment Report and Management Plan for the Expansion of the Met Grade Chrome Stockpile and Discard Dump with Ancillary Infrastructure Mining Right Ref: 30/5/1/3/2/1(179) EM Project Ref: 21714 Version: FINAL
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Table 48: Operational Phase Impact Assessment and Management Measures (Significance before Mitigation –SbM; Significance after Mitigation – SaM)
Name of Activity
Impact Area
Potential Impacts Rating Prior to Measures Mitigation Type Rating Post Measures
Soils Erosion around the fence infrastructure could lead to a loss of soil resources.
Loss of Soil Resources
N -3 -3 -3 -4 -13 CbA
The areas where infrastructure are implemented (i.e. fence poles) should be equipped with erosion control measures (gabions) to reduce the potential for erosion. Use of biodegradable hessian sheeting must be made to prevent sedimentation of downstream resources.
N -1 -1 -1 -1 -4
Ecology No impact - - - - - - - - - - - - - - -
Wetlands No impact - - - - - - - - - - - - - - -
Riparian Habitat
Impact on the flow of the river could impact the riparian habitat.
Loss of aquatic character.
N -3 -2 -2 -3 -10 CbA
Limit vehicle/machinery activity within the active channel as well as in the riparian zone to what is absolutely essential. Disturbances to the riparian zone should be limited as far as possible. Re-fuelling of vehicles to take place outside of the riparian zone & associated buffer zones, on sealed surfaces. Activities should not obstruct flow. Where possible, existing access roads should be used for monitoring purposes so as to minimise the compaction of soils and loss of both riparian and instream habitat. Hot spots for build-up of debris must be identified and debris must be regularly
N -1 -1 -1 -2 -5
ENVIROGISTICS (PTY) LTD 10/12/17
Dwarsrivier Chrome Mine: Basic Assessment Report and Management Plan for the Expansion of the Met Grade Chrome Stockpile and Discard Dump with Ancillary Infrastructure Mining Right Ref: 30/5/1/3/2/1(179) EM Project Ref: 21714 Version: FINAL
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Name of Activity
Impact Area
Potential Impacts Rating Prior to Measures Mitigation Type Rating Post Measures
Activities Potential Impacts Aspect
Stat
us
Exte
nt
Du
rati
on
Pro
bab
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Inte
nsi
ty
SbM
Reversible (R),
Irreplaceable Damage (ID)
or Can be Avoided
(CbA)
Mitigation Measures
Stat
us
Exte
nt
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bab
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Inte
nsi
ty
SaM
removed to prevent flooding and damage of infrastructure. In this regard, special mention is made of periods following high rainfall and subsequent high instream water volumes. During monitoring, always use the shortest routes possible so as to minimise disturbance and loss of habitat both instream as well as in the riparian zone. The riparian zone must be monitored for alien vegetation encroachment and all alien vegetation/weeds must be removed according to a suitable alien vegetation control plan. Any erosion or gully formation must be identified on an ongoing basis and re-profiled and revegetated accordingly.
Surface Water
Impact of fence collaption during floods.
Both the Groot-Dwars River, as well as the unnamed tributary, are subject to extremely high flow and flood conditions during periods of high rainfall. Thus, each of the fence crossing
N -1 -2 -2 -3 -8 CbA
Each fence will thus need to be designed in such a way as to: o absorb the impact of a flood; and o restore its function post‐flood, with limited repairs.
N -1 -1 -1 -1 -4
Design options to enable a fence to be re‐established and repaired if necessary post‐flood include: o installing collapsible fences; or o installing sacrificial fences.
The fences must be built independently of other fences, to avoid damage to large lengths of fencing
If possible, the fences should be built in a straight section of the waterway or at the crossover point in the middle of a
ENVIROGISTICS (PTY) LTD 10/12/17
Dwarsrivier Chrome Mine: Basic Assessment Report and Management Plan for the Expansion of the Met Grade Chrome Stockpile and Discard Dump with Ancillary Infrastructure Mining Right Ref: 30/5/1/3/2/1(179) EM Project Ref: 21714 Version: FINAL
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Name of Activity
Impact Area
Potential Impacts Rating Prior to Measures Mitigation Type Rating Post Measures
Activities Potential Impacts Aspect
Stat
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Exte
nt
Du
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Pro
bab
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Inte
nsi
ty
SbM
Reversible (R),
Irreplaceable Damage (ID)
or Can be Avoided
(CbA)
Mitigation Measures
Stat
us
Exte
nt
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Inte
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ty
SaM
will need to be designed in such a way as to be resilient to flood damage.
meander, where the main flow is naturally directed to the centre of the channel
The point of crossing must consider natural high points on the longitudinal profile, thus reducing the fence height.
Groundwater
No impact - - - - - - - - - - - - - - -
Heritage No impact - - - - - - - - - - - - - - -
Air Quality No impact - - - - - - - - - - - - - - -
Visual No impact - - - - - - - - - - - - - - -
Noise No impact - - - - - - - - - - - - - - -
Social No impact - - - - - - - - - - - - - - -
Operation of Discard Dump and Met Grade Product Stockpile
Geology No direct impact. Impacts are addressed during the construction phase.
- - - - - - - - - - - - - - -
Topography
The ongoing development of the Discard Dump and Plant Stockpile will result in an ongoing change in the topography.
Ongoing deposition of material (product and discard).
N -2 -3 -4 -3 -12 R
The slopes of the Met Grade Plant stockpile should be developed and managed in such a manner that the facility remains within the contained footprint and at a stable slope.
N -1 -2 -2 -1 -6
The mine should initiate the site selection process for the long term Discard Dump facility as a matter of urgency.
For the Discard Dump expansion, at closure the side slopes will have been constructed at an angle of no steeper than 1:3. The Discard Dump will be covered with a course (gravel/topsoil) medium or a medium as prescribed by an Ecologist. Should it be determined that vegetation self-succession does not establish, a growth medium will be placed on top of the rock and vegetation re-established.
ENVIROGISTICS (PTY) LTD 10/12/17
Dwarsrivier Chrome Mine: Basic Assessment Report and Management Plan for the Expansion of the Met Grade Chrome Stockpile and Discard Dump with Ancillary Infrastructure Mining Right Ref: 30/5/1/3/2/1(179) EM Project Ref: 21714 Version: FINAL
P a g e 109 | 393
Name of Activity
Impact Area
Potential Impacts Rating Prior to Measures Mitigation Type Rating Post Measures
Activities Potential Impacts Aspect
Stat
us
Exte
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Du
rati
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Pro
bab
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Inte
nsi
ty
SbM
Reversible (R),
Irreplaceable Damage (ID)
or Can be Avoided
(CbA)
Mitigation Measures
Stat
us
Exte
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Inte
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SaM
Ongoing vegetation of slopes should be implemented, this will be specifically required on the side of the current Discard Dump which will be expanded.
Where possible mine residue should be used to backfill voids according to the approved EMP.
Designs should take cognizance of topographical features of the site.
The Discard Dump should remain within authorised footprint, design and height conditions.
Where possible, and under Environmental Authorisations the mine should implemented the waste hierarchy in an attempt to reduce the disposal of waste rock on site.
Berms will be constructed upstream of the Discard Dump to ensure that clean water is kept separate from dirty water where required.
Soils
The unmanaged disposal of Discard and the overflow of product from the demarcated areas could result in an impact beyond the designated footprints.
Loss of Soil Resources
N -3 -3 -3 -4 -13 CbA Stockpiling of waste and product should take place within the demarcated areas.
N -1 -1 -2 -1 -5
Ecology
The unmanaged disposal of Discard and the overflow of product from the demarcated areas could result in an impact beyond the designated footprints.
Loss of Vegetation
N -3 -3 -3 -4 -13 CbA Stockpiling of waste and product should take place within the demarcated areas.
N -1 -1 -2 -1 -5
Presence of invader species could impact on the natural
N -2 -3 -4 -4 -13 CbA A search must be undertaken prior to clearance for indigenous plants that can be
N -1 -1 -2 -1 -5
ENVIROGISTICS (PTY) LTD 10/12/17
Dwarsrivier Chrome Mine: Basic Assessment Report and Management Plan for the Expansion of the Met Grade Chrome Stockpile and Discard Dump with Ancillary Infrastructure Mining Right Ref: 30/5/1/3/2/1(179) EM Project Ref: 21714 Version: FINAL
P a g e 110 | 393
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Inte
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Reversible (R),
Irreplaceable Damage (ID)
or Can be Avoided
(CbA)
Mitigation Measures
Stat
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Inte
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SaM
succession of vegetation on the slopes of Discard Dumps.
Increase in invader species.
carefully removed and stored for rehabilitation.
Where self-succession does not establish, harvested seeds and plants must be used in concurrent rehabilitation for any areas along the area which may be affected.
Compile list of protected and Red Data species, compile relocation programme.
The plan for vegetation clearance, must be developed and implemented prior to site clearance.
Seeds of indigenous plants must also be collected during the clearance activities where practical.
All employees, or contractors on site, involved in this project, must undergo an induction prior to construction where they will be made aware of the footprint, prohibited areas and the importance of compliance with management measures, as well as potential penalties for noncompliance.
No open fires must be allowed.
Vegetation clearance must be limited to within the footprint area
A weed eradication programme must be implemented on site and enforced. This programme must stipulate the monitoring plan, which should include: capturing of areas where invader species are present; action plan to remove these; % successful removal).
Wetlands No direct impact. - - - - - - - - - - - - - - -
ENVIROGISTICS (PTY) LTD 10/12/17
Dwarsrivier Chrome Mine: Basic Assessment Report and Management Plan for the Expansion of the Met Grade Chrome Stockpile and Discard Dump with Ancillary Infrastructure Mining Right Ref: 30/5/1/3/2/1(179) EM Project Ref: 21714 Version: FINAL
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Name of Activity
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Inte
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Reversible (R),
Irreplaceable Damage (ID)
or Can be Avoided
(CbA)
Mitigation Measures
Stat
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bab
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Inte
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ty
SaM
Riparian Habitat
The unmanaged disposal of Discard and the overflow of product from the demarcated areas could result in an impact beyond the designated footprints.
Loss of aquatic character.
N -3 -2 -2 -3 -10 CbA
Remain at all times outside of the 1:100 year flood line of the watercourses. Stockpiling of waste and product should take place within the demarcated areas. Ongoing Biomonitoring Monitoring should be undertaken at the upstream and downstream points. Ongoing surface water monitoring should be undertaken at the upstream and downstream monitoring points. The storm water management plans should be implemented in and around the facilities to ensure that dirty water runoff or water with high sediment loads do not enter the existing watercourses. Develop dedicated waste handling areas, fit for purpose and prevent the spread of waste.
N -1 -1 -1 -2 -5
Surface Water
Increase in siltation within the internal water circuit reducing existing RWD capacities, which could lead to overflows in the system.
Stockpiling of product at the Met Grade Product Stockpile.
N -1 -2 -5 -4 -12 CbA
The product should be stockpiled within a contained facility.
N -1 -1 -2 -2 -6
The slopes of the Met Grade Plant stockpile should be developed and managed in such a manner that the facility remains within the contained footprint and at a stable slope.
The slopes of the active Discard Dump should be formed with the placement of material to reduce the potential for erosion
Surface water monitoring must continue in accordance with the approved WUL.
ENVIROGISTICS (PTY) LTD 10/12/17
Dwarsrivier Chrome Mine: Basic Assessment Report and Management Plan for the Expansion of the Met Grade Chrome Stockpile and Discard Dump with Ancillary Infrastructure Mining Right Ref: 30/5/1/3/2/1(179) EM Project Ref: 21714 Version: FINAL
P a g e 112 | 393
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Inte
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SbM
Reversible (R),
Irreplaceable Damage (ID)
or Can be Avoided
(CbA)
Mitigation Measures
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Inte
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SaM
Maintenance of all SWM systems must be undertaken regularly on site.
Groundwater
Stockpiling of material onto the surfaced (cemented) product stockpile.
Release of Contaminated Water.
N -2 -3 -1 -2 -8 R
The groundwater monitoring programme must be implemented and undertaken in accordance to the approved WUL.
N -1 -2 -2 -2 -7 The product should be stockpiled within a contained facility, no material to be stored on unsurfaced areas.
Stockpiling of Discard Material onto compacted surfaces. The extension of the Discard dump is expected to have a limited impact and nitrate contamination is not expected to extend more than 400m from the Discard dump during the operational phase. The historical impact of the Northern Discard Dump will however dominate groundwater contamination in this area and even if the Discard dump is not extended, there is already a residual impact in this area, as indicated by the DCM monitoring programme. In the long-term, contamination from the Discard dump will migrate towards the Dwarsrivier and may reach this stream within a 100 years after closure. Only a small section of the Dwarsrivier may be affected (<100m in length).
Release of Contaminated Water.
N -2 -3 -3 -2 -10 R
The groundwater monitoring programme must be implemented and undertaken in accordance to the approved WUL.
N -1 -2 -2 -2 -7
For the Discard Dump expansion, at closure the side slopes will have been constructed at an angle of no steeper than 1:3. The Discard Dump will be covered with a course (gravel/topsoil) medium or a medium as prescribed by an Ecologist. Should it be determined that vegetation self-succession does not establish, a growth medium will be placed on top of the rock and vegetation re-established.
The groundwater model should be updated annually, at least for five year post the implementation of the WTP, where after the model update schedule can be reassessed.
Ongoing vegetation of slopes should be implemented, this will be specifically required on the side of the current Discard Dump which will be expanded.
The product should be stockpiled within a contained facility, no material to be stored on unsurfaced areas.
Heritage No direct impact - - - - - - - - - - - - - - -
ENVIROGISTICS (PTY) LTD 10/12/17
Dwarsrivier Chrome Mine: Basic Assessment Report and Management Plan for the Expansion of the Met Grade Chrome Stockpile and Discard Dump with Ancillary Infrastructure Mining Right Ref: 30/5/1/3/2/1(179) EM Project Ref: 21714 Version: FINAL
P a g e 113 | 393
Name of Activity
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Inte
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Reversible (R),
Irreplaceable Damage (ID)
or Can be Avoided
(CbA)
Mitigation Measures
Stat
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Inte
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SaM
Air Quality Wind erosion from Stockpiles and Discard Dump may produce fugitive dust.
Dispersion of dust.
N -2 -1 -3 -3 -9 R
Install air quality monitoring stations that determine fallout and respirable dust (PM10) concentrations that could arise from the mining activities.
N -2 -1 -2 -2 -7
Construct berms on top of the completed Discard Dump and vegetate side as much as possible
Dust control measures in the form of slope stability and vegetation (self-succession will be encouraged) will be implemented. Should self-succession to take place the mine will commit to a vegetation strategy.
Dust suppression should be undertaken if required [(i.e. on recommendation by the Environmental Control Officer and/or if indicated in the monitoring reports, that the current dust fall out results are increasing towards unacceptable levels (non-compliances)].
Visual
Fugitive dust emissions during stockpiling on the dumps and the mere presence of the Mine Residue Stockpiles may have a negative impact on the visual characteristics of the area.
Deterioration of visual character.
N -2 -1 -3 -1 -7 R
Any signs of erosion must be rehabilitated immediately.
N -2 -1 -1 -1 -5
A slope of 1:3 should be maintained.
The height of the Discard Dump must not exceed the appropriate height as presented in the pending engineering design of the facility from ground level. At the current time a height of approximately 30m is foreseen, this may be amended based on the Engineering design.
Discard Dump will be subjected to natural vegetation re-establishment, where this is not successful the mine will commit to vegetation strategies.
The slopes of the Discard Dump should be formed with the placement of material to reduce the potential for erosion
ENVIROGISTICS (PTY) LTD 10/12/17
Dwarsrivier Chrome Mine: Basic Assessment Report and Management Plan for the Expansion of the Met Grade Chrome Stockpile and Discard Dump with Ancillary Infrastructure Mining Right Ref: 30/5/1/3/2/1(179) EM Project Ref: 21714 Version: FINAL
P a g e 114 | 393
Name of Activity
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Inte
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Reversible (R),
Irreplaceable Damage (ID)
or Can be Avoided
(CbA)
Mitigation Measures
Stat
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Inte
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Noise No direct impact - - - - - - - - - - - - - - -
Social
The demand for chrome has increased globally due to the increase in China Markets. No allowing the expansion of the Met Grade Plant Stockpile will result in a restriction on the volume of this material to be produced. This will result in restricting the mine to market supply available reserves, and could impact on the economics of scale of the mining operation. The load out facility is an ancillary infrastructure to this product stockpile and is required to allow for the movement of the product off site. Not allowing this facility will restrict the logistics of supply to the various markets. The Discard Dump is a key component to the mining operation, with all Discard from the Plant deposited on this site. The capacity of the Discard Dump is fast reaching its capacity and for this reason additional capacity is required. The Discard Dump extension will only provide approximately four (4) years of life of facility, however, by not allowing this extension the opportunity to assess a new site in terms of detailed specialist studies are
Investment into markets and long term operational mine.
P -4 -3 -5 -4 -16 CbA
The approval of the project will allow the mine to continue at least for another 10 years in terms of the Discard Capacity. The mine should immediately commence with the assessment of alternatives for long terms discard disposal.
P 3 3 5 4 15
ENVIROGISTICS (PTY) LTD 10/12/17
Dwarsrivier Chrome Mine: Basic Assessment Report and Management Plan for the Expansion of the Met Grade Chrome Stockpile and Discard Dump with Ancillary Infrastructure Mining Right Ref: 30/5/1/3/2/1(179) EM Project Ref: 21714 Version: FINAL
P a g e 115 | 393
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Reversible (R),
Irreplaceable Damage (ID)
or Can be Avoided
(CbA)
Mitigation Measures
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SaM
lost, as the requirement for capacity is immediate.
Transportation (Load out area, roads)
Geology No direct impact. Impacts are addressed during the construction phase.
- - - - - - - - - - - - - - -
Soil
Contamination of Soil due to hydrocarbon spills
Loss of Soil Resources
N -1 -2 -4 -4 -11 CbA
Vehicles and Machinery will be regularly maintained. Maintenance programmes will be established and implemented.
N -1 -1 -2 -1 -5 All refuelling of vehicles and equipment maintenance must be done within designated bunded areas.
If necessary, the polluted soils will be remediated and affected areas rehabilitated.
Spills from conveyors. Contamination of Soils.
N -1 -2 -4 -4 -11 CbA
Ongoing maintenance around transfer points should be undertaken.
N -1 -1 -2 -1 -5 Any spills of Discard or Product around the conveyor systems should be collected and taken to designated stockpile areas.
Ecology
The establishment of Weeds and Invader Species.
Loss of Vegetation
N -2 -3 -4 -4 -13 CBA
A weed eradication programme will be developed and implemented to eradicate weeds and invader plants and to prevent new invasions during the ongoing mining operation.
N -1 -1 -2 -1 -5 Where self-succession does not establish, harvested seeds and plants must be used in concurrent rehabilitation for any areas along the area which may be affected.
Accidental death of animals on the roads.
Loss of Animal N -2 -3 -2 -5 -13 CbA
Clearly marked signs will be erected along the transportation routes to create awareness of animal crossings.
N -1 -3 -1 -5 -10 A clearly marked and enforced vehicle speed will be implemented on the internal mine and transportation routes.
ENVIROGISTICS (PTY) LTD 10/12/17
Dwarsrivier Chrome Mine: Basic Assessment Report and Management Plan for the Expansion of the Met Grade Chrome Stockpile and Discard Dump with Ancillary Infrastructure Mining Right Ref: 30/5/1/3/2/1(179) EM Project Ref: 21714 Version: FINAL
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Inte
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SbM
Reversible (R),
Irreplaceable Damage (ID)
or Can be Avoided
(CbA)
Mitigation Measures
Stat
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SaM
A detailed induction programme will be in place to ensure that all parties are aware of the rules and regulations on site in terms of the use of roads.
Vehicles may only travel on demarcated roads on site.
Riparian Habitats
No direct impact - - - - - - - - - - - - - - -
Surface & Groundwater Water
Contamination of surface water resources. There are no surface water resources in the area, however, the natural runoff, which must be managed internally on site could become impacted
Spill and Release of Waste Material and Contaminated Water.
N -1 -2 -3 -3 -9 CbA
Clean and Dirty water separation systems should be maintained.
N -1 -1 -2 -1 -5
Manage storm water flow with temporary erosion control measures where possible (cut-off trenches or berms)
Conveyors will be maintained and constructed with the appropriate culverts and drains, levelling and surfacing to ensure adequate drainage.
Vehicles/machinery will be regularly monitored and maintained. Maintenance programmes will be established and implemented.
All used oils must be removed from site by a licensed company and disposed of at a suitably licensed site
Any spills occurring during the collection process must be cleaned up immediately.
Soil that has been contaminated by spillages, seepages and leachates will be sampled and analysed. If necessary, the soils will be treated, ameliorated or removed for safe disposal.
Any significant spills must be captured in the incident reports and must be reported to the relevant department. In this event a remediation strategy should be developed and enforced.
ENVIROGISTICS (PTY) LTD 10/12/17
Dwarsrivier Chrome Mine: Basic Assessment Report and Management Plan for the Expansion of the Met Grade Chrome Stockpile and Discard Dump with Ancillary Infrastructure Mining Right Ref: 30/5/1/3/2/1(179) EM Project Ref: 21714 Version: FINAL
P a g e 117 | 393
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Inte
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Reversible (R),
Irreplaceable Damage (ID)
or Can be Avoided
(CbA)
Mitigation Measures
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Inte
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A clean up procedure (i.e. Works Instruction) must be in place.
Air Quality The use of unsurfaced roads may lead to an increase of dust emissions in the area.
Dispersion of dust.
N -2 -1 -3 -3 -9 CbA
Install air quality monitoring stations that determine fallout and respirable dust (PM10) concentrations that could arise from the mining activities.
N -1 -1 -2 -1 -5
Dust suppression should be undertaken if required [(i.e. on recommendation by the Environmental Control Officer and/or if indicated in the monitoring reports, that the current dust fall out results are increasing towards unacceptable levels (non-compliances)].
During operational phase of the mine, haulage roads will be treated with dust suppression techniques such as wet to reduce dust creation.
Tarpaulins will be placed over all vehicles transporting product.
Heritage No direct impact - - - - - - - - - - - - - - -
Noise Noise of vehicles traversing the access roads will be almost constant
Increase in noise levels.
N -2 -3 -3 -2 -10 CbA
Machinery and vehicles will be well maintained to prevent excessive nose and to comply with national and provincial regulations.
N -1 -3 -2 -2 -8
All vehicles will have muffles to minimise noise emissions, where necessary.
Where noise becomes a nuisance nose management measures will be investigated and implemented to address these concerns.
Noise monitoring will be undertaken (ambient conditions) to ensure that noise levels comply with Health and Safety Standards.
Visual No direct impact - - - - - - - - - - - - - - -
Social No direct impact - - - - - - - - - - - - - - -
ENVIROGISTICS (PTY) LTD 10/12/17
Dwarsrivier Chrome Mine: Basic Assessment Report and Management Plan for the Expansion of the Met Grade Chrome Stockpile and Discard Dump with Ancillary Infrastructure Mining Right Ref: 30/5/1/3/2/1(179) EM Project Ref: 21714 Version: FINAL
P a g e 118 | 393
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Inte
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SbM
Reversible (R),
Irreplaceable Damage (ID)
or Can be Avoided
(CbA)
Mitigation Measures
Stat
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Operation of Workshop and Sewage Plant
Geology No direct impact. Impacts are addressed during the construction phase.
- - - - - - - - - - - - - - -
Topography No direct impact. Impacts are addressed during the construction phase.
- - - - - - - - - - - - - - -
Soils Contamination of soils in the event of an emergency overflow.
Loss of Soil Resources
N -1 -2 -3 -3 -9 CbA
Clean and Dirty water separation systems should be incorporated and maintained.
N -1 -1 -2 -1 -5
All containment facilities should cater for 110% capacity.
Any spills occurring during an emergency or maintenance procedure should be cleaned immediately.
Contaminated soils should be stockpiled in contained areas temporarily until remediation has taken place, or the soil has been removed by a licensed contractor to a lawful disposal facility.
A clean up procedure (i.e. Works Instruction) must be in place.
Ecology No direct impact. Impacts are addressed during the construction phase.
- - - - - - - - - - - - - - -
Wetlands and Riparian Habitats
No direct impact. Impacts are addressed during the construction phase.
- - - - - - - - - - - - - - -
Groundwater
The sewage treatment plant will be operated as a closed circuit within the mining area. All treated water will report to the existing RWDs on site, from where water will be reused in the system. No drying beds are present. For this reason no areas of groundwater contamination are expected.
- - - - - - - - - - - - - - -
ENVIROGISTICS (PTY) LTD 10/12/17
Dwarsrivier Chrome Mine: Basic Assessment Report and Management Plan for the Expansion of the Met Grade Chrome Stockpile and Discard Dump with Ancillary Infrastructure Mining Right Ref: 30/5/1/3/2/1(179) EM Project Ref: 21714 Version: FINAL
P a g e 119 | 393
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Inte
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ty
SbM
Reversible (R),
Irreplaceable Damage (ID)
or Can be Avoided
(CbA)
Mitigation Measures
Stat
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Exte
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Inte
nsi
ty
SaM
Surface Water
Contamination of surface water resources.
Contamination of Surface Water
N -1 -2 -2 -3 -8 CbA
Clean and Dirty water separation systems should be incorporated and maintained.
N -1 -1 -1 -1 -4
All containment facilities should cater for 110% capacity.
Any spills occurring during an emergency or maintenance procedure should be cleaned immediately.
A clean up procedure (i.e. Works Instruction) must be in place.
Heritage No direct impact - - - - - - - - - - - - - - -
Noise No direct impact - - - - - - - - - - - - - - -
Visual No direct impact - - - - - - - - - - - - - - -
Social No direct impact - - - - - - - - - - - - - - -
Waste Management and Handling Hydrocarbon spills within the Mining Area and the management of Domestic and Hazardous Waste
Geology No direct impact. - - - - - - - - - - - - - - -
Topography No direct impact. - - - - - - - - - - - - - - -
Soils Contamination of soil resources due to hydrocarbon spills.
Spills and Release of Contaminants.
N -1 -2 -4 -4 -11 CBA
Storage of fuels and oils, the refuelling of vehicles and equipment maintenance must be limited to designated, bunded (bunds to be 110% of volume of the materials stored) areas.
N -1 -2 -1 -1 -5
All fuels and soils must be stored in appropriate containers.
Chemicals and hazardous material must be stored in suitable containers, fit for purpose and in line with SDS requirements.
Where drip trays are too small, specially prepared, non-pervious bunds with solution trenches must be used to capture spillages
Oils and potentially hazardous materials must be disposed of at a licensed facility and waste certificates obtained.
A spill kit must be provided to be used in the event of a spill.
ENVIROGISTICS (PTY) LTD 10/12/17
Dwarsrivier Chrome Mine: Basic Assessment Report and Management Plan for the Expansion of the Met Grade Chrome Stockpile and Discard Dump with Ancillary Infrastructure Mining Right Ref: 30/5/1/3/2/1(179) EM Project Ref: 21714 Version: FINAL
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SbM
Reversible (R),
Irreplaceable Damage (ID)
or Can be Avoided
(CbA)
Mitigation Measures
Stat
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Inte
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SaM
If a spill occurs, the contaminated soil must be removed immediately. Contaminated soil must be stored according to best practices until it can be disposed of at a suitably licensed facility.
Safety signage must be used at designated storage areas.
All workers must undergo an induction which includes environmental awareness training to make them aware of the environmental incident management procedures as well as the importance of complying with management measures.
Ecology
The unmanaged disposal of waste, could result in the spread of invader species, as well as the influx of opportunistic species.
Loss of Ecology and the influx of Opportunistic Species.
N -2 -3 -3 -4 -12 CbA
Develop dedicated waste handling areas; prevent access to rodents and opportunistic species; prevent the spread of waste. N -1 -1 -2 -1 -5 Develop dedicated waste handling areas, fit for purpose and prevent the spread of waste.
Wetlands No direct impact. - - - - - - - - - - - - - - -
Riparian Habitat
The Sprinkaan Spruit is located just 100m to the south of the proposed infrastructure construction (workshops, loadout and sewage facilities). The Dwarsrivier is located to the west of the proposed loadout facility (520m) and Discard Dump (220m). The presence of littering could enter the watercourses in the area if not managed.
Airborne littering
N -3 -2 -2 -3 -10 CbA
Remain at all times outside of the 1:100 year flood line of the watercourses. Ongoing Biomonitoring Monitoring should be undertaken at the upstream and downstream points. Ongoing surface water monitoring should be undertaken at the upstream and downstream monitoring points. The storm water management plans should be implemented in and around the facilities to ensure that dirty water runoff or water with high sediment loads do not
N -1 -1 -1 -2 -5
ENVIROGISTICS (PTY) LTD 10/12/17
Dwarsrivier Chrome Mine: Basic Assessment Report and Management Plan for the Expansion of the Met Grade Chrome Stockpile and Discard Dump with Ancillary Infrastructure Mining Right Ref: 30/5/1/3/2/1(179) EM Project Ref: 21714 Version: FINAL
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Inte
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SbM
Reversible (R),
Irreplaceable Damage (ID)
or Can be Avoided
(CbA)
Mitigation Measures
Stat
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Inte
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SaM
enter the existing watercourses. Develop dedicated waste handling areas, fit for purpose and prevent the spread of waste.
Surface Water
Handling of Hazardous Waste within workshops and general mine area could contaminate the dirty water storage areas. The water is then reused in the system and could have impacts on the integrity of the storm water system and also the production.
Spill and Release of Waste Material and Contaminated Water.
N -3 -2 -2 -4 -11 CbA
Clean and Dirty water separation systems should be incorporated in terms of the 2016 SWMP or any approved update thereafter.
N -1 -1 -2 -2 -6
A detailed waste management strategy will be established and implemented, which will clearly demarcate the containments for different waste streams.
Waste management training must be implemented on site.
Clear signs informing staff of waste management practices must be implemented on site.
Hazardous waste handling should only take place within bunded and/or lined areas.
Hazardous waste should be removed by a licenced removal company and taken to a suitable and licenced landfill site.
Documentation of removal and safe disposal must be kept on record and in good order.
The mine will adopt a cradle-to grave (inspection of disposal sites) approach to ensure that the waste is removed and disposed of in a legally compliant manner.
Weekly inspections of Storm Water Management Systems must be undertaken. Any blockages or maintenance requirements must be
ENVIROGISTICS (PTY) LTD 10/12/17
Dwarsrivier Chrome Mine: Basic Assessment Report and Management Plan for the Expansion of the Met Grade Chrome Stockpile and Discard Dump with Ancillary Infrastructure Mining Right Ref: 30/5/1/3/2/1(179) EM Project Ref: 21714 Version: FINAL
P a g e 122 | 393
Name of Activity
Impact Area
Potential Impacts Rating Prior to Measures Mitigation Type Rating Post Measures
Activities Potential Impacts Aspect
Stat
us
Exte
nt
Du
rati
on
Pro
bab
ility
Inte
nsi
ty
SbM
Reversible (R),
Irreplaceable Damage (ID)
or Can be Avoided
(CbA)
Mitigation Measures
Stat
us
Exte
nt
Du
rati
on
Pro
bab
ility
Inte
nsi
ty
SaM
documented and an action plan developed.
Handling and Storing of Domestic Waste should have no impact on the surface water resources due to the location of the facility. However, incorrect disposal of waste could hamper the integrity of the storm water system.
Spill and Release of Waste Material and Contaminated Water.
N/A -1 -2 -3 -3 -9 CbA
Clean and Dirty water separation systems should be incorporated in terms of the 2016 SWMP or any approved update thereafter.
N -1 -1 -2 -1 -5
Waste management training must be implemented on site.
Weekly inspections of Storm Water Management Systems must be undertaken. Any blockages or maintenance requirements must be documented and an action plan developed.
Clear signs informing staff of waste management practices must be implemented on site.
Access control must be strictly enforced.
The berm around upstream of the facility must be maintained.
Recycling practices must be investigated and implemented on site.
Groundwater
Large scale hydrocarbon spills could be present at the mining area
Spill and Release of Waste Material.
N -1 -1 -4 -4 -10 R
Clean and Dirty water separation systems should be incorporated in terms of the 2016 SWMP or any approved update thereafter.
N -1 -1 -2 -1 -5
No activities associated with hydrocarbons and/or chemicals may be undertaken outside of an effectively designed and contained area.
All used oils must be removed from site by a licensed company and disposed of at a suitably licensed site.
Any spills occurring during the collection process must be cleaned up immediately.
ENVIROGISTICS (PTY) LTD 10/12/17
Dwarsrivier Chrome Mine: Basic Assessment Report and Management Plan for the Expansion of the Met Grade Chrome Stockpile and Discard Dump with Ancillary Infrastructure Mining Right Ref: 30/5/1/3/2/1(179) EM Project Ref: 21714 Version: FINAL
P a g e 123 | 393
Name of Activity
Impact Area
Potential Impacts Rating Prior to Measures Mitigation Type Rating Post Measures
Activities Potential Impacts Aspect
Stat
us
Exte
nt
Du
rati
on
Pro
bab
ility
Inte
nsi
ty
SbM
Reversible (R),
Irreplaceable Damage (ID)
or Can be Avoided
(CbA)
Mitigation Measures
Stat
us
Exte
nt
Du
rati
on
Pro
bab
ility
Inte
nsi
ty
SaM
Any significant spills must be captured in the incident reports and must be reported to the relevant department (LDEDET, Catchment Management Agency/DWS).
All equipment and machinery should be kept in good working order.
A clean up procedure (i.e. Works Instruction) must be in place.
Handling or Hazardous Waste within workshops and general mine area.
Spill and Release of Waste Material and Contaminated Water.
N -2 -2 -2 -4 -10 CbA
Clean and Dirty water separation systems should be incorporated in terms of the 2016 SWMP or any approved update thereafter.
N -1 -1 -2 -2 -6
The workshop should be designed with the suitable waste containment measures (berms, sumps, oil separators).
Waste management training must be implemented on site.
Clear signs informing staff of waste management practices must be implemented on site.
Hazardous waste handling should only take place within bunded and/or lined areas, with a capacity of at least 110% of the volume stored.
Hazardous waste should be removed by a licenced removal company and taken to a suitable and licenced landfill site.
Documentation of removal and safe disposal must be available on site.
Handling and Storing of Domestic Waste
Spill and Release of Waste Material and Contaminated Water.
N -3 -3 -3 -3 -12 CbA
Clean and Dirty water separation systems should be incorporated in terms of the 2016 SWMP or any approved update thereafter.
N -2 -3 -2 -2 -9
Waste management training must be implemented on site.
ENVIROGISTICS (PTY) LTD 10/12/17
Dwarsrivier Chrome Mine: Basic Assessment Report and Management Plan for the Expansion of the Met Grade Chrome Stockpile and Discard Dump with Ancillary Infrastructure Mining Right Ref: 30/5/1/3/2/1(179) EM Project Ref: 21714 Version: FINAL
P a g e 124 | 393
Name of Activity
Impact Area
Potential Impacts Rating Prior to Measures Mitigation Type Rating Post Measures
Activities Potential Impacts Aspect
Stat
us
Exte
nt
Du
rati
on
Pro
bab
ility
Inte
nsi
ty
SbM
Reversible (R),
Irreplaceable Damage (ID)
or Can be Avoided
(CbA)
Mitigation Measures
Stat
us
Exte
nt
Du
rati
on
Pro
bab
ility
Inte
nsi
ty
SaM
Clear signs informing staff of waste management practices must be implemented on site.
All waste must be removed by licensed contractors and disposed of at a licensed landfill site.
As a duty of care and the cradle to grave principles, the mine should regularly inspect disposal site to ensure that best practices are implemented.
Recycling practices must be investigated and implemented on site.
Records and manifests of waste disposal should be kept on file and in good order.
Groundwater monitoring must be undertaken in such a manner as to ensure that any potential impacts from the landfill site can be detected.
Air Quality No direct impact - - - - - - - - - - - - - - -
Heritage No direct impact - - - - - - - - - - - - - - -
Noise No direct impact - - - - - - - - - - - - - - -
Visual No direct impact - - - - - - - - - - - - - - -
Social No direct impact - - - - - - - - - - - - - - -
ENVIROGISTICS (PTY) LTD 10/12/17
Dwarsrivier Chrome Mine: Basic Assessment Report and Management Plan for the Expansion of the Met Grade Chrome Stockpile and Discard Dump with Ancillary Infrastructure Mining Right Ref: 30/5/1/3/2/1(179) EM Project Ref: 21714 Version: FINAL
P a g e 125 | 393
Table 49: Decommissioning and Closure Phase Impact Assessment and Management Measures (Significance before Mitigation –SbM; Significance after Mitigation – SaM)
Name of Activity
Impact Area
Potential Impacts Rating Prior to Measures Mitigation Type Rating Post Measures
Activities Potential Impacts Aspect
Stat
us
Exte
nt
Du
rati
on
Pro
bab
ility
Inte
nsi
ty
SbM
Reversible (R),
Irreplaceable Damage (ID)
or Can be Avoided
(CbA)
Mitigation Measures
Stat
us
Exte
nt
Du
rati
on
Pro
bab
ility
Inte
nsi
ty
SaM
Decommissioning and Closure Phase
Legal Requirements (Environmental Permits)
South Africa Enviro-Legal Requirements
Unlawful activities could lead to NWA Directives and Section 24G Rectification fines.
Legal Compliance.
N -4 -3 -2 -5 -14 CbA
A legal assessment of all activities must be undertaken annually to ensure that all are licensed.
P 4 3 5 5 17
A detailed closure plan must be developed and submitted to the relevant departments for approval.
All legally appointed personnel responsible or involved in activities on site must receive training on the requirements of the Environmental Authorisations and EMPs
Quarterly (construction); Biannually (after construction) integral audits must be undertaken during the construction phase, where after biannual audits can be undertaken, on the lawful implementation of the Environmental Authorisation
Environmental Authorisations must be available on site at all times.
The legal register must be updated to indicate all updated activities.
Rehabilitation of Waste Rock Dumps
Geology No direct impact. - - - - - - - - - - - - - - -
Topography Returning the area to be stable and free draining.
Shaping and landscaping
N -2 -3 -2 -5 -12 CbA
Existing waste rock dumps will be used to fill the existing voids and excess material will be employed for mining and vent shaft closure.
P 2 3 3 5 13 All remaining waste disposal facilities, must be capped (could only include vegetation to reduce recharge), rehabilitated and closed in compliance with the relevant provisions of Section 11 of the DWA Minimum Requirements
ENVIROGISTICS (PTY) LTD 10/12/17
Dwarsrivier Chrome Mine: Basic Assessment Report and Management Plan for the Expansion of the Met Grade Chrome Stockpile and Discard Dump with Ancillary Infrastructure Mining Right Ref: 30/5/1/3/2/1(179) EM Project Ref: 21714 Version: FINAL
P a g e 126 | 393
Name of Activity
Impact Area
Potential Impacts Rating Prior to Measures Mitigation Type Rating Post Measures
Activities Potential Impacts Aspect
Stat
us
Exte
nt
Du
rati
on
Pro
bab
ility
Inte
nsi
ty
SbM
Reversible (R),
Irreplaceable Damage (ID)
or Can be Avoided
(CbA)
Mitigation Measures
Stat
us
Exte
nt
Du
rati
on
Pro
bab
ility
Inte
nsi
ty
SaM
for Waste Disposal by Landfill, or any future amendments thereto/new legislation applicable to such (such as Reg 634-636 of the NEM:WA)
The side slopes of steep areas are to be graded to a slope of approximately 1:3 (or unless otherwise stated) in order to prevent excessive erosion and to allow vegetation to establish sufficient root growth and in line with Health and safety requirements for closure
Side slopes of the rehabilitation area are to be covered by topsoil sourced from the topsoil stockpiles which were created during the clearing of the open pit areas, construction of new activities and tailings areas
Along the crest of steep gradients a 1 meter high Hessian screen should be placed around the facility to assist with the trapping of seeds and to protect the crest from wind erosion
All mine residue deposits should be effectively fenced off to avoid access thereto by unauthorised parties.
Soils No direct impact. - - - - - - - - - - - - - -
Ecology No direct impact.
Loss of ecology and end land use objectives.
N -3 -3 -3 -5 -14 CbA
A grass mixture off endemic grasses recommended by an ecologist should be utilised in the seeding process. Note that hydro-seeding is primarily for grasses and smaller shrubs. Larger shrubs and trees will need to be hand-planned.
P 3 3 3 5 14
The seed mixture should be incorporated into mulch which includes fertiliser and
ENVIROGISTICS (PTY) LTD 10/12/17
Dwarsrivier Chrome Mine: Basic Assessment Report and Management Plan for the Expansion of the Met Grade Chrome Stockpile and Discard Dump with Ancillary Infrastructure Mining Right Ref: 30/5/1/3/2/1(179) EM Project Ref: 21714 Version: FINAL
P a g e 127 | 393
Name of Activity
Impact Area
Potential Impacts Rating Prior to Measures Mitigation Type Rating Post Measures
Activities Potential Impacts Aspect
Stat
us
Exte
nt
Du
rati
on
Pro
bab
ility
Inte
nsi
ty
SbM
Reversible (R),
Irreplaceable Damage (ID)
or Can be Avoided
(CbA)
Mitigation Measures
Stat
us
Exte
nt
Du
rati
on
Pro
bab
ility
Inte
nsi
ty
SaM
germination acceleration agents where required.
Regular application of fertiliser should take place in order to ensure efficient establishment of vegetation cover until such time as sufficient organic matter is being produced by the established grasses to allow for self-sustaining growth
If re-seeding for basal cover establishment was not effective during 1st application, a second application of hydro-seed mixture may have to be applied in certain areas. The application of hydro-seed should be at the discretion of the specialist contractor.
No grazing on rehabilitated areas is to occur within three years of reseeding completion
Once sufficient basal cover has been established, the introduction of species representative of the Sekhukhune Mountain Bushveld vegetation type may commence.
Once sufficient basal cover has been established, the introduction of species representative of the Sekhukhune Mountain Bushveld vegetation type may commence.
Introduction of these species should commence through the stages of natural succession, i.e. Pioneer species (grasses, herbaceous species), Secondary species (grasses, small shrubs, and small trees) and Climax state (larger shrubs, large trees). This process will also occur
ENVIROGISTICS (PTY) LTD 10/12/17
Dwarsrivier Chrome Mine: Basic Assessment Report and Management Plan for the Expansion of the Met Grade Chrome Stockpile and Discard Dump with Ancillary Infrastructure Mining Right Ref: 30/5/1/3/2/1(179) EM Project Ref: 21714 Version: FINAL
P a g e 128 | 393
Name of Activity
Impact Area
Potential Impacts Rating Prior to Measures Mitigation Type Rating Post Measures
Activities Potential Impacts Aspect
Stat
us
Exte
nt
Du
rati
on
Pro
bab
ility
Inte
nsi
ty
SbM
Reversible (R),
Irreplaceable Damage (ID)
or Can be Avoided
(CbA)
Mitigation Measures
Stat
us
Exte
nt
Du
rati
on
Pro
bab
ility
Inte
nsi
ty
SaM
naturally as seeds from the neighbouring Sekhukhune Mountain Bushveld areas are introduced and germinate
Certain tree species can be selectively introduced, however consideration will need to be given to rooting depths and soil stability as well as the ability of the trees to establish on the subject area
Wetlands No direct impact. - - - - - - - - - - - - - - -
Surface Water
Erosion of the side walls of the Discard Dump could lead not only to instability, but also siltation of water resources.
Contamination of Surface Water
N -2 -3 -3 -3 -11 CbA
The side walls should be sloped to a degree which will allow stability and self-succession of vegetation.
N -1 -1 -2 -1 -5
Where self-succession does not establish, it is recommended that the mine investigate a seeding programme.
Clean and dirty water measures must be implemented around and on top of the facilities to manage water and runoff on and around the facility.
Groundwater
The extension of the Northern Discard Dump is expected to have a limited impact and nitrate contamination is not expected to extend more than 400m from the Discard Dump during the operational phase. The historical impact of the Northern Discard Dump will however dominate groundwater contamination in this area and even if the Discard Dump is not extended, there is already a residual impact in this area, as
Contamination of Groundwater Resources
N -2 -3 -2 -2 -9 Cba
Engineering design drawings for capping and closure of the aforementioned facilities, as developed by a competent civil engineer, must be submitted to the DWS, as well as the DMR, for approval prior to commencing with the closure thereof. Recharge through this facility must be limited through capping to reduce the potential seep of contaminated water. Continuous update of the groundwater numerical model.
N -1 -3 -2 -1 -7
ENVIROGISTICS (PTY) LTD 10/12/17
Dwarsrivier Chrome Mine: Basic Assessment Report and Management Plan for the Expansion of the Met Grade Chrome Stockpile and Discard Dump with Ancillary Infrastructure Mining Right Ref: 30/5/1/3/2/1(179) EM Project Ref: 21714 Version: FINAL
P a g e 129 | 393
Name of Activity
Impact Area
Potential Impacts Rating Prior to Measures Mitigation Type Rating Post Measures
Activities Potential Impacts Aspect
Stat
us
Exte
nt
Du
rati
on
Pro
bab
ility
Inte
nsi
ty
SbM
Reversible (R),
Irreplaceable Damage (ID)
or Can be Avoided
(CbA)
Mitigation Measures
Stat
us
Exte
nt
Du
rati
on
Pro
bab
ility
Inte
nsi
ty
SaM
indicated by the DCM monitoring programme. In the long-term, contamination from the Northern Discard Dump will migrate towards the Dwarsrivier and may reach this stream within a 100 years after closure. Only a small section of the Dwarsrivier may be affected (<100m in length).
Heritage No direct impact. - - - - - - - - - - - - - - -
Visual No direct impact. - - - - - - - - - - - - - - -
Noise No direct impact. - - - - - - - - - - - - - - -
Social No direct impact. - - - - - - - - - - - - - - -
Dismantling and decommissioning of infrastructure and buildings, including product stockpiles
Geology No direct impact - - 0 0 0 0 0 CbA - - - 0 0 0 0
Topography Removal of infrastructure may impact on the topography.
Alteration of surface topography.
N -2 -3 -4 -4 -13 R
Linear Infrastructure constructed by the mine will be removed if it proves to inhibit land use at decommissioning. Where possible infrastructure will remain for social investment opportunities, this will be decided in conjunction with the Integrated Development Plan of the area ant eh local authorities.
P 3 3 4 4 14 Ensure the entire site remains fenced for the duration of rehabilitation. 2. Retain security access control to the site for the duration of rehabilitation.
All product stockpile to be removed from site.
All fixed assets that can be profitably removed will be removed for salvage or resale (the salvage and resale value have however not been incorporated into the
ENVIROGISTICS (PTY) LTD 10/12/17
Dwarsrivier Chrome Mine: Basic Assessment Report and Management Plan for the Expansion of the Met Grade Chrome Stockpile and Discard Dump with Ancillary Infrastructure Mining Right Ref: 30/5/1/3/2/1(179) EM Project Ref: 21714 Version: FINAL
P a g e 130 | 393
Name of Activity
Impact Area
Potential Impacts Rating Prior to Measures Mitigation Type Rating Post Measures
Activities Potential Impacts Aspect
Stat
us
Exte
nt
Du
rati
on
Pro
bab
ility
Inte
nsi
ty
SbM
Reversible (R),
Irreplaceable Damage (ID)
or Can be Avoided
(CbA)
Mitigation Measures
Stat
us
Exte
nt
Du
rati
on
Pro
bab
ility
Inte
nsi
ty
SaM
closure cost estimate as per the legislative requirements)
All surface structures, infrastructure and ‘hard surfaces’ (inter alia, redundant surfaced roads, parking and paved areas) are to be demolished and removed from the disturbed mine footprint; unless an alternative/continued use for any such items is agreed upon, in writing, with the Department of Mineral Resources (DMR).
All surface infrastructure would be demolished and removed to a depth of 500mm. Any infrastructure below 500mm will be sealed, made safe and left in situ.
All fences erected around the infrastructure be dismantled and either disposed of at a permitted disposal site or sold off as scrap (provided that these structures will no longer be required by the post mining land owner). Fences erected to cordon off dangerous excavations will remain in place and will be maintained as and when required.
Water pollution control structures will remain until the completion of all demolition and associated rehabilitation activities where after these will be rehabilitated.
Soil, Land Use and Land Capability
Spills around the workshops, sewage facilities and stockpiles may result in the contamination of soils.
Operational activities
N -1 -2 -4 -4 -11 CbA Any hydrocarbon, effluent or other contaminants should be collected and the soils remediated immediately.
- -1 -2 -1 -1 -5
ENVIROGISTICS (PTY) LTD 10/12/17
Dwarsrivier Chrome Mine: Basic Assessment Report and Management Plan for the Expansion of the Met Grade Chrome Stockpile and Discard Dump with Ancillary Infrastructure Mining Right Ref: 30/5/1/3/2/1(179) EM Project Ref: 21714 Version: FINAL
P a g e 131 | 393
Name of Activity
Impact Area
Potential Impacts Rating Prior to Measures Mitigation Type Rating Post Measures
Activities Potential Impacts Aspect
Stat
us
Exte
nt
Du
rati
on
Pro
bab
ility
Inte
nsi
ty
SbM
Reversible (R),
Irreplaceable Damage (ID)
or Can be Avoided
(CbA)
Mitigation Measures
Stat
us
Exte
nt
Du
rati
on
Pro
bab
ility
Inte
nsi
ty
SaM
Loss of soils due to decommissioning activities present on site.
Operational activities
N -1 -2 -4 -4 -11 CbA
Draw up a plan clearly defining the area where the removal of infrastructure should take place. Implement the plan with sufficient measures in place not to compact new areas.
N -1 -2 -1 -1 -5 Implement a strict penalty fine system for rule breaking with regard to vehicular movement.
Maintain clean and dirty water systems and undertake regular monitoring and maintenance thereof.
Ecology
The establishment of Weeds and Invader Species.
Loss of Vegetation
N -2 -3 -4 -4 -13 CBA
A weed eradication programme will be developed and implemented to eradicate weeds and invader plants and to prevent new invasions during the ongoing mining operation.
N -1 -1 -2 -1 -5 Where self-succession does not establish, harvested seeds and plants must be used in concurrent rehabilitation for any areas along the area which may be affected.
Direct impact: Unplanned loss of floral and faunal species of conservation importance
Footprint clearance
N -2 -4 -4 -4 -14 CbA
Prior to the removal of plant species, an ecologist should investigate the site (if not already done) to record all species of importance and which should be removed under tree removal permits. All such species should be demarcated by signage or tape. N -2 -1 -1 -2 -6
Obtain tree removal permit prior to the removal of any protected species.
ENVIROGISTICS (PTY) LTD 10/12/17
Dwarsrivier Chrome Mine: Basic Assessment Report and Management Plan for the Expansion of the Met Grade Chrome Stockpile and Discard Dump with Ancillary Infrastructure Mining Right Ref: 30/5/1/3/2/1(179) EM Project Ref: 21714 Version: FINAL
P a g e 132 | 393
Name of Activity
Impact Area
Potential Impacts Rating Prior to Measures Mitigation Type Rating Post Measures
Activities Potential Impacts Aspect
Stat
us
Exte
nt
Du
rati
on
Pro
bab
ility
Inte
nsi
ty
SbM
Reversible (R),
Irreplaceable Damage (ID)
or Can be Avoided
(CbA)
Mitigation Measures
Stat
us
Exte
nt
Du
rati
on
Pro
bab
ility
Inte
nsi
ty
SaM
All employees, or contractors on site, involved in this project, should receive a detailed induction on the expectations for the protection of fauna and flora on site.
Weed eradication should be implemented on site.
Accidental death of animals on the roads.
Loss of Animal
N -2 -3 -2 -5 -13 CbA
Clearly marked signs will be erected along the transportation routes to create awareness of animal crossings.
N -1 -3 -1 -5 -10
A clearly marked and enforced vehicle speed will be implemented on the internal mine and transportation routes.
A detailed induction programme will be in place to ensure that all parties are aware of the rules and regulations on site in terms of the use of roads.
Vehicles may only travel on demarcated roads on site.
Riparian Habitat
The Sprinkaan Spruit is located just 100m to the south of the proposed infrastructure (workshops, loadout and sewage facilities). The Dwarsrivier is located to the west of the proposed loadout facility (520m) and Discard Dump (220m).
Decommissioning and Closure Activities
N -3 -2 -2 -3 -10 CbA
Remain at all times outside of the 1:100 year flood line of the watercourses. Ongoing Biodiversity Monitoring should be undertaken at the upstream and downstream points. Ongoing surface water monitoring should be undertaken at the upstream and downstream monitoring points. The storm water management plans should be retained in and around the facilities to ensure that dirty water runoff or water with high sediment loads do not enter the existing watercourses.
N -1 -1 -1 -2 -5
ENVIROGISTICS (PTY) LTD 10/12/17
Dwarsrivier Chrome Mine: Basic Assessment Report and Management Plan for the Expansion of the Met Grade Chrome Stockpile and Discard Dump with Ancillary Infrastructure Mining Right Ref: 30/5/1/3/2/1(179) EM Project Ref: 21714 Version: FINAL
P a g e 133 | 393
Name of Activity
Impact Area
Potential Impacts Rating Prior to Measures Mitigation Type Rating Post Measures
Activities Potential Impacts Aspect
Stat
us
Exte
nt
Du
rati
on
Pro
bab
ility
Inte
nsi
ty
SbM
Reversible (R),
Irreplaceable Damage (ID)
or Can be Avoided
(CbA)
Mitigation Measures
Stat
us
Exte
nt
Du
rati
on
Pro
bab
ility
Inte
nsi
ty
SaM
Wetland Loss or Impact on NEFPA Sites Footprint clearance
N -4 -3 -1 -5 -13 CbA No activities are planned within 500m from any NEFPA sites. This restriction should be maintained.
N -1 -1 -1 -1 -4
Hydrology
Erosion control over rehabilitated areas and the prevention of erosion gullies.
Active Rehabilitation
N -1 -1 -4 -2 -8 CbA
The topography of all disturbed areas must be rehabilitated in such a manner that the surrounding natural area blends naturally with the rehabilitated areas well as to be free-draining. This will reduce soil erosion and improve natural re-vegetation.
N -1 -1 -2 -2 -6
Contamination of surface water as a result of removal of infrastructure.
Operation of machinery and vehicle
N -2 -2 -4 -3 -11 R
The detailed waste management strategy implemented during the construction and operation phases must be continuously implemented throughout the closure and decommissioning phase.
N -1 -1 -2 -2 -6
Rubble and waste from site could pollute local water resources.
Waste generation and disposal
N -1 -1 -4 -2 -8 CbA Waste that is not removed from site should be spread, covered and suitably rehabilitated.
N -1 -1 -2 -2 -6
Geohydrology No direct impact - - 0 0 0 0 0 CbA - - 0 0 0 0 0
Heritage No direct impact - - 0 0 0 0 0 CbA - - 0 0 0 0 0
Visual
Fugitive dust emissions as a result of infrastructure removal and associated exposed/bare areas may have an impact in terms of air quality and visual characteristics.
Vehicle movement and active rehabilitation
N -2 -2 -4 -3 -11 R
The dust monitoring network and dust suppression programme established during the construction phase of the project will be maintained throughout the closure phase of the mine. With respect to haul road dust levels, it is recommended to limit vehicle speeds, especially during high risk periods of high winds, high temperature and low humidity.
N -2 -1 -3 1 -5
Establish and implement a dust suppression plan in consultation with the environmental control officer and an air quality specialist as part of the contractor’s responsibility.
ENVIROGISTICS (PTY) LTD 10/12/17
Dwarsrivier Chrome Mine: Basic Assessment Report and Management Plan for the Expansion of the Met Grade Chrome Stockpile and Discard Dump with Ancillary Infrastructure Mining Right Ref: 30/5/1/3/2/1(179) EM Project Ref: 21714 Version: FINAL
P a g e 134 | 393
Name of Activity
Impact Area
Potential Impacts Rating Prior to Measures Mitigation Type Rating Post Measures
Activities Potential Impacts Aspect
Stat
us
Exte
nt
Du
rati
on
Pro
bab
ility
Inte
nsi
ty
SbM
Reversible (R),
Irreplaceable Damage (ID)
or Can be Avoided
(CbA)
Mitigation Measures
Stat
us
Exte
nt
Du
rati
on
Pro
bab
ility
Inte
nsi
ty
SaM
Air Quality
All activities associated with the removal of infrastructure and rehabilitation has the potential to release dust.
Active Rehabilitation
N -2 -2 -4 1 -7 R
The dust monitoring network and dust suppression programme established during the construction phase of the project will be maintained throughout the closure phase of the mine. With respect to haul road dust levels, it is recommended to limit vehicle speeds, especially during high risk periods of high winds, high temperature and low humidity.
N -2 -1 -3 1 -5
Noise
All activities associated with the removal of infrastructure and rehabilitation has the potential to generate noise.
Active Rehabilitation
N -2 -2 -4 1 -7 CbA
The removal of all infrastructure is to take place during daytime periods only.
N -2 -1 -3 1 -5 Where noise becomes a nuisance, management measures will be investigated and implemented to address these.
Social
Disruption and nuisance factors associated with the actual decommissioning such as noise, visual and traffic related impacts.
Active Rehabilitation
N -2 -2 -4 1 -7 CbA
Local residents, with the focus on the surrounding landowners, should receive accurate information with regards to the project status, timeframes for decommissioning and other relevant information about issues that could influence their daily living and movement patterns.
N -2 -1 -3 1 -5
Earth Moving, shaping and ripping of ground
Geology No direct impact - - 0 0 0 0 0 - - - 0 0 0 0 0
Topography
The shaping of the site should be undertaken in such a manner that it improves the overall topography of the site.
Active Rehabilitation
P 1 3 4 5 13 CbA
Pre-mining topography should be reasonably restored through shaping and landscaping, such that the topography of rehabilitated areas will ultimately be commensurate with that of adjacent, non-disturbed areas.
- 1 3 5 5 14
Soil erosion Wind and
water erosion in
N -6 -3 -4 -3 -16 CbA Re-vegetate as soon as possible N -2 -1 -3 1 -5
ENVIROGISTICS (PTY) LTD 10/12/17
Dwarsrivier Chrome Mine: Basic Assessment Report and Management Plan for the Expansion of the Met Grade Chrome Stockpile and Discard Dump with Ancillary Infrastructure Mining Right Ref: 30/5/1/3/2/1(179) EM Project Ref: 21714 Version: FINAL
P a g e 135 | 393
Name of Activity
Impact Area
Potential Impacts Rating Prior to Measures Mitigation Type Rating Post Measures
Activities Potential Impacts Aspect
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Exte
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Inte
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SbM
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Irreplaceable Damage (ID)
or Can be Avoided
(CbA)
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unvegetated areas
Ripping and topsoil replacement will restore the soil physical characteristics prior to re-vegetation.
Active Rehabilitation
P 1 3 4 5 13 CbA
Compacted soils will be ripped and topsoil will be replaced. After the topsoil has been replaced the area should be ameliorated and seeded, should self-succession of vegetation not take place. Only species indigenous to the area will be included.
P 1 3 5 5 14
Where sites have been alienated of vegetation or where soils have been compacted or covered with concretes, these sites will be ripped and ploughed.
The topsoil and sub-soils with the appropriate seedbed as stripped during the construction and operational phases will be placed over these areas to a depth as specified by a qualified specialist. The topsoil shall be appropriately ameliorated to allow vegetation to grow rapidly if required – it should be noted that the mine will encourage self-succession of vegetation, if this does not take place effectively a re-vegetation project will be implemented
Terrestrial Ecology (Fauna & Flora)
The rehabilitation of the site will allow reestablishment of natural vegetation.
Rehabilitation P 1 2 3 4 10 CbA
Compacted soils will be ripped and topsoil will be replaced. After the topsoil has been replaced the area should be ameliorated and seeded, should self-succession of vegetation not take place. Only species indigenous to the area will be included. Remove alien vegetation post decommissioning, with long term follow-up afterwards.
P 3 3 3 4 13
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On-going alien and invasive floral species control is required through all phases of rehabilitation.
If a reasonable assessment indicates that the re-establishment of vegetation is unacceptable slow, the soil need to be analysed and any deleterious effects must be corrected and the area be seeded with a seed mix to specification
Access to rehabilitated areas should be restricted to vehicles/machinery specifically required for the implementation of the closure plan.
Wetland No direct impact - N 0 0 0 0 0 CbA - - - - - - -
Hydrology
The areas will be landscaped to be free draining in line with the approved storm water management plan.
Runoff from rehabilitated areas will impact on watercourses especially during intensive rainstorms especially if the area are not free draining.
N -2 -1 -3 1 -5 CbA
Berms, should they be necessary, must remain upstream and downstream of the dumps and stockpiles to ensure that clean water is kept separate from dirty water until the area is free draining and re-vegetation has occurred.
N -2 -3 -4 1 -8
Geohydrology No direct impact - - 0 0 0 0 0 CbA - 0 0 0 0 0
Heritage No direct impact - - 0 0 0 0 0 CbA - - 0 0 0 0 0
Visual
The rehabilitation (ripping, topsoil replacement and landscaping) will remove the visual incongruity.
Infrastructure removal
P 2 4 4 1 11 CbA An overall visual improvement will be noticed once all mining related infrastructure has been demolished and
P 2 4 4 3 13
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the area has been landscaped and re-vegetated.
Demarcate the decommissioning area and limit the decommissioning activities as far as possible.
Final shaping will be implemented such that the final profile of the rehabilitated areas are formed to emulate natural contours of the area.
Foundations will be removed to a depth of 1 m below the surface and the area rehabilitated.
All material recovered from the demolition of buildings and/or structures will either be transported to a permitted disposal site, or made available to the local community as building materials (provided they are in a satisfactory condition following demolition).
Linear infrastructure constructed by the mine (i.e. roads, conveyors and power lines) will be removed if it proves to inhibit land use at decommissioning.
All fences erected around the mine will be dismantled and disposed of at a permitted disposal site.
Air Quality All activities associated with the removal of infrastructure
Infrastructure removal
N -2 -2 -4 1 -7 CbA Dust sampling will be undertaken on a monthly basis.
N -2 -1 -3 1 -5
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has the potential to release dust.
Monthly monitoring reports will be generated by the mine or through a suitably qualified air quality specialist.
In the event that air quality or dust issues are identified based on the monitoring programme, an independent specialist should be appointed to determine the best course of action to ameliorate the situation.
Noise
All activities associated with the removal of infrastructure and rehabilitation has the potential to generate noise.
Infrastructure removal
N -2 -1 -4 3 -4 CbA
The removal of all infrastructure is to take place during daytime periods only. Where noise becomes a nuisance, management measures will be investigated and implemented to address these.
N -2 -1 -3 1 -5
Machinery with low noise levels and maintained in a good order to be used and to comply with the IFC’s Health and Safety Regulations.
Speed control measures will be implemented by the mine through the placement of adequate signage.
Implement a penalty system for non-compliance to speed control measures and ensure that all workers are made aware of the penalty systems.
Gravel roads to be maintained in as good and smooth a condition as possible.
Social - - 0 0 0 0 0 - - - 0 0 0 0 0
Cessation of
Geology No direct impact - - 0 0 0 0 0 - - - - - - - -
Topography No direct impact - - 0 0 0 0 0 - - - - - - - -
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Reversible (R),
Irreplaceable Damage (ID)
or Can be Avoided
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Labour Contracts
Soil, Land Use and Land Capability
No direct impact - - 0 0 0 0 0 - - - - - - - -
Terrestrial Ecology (Fauna & Flora)
No direct impact - - 0 0 0 0 0
- - - - - - - -
Wetland No direct impact - - 0 0 0 0 0 - - - - - - - -
Hydrology No direct impact - - 0 0 0 0 0 - - - - - - - -
Geohydrology No direct impact - - 0 0 0 0 0 - - - - - - - -
Heritage No direct impact - - 0 0 0 0 0 - - - - - - - -
Visual No direct impact - - 0 0 0 0 0 - - - - - - - -
Air Quality No direct impact - - 0 0 0 0 0 - - - - - - - -
Noise No direct impact - - 0 0 0 0 0 - - - - - - - -
Socio-Economic
Plant, store and workshop areas could benefit the local community.
Opportunity to improve economic conditions.
N -3 -3 -4 -5 -15 CbA
Instead of demolition of certain areas, these areas could be sold off as commercial property for use in the local community. All surface structures, infrastructure and ‘hard surfaces’ (inter alia, redundant surfaced roads, parking and paved areas) are to be demolished and removed from the disturbed mine footprint; unless an alternative/continued use for any such items is agreed upon, in writing, with the Department of Mineral Resources (DMR).
P 3 3 4 4 14
Loss of Employment.
Reduction in Economic Activities and Job Opportunities on site.
N -3 -3 -4 -5 -15 CbA
The mine should continue with the skills development programme and Social and Labour Plan commitments to empower the workforce to undertake other economically viable activities.
P 2 3 3 3 11
Waste Management
Groundwater Spill and Release of
N -2 -2 -2 -4 -10 CbA Clean and Dirty water separation systems should be incorporated in terms
N -1 -1 -2 -2 -6
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Reversible (R),
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Handling or Hazardous Waste within workshops and general mine area.
Waste Material and Contaminated Water.
of the 2016 SWMP or any approved update thereafter.
Waste management training must be implemented on site.
Clear signs informing staff of waste management practices must be implemented on site.
Hazardous waste handling should only take place within bunded and/or lined areas.
Hazardous waste should be removed by a licenced removal company and taken to a suitable and licenced landfill site.
Documentation of removal and safe disposal must be available on site.
Handling of Building Rubble
Disposal of demolished infrastructure and the potential impact on groundwater resources.
N -2 -2 -2 -3 -9 CbA
All infrastructure will be removed and rehabilitated, should no alternative use be found for the structures.
N -1 -1 -2 -2 -6
Foundations will be removed to a depth of 500cm below surface.
All building rubble will follow the waste hierarchy and will therefore either be sold for reuse where possible or as a last option be disposed of at a licensed facility suitable for such waste.
Handling and Storing of Domestic Waste
Spill and Release of Waste Material and Contaminated Water.
N -3 -3 -3 -3 -12 CbA
Clean and Dirty water separation systems should be maintained.
N -2 -3 -2 -2 -9
Waste management training must be implemented on site.
Clear signs informing staff of waste management practices must be implemented on site.
Groundwater monitoring must be undertaken in such a manner as to ensure that any potential impacts from the site can be detected.
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Recycling practices must be investigated and implemented on site.
Surface Water
Handling of Hazardous Waste within workshops and general mine area could contaminate the dirty water storage areas. The water is then reused in the system and could have impacts on the integrity of the storm water system and also the production.
Spill and Release of Waste Material and Contaminated Water.
N -3 -2 -2 -4 -11 CbA
Clean and Dirty water separation systems should be maintained up until closure.
N -1 -1 -2 -2 -6
Waste management training must be implemented on site.
Clear signs informing staff of waste management practices must be implemented on site.
Hazardous waste handling should only take place within bunded and/or lined areas.
Hazardous waste and contaminated materials should be removed by a licenced removal company and taken to a suitable and licenced landfill site.
Documentation of removal and safe disposal must be available on site.
Weekly inspections of Storm Water Management Systems must be undertaken. Any blockages or maintenance requirements must be documented and an action plan developed.
Handling and Storing of Domestic Waste should have no impact on the surface water resources due to the location of the facility. However,
Spill and Release of Waste Material and
N/A -1 -2 -3 -3 -9 CbA
Clean and Dirty water separation systems should be maintained up until closure. N -1 -1 -2 -1 -5
Waste management training must be implemented on site.
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incorrect disposal of waste could hamper the integrity of the storm water system.
Contaminated Water.
Weekly inspections of Storm Water Management Systems must be undertaken. Any blockages or maintenance requirements must be documented and an action plan developed.
Clear signs informing staff of waste management practices must be implemented on site.
Recycling practices must be investigated and implemented on site.
Building rubble must be disposed of in line with the requirements of the NEM: WA.
Access control must be strictly enforced.
Air Quality
The area is located within the mining area and neighbouring the Village Opencast Pit. Dust emissions is not considered to be significant but can occur during excavation and construction activities.
Removal of topsoil.
N -2 -2 -2 -2 -8 CbA
Dust suppression should be undertaken if required [(i.e. on recommendation by the Environmental Control Officer and/or if indicated in the monitoring reports, that the current dust fall out results are increasing towards unacceptable levels (non-compliances)].
N -1 -1 -2 -2 -6
Noise
The area is located within the mining area and neighbouring the Village Opencast Pit. Noise impacts are not considered to
Removal of topsoil.
N -2 -2 -2 -2 -8 CbA
Equipment will be well maintained to reduce excessive noise creation.
N -1 -1 -2 -2 -6 Activities will be restricted to the day time.
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be significant but can occur during excavation and construction activities.
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3.i.xii The Positive and Negative Impacts that the Proposed Activity (in terms of the Initial Site Layout) and Alternatives will have on the Environment and the Community that may be affected
The following key positive impacts are foreseen:
The operation of the mine due to a lawful Discard Dump expansion will allow the mine to operation within the legal realm of the Environmental Legislation;
The expansion of the Discard Dump will allow to the mine to continue in its underground mining operation;
The expansion of the Met Grade Chrome Stockpile and its associated loadout facility will allow the mine to optimally supply to market demands;
The activities mentioned above, allows the mine to operate, invest in the local municipal setting, be a key employment supplier in the area, and participate as one of South Africa’s chrome supply mines.
With any activity where invasive tasks will take place, such as site clearance and constructions, negative impacts may arise. AS part of this project various impacts have been identified in Table 47 to Table 49, it is however clear from these tables that with the correct management measures in place these impacts could be managed successfully with no impact, rated as significant remaining:
The key negative impacts which may/will arise and for which management measures have been recommended are:
Clearance of vegetation within a Critical Biodiversity Area; Potential Loss of soil resources, in a mining operation currently operating in a negative topsoil balance; Potential impact on the surface water resources with an increase in run off, which could lead to the
increase in suspended solids not only within the internal water management system, but also the surrounding watercourses;
Impact on the Dwarsrivier due to the current and foreseen long term pollution plume. It should be noted in this case, that the groundwater numerical model identified that the expansion of the Discard Dump will not have any significant contribution to this existing plume.
3.i.xiii The Possible Mitigation Measures that could be applied and the Level of Risk
When considering Table 47 to Table 49 it is clear that with the correct management measures, the operation is in a position to manage potential impacts to be of manageable or low risk. These management measures include the following:
Site Clearance and Construction Activities: o Initiate the site selection studies for a longer term Discard Dump location; o Demarcate the site activities to the designated sites; o Formulate a site layout indicate the various no go zones (in terms of the Biodiversity Action Plan
Management Areas, watercourse buffers and 1:100 year flood lines); o Implement a disciplinary system for non-compliance to EMP conditions; o Ensure that maximum topsoil is stripped and stockpiled in terms of the mine’s topsoil
management plan (refer to Annexure 10); o Formulate a detailed training plan as part of induction to ensure that all parties are aware of
the environmental characteristics in which the mine is located and the important management commitment, an liabilities;
o Remove vegetation only under a valid Tree Removal Permit; o Establishment of infrastructure: o Ensure that the storm water management system is in place prior to the establishment of
infrastructure; o Construct the foundations of the Discard Dump and Met Grade Stockpile under the supervision
of a registered Engineer. Operational Activities:
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o Maintain topsoil stockpiles; o Initiate the revegetation of the existing Discard Dump where deposition will no longer take
place; o Remain within the design perimeters of the facilities; o Remain within the GN704 Regulations; o Continue with the WUL Conditions in terms of Water Management and Monitoring; o Maintain the Storm Water Management Network; o Continue with internal environmental training; o Ensure that any non-compliance or incident (such as a major spill, encroachment beyond
footprints) are rectified immediately. Closure Phase
o Ensure to rehabilitate the slopes of the Discard Dump to limit recharge from this facility; o Maintain storm water management systems up until rehabilitation has been successful; o Implement the vegetation programme as prescribed by a registered Ecologist; o Formulate a detailed Closure Plan; o Continue with water monitoring for at least 3 years after closure.
3.i.xiv Motivation where no alternative sites were considered
Alternatives were considered as part of this project. Please refer to Section 3.g and Section 3.h.
3.i.xv Statement Motivating the Alternative Development Location within the overall Site
Should the project not be approved (No Go Option) the following implications may arise:
As mentioned before (Section 3f) the demand for chrome has increased globally due to the increase in China Markets. No allowing the expansion of the Met Grade Plant Stockpile will result in a restriction on the volume of this material to be produced. This will result in restricting the mine to market supply available reserves, and could impact on the economics of scale of the mining operation. The load out facility is an ancillary infrastructure to this product stockpile and is required to allow for the movement of the product off site. Not allowing this facility will restrict the logistics of supply to the various markets.
The Discard Dump is a key component to the mining operation, with all Discard from the Plant deposited on this site. The capacity of the Discard Dump is fast reaching its capacity and for this reason additional capacity is required. The Discard Dump extension will provide approximately ten (10) years of life of facility, however, by not allowing this extension the opportunity to assess a new site in terms of detailed specialist studies are lost, as the requirement for capacity is immediate.
Saying the above, specialist studies have been undertaken on both the expansion sites, and no areas of concern have been raised. Although the site is located in a CBA, the mine has already received the required tree removal permits to relocate and remove sensitive tree species.
3.j Full Description of the Process undertaken to Identify, Assess and Rank the Impacts and Risks the Activity will Impose on the preferred Site (In respect of the Final Site Layout Plan) through the Life of the Activity
In order to identify the potential impacts associated with the proposed activities the following steps were undertaken:
The stakeholder consultation process is undertaken in a manner to be interactive, providing landowners and identified stakeholders with the opportunity to provide input into the project. This is a key focus, as the local residence have capabilities of providing site specific information, which may not be available in desktop research material. Stakeholders are requested (as part of the BID) to provide their views on the project and any potential concerns which they may have. All comments and concerns received to date, have been captured and formulated into the impact assessment.
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Various Environmental Studies have been undertaken for a number of projects at the Mine, these include the MPRDA EMP, EMP Alignment, various Basic Assessment Processes, etc. on the portions of land, applicable to this project. The baseline studies and impact findings, were incorporated into the assessment of impacts and the ranking of these.
Additional specialist studies were conducted to determine the risk of the proposed project on the environment which included:
o Ecological Sensitivity Assessment; o Wetland Clarification Study; o Updated Hydrogeological Study including a numerical model.
A detailed desktop investigation was undertaken to determine the environmental setting in which the project is located. Based on the desktop investigations various resources were used to determine the significance and sensitivity of the various environmental considerations. The desktop investigation involved the use of:
o South African National Biodiversity Institute (SANBI) Biodiversity Geographic Database LUDS system;
o Geographic Information System base maps; o Department of Water and Sanitation (previously the Department of Water Affairs) information
documents such as the (ISP and Groundwater Vulnerability Reports); o AGIS; o Municipal Integrated Development Plan; etc. o Site Visits were undertaken in May 2017 and again July 2017. This site visit was utilized to
ensure that the information gathered as part of the desktop investigation reflects the current status of the land.
The rating of the identified impacts were undertaken in a quantitative manner as provided in Section 3.i.x.1 (Impact Ratings). The ratings are undertaken in a manner to calculate the significance of each of the impacts. The EAP also assessed the outcomes of the calculation to determine whether the outcome reflects the perceived and actual views.
The identification of management measures are done based on the significance of the impacts and measures that have been considered appropriate and successful, specifically as Best Practical and Economical Options.
3.k Assessment of Each Identified Potential Significant Impact and Risk
The assessment of the impacts are presented in Table 47 to Table 49.
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3.l Summary of Specialist Reports
For the purposes of this project, a detailed Ecological, Heritage and Paleontological investigation was undertaken. Please refer to Annexure 7, 9, 11 for these reports. The table below presents a concise snapshot of what the outcomes of this study were and what led to this Basic Assessment Application.
Table 50: Specialist Study Findings
List of studies undertaken
Recommendations of specialist reports
Specialist recommendations that have been included in
the Basic Assessment report (mark with an x where
applicable)
Reference to applicable section of report where
specialist recommendations have been included.
Ecology (Annexure 7)
Protected plant species were identified, which requires tree removal permits.
Tree removal permits have already been obtained.
Refer to Section 3.i.ix.1.f
Wetland (Annexure 9)
The study found that the area of concern is not regarded as a wetland. No further recommendations.
No further recommendations
Refer to Section 3.i.ix.1.j
Hydrogeological (Annexure 11)
The focus of the 2017 Dwarsrivier Chrome Mine (DCM) groundwater model review study was on the contaminant transport model in order to improve the confidence in long-term predictions of impacts associated with mining on groundwater quality. The study also evaluated the impacts of extending the Discard Dump. Mine rehabilitation measures were also evaluated as part of the assessment
The main source of nitrate in the mining environment is the mine water circuit. Leach tests undertaken on several rock, discard and tailings samples yielded very low nitrate concentrations. It is thought the nitrates originate from oxidation of the ammonia used in the explosives in the pits and underground workings. When exposed to oxygen and water in the mine water circuit, the ammonia is oxidized to nitrate and concentrated in the closed loop circuit.
Comparison between the leach test results of perceived sources to groundwater contamination and the results of the monitoring programme indicate nitrate concentrations in groundwater in many instances far exceeds the nitrate concentrations in the leach tests. This is especially true for the Northern WRD, where leach tests indicate low nitrate concentrations (<5 mg/l), but groundwater from two monitoring boreholes in this area have nitrate concentrations exceeding 300 mg/l. It is thought that the historical impact on groundwater quality in this area is associated with water and fines entrained in the waste rock. With time and especially in the long-term, the quality of leachate from the WRDs is expected to improve and to reduce to concentrations observed in the leach tests. This was taken into consideration during numerical modelling.
The following operational and long-term scenarios related to the extension of the Discard Dump were tested during modelling:
o Impacts if the extension to the Discard Dump is not lined. The outcome of this scenario indicates that groundwater contamination from the area would move in a northerly direction towards the Dwarsrivier. Contamination is not expected to reach the river within 100 years of mine closure. Nitrate concentrations may increase by between 6 and 10% under the footprint if the extension area is not lined. The plume may move 140m further north than if the extension to the Discard Dump is not constructed. Simulations indicate that the existing contamination already present will continue to impact on groundwater quality in the future. A dolerite dyke thought to be present in this area may affect
Commitments are included into the EMP
Refer to Table 47 to Table 49 for management measures.
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List of studies undertaken
Recommendations of specialist reports
Specialist recommendations that have been included in
the Basic Assessment report (mark with an x where
applicable)
Reference to applicable section of report where
specialist recommendations have been included.
the movement of contamination, but in a limited way. It is important to drill a monitoring borehole into this dyke to determine how it will impact on groundwater flow in this area; o Impacts if the area over which the Discard Dump would
be extended is lined with compacted clay or with a High Density Polyethylene plastic liner. Model simulations indicate that lining the facility would have a limited impact on groundwater quality in the long-term. This is due to the fact that the contamination already present will continue to impact on groundwater quality. Both liners tested will not reduce the existing contamination. Simulations indicate that although the construction of liners under the Discard Dump expansion will reduce the area of contamination and distance over which it will move in the long-term, the liners will not reduce nitrate contamination to below the limit set in the WUL in the long-term.
o Impacts if the Discard Dump is sloped and vegetated at closure. Similar results, as discussed above for the scenarios testing the liners, were obtained for the scenario testing the impact of rehabilitating the Discard Dump at closure (in the scenario that the dump is not lined). It was shown that the implementation of sloping and vegetating the site reduces the concentration and the extent of nitrate contamination in the long-term, but it does not reduce nitrate concentrations to below the WUL condition. This is due to the fact that the existing contamination will continue to impact on groundwater quality in the future and rehabilitation of the site will not eliminate the existing contamination.
Recommendations: o Based on the outcome of the study, it is recommended
that two (2) additional groundwater monitoring boreholes are drilled at the site, once the final designs are available.
o In order to reduce long-term impacts associated with the Discard Dump extension, it is recommended that the suitable base preparation be undertaken as determined by a registered engineer for a Type 4 waste and that the site is rehabilitated to reduce the rate of recharge to near-natural conditions upon closure.
o Focus should be placed on developing more detailed rehabilitation plans (such as ongoing rehabilitation of slopes), based on the outcome of this study. The numerical model should be updated once the final rehabilitation plan has been developed in order to confirm the long-term and residual impacts of the operations on groundwater quality.
o To understand the water as part of the shallow aquifers, test pits are recommended. Any water intercepted should be analysed to determine the quality of the water. The quality will indicate whether surface water runoff may be a resulting cause of nitrate contamination.
o The base of the site is prepared with a suitable base preparation layer as recommended by a registered Engineer to reduce the rate of infiltration to the underlying aquifers.
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List of studies undertaken
Recommendations of specialist reports
Specialist recommendations that have been included in
the Basic Assessment report (mark with an x where
applicable)
Reference to applicable section of report where
specialist recommendations have been included.
o Development of a shallow trench around the facility to avoid the infiltration of upstream runoff and also the discharge of surface seep from the facility;
o Development of berms around the facility to separate clean and dirty water;
o Allowance for a sump within the dirty water catchment of the Discard Dump expansion to capture shallow seep and runoff and pump this water back to the closed water circuit of the mine from where it will be treated through the water treatment plant and reused.
o Upon closure, the site must be sloped and rehabilitated to reduce the rate of recharge to near-natural conditions. Focus must be placed on developing more detailed rehabilitation plans to facilitate this scenario.
Also refer to Appendix 12 for the risk assessment conducted on the fences.
3.m Environmental Impact Statement
3.m.i Summary of the Key Findings of the Environmental Impact Assessment
It should be noted that impacts associated with the proposed project will be significantly lower than a Greenfields project, as activities are located within the existing mining right area and mostly within already disturbed or impact environments.
The activities proposed by the applicant, have not indicated any significant impact in the long term. The main concern of the project was the potential impact of the Discard Dump on the groundwater resources, which has indicated that limited impact is foreseen. Refer to the following key areas which were considered.
Cultural and Heritage Sites
Based on existing studies conducted as part of the overall mine site, no sits of cultural and heritage importance are present on site.
Sensitive Ecosystems
Although the site is located in a CBA, an ecological study was undertaken to determine the presence of sensitive plant and tree species in the area. A detailed study of each of the species were undertaken to determine the location and to obtain a removal certificate from the Department of Agriculture, Forestry, and Fisheries (Ref: LP-SDM-201-06-06-B).
NFEPA Wetlands
Three NFEPA wetlands are indicated around the proposed project area (refer to Section 3.i.ix.1.j). After consideration of these areas, it was found that these sites are in fact the mines internal Return Water Dams and not wetlands.
Another study was undertaken to determine whether a wetland is present to the west of the existing Discard Dump. The study concluded that no wetland is present in this area.
Based on this assessment, no wetlands are located within 500m of the activities considered for this application.
River Systems
The activities will remain outside of the 1:100 year flood lines for both the Springkaanspruit to the east of the proposed developments and the Groot Dwarsrivier towards the south of the proposed developments.
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Groundwater Resources
The hydrogeological study stated that the impact of the expansion will not contribute to any significant increase in impact not already foreseen in the study. Modelling results further indicated that full rehabilitation at mine closure will limit the spread of contamination from the site.
The outcome of the waste classification study completed for the site indicate that the discard material is a Type 4 waste. According to Regulation 636 of the NEM: WA: Type 4 wastes may only be disposed of at Class D landfill sites (see diagram below), designed in accordance with Section 2(1) and (3) of these Norms and Standards, or, subject to Section 3(4) of these Norms and Standards, may be disposed of at a landfill site designed in accordance with the requirements of a GLB- landfill as specific in the Minimum Requirements for Waste Disposal by Landfill (2nd Ed., DWAF, 1998).
Diagram 4: Class D Landfill Liner
The outcome of the numerical groundwater modelling completed as part of the study indicates that groundwater in the vicinity of the expansion to the Discard Dump is already contaminated. This contamination will continue to impact on groundwater quality in this area during the operational phase and in the long-term. Scenarios tested with the model suggest that lining of the Discard Dump extension will not eliminate the existing contamination and that the latter will continue to affect groundwater quality even if liners are constructed. If the Discard Dump extension is lined, nitrate concentrations and the area of contamination will be slightly reduced, but nitrate concentrations will continue to exceed the license conditions in future. The impact of the expansion will have a limited addition to the already expected scenario.
Leach tests undertaken on the discard material furthermore suggests that the discard is not a source to nitrate contamination, with nitrate concentrations below the mine’s WUL conditions. In the long-term the source of nitrate contamination associated with the site is expected to be reduced as very little nitrates will leach from the site.
Based on the available information, it is therefore recommended that the base of the site is designed with the suitable base preparation for a Type 4 waste to reduce the rate of infiltration to the underlying aquifers. Upon closure, the site must be sloped and rehabilitated to reduce the rate of recharge to near-natural conditions. Focus must be placed on developing more detailed rehabilitation plans to facilitate this scenario.
Please refer to Table 47 to Table 49 for the detailed impact discussion.
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3.m.i.1 Direct Impacts during Construction
The following direct impacts are foreseen during the construction phase, but with management measures could be avoided or mitigated (please refer to Table 47 to Table 49):
Geology
Activities will not be placed over undermining areas and therefore the sterilisation of ore reserves are not foreseen.
Topography
Direct impact: topographical changes as a result of land and footprint clearance, topsoil stripping, stockpiling, and infrastructure establishment.
Soils, Land Use and Land Capability
Direct impact: loss of topsoil (soil stripping) in preparation for the construction phase; Direct impact: stripping of topsoil and sub-surface layers will alter the soil landscape during the
construction phase; Direct impact: soil compaction due to construction activities and vehicular movement on site; Direct impact: soil erosion due to exposed surfaces; and Direct impact: soil contamination due to construction vehicles and potential hydrocarbon spillages
and/or leaks.
Hydrology
Direct impact: hydrocarbon spillages from equipment utilised in construction activities.
Geohydrology
Due to the nature of the activities, no additional impact on groundwater environment is expected during the construction phase.
Biodiversity
Direct impact: loss of floral and faunal species of conservation importance due to topsoil removal and vegetation disturbance;
Direct impact: Encroachment of activities further into a CBA area; Direct impact: displacement of faunal species and human/animal conflict during site preparation
activities.
Heritage:
Direct impact: the excavation of footprints for the construction of infrastructure could result in the excavation of heritage resources.
Air Quality
Direct impact: increase in dust fallout from topsoil removal and vegetation removal.
Visual
Direct impact: The expansion of the Discard Dump will be visible from both the Richmond Road, as well as the Sekhukhune Road which will further contribute to the aesthetics of the area, which is already dominated by mining activities.
Noise
Increased noise due to increased vehicular movement on site is not foreseen, as the activities are located within the existing plant and mining area.
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Wetlands
The infrastructures have been placed in such a manner to not disturb or impact on any National Ecosystem & Freshwater Protected Areas (NEFPA). It should be noted that the three identified NFEPA wetlands are in fact the mines’ Return Water Dams and not wetlands.
3.m.i.2 Direct Impacts during the Operational Phase
Topography
No additional impacts are foreseen as part of the operational phase.
Soils, Land Use and Land Capability
Direct impact: soil erosion due to exposed surfaces; Direct impact: soil compaction should vehicles not remain to designated areas; and. Direct impact: soil contamination due to operations vehicles and equipment possibly spilling
hydrocarbons, waste and product beyond contained areas.
Geohydrology
Direct impact: Impact on groundwater due to the increase in the footprint of the Discard Dump. No impact is foreseen on the Met Grade Stockpile, as the facility will be contained on a concrete footprint.
Direct impact: The outcome of this scenario indicates that groundwater contamination from the area would move
in a northerly direction towards the Dwarsrivier. Contamination is not expected to reach the river within 100 years of mine closure. Nitrate concentrations may increase by between 6 and 10% under the footprint if the extension area is not lined. The plume may move 140m further north than if the extension to the Discard Dump is not constructed.
Biodiversity
No further impacts foreseen.
Air Quality
Direct impact: increase in dust fallout from the stockpiles due to the disposal of material onto the Discard dump. The Met Grade Stockpile is a wet process, and no dust should originate for this area.
Visual
No further impact is foreseen as part of the operational phase.
Noise
No further impact is foreseen as part of the operational phase.
Heritage:
No impact on heritage resources are foreseen.
Wetlands
The infrastructure have been placed in such a manner to not disturb or impact on any NEFPA wetlands.
3.m.i.3 Direct Impacts during Decommissioning and Closure
The nature of the listed activities applied for is that these are required as part of the long term mining strategy. Therefore the decommissioning and rehabilitation of this infrastructure will only be required at the end of the Life of Mine (LOM).
Topography
Direct positive impact: reshaping of the area following mining activities in order to achieve the proposed end of mine land use.
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Soils, Land Use and Land Capability
Direct impact: soil erosion due to exposed surfaces and rehabilitation; Direct impact: soil contamination due to operations vehicles and equipment possibly spilling
hydrocarbons. Direct positive impact: Re-establishment of end land use objectives.
Hydrology
Direct impact: surface water contamination as a result of hydrocarbon spills from vehicles used during decommissioning.
Geohydrology
Direct and cumulative impact: Impact on the groundwater due to the pollution plume from the mining related activities (in this case the Discard Dump).
Biodiversity
Direct impact: disruption to faunal and floral communities that have established on site during the operational phase; and.
Direct positive impact: re-establishment of faunal and floral communities during the rehabilitation process.
Air Quality
Direct impact: fugitive dust emissions; and Direct impact: dust entrainment from vehicles on site as a result of driving on exposed surfaces.
Visual
Direct positive impact: landscaping of the entire site; and Direct positive impact: removal of infrastructure from site and re-establishment of vegetated areas.
Noise
Direct impact: increased noise due to rehabilitation activities; and Direct positive impact: reduction in noise levels due to mining cessation.
Social
Direct impact: out-migration of job seekers as the mining operations cease; Direct impact: job losses; Direct impact: loss of the social and economic investment by Khumani as part of the mine’s Social and
Labour Plan into the municipal Integrated Development Plan (IDP); and Direct impact: a reduction in economic activities due to job losses and mine closure.
3.m.ii Direct Cumulative Impacts
The following two environmental parameters are considered potential cumulative impacts:
Groundwater and Surface Water
The extension of the Discard dump is expected to have a limited impact and nitrate contamination is not expected to extend more than 150m from the Discard dump during the operational phase. The historical impact of the mine will however dominate groundwater contamination in this area and even if the Discard dump is not extended, there is already a residual impact in this area, as indicated by the monitoring programme. In the long-term, contamination from the Discard dump will migrate towards the Dwarsrivier and may reach this stream within a 100 years after closure. Only a small section of the Dwarsrivier may be affected (<100m in length). Contamination associated with the extension to the Discard Dump will however migrate in a northerly direction towards the Dwarsrivier. It is not expected that this plume will reach the river 100 years after mining ceases.
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Social and Economic Character
As mentioned before (Section 3f) the demand for chrome has increased globally due to the increase in China Markets. No allowing the expansion of the Met Grade Plant Stockpile will result in a restriction on the volume of this material to be produced. This will result in restricting the mine to market supply available reserves, and could impact on the economics of scale of the mining operation. The load out facility is an ancillary infrastructure to this product stockpile and is required to allow for the movement of the product off site. Not allowing this facility will restrict the logistics of supply to the various markets.
The Discard Dump is a key component to the mining operation, with all Discard from the Plant deposited on this site. The capacity of the Discard Dump is fast reaching its capacity and for this reason additional capacity is required. The Discard Dump extension will provide approximately ten (10) years of life of facility, however, by not allowing this extension the opportunity to assess a new site in terms of detailed specialist studies are lost, as the requirement for capacity is immediate.
Increased sustainability of mining operations in this area will have a multiplier effect in terms of employment and economic activities in the region.
3.m.iii Final Site Map
Refer to Figure 3 for the final site map indicating the listed activity footprints.
3.m.iv Summary of the Positive and Negative Impacts and Risks of the Proposed Activity and Identified Alternatives
Please refer to Table 47 for the detailed assessment of impacts. The key impacts to consider will include:
Positive Impacts o The approval of the project will allow the mine to operate with suitable Mine Residue Disposal
capacity for a further 10 years, whilst investigating alternative long term sites for disposal. o The approval of the project will allow the mine to optimally store and supply Met Grade Chrome to
the markets, which would further increase the mine sustainability and economics.
Negative Impacts o No significant impacts are associated with this project, with the exception of the potential
groundwater impacts associated with the Discard Dump, which is a factor of historical impacts. The numerical model has indicated that the current expected impact vs. the impact with the expansion of the Discard Dump will not have a significant impact or change in impact. It is however important for the mine to consider the various options for closure to determine remedial impacts in the long term.
o The outcome of the waste classification for the discard material indicates that it is a Type 4 waste. In order to reduce the negative impacts associated with the site, it is recommended that the base of the Discard Dump extension is compacted to reduce infiltration from the site.
o Other impacts, which are generally associated with construction and operational activities will required management in order to mitigate any potential impacts and these include:
▪ Loss of soil resources, which will be used in rehabilitation activities; ▪ Relocation of sensitive flora will be required; ▪ Increase presence of weeds and invader species due to the presence of human activities in
the area and the clearing of surfaces; ▪ Erosion due to the clearing of vegetation. ▪ Waste management due to increased presence of construction workers in the area –
specifically considering domestic waste management; and ▪ Increased occurrence of hydrocarbon spills during the presence of construction vehicle and
activities on site which could lead to the presence of soil contamination. Alternatives
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The only alternative considered was that of the Discard Dump. It should be noted that the expansion to the facility is considered a temporary measure, whilst a long term final disposal area to cater for the required capacity is sourced.
o In terms of the Discard Dump certain considerations were made: ▪ The current Discard Dump has reached its capacity. The options the applicant have is
either to backfill discard into old pits, extend the existing footprint or develop a new facility:
▪ The opencast pits present on site has been backfilled in terms of the EMP and the only voids available are those of the underground adit accesses, therefore no further backfilling is possible;
▪ The applicant would prefer to optimally utilise existing and available land in close proximity to the approved facilities. Surface area is available around the existing Discard Dump, the size available is however constraints between the access road to Two Rivers on the west, the Sekhukhune Regional Road on the east, and various Mine and Eskom Powerlines on the North and East. For this reason an areas of 13ha has been allocated for the current expansion.
▪ The current expansion of 13ha could provide a life of facility of over 24 years with a slope angle of 35% (angle of repose). However, the mine is committed to design and operate the facility with closure in mine, and for that reason is committed to a 1:3 slope, which reduces the available capacity, in terms of the available footprint to approximately 10 years.
▪ The current expansion of the Discard Dump is therefore regarded as a temporary solution to a present capacity constraint. During the following four (4) years, the operation will enter into a detailed site selection process during which time a suitable site for a new long term Discard Dump will be assessed.
▪ The current preferred alternative is therefore to utilise the existing surface area around the existing Discard Dump, whilst the operation investigate the preferred location for a long term site in terms of specific environmental studies and impact assessments.
Should the project not be approved (No Go Option) the following implications may arise:
As mentioned before (Section 3f) the demand for chrome has increased globally due to the increase in China Markets. No allowing the expansion of the Met Grade Plant Stockpile will result in a restriction on the volume of this material to be produced. This will result in restricting the mine to market supply available reserves, and could impact on the economics of scale of the mining operation. The load out facility is an ancillary infrastructure to this product stockpile and is required to allow for the movement of the product off site. Not allowing this facility will restrict the logistics of supply to the various markets.
The Discard Dump is a key component to the mining operation, with all Discard from the Plant deposited on this site. The capacity of the Discard Dump is fast reaching its capacity and for this reason additional capacity is required. The Discard Dump extension will provide approximately ten (10) years of life of facility, however, by not allowing this extension the opportunity to assess a new site in terms of detailed specialist studies are lost, as the requirement for capacity is immediate.
Saying the above, specialist studies have been undertaken on both the expansion sites, and no areas of concern have been raised. Although the site is located in a CBA, the mine has already received the required tree removal permits to relocate and remove sensitive tree species.
3.n Proposed Impact Management Objectives and the Impact Management Outcomes for inclusion in the EMPr
Please refer to the PART B EMP (Table 56 to Table 58) for the detailed assessment of impacts and recommended objectives. The key objectives to consider will include:
The EMP must be utilised to:
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o Provide sufficient information to strategically plan the activities as to avoid unnecessary social and environmental impacts.
o Provide sufficient information and guidance to plan prospecting activities in a manner that would reduce impacts (both social and environmental) as far as practically possible.
o Ensure an approach that will provide the necessary confidence in terms of environmental compliance.
o Provide a management plan that is effective and practical for implementation.
The proposed impact management objectives as referred to in the table above includes:
To operate within the enviro-legal ambits of South Africa. To be aware of the latest environmental legal requirements. Limit the impact of the activities on the Ecological Setting of the area. Operate the water management circuit on site to increase mining efficiency and reduce the need for
maintenance of these facilities. Limit the loss of soils as far as possible and ensure that the integrity remains during stockpiling for the
purposes of successful rehabilitation. Protect the soil resources within the area in which the mine operates. Remain within the designated area demarcated for activities. Remain within the National Environmental Management: Air Quality Act, 2004 Dust Regulation guidelines
for rural communities. Protect heritage resources for future generations. Protect the groundwater resources to ensure that limited to no impact on groundwater resources occur as a
result of the mining operations. Follow the waste hierarchy approach. Protect the integrity of the Storm Water Management System. Develop the area to its intended final land use.
Through the implementation of the proposed mitigation measures, it is anticipated that the identified impacts can be managed and mitigated effectively and the objectives set can be met. Through the implementation of the mitigation and management measures it is expected that:
The pollution of soil and water resources can be effectively managed through containment; Impact on unknown heritage sites can be effectively managed to the implementation of a management
protocol in the event that such facilities are encountered. Ecological impact can be managed through the implementation of pollution prevention measures, minimizing
land clearing, restricting working hours (faunal disturbance) and rehabilitation. Potential impact of the Discard Dump on the Dwarsrivier in the long term can be managed to ensure the least
impact. This may be achieved through compacting the base of the facility and by sloping and rehabilitating the surface at closure to reduce the rate of recharge of rainwater in the long-term.
3.o Aspects for Inclusion as Conditions of Authorisation
The following conditions should be included in the authorisation in addition to the general conditions included in the Environmental Authorisations:
An independent Environmental Control Officer must be appointed to assess the construction activities, at least once a month to ensure that all components of the EMP are addressed.
Tree removal permits to be applied for where required, after the current permits have lapsed. No activities may be established within either 100m of a river or within the 1:100 year flood line. The numerical model must be updated at least once every two years. The maximum volume of topsoil is to be removed from construction activities. New monitoring boreholes, identified as a requirement in the numerical groundwater model, should be
implemented within 24 months from the date of approval of the Environmental Authorisation. Tests pits must be developed around the Discard Dump expansion to provide further information on the
quality of water seep in this area. Geophysical and Geotechnical assessments on the footprint of the facility should be conducted.
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3.p Description of any Assumptions, Uncertainties and Gaps in Knowledge
The following assumptions, uncertainties and gaps are applicable to this project:
The Basic Assessment Report is based on existing available environmental information and those presented by the specialists and is considered as true and correct;
The project description is based on the information presented by the appliance and is considered as true and correct;
The Basic Assessment Report is a draft report and will be updated with comments received; Some additional work is currently being undertaken which will be included into the final report, which
includes: o Design of the Discard Dump by an engineering team, based on the outcomes of the draft Numerical
Model (presented in this report).
3.q Reasoned Opinion as to Whether the Proposed Activity should or should not be authorised
It is the opinion of the EAP that the activity should be authorized.
Aim of the Project
Currently Dwarsrivier is serviced by 1200 permanent and 800 contractor employees. The majority of the employees are locals drawn from Lydenburg and villages around DWR, including Steelpoort Park, Kalkfontein and Buffelshook. The aim of the proposed activities are to improve the logistics on site, ensure suitable supply of chrome for markets, as well as to ensure a suitable waste rock disposal strategy, whilst a long term strategy is investigated:
The mine has an approved footprint for the Discard Dump. The capacity of this footprint is not suitable to maintain the underground mining operations waste volume production. The capacity of the footprint is being reached and the footprint has to be expanded. According to the production department, the expanded facility can provide a much longer timespan if the angle of the Discard Dump is designed at 35 degrees ( approximately 24 years), however to design and operate the facility at a 1:3 slope for closure a life of facility of approximately 10 years will be available. It should be noted, that for the long terms, an additional facility may still be required. The purpose of the Discard Dump expansion is therefore to provide the mine with an additional 10 years of life, during which time a detailed investigations will be undertaken to determine a suitable site for a long term Discard Dump facility.
According to an article by S&P Global Plats, 6 March 2017 (https://www.platts.com/latest-news/metals/tokyo/strong-chrome-demand-to-hold-but-views-divided-26678512), “strong demand for chromite feedstock of ferrochrome will continue to hold on the back of robust Chinese stainless steel output, but views are divided on whether global supply will move into deficit due to constraints of South African production to meet that demand, industry sources told S&P Global Platts Monday”. According to the article, “sources said there are two possible scenarios arising from South Africa trying to meet Chinese demand amid stagnated output: the market will be short on chrome ore supply as other global suppliers will not be able to fully meet China's demand; or China will reduce dependency on South African chromite supply and diversify to other resources.” According to the Mining Weekly Online (http://m.miningweekly.com/article/strong-outlook-for-recovering-ferrochrome-industry-merafe-2017-03-08/rep_id:3861): “The Chinese economy, on which the ferrochrome and chrome ore markets are heavily dependent, grew by 6.7% year-on-year, underpinning pleasing growth in stainless steel production. Ferrochrome-using stainless steel production is projected to grow by 3.5% in 2017 and by 3.8% in 2018, which should be followed by increased ferrochrome demand.” The Met Grade Plant Stockpile and load out facility allow the mine to sell additional grades to the market. The market demand has increased and therefore a greater size stockpile is required to meet the supply requirements.
The ancillary infrastructure (sewage treatment plant and workshops) are required to fulfil the operational requirements of the mine. The location of these facilities in proximately to the plant will assist in the operational logistics.
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Alternatives Considered:
The following considerations were taken in terms of alternatives:
The capacity of the existing facilities have been reached on site. The ancillary infrastructure will be placed at the closest available open space located near the Plant area, for this reason no alternatives were investigated.
The Met Grade Plant Stockpile is an existing facility and therefore the expansion of the facility is based on available space around the existing site. For this reason no alternatives are available for the stockpile or the load out facility.
In terms of the Discard Dump certain considerations were made in terms of the location of the facility which included backfilling, expansion to the existing area, and a new disposal area. To address the current needs of the applicant and to ensure a sound level of compliance, the best alternative is to utilise the existing area of the Discard Dump and extent this facility in the interim, whilst a suitable long term alternative is found (please refer to Section 3h for a detailed discussion). In the interim the applicant will continue with their investigations for the most effective and practical manner in which to implement the waste management hierarchy, with the aim to reduce waste (optimise mining practices), or reuse the waste (assess avenues to use the discard as aggregate or alternative uses) (please refer to Section 3h for a detailed discussion).
Impacts:
Positive Impacts o The approval of the project will allow the mine to operate with suitable Mine Residue Disposal
capacity for a further 10 years, whilst investigating alternative long term sites for disposal. o The approval of the project will allow the mine to optimally store and supply Met Grade Chrome to
the markets, which would further increase the mine sustainability and economics. Negative Impacts
o No significant additional impacts are associated with this project, with the exception of the potential groundwater impacts associated with the Discard Dump, which is a factor of historical impacts. The numerical model has indicated that the current expected impact vs. the impact with the expansion of the Discard Dump will not have a significant impact or change in impact. It is however important for the mine to consider the various options for closure to determine remedial impacts in the long term.
o The outcome of the waste classification for the discard material indicates that it is a Type 4 waste. In order to reduce the negative impacts associated with the site, it is recommended that the base of the Discard Dump extension is compacted to reduce infiltration from the site.
o Other impacts, which are generally associated with construction and operational activities will required management in order to mitigate any potential impacts and these include:
▪ Loss of soil resources, which will be used in rehabilitation activities; ▪ Relocation of sensitive flora will be required; ▪ Increase presence of weeds and invader species due to the presence of human activities in
the area and the clearing of surfaces; ▪ Erosion due to the clearing of vegetation. ▪ Waste management due to increased presence of construction workers in the area –
specifically considering domestic waste management; and ▪ Increased occurrence of hydrocarbon spills during the presence of construction vehicle and
activities on site which could lead to the presence of soil contamination.
Recommended Conditions:
The following conditions should be included in the authorisation in addition to the general conditions included in the Environmental Authorisations:
An independent Environmental Control Officer must be appointed to assess the construction activities, at least once a month to ensure that all components of the EMP are addressed.
Tree removal permits to be applied for where required, after the current permits have lapsed. No activities may be established within either 100m of a river or within the 1:100 year flood line.
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The numerical model must be updated at least once every two years. The maximum volume of topsoil is to be removed from construction activities. New monitoring boreholes, identified as a requirement in the numerical groundwater model, should be
implemented within 24 months from the date of approval of the Environmental Authorisation. Tests pits must be developed around the Discard Dump expansion to provide further information on the
quality of water seep in this area. Geophysical and Geotechnical assessments on the footprint of the facility should be conducted.
3.r Period for which the Environmental authorisation is required
The project is required for the LOM, which may still continue in excess of 30 years.
3.s Undertaking
An undertaken by the EAP and the client is provided for in Section 2 of the EMP (PART B).
3.t Financial Provision
Newly promulgated regulations (November 2015) pertaining to the Financial Provision for Prospecting, Exploration, Mining and Production Operations in terms of the National Environmental Management Act, 1998 (Act 107 of 1998) (“NEMA”) prescribes the determination and making of Financial Provision for existing rights/permit holders (Regulation 11 of GNR.1147). Importantly, the provisions in Section 24P of NEMA has been given effect through these newly promulgated regulations. These regulations will however only come into full effect during 2019.
An instruction received by the mine from the Limpopo DMR (dated 7 February 2017) indicated that the current financial provisions should still follow the DMR Guideline Document, with the use of the 2016 master Rates.
The following sections presents the methodology for the determination of the financial provision.
3.t.i Explain how the amount was derived
Most important to note is that the prescribed method for estimating a closure cost, as provided for by the DMR in the form of the Guideline Document for the Evaluation of Financial Provisions, only acts as a guideline, and therefore indicates the minimum requirements for assessing and reporting on a closure cost estimate.
3.t.i.1 Method of Assessment
As mentioned before, EnviroGistics made use of the Guideline Document for the Evaluation of Financial Provisions made by the Mining Industry. The following table presents the step-by-step details on how the financial provision has been derived. For the purposes of determining the quantum for closures, it is assumed that the infrastructure will have no salvage value.
3.t.i.2 Summary of Input
The follow table presents the input requirements according to the former DME, now DMR 2005 Guideline Document:
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Table 51: Summary Input Data
Input data required Comment
1. Mineral mined Chrome
2A. Primary risk class for mineral mined Class B
2B. Risk ranking for the mine type and mineral by-product Not applicable to assessment
3. Environmental sensitivity of the mining area High
4.1 Level of information available Extensive
4.2 Identification of closure components As per the approved Environmental Management Plan
4.3 Unit rates for closure components
DMR Master Rates escalated by 6% CPIX to reflect 2017 rates
4.4 Weighting factors Used as applicable to a Class B mine with high sensitivity:
Weighting factor 1 = 1,1 (Undulating terrain)
Weighting factor 2 = 1,05 (Peri-urban)
4.5 Identification of areas of disturbance Undertaken annually by DCM as part of a detailed quantity survey for the operations
4.6 Identification of closure costs from specialist studies As per the approved Environmental Management Plan
4.7 Calculation of closure costs As per the tables presented in Appendix 1
5. Assessment for Class C operations Not applicable to this assessment
6. Independent review This assessment represents an independent review
3.t.i.3 Quantity Estimation
iLEH conducted and updated financial provision assessment during March 2017. The update presented was undertaken with the surveyed quantum for the operations. The survey is undertaken by the mine on an annual basis and is captured in a detailed spreadsheet.
For the purposes of this assessment, EnviroGistics can confirm that the method adopted to obtain and compile the schedule of quantities is sound, correct, and provides detail that is required by the DMR. The information will allow for continued monitoring and updating of quantities and provides the ideal platform to manage and monitor the actual on-site rehabilitation measures and costs incurred.
3.t.i.4 Determination of Rates
The DMR Master Rates used in the calculations were escalated at 6% CPIX (Consumer Price Index) to represent 2017 costs as part of the assessment, and was used for the purposes of this project. These are listed in in the table below.
Table 52: Annual Escalation of DMR Published Rates
Component Description Unit 2005 Published Rate 201 Rate used in
2016/2017 calculation
1 Dismantling of processing plant m3 R6,82 R14.55
2A Demolition of steel buildings & structures m2 R95,00 R202.63
2B Demolition of reinforced concrete structures m2 R140,00 R298.61
3 Rehabilitation of access roads m2 R17,00 R36.26
4A Demolition and rehabilitation of electrified railway lines
m R165,00 R351.93
4B Demolition and rehabilitation of non-electrified railway lines
m R90,00 R191.96
5 Demolition of housing and facilities m2 R190,00 R405.26
6 Opencast rehabilitation including final voids and ramps
ha R99 600,00 R212 439.65
7 Sealing of shafts, adits and inclines m3 R51,00 R108.78
8A Rehabilitation of overburden and spoils ha R66 400,00 R141 626.44
8B Processing waste deposits and evaporation ponds (salt)
ha R82 700,00 R176 393.17
8C Processing waste deposits and evaporation ponds (acid, metal )
ha R240 200,00 R512 329.37
9 Rehabilitation of subsided areas ha R55 600,00 R118 590.81
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Component Description Unit 2005 Published Rate 201 Rate used in
2016/2017 calculation
10 General surface rehab and grassing ha R52 600,00 R112 192.03
11 River diversions ha R52 600,00 R112 192.03
12 Fencing ha R60 000,00 R127.98
13 Water management ha R20 000,00 R42 658.57
14 2 to 3 years of maintenance and aftercare ha R7 000,00 R14 930.50
The mine, as part of the 2016/2017 assessment, categorised all areas, buildings and associated infrastructures in their detailed quantity survey programme. This information was used to assess the current closure estimation.
3.t.i.5 Preliminary Cost Estimation
The following table presents the closure cost rehabilitation components and cost.
Table 53: Closure Cost
Item Description
Area Master Rate Multiplication
Factor Weighting
Factor Weighting
Factor 2 Amount
2B (Concrete Floor) Workshop m2 2000 R 298,61 1 1,1 1,05 R 689 789,10
2B Concrete Slab (Sewage Treatment Facilities) m2 600 R 298,61 1 1,1 1,05 R 206 936,73
2B Concrete Slag (Met Grade Stockpile) m2 7000 R 298,61 1 1,1 1,05 R 2 414 261,85
8A Waste Dumps (Discard MRD) ha 5,5 R 141 626,44 1 1,1 1,05 R 2 617 256,61
0
General Surface Rehabilitation and Grassing (includes 1.5 factor for all areas) ha 9,69 R 112 192,03 1 1,1 1,05 R 1 255 647,59
13 Water Management (includes 1.5 factor for all areas) ha 9,69 R 42 658,57 1 1,1 1,05 R 477 432,58
14 2-3 years of maintenance (includes 1.5 factor for all areas) ha 9,69 R 14 930,50 1 1,1 1,05 R 167 101,41
Sub Total 1 R 7 828 425,87
Preliminary and General (12% of Sub Total 1) R 939 411,10
Contingency (10% of Sub Total 1) R 782 842,59
Sub Total 2 (including minimum requirements) R 9 550 679,57
Administration and supervision costs (6% of Sub Total 1) R 469 705,55
Sub Total 3 R 10 020 385,12
3.t.i.6 Financial Provision
The rehabilitation and liability estimation for the proposed infrastructure related to this application only was determined as a clean closure estimate – no allowance for off-sets or salvage value. The assessment was conducted in accordance with the DMR Guideline and best current practice.
A Sub Total 1 Amount of approximately R 7 828 425,87 (excluding VAT, P&Gs and Contingencies), will be required. With the inclusion of Vat, Contingencies and Preliminary and Generals, the Sub Total 3 will arise to R 10 020 385,12.
The financial provision required by the holder of the mining right must be provided for by one or more of the following methods in order to achieve the total quantum of rehabilitation and remediation of environmental impacts and damage as well as final closure:
Approved dedicated trust fund; Financial guarantee from a South African registered bank or any other approved financial institution; Cash deposit to be deposited at the office of the Regional Manager; or
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Any other manner determined by the Minister.
The client is required to annually assess the total quantum of environmental liability for the operation and ensure that financial provision is sufficient to cover the current liability (in the event of premature closure), as well as the end of life liability.
As per Government Legislature, the client is required to ensure full financial cover for the current liability at any point in the life of the operation. Pecuniary provision must be made for the shortfall between the existing trust fund balance and the premature closure or current environmental rehabilitation liability if applicable.
3.t.ii Confirm that this amount can be provided for from Operating Expenditure
The mine has a guarantee in place to cater for the financial provision of rehabilitation activities. This is assessed annually to ensure that suitable funds are available. The next assessment will be undertaken in March 2018 and annually thereafter.
3.u Specific Information Required by the Competent Authority
3.u.i Compliance with the Provisions of Section 24(4) (a) and (b) read with Section 24(3) (a) and (7) of the National Environmental Management Act (Act 107 of 1998) The EIA Report must include the:-
3.u.i.1 Impact on the Socio-Economic Conditions of any Directly Affected Person
The project is undertaken to allow for optimal mining operations. As mentioned before (Section 3f) the demand for chrome has increased globally due to the increase in China Markets. No allowing the expansion of the Met Grade Plant Stockpile will result in a restriction on the volume of this material to be produced. This will result in restricting the mine to market supply available reserves, and could impact on the economics of scale of the mining operation. The load out facility is an ancillary infrastructure to this product stockpile and is required to allow for the movement of the product off site. Not allowing this facility will restrict the logistics of supply to the various markets.
The Discard Dump is a key component to the mining operation, with all Discard from the Plant deposited on this site. The capacity of the Discard Dump is fast reaching its capacity and for this reason additional capacity is required. The Discard Dump extension will provide approximately ten (10) years of life of facility, however, by not allowing this extension the opportunity to assess a new site in terms of detailed specialist studies are lost, as the requirement for capacity is immediate.
The project should not have any negative impact on the Socio-Economic Conditions of the any party.
3.u.i.2 Impact of any National Estate referred to in Section 3(2) of the National Heritage Resources Act.
Based on the available information, no impact on the natural estate will take place as part of this project.
3.v Other Matters Required in terms of Section 24(4) (a) and (b) of the Act
None.
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The following table presents a summary of the EAPs experience:
Table 55: Experience of EAP
Name Position Qualification Professional Registrations Experience
Tanja Bekker Principal Practitioner
M.Sc. Environmental Management (RAU), now Johannesburg University)
Certified member of the Environmental Assessment Practitioners Association of South Africa (October 2013) Registered with the South African Council of National Scientific Professions (SACNASP: Pr.Sci.Nat. Reg No. 400198/09) Member of International Association of Impact Assessors Member of the Environmental Law Association of South Africa
14 Years
Please refer to Annexure 2 for the Curriculum Vitae of the EAP.
B.Sc. Geography Honours - RAU (University of Johannesburg)
M.Sc. Environmental Management - RAU (University of Johannesburg)
Career Enhancing Courses
ISO 14000 Lead Auditors Course (WTH Management)
Certificate in Project Management (Pretoria University)
Management Advance Programme (MAP 81) (Wits Business School)
Professional Affiliations
Certified member of Environmental Assessment Practitioners Association of South Africa
Certified ISO 14001 Environmental Management System Auditor
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Registered as a Professional Natural Scientist,
Member of the South African affiliate of the International Association for Impact Assessment
Member of the Environmental Law Association of South Africa (ELA).
Summary of the EAP’s past experience
Ms. Bekker is registered as a Professional Natural Scientist with the South African Council of Natural Science Professional Board and is also a Certified Environmental Assessment Practitioner (EAP) with the Interim Certification Body of Environmental Practitioner Association of South Africa (EPASA), a legal requirement stipulated by the National Environmental Management Act, 1998. She is further certified as an ISO 14001 Lead Auditor. Her qualifications include a BSc. Earth Sciences (Geology and Geography), BSc. Hons. Geography, and a MSc. Environmental Management. In addition to the tertiary qualifications, she obtained a Certificate in Project Management, and completed the Management Advance Programme at Wits Business School.
With more than 14 years' working experience in environmental management and the consulting industry and managing various Large Account Clients, she understands the South African Regulatory System, and can advise client with due diligence on their environmental regulatory requirements and offer a solution driven service to their project life cycle. She is equipped with exceptional project management and coordination skills, which especially enhances the service she offers clients within the environmental permitting system.
Her key focus is environmental management and compliance with extensive experience in the mining industry. Project Management and Coordination of projects form a critical component of her duties, which include project planning, initiation of projects, client, authority and stakeholder consultation, specialist coordination, budget control, process control, quality control and timeframe management. Her interest lies in a client advisory capacity, being involved during due diligence investigations, pre-project development and assist the client and engineering team in adding value to develop the project in and environmental sustainable manner, considering client costs and liabilities, as well as consider the implication of environmental authorisation conditions and requirements on project deliverables. Her involvement in projects has spanned over the project life cycle from Due Diligence Investigations, Pre-Feasibility Investigation’s, Prospecting Right Applications, Mining Right Applications, Environmental Reporting and implementation and auditing of Environmental Management Plans and Authorisations.
1.b Description of the Aspects of the Activity
The requirement to describe the aspects of the activity that are covered by the draft environmental management programme is already included in PART A, Section 3.d.
1.c Composite Map
Please refer to the following figure presenting the following:
Aerial image of existing mining operation; CBA areas; NFEPA wetlands and rivers; Surrounding mines.
For further information regarding the environmental characteristics of the area, please refer to Section A (Section 3.i.ix.1).
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Figure 24: Composite Map
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1.d Description of Impact Management Objectives including Management Statements
1.d.i Determination of Closure Objectives
The rehabilitation plan is developed on the basis that the rehabilitated areas are safe, stable, and non-polluting and are able to support a self-sustaining ecosystem similar to surrounding natural environment. To ensure that the rehabilitation plan is aligned with the closure objective, a high level risk assessment of the prospecting components has been undertaken to establish the potential risks associated therewith.
Please refer to Table 56 for the detailed assessment of impacts and recommended objectives. The key objectives to consider will include:
To operate within the enviro-legal ambits of South Africa. To be aware of the latest environmental legal requirements. Limit the impact of the activities on the Ecological Setting of the area. Operate the water management circuit on site to increase mining efficiency and reduce the need for
maintenance of these facilities. Limit the loss of soils as far as possible and ensure that the integrity remains during stockpiling for the
purposes of successful rehabilitation. Protect the soil resources within the area in which the mine operates. Remain within the designated area demarcated for activities. Remain within the National Environmental Management: Air Quality Act, 2004 Dust Regulation guidelines
for rural communities. Protect heritage resources for future generations. Protect the groundwater resources to ensure that limited to no impact on groundwater resources occur as a
result of the mining operations. Follow the waste hierarchy approach. Protect the integrity of the Storm Water Management System. Develop the area to its intended final land use.
1.d.ii Volumes and Rate of Water Use Required for the Operation
No additional water is required for the proposed activities. The water uses as approved in terms of water supply will not require amendment. The mine is currently in the process of establishing a water treatment plant, which will further reduce the need for additional clean water on site, but rather use the treatment of water within the internal circuit.
1.d.iii Has a Water Use License been applied for?
The Discard Dump is an approved activity in terms of the approved 2009 WUL. This WUL will be updated to make provision for the increased capacity of the facility.
1.d.iv Impacts to be mitigated in their Respective Phases
The following table presents the:
Phases of the proposed project; Mitigation requirements; Compliance standards; and Time period during which the management measures should be implemented.
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Table 56: Construction Phase Impact Table with Management Measure, Objectives and Standards
Name of Activity
Impact Area
Potential Impacts Rating
Prior to Measures
Mitigation Type
Performance Objectives
Goals
Activities Potential Impacts Aspect SbM
Reversible (R),
Irreplaceable Damage (ID)
or Can be Avoided
(CbA)
Mitigation Measures SaM
Planning Phase
Legal Requirements (Environmental Permits)
Legal Compliance
Unlawful water and waste (mine residue) activities, which could lead to NWA Directives and Section 24G Rectification fines.
Legal Compliance
-14 CbA
A legal assessment of all activities and future planned activities must be undertaken annually to ensure that all activities are authorised.
17
To operate within the enviro-legal ambits of South Africa.
Ensure that all activities undertaken by the mine are lawful with the required environmental licences in place.
The mine must familiarise themselves with the NEM: WA Regulations for the management of Mine Residue Deposits. Those included in previous approved EMPs are considered lawful under the NEM:WA, however where reworking, rehabilitation, stockpiling is taking place, not included into the previous EMP, these activities are unlawful and may require a Waste License.
To be aware of the latest environmental legal requirements.
Ensure that all environmental authorisations on site is implemented on site and ongoing monitoring of compliance are undertaken to reach 100% compliance.
All legally appointed personnel responsible or involved in water use activities and activities associated in the Environmental Authorisations on site must receive training on the requirements of the Environmental Authorisations and relevant Environmental Legislation.
All Departments responsible for development of the mine, must understand the requirements of the environmental legislation and must involve this into their planning processes.
Quarterly (construction); Biannually (after construction) integral audits must be undertaken during the construction phase, where after biannual audits can be undertaken, on the lawful implementation of the Environmental Authorisation
Water Use Licence must be available on site at all times.
The legal register must be updated to indicate all activities associated with Environmental Authorisations.
Proactive knowledge of potential system errors and/or constraints will
Operational Environmental Management System that addresses the needs and responsibilities of all departments.
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Name of Activity
Impact Area
Potential Impacts Rating
Prior to Measures
Mitigation Type
Performance Objectives
Goals
Activities Potential Impacts Aspect SbM
Reversible (R),
Irreplaceable Damage (ID)
or Can be Avoided
(CbA)
Mitigation Measures SaM
avoid potential non-compliance or process delays.
Relocation of Eskom Powerline
Socio-Economic
The relocation of the Eskom 33kV powerlines feeding towards the Two Rivers Mine could temporarily disrupt Economic Activities in the area which the powerline supplies.
Electricity disruptions.
-12 CbA
The mine should obtain approval from Eskom and affected parties regarding the relocation of the powerlines.
1
Maintain good relationship with surrounding mines.
Approved operating procedure for the relocation of the powerline.
The mine should enter into discussions with Eskom and the affected parties to develop an operating procedure and time line for the removal of the powerlines.
The powerlines may not be removed without the required approvals by Eskom.
No impact on economic activities in the area.
Good relationship with surrounding mines.
Development of Test Pits and additional investigations (geophysics and geotechnical investigations).
Ecology Removal of vegetation. Clearance of footprints.
-6 CbA Restrict clearance to demarcated areas within the area of disturbance.
-4 No additional impact on surface area.
Remain within approved footprints.
Construction Phase
Land and Footprint Clearance Topsoil Stripping and Stockpiling
Geology
No direct impact - Activities will not be constructed over future planned mining areas.
- - - - - - -
Topography
Direct impact: Alteration of topography. Removal of vegetation and the associated shaping of the area will lead to change in topographical characteristics of the area.
Footprint clearance
-9 R
Construction areas must be clearly demarcated to control movement of personnel and vehicles, providing clear boundaries for construction sites in order to limit the spread of impacts. Markers and pegs will be erected and maintained along the boundaries of the working areas, access roads, haul roads and paths before commencing
-5
Remain within demarcated areas. Design facilities to blend into the existing site character as far as
No disturbed areas should remain beyond the demarcated areas. 100% compliance to remain with approved footprint areas.
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Name of Activity
Impact Area
Potential Impacts Rating
Prior to Measures
Mitigation Type
Performance Objectives
Goals
Activities Potential Impacts Aspect SbM
Reversible (R),
Irreplaceable Damage (ID)
or Can be Avoided
(CbA)
Mitigation Measures SaM
The impact is not considered significant due to the fairly flat nature of the topography and the location of the activities in the immediate vicinity of the existing plant area.
any work. If proved insufficient for control, these shall be replaced by fencing.
practically possible.
Designs of the facilities (Stockpile and Discard Dump) must be undertaken by a registered Engineer.
Draw up a procedure clearly reflecting the method and phases of clearance of vegetation only in areas where construction will take place.
Removal of vegetation must be undertaken in a phased approach to limit surface exposure.
Erosion control measures must be implemented early in the construction phase.
Clean and dirty water separation must be implemented early in the construction phase, especially down-gradient of construction areas to ensure that the natural runoff patterns are impacted as little as possible.
Where possible existing roads must be utilised.
Linear infrastructure must follow for as far as practically possible the natural contours of the area.
Soil, Land Use and Land Capability
Direct impact: The removal and stockpiling of topsoil may lead to a loss of soil resource and land capability through erosion of the stockpiles and chemical and physical degradation. This impact is considered important due to the fact that the mine
Footprint clearance
-13 CbA
Adhere to Soil Stripping, Soil Stockpiling and Soil Management Plan as part of the original EMP (Soil Utilisation Guideline). Prior to construction of the road the soil will be stripped and placed on a soil stockpile. Remove at least 30cm of soil or until hard rock is reached. Topsoil should be stockpiled on designated
-5
Limit the loss of soils as far as possible and ensure that the integrity remains during stockpiling for the purposes of successful rehabilitation.
The integrity of the soils stockpiled must remain suitable for the purposes of rehabilitation. No disturbed areas should remain beyond the demarcated areas.
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Name of Activity
Impact Area
Potential Impacts Rating
Prior to Measures
Mitigation Type
Performance Objectives
Goals
Activities Potential Impacts Aspect SbM
Reversible (R),
Irreplaceable Damage (ID)
or Can be Avoided
(CbA)
Mitigation Measures SaM
may be operating on a negative topsoil balance and therefore the retaining of suitable topsoil is important for successful rehabilitation.
topsoil stockpiles, unless around linear infrastructure, where the topsoil could be stockpiled next to the linear structure. The topsoil management plan, 2016 should be implemented on all topsoil’s immediately to ensure that the integrity of the soils are maintained. Any new topsoil stockpiles should not exceed the recommended height in terms of the Topsoil Management Plan, 2016 of 2-4m. Where exceedance is present on existing facilities, erosion control measures should be implemented and vegetation establishment should be encouraged to assist in maintaining the structure of the soils for rehabilitation.
Protect the soil resources within the area in which the mine operates.
100% compliance to remain with approved footprint areas.
Direct impact: Soil compaction
Footprint clearance
-9 CbA
The contractor will ensure that all activities, material and equipment storage and personnel movement take place within the designated area.
-5
A site plan must be developed, indicating the following: Location of all approved activities; 1:100 year buffer around all watercourses; Location of the CBA and mark this as a no-go zone; All vegetation management zones as per the Biodiversity Action Plan.
All contractors must receive induction. The induction should be updated on site, to make provision for the site plan and a detailed explanation on the purpose of the no-go zones, presence of protected species, presence of the CBA and ESAs and the meeting thereof.
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Name of Activity
Impact Area
Potential Impacts Rating
Prior to Measures
Mitigation Type
Performance Objectives
Goals
Activities Potential Impacts Aspect SbM
Reversible (R),
Irreplaceable Damage (ID)
or Can be Avoided
(CbA)
Mitigation Measures SaM
The management of topsoil stockpiles should be undertaken in terms of the Topsoil Management Plan, 2016 to ensure that the topsoil stockpiles maintain its integrity and are not subjected to compaction.
A fine system/disciplinary system must be implemented on site for all significant or recurring environmental non-compliances.
Site clearance and activities should be restricted to the approved footprint. Contractor’s areas should be established on already disturbed footprints.
Direct impact: Clearing vegetation will result in the exposure of soil, which may in turn lead to soil erosion. This impact is considered important due to the fact that the mine may be operating on a negative topsoil balance and therefore the retaining of suitable topsoil is important for successful rehabilitation.
Footprint clearance
-13 CbA
Adhere to Storm water Management Plan, developed by SWS, 2016 or any approved update thereafter.
-6
Limit the loss of soils as far as possible and ensure that the integrity remains during stockpiling for the purposes of successful rehabilitation. Protect the soil resources within the area in which the mine operates.
The integrity of the soils stockpiled must remain suitable for the purposes of rehabilitation.
Ensure that all design drawings include effective erosion control measures.
Ensure the required erosion protection measures are monitored and corrected where necessary.
Natural vegetation establishment (self-succession) will be encouraged on cleared areas, topsoil stockpiles and the Discard Dump slopes.
If natural succession of vegetation is not established within one rainy season after the 1:3 slope of the Discard Dump has been achieved, hydro seeding will be undertaken.
The mine will investigate an appropriate seed mix for the rehabilitation purposes should self-succession not establish on rehabilitated sites.
Areas of construction must be clearly demarcated.
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Name of Activity
Impact Area
Potential Impacts Rating
Prior to Measures
Mitigation Type
Performance Objectives
Goals
Activities Potential Impacts Aspect SbM
Reversible (R),
Irreplaceable Damage (ID)
or Can be Avoided
(CbA)
Mitigation Measures SaM
No construction or project related activities may be undertaken outside of the demarcated areas.
Clean and dirty water systems must be established prior to construction.
Where vegetation cannot be established during the life of construction and operations, appropriate measure will be taken to control erosion. These will include grading of surfaces to prevent rapid run-off of storm water and / or the use of energy dissipaters.
Retaining soil integrity for rehabilitation.
Maintaining soil integrity, with successful vegetation establishment.
The mine will ensure that erosion controls are included in the designs of all linear infrastructure (roads, conveyors, pipelines or open channels) and points of water discharge (where required).
Terrestrial Ecology (Fauna & Flora)
Direct & Cumulative impact: Unplanned loss of floral and faunal species of conservation importance is an important activity to assess and manage due to the fact that the planned activities are located within a CBA. The activity is regarded as a direct and cumulative impact as the loss of species will restrict the purpose and philosophy of the Regional Biodiversity Management Plans.
Footprint clearance
-16 CbA
Prior to the removal of plant species, the mine should appoint an ecologist to monitor and oversee the removal of all identified protected species, which should be removed under tree removal permits. All such species should be demarcated by signage or tape. -6
Limit the impact of the mining operation on the Ecological Setting of the area.
No unlawful removal of flora of conservation importance should take place. Initiate rehabilitation of disturbed areas once the construction phase has been completed. Successful self-succession to be achieved. Eradication of invasive species within the mining area footprint.
Natural vegetation establishment (self-succession) will be encouraged on cleared areas, topsoil stockpiles and the Discard Dump slopes.
If natural succession of vegetation is not established within one rainy season, after the 1:3 slope of the Discard Dump has been achieved, hydro seeding will be undertaken.
ENVIROGISTICS (PTY) LTD 10/12/17
Dwarsrivier Chrome Mine: Basic Assessment Report and Management Plan for the Expansion of the Met Grade Chrome Stockpile and Discard Dump with Ancillary Infrastructure Mining Right Ref: 30/5/1/3/2/1(179) EM Project Ref: 21714 Version: FINAL
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Name of Activity
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Prior to Measures
Mitigation Type
Performance Objectives
Goals
Activities Potential Impacts Aspect SbM
Reversible (R),
Irreplaceable Damage (ID)
or Can be Avoided
(CbA)
Mitigation Measures SaM
However, saying this it is important to understand that the planned activities are not located within pristine environments, but rather directly adjacent to the approved and operational plant, stockpiles and Discard Dump.
Obtain tree removal permit prior to the removal of any protected species, in the event that the existing permit (valid until 26 June 2018) has lapsed.
A fine system/disciplinary system must be implemented on site for all significant or recurring environmental non-compliances.
Site clearance and activities should be restricted to the approved footprint. Contractor’s areas should be established on already disturbed footprints.
All employees, or contractors on site, involved in this project, should receive a detailed induction on the expectations for the protection of fauna and flora on site.
Weed eradication should be implemented on site.
Direct impact: Displacement of faunal species and human/animal conflict. Due to the fact that the site is located within an existing operation mining footprint, and directly adjacent to the plant and perimeter of the existing water management facilities, the impact is not regarded to be as significant as it would have been for a green field’s site.
Footprint clearance
-10 CbA
A record of any animal fatalities should be kept on site. The reason for the fatality and action to avoid such in the future (if possible) should be stated.
-6
Limit the impact of the mining operation on the Ecological Setting of the area.
Zero animal fatality rates should be achieved. No unlawful removal of flora of conservation importance should take place. Offset area should be in place and efficiently operated for the intended purpose of conservation.
Construction and site clearance should be undertaken in a systematic approach to allow animals to relocate from the site where construction will take place.
All employees, or contractors on site, involved in this project, should receive a detailed induction on the expectations for the protection of fauna and flora on site.
Clearance of vegetation must be undertaken in such a manner as to provide sufficient time for animals to relocate.
Direct impact: Loss of ecological connectivity and
Footprint clearance
-10 R No construction or project related activities may be undertaken outside of the demarcated areas.
-4 Limit the impact of the mining
Zero animal fatality rates should be achieved.
ENVIROGISTICS (PTY) LTD 10/12/17
Dwarsrivier Chrome Mine: Basic Assessment Report and Management Plan for the Expansion of the Met Grade Chrome Stockpile and Discard Dump with Ancillary Infrastructure Mining Right Ref: 30/5/1/3/2/1(179) EM Project Ref: 21714 Version: FINAL
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Activities Potential Impacts Aspect SbM
Reversible (R),
Irreplaceable Damage (ID)
or Can be Avoided
(CbA)
Mitigation Measures SaM
ecosystem functioning. Due to the fact that the site is located within an existing operation mining footprint, and directly adjacent to the plant and perimeter of the existing water management facilities, the impact is not regarded to be as significant as it would have been for a green field’s site.
The construction area can be isolated by means of a chain link fence in order to prevent animals on local migrations entering the area and being killed.
operation on the Ecological Setting of the area.
In the establishment of fences, erect fences in such a manner as to limit the potential of animals to enter the plant and silo areas. This could involve the placement of rocks and materials at on the surface of the fences.
Direct impact: The disturbance of the cleared areas may allow the establishment of alien invasive vegetation. Increased prevalence of exotic invasive species: The fact that the area will be cleared for construction creates niches that can be colonised by exotic and/or invasive species. This is compounded by the fact that trucks and other heavy machinery often act as vectors for seeds of these species.
Footprint clearance
-12 CbA
Weed eradication should be implemented on site.
-5
Awareness creation on the importance of that natural ecosystem in which the mine operates. Rehabilitation of disturbed areas with indigenous vegetation. Smallest possible area of disturbance philosophy.
Eradication of invasive species within the mining area footprint. Successful self-succession to be achieved. 100% compliance to remain with approved footprint areas. Initiate rehabilitation of disturbed areas within one year of final activity.
Areas of construction must be clearly demarcated.
No construction or project related activities may be undertaken outside of the demarcated areas.
Direct impact: Increased vibration and noise will have a significant effect mainly on fauna species in the immediate vicinity of the development, due to the heavy machinery
Footprint clearance
-8 CbA
Equipment will be well maintained to reduce excessive noise creation.
-6
Limit the impact of the mining operation on the Ecological Setting of the area. Remain within the
Remain within the regulated guidelines and limits as required by the Mine Health and Safety Act. Zero complaints from
Activities should remain within the demarcated sites.
Activities will be restricted to the day time.
ENVIROGISTICS (PTY) LTD 10/12/17
Dwarsrivier Chrome Mine: Basic Assessment Report and Management Plan for the Expansion of the Met Grade Chrome Stockpile and Discard Dump with Ancillary Infrastructure Mining Right Ref: 30/5/1/3/2/1(179) EM Project Ref: 21714 Version: FINAL
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Name of Activity
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Potential Impacts Rating
Prior to Measures
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Performance Objectives
Goals
Activities Potential Impacts Aspect SbM
Reversible (R),
Irreplaceable Damage (ID)
or Can be Avoided
(CbA)
Mitigation Measures SaM
utilised, and the presence of the activities towards the Springkaanspruit and Dwarsrivier. Direct impact: Vibration can also affect a number of subterranean fauna taxa, such as burrowing mammals, reptiles and arthropods. Vibration affects these animals by causing the collapsing of burrows, and causing these animals to leave the area due to the vibration. Direct impact: Noise will also affect a wide range of taxa including avifauna, mammals, reptiles, amphibians and arthropods.
current ambient character of the site.
surrounding landowners regarding noise levels
Direct and Cumulative Impact: Habitat degradation due to dust: Increased dust will occur in all areas where vegetation is cleared. Dust will be caused by excavation, and construction. Dust in the area will be greatly increased due to the dry weather conditions and the nature of the soil in the
Dust dispersion
-9 CbA
Maintain the current air quality monitoring stations that determine fallout and implement respirable dust (PM10) monitoring that could arise from the mining activities. Implement dust suppression in and around the construction area where required.
-5 Recording of dust fall out to determine trends.
Meeting ambient dust fall out limits in terms of applicable NEM:AQA Regulations.
ENVIROGISTICS (PTY) LTD 10/12/17
Dwarsrivier Chrome Mine: Basic Assessment Report and Management Plan for the Expansion of the Met Grade Chrome Stockpile and Discard Dump with Ancillary Infrastructure Mining Right Ref: 30/5/1/3/2/1(179) EM Project Ref: 21714 Version: FINAL
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Prior to Measures
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Performance Objectives
Goals
Activities Potential Impacts Aspect SbM
Reversible (R),
Irreplaceable Damage (ID)
or Can be Avoided
(CbA)
Mitigation Measures SaM
area. Dust settling on plant material can reduce the amount of light reaching the chlorophyll in the leaves, thereby reducing photosynthesis, which in turn reduces plant productivity, growth and recruitment.
Direct Impact: Increased erosion can eventually lead to the loss of vegetation and habitats for further species. Soils in the area are prone to erosion in areas where vegetation is cleared, this is further compounded by the fact that precipitation in the area occurs through heavy rainfall events in in the form of thundershowers in summer. Furthermore large areas will be cleared before construction leaving these areas prone to erosion.
Footprint clearance
-16 CbA
Ensure the required erosion protection measures are monitored and corrected where necessary.
-6
Limit the impact of the mining operation on the Ecological Setting of the area.
Maintaining soil integrity, with successful vegetation establishment.
Storm water management plan should be implemented prior to construction to ensure that runoff does not lead to the formation of erosion gulley’s.
Where vegetation cannot be established during the life of construction and operations, appropriate measure will be taken to control erosion. These will include grading of surfaces to prevent rapid run-off of storm water and / or the use of energy dissipaters.
Limited to no presence of erosion gulley’s.
An erosion monitoring and mitigation plan should be put in place.
Retaining soil integrity for rehabilitation.
Wetland
No direct impact. The National Freshwater Ecosystem Priority Areas (NFEPA) wetlands present on site, is in fact the mines' dirty water RWDs and not wetlands. No activities will be undertaken within 500m of any wetland system
- 0 - - 0 - -
ENVIROGISTICS (PTY) LTD 10/12/17
Dwarsrivier Chrome Mine: Basic Assessment Report and Management Plan for the Expansion of the Met Grade Chrome Stockpile and Discard Dump with Ancillary Infrastructure Mining Right Ref: 30/5/1/3/2/1(179) EM Project Ref: 21714 Version: FINAL
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Name of Activity
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Potential Impacts Rating
Prior to Measures
Mitigation Type
Performance Objectives
Goals
Activities Potential Impacts Aspect SbM
Reversible (R),
Irreplaceable Damage (ID)
or Can be Avoided
(CbA)
Mitigation Measures SaM
based on the NFEPA sites, if the RWDs are not considered.
Riparian Habitat
The Sprinkaan Spruit is located just 100m to the south of the proposed infrastructure construction (workshops, loadout and sewage facilities). The Dwarsrivier is located to the west of the proposed loadout facility (520m) and Discard Dump (220m).
Footprint clearance
-10 CbA
Remain at all times outside of the 1:100 year flood line of the watercourses. Ongoing Biodiversity Monitoring should be undertaken at the upstream and downstream points. Ongoing surface water monitoring should be undertaken at the upstream and downstream monitoring points. The storm water management plans should be implemented in and around the facilities to ensure that dirty water runoff or water with high sediment loads do not enter the existing watercourses.
-5
Remain within or approve upon the current Aquatic Health and Water Quality baseline conditions.
Improve upon the current aquatic health and water quality baseline conditions.
Hydrology
Direct impact: The removal of vegetation can lead to increased surface runoff, which may in turn alter natural surface water flows and increase siltation of watercourses as well as pollution control facilities.
Footprint clearance
-10 CbA
Rehabilitate open areas as soon as practically possible. Self-succession should be encouraged.
-5
Operate the water management circuit on site to increase mining efficiency and reduce the need for maintenance of these facilities.
Implement the SWMP on site.
The storm water management plans should be implemented in and around the facilities to ensure that dirty water runoff or water with high sediment loads do not enter the existing watercourses.
Limit the areas to be cleared to the demarcated sites.
Geohydrology No direct impact during the construction phase.
- 0 - - 0 - -
Heritage
No direct impact is foreseen in this area. However, due to the nature of heritage sites, graves
Footprint clearance and foundation excavation.
-13 CbA
In the event that heritage artefacts or graves are encountered during the excavation activities, all activities must cease and the SAHRA should be contacted to determine the way forward before construction may continue.
-1
Protect heritage resources for future generations.
Ensure that there is a 100% non-occurrence of impacts to heritage resources.
ENVIROGISTICS (PTY) LTD 10/12/17
Dwarsrivier Chrome Mine: Basic Assessment Report and Management Plan for the Expansion of the Met Grade Chrome Stockpile and Discard Dump with Ancillary Infrastructure Mining Right Ref: 30/5/1/3/2/1(179) EM Project Ref: 21714 Version: FINAL
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Name of Activity
Impact Area
Potential Impacts Rating
Prior to Measures
Mitigation Type
Performance Objectives
Goals
Activities Potential Impacts Aspect SbM
Reversible (R),
Irreplaceable Damage (ID)
or Can be Avoided
(CbA)
Mitigation Measures SaM
may be uncovered during the clearance activities.
Visual Direct impact: soil stripping and footprint clearance
Footprint clearance
-4 CbA Stripping of vegetation and soils should be undertaken within the demarcated areas.
-3
Retain the aesthetics of the area as far as practically possible.
Design and construction infrastructure to blend in with the general topography as far as practically possible. No encroachment outside of demarcated areas.
Air Quality Direct impact: Dust-fallout Footprint clearance
-9 CbA
Utilised the existing monitoring network to monitor dust fall out in and around the construction area. -5
Recording of dust fall out to determine trends.
Meeting ambient dust fall out limits in terms of applicable NEM:AQA Regulations. Strictly enforced speed limits on all roads
Limit site clearance to designated areas.
Noise
The area is located within the mining area. Noise impacts are not considered to be significant but can occur during excavation and construction activities.
Removal of topsoil.
-5 CbA
Equipment will be well maintained to reduce excessive noise creation.
-4
Remain with the required health and safety standards.
Remain within the regulated guidelines and limits as required by the Mine Health and Safety Act.
Activities will be restricted to the day time.
Social No direct impact - 0 - - 0 - -
Establishment of Surface Infrastructure
Geology
No direct impact - Activities will not be constructed over future planned mining areas.
- - - - - - -
Topography
During the site clearance activity, the required storm water management systems and shaping of land would have been completed. Therefore no further impact on the topography is expected
- - - - - - -
No further impact on soil compaction is expected as
- - - - - - -
ENVIROGISTICS (PTY) LTD 10/12/17
Dwarsrivier Chrome Mine: Basic Assessment Report and Management Plan for the Expansion of the Met Grade Chrome Stockpile and Discard Dump with Ancillary Infrastructure Mining Right Ref: 30/5/1/3/2/1(179) EM Project Ref: 21714 Version: FINAL
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Name of Activity
Impact Area
Potential Impacts Rating
Prior to Measures
Mitigation Type
Performance Objectives
Goals
Activities Potential Impacts Aspect SbM
Reversible (R),
Irreplaceable Damage (ID)
or Can be Avoided
(CbA)
Mitigation Measures SaM
Soil, Land Use and Land Capability
all soils would have been removed during the site clearance activities.
Direct impact: Construction activities with surrounding exposed soil may in turn lead to soil erosion.
Active construction
-10 CbA
Ensure that all design drawings include effective erosion control measures and that these are implemented during the establishment of the infrastructure.
-5
Limit the loss of soils as far as possible and ensure that the integrity remains during stockpiling for the purposes of successful rehabilitation.
The integrity of the soils stockpiled must remain suitable for the purposes of rehabilitation.
Ensure the required erosion protection measures are monitored and corrected where necessary.
Vegetation established as part of the site clearance activities, will be monitored and assessed to ensure that these remain well established.
Retaining soil integrity for rehabilitation.
Areas of construction must be clearly demarcated. No construction or project related activities may be undertaken outside of the demarcated areas.
Clean and dirty water systems must be established prior to construction and must be maintained throughout the life of mine.
Where vegetation cannot be established during the life of construction and operations, appropriate measure will be taken to control erosion. These will include grading of surfaces to prevent rapid run-off of storm water and / or the use of energy dissipaters.
Where erosion gulley are formed, these will be recorded on the IsoMetrix system for immediate action.
Terrestrial Ecology
All impacts are assessed under Footprint Clearance.
- 0 CbA - - - -
ENVIROGISTICS (PTY) LTD 10/12/17
Dwarsrivier Chrome Mine: Basic Assessment Report and Management Plan for the Expansion of the Met Grade Chrome Stockpile and Discard Dump with Ancillary Infrastructure Mining Right Ref: 30/5/1/3/2/1(179) EM Project Ref: 21714 Version: FINAL
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Name of Activity
Impact Area
Potential Impacts Rating
Prior to Measures
Mitigation Type
Performance Objectives
Goals
Activities Potential Impacts Aspect SbM
Reversible (R),
Irreplaceable Damage (ID)
or Can be Avoided
(CbA)
Mitigation Measures SaM
(Fauna & Flora)
Wetland No direct impact - 0 - - 0 - -
Hydrology All impacts are assessed under Footprint Clearance.
- 0 CbA - - - -
Geohydrology
Direct impact. The use of waste rock in the compaction of the Discard Dump should not lead to an impact on the groundwater resources as the material is not considered a pollutant. According to Ivusi [Ivusi 2009] the outcome of acid-base accounting (ABA) leach tests results undertaken on tailings and waste rock samples at Dwarsrivier in 2006 was that the material is relatively inert.
Active construction
-9 CbA
In order to reduce long-term impacts associated with the Discard Dump extension, it is recommended that the base of the facility is compacted and that the site is rehabilitated to reduce the rate of recharge to near-natural conditions upon closure. The design of the Discard Dump Footprint should be undertaken in terms of signed of engineering drawings. The correct compaction of the footprint should be undertaken to ensure that the liner is fit for purpose. Exemption in terms of GN704 (Regulation 5) should be obtained from the DWS for the use of the Waste Rock in the construction of the facility. Groundwater monitoring should be undertaken to ensure that the facilities are operated in a manner as not contributed to the current and historic pollution plumes - this should include the implementation of the two new monitoring boreholes as proposed in the numerical model.
-5
Remain within or approve upon the current groundwater quality.
Improve upon the current groundwater quality.
Heritage No direct impact - 0 - - - - -
Visual Direct impact: Establishment of infrastructure.
Active construction
-3 CbA Activities should be restricted within the approved footprints.
-3 Retain the aesthetics of the area as far as
Design and construction infrastructure to blend in with the general topography as far as
ENVIROGISTICS (PTY) LTD 10/12/17
Dwarsrivier Chrome Mine: Basic Assessment Report and Management Plan for the Expansion of the Met Grade Chrome Stockpile and Discard Dump with Ancillary Infrastructure Mining Right Ref: 30/5/1/3/2/1(179) EM Project Ref: 21714 Version: FINAL
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Name of Activity
Impact Area
Potential Impacts Rating
Prior to Measures
Mitigation Type
Performance Objectives
Goals
Activities Potential Impacts Aspect SbM
Reversible (R),
Irreplaceable Damage (ID)
or Can be Avoided
(CbA)
Mitigation Measures SaM
practically possible.
practically possible. No encroachment outside of demarcated areas.
Air Quality All impacts are assessed under Footprint Clearance.
- 0 CbA - - - -
Noise All impacts are assessed under Footprint Clearance.
- 0 CbA - - - -
Social No direct impact - 0 CbA - - - -
Waste Management and Handling Hydrocarbon spills within the Mining Area and the management of Domestic and Hazardous Waste
Geology No direct impact. - - - - - - -
Topography No direct impact. - - - - - - -
Soils Contamination of soil resources due to hydrocarbon spills.
Spills and Release of Contaminants.
-11 CBA
Storage of fuels and oils, the refuelling of vehicles and equipment maintenance must be limited to designated, bunded (bunds to be 110% of volume of the materials stored) areas.
-5
Protecting of soil integrity.
Zero presence of contaminated land due to early detection and implementation of actions.
All fuels and soils must be stored in appropriate containers.
Chemicals and hazardous material must be stored in suitable containers, fit for purpose and in line with SDS requirements.
Where drip trays are too small, specially prepared, non-pervious bunds with solution trenches must be used to capture spillages
Oils and potentially hazardous materials must be disposed of at a licensed facility and waste certificates obtained.
A spill kit must be provided to be used in the event of a spill.
Awareness creation on site regarding duty of care and waste management.
If a spill occurs, the contaminated soil must be removed immediately. Contaminated soil must be stored according to best practices until it can be disposed of at a suitably licensed facility.
Safety signage must be used at designated storage areas.
ENVIROGISTICS (PTY) LTD 10/12/17
Dwarsrivier Chrome Mine: Basic Assessment Report and Management Plan for the Expansion of the Met Grade Chrome Stockpile and Discard Dump with Ancillary Infrastructure Mining Right Ref: 30/5/1/3/2/1(179) EM Project Ref: 21714 Version: FINAL
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Name of Activity
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Prior to Measures
Mitigation Type
Performance Objectives
Goals
Activities Potential Impacts Aspect SbM
Reversible (R),
Irreplaceable Damage (ID)
or Can be Avoided
(CbA)
Mitigation Measures SaM
All workers must undergo an induction which includes environmental awareness training to make them aware of the environmental incident management procedures as well as the importance of complying with management measures.
Ecology
The unmanaged disposal of waste, could result in the spread of invader species, as well as the influx of opportunistic species.
Loss of Ecology and the influx of Opportunistic Species.
-12 CbA
Develop dedicated waste handling areas; prevent access to rodents and opportunistic species; prevent the spread of waste. -5
Proper waste management practices on site.
No unlawful disposal of waste. Registration of all waste handling and/or storage areas on site.
Develop dedicated waste handling areas, fit for purpose and prevent the spread of waste.
Wetlands No direct impact. - - - - - - -
Riparian Habitat
The Sprinkaan Spruit is located just 100m to the south of the proposed infrastructure construction (workshops, loadout and sewage facilities). The Dwarsrivier is located to the west of the proposed loadout facility (520m) and Discard Dump (220m). The presence of littering could enter the watercourses in the area if not managed.
Airborne littering
-10 CbA
Remain at all times outside of the 1:100 year flood line of the watercourses. Ongoing Biomonitoring Monitoring should be undertaken at the upstream and downstream points. Ongoing surface water monitoring should be undertaken at the upstream and downstream monitoring points. The storm water management plans should be implemented in and around the facilities to ensure that dirty water runoff or water with high sediment loads do not enter the existing watercourses. Develop dedicated waste handling areas, fit for purpose and prevent the spread of waste.
-5
Remain within or approve upon the current Aquatic Health and Water Quality baseline conditions.
Improve upon the current aquatic health and water quality baseline conditions.
Surface Water
Handling of Hazardous Waste within workshops and general mine area
Spill and Release of Waste
-11 CbA Clean and Dirty water separation systems should be incorporated in terms of the 2016 SWMP or any approved update thereafter.
-6 Protect the integrity of the Storm Water
Implement the SWMP on site.
ENVIROGISTICS (PTY) LTD 10/12/17
Dwarsrivier Chrome Mine: Basic Assessment Report and Management Plan for the Expansion of the Met Grade Chrome Stockpile and Discard Dump with Ancillary Infrastructure Mining Right Ref: 30/5/1/3/2/1(179) EM Project Ref: 21714 Version: FINAL
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Goals
Activities Potential Impacts Aspect SbM
Reversible (R),
Irreplaceable Damage (ID)
or Can be Avoided
(CbA)
Mitigation Measures SaM
could contaminate the dirty water storage areas. The water is then reused in the system and could have impacts on the integrity of the storm water system and also the production.
Material and Contaminated Water.
A detailed waste management strategy will be established and implemented, which will clearly demarcate the containments for different waste streams.
Management System.
Waste management training must be implemented on site.
Maintain a 100% no-spill record.
Clear signs informing staff of waste management practices must be implemented on site.
Clean spills, if occur witan 24 hours.
Hazardous waste handling should only take place within bunded and/or lined areas.
Maintain a 100% safe disposal record on the disposal of hazardous waste.
Hazardous waste should be removed by a licenced removal company and taken to a suitable and licenced landfill site.
Provide training to all staff on best practices regarding waste management every year.
Documentation of removal and safe disposal must be available on site.
The mine will adopt a cradle-to grave approach to ensure that the waste is removed and disposed of in a legally compliant manner.
Weekly inspections of Storm Water Management Systems must be undertaken. Any blockages or maintenance requirements must be documented and an action plan developed.
Handling and Storing of Domestic Waste should have no impact on the surface water resources due to the location of the facility. However, incorrect disposal of waste could hamper the integrity of the storm water system.
Spill and Release of Waste Material and Contaminated Water.
-9 CbA
Clean and Dirty water separation systems should be incorporated in terms of the 2016 SWMP or any approved update thereafter.
-5
Maintain a 100% compliance with the conditions of the NEM:WA Permit on site for the Salvage Yards.
Waste management training must be implemented on site.
Weekly inspections of Storm Water Management Systems must be undertaken. Any blockages or maintenance requirements must be documented and an action plan developed.
ENVIROGISTICS (PTY) LTD 10/12/17
Dwarsrivier Chrome Mine: Basic Assessment Report and Management Plan for the Expansion of the Met Grade Chrome Stockpile and Discard Dump with Ancillary Infrastructure Mining Right Ref: 30/5/1/3/2/1(179) EM Project Ref: 21714 Version: FINAL
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Name of Activity
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Prior to Measures
Mitigation Type
Performance Objectives
Goals
Activities Potential Impacts Aspect SbM
Reversible (R),
Irreplaceable Damage (ID)
or Can be Avoided
(CbA)
Mitigation Measures SaM
Clear signs informing staff of waste management practices must be implemented on site.
Access control must be strictly enforced.
The berm around upstream of the facility must be maintained.
Recycling practices must be investigated and implemented on site.
Groundwater
Large scale hydrocarbon spills could be present at the mining area
Spill and Release of Waste Material.
-10 R
Clean and Dirty water separation systems should be incorporated in terms of the 2016 SWMP.
-5
Protect the groundwater resources to ensure that limited to no impact on groundwater resources occur as a result of the mining operations.
Achieve 100% compliance to the water quality objectives as agreed to between the mine and the DWS based on the discussions within this IWWMP.
No activities associated with hydrocarbons and/or chemicals may be undertaken outside of an effectively designed and contained area.
All used oils must be removed from site by a licensed company and disposed of at a suitably licensed site.
Any spills occurring during the collection process must be cleaned up immediately.
Implement the SWMP on site.
Any significant spills must be captured in the incident reports and must be reported to the relevant department (LDEDET, Catchment Management Agency/DWS).
Maintain a 100% no-spill record.
All equipment and machinery should be kept in good working order.
A clean up procedure (i.e. Works Instruction) must be in place.
Clean spills, if occur witan 24 hours.
Handling or Hazardous Waste within workshops and general mine area.
Spill and Release of Waste Material and Contaminated Water.
-10 CbA
Clean and Dirty water separation systems should be incorporated in terms of the 2016 SWMP or any approved update thereafter.
-6
Protect the groundwater resources to ensure that limited to no impact on groundwater resources occur as
Achieve 100% compliance to the water quality objectives as agreed to between the mine and the DWS based on the discussions within this IWWMP.
The workshop should be designed with the suitable waste containment measures (berms, sumps, oil separators).
Waste management training must be implemented on site.
ENVIROGISTICS (PTY) LTD 10/12/17
Dwarsrivier Chrome Mine: Basic Assessment Report and Management Plan for the Expansion of the Met Grade Chrome Stockpile and Discard Dump with Ancillary Infrastructure Mining Right Ref: 30/5/1/3/2/1(179) EM Project Ref: 21714 Version: FINAL
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Name of Activity
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Prior to Measures
Mitigation Type
Performance Objectives
Goals
Activities Potential Impacts Aspect SbM
Reversible (R),
Irreplaceable Damage (ID)
or Can be Avoided
(CbA)
Mitigation Measures SaM
Clear signs informing staff of waste management practices must be implemented on site.
a result of the mining operations.
Maintain a 100% safe disposal record on the disposal of hazardous waste.
Hazardous waste handling should only take place within bunded and/or lined areas, with a capacity of at least 110% of the volume stored.
Hazardous waste should be removed by a licenced removal company and taken to a suitable and licenced landfill site.
Documentation of removal and safe disposal must be available on site.
Handling and Storing of Domestic Waste
Spill and Release of Waste Material and Contaminated Water.
-12 CbA
Clean and Dirty water separation systems should be incorporated in terms of the 2016 SWMP or any approved update thereafter.
-9
Achieve 100% compliance to the water quality objectives as agreed to between the mine and the DWS based on the discussions within this IWWMP.
Waste management training must be implemented on site.
Clear signs informing staff of waste management practices must be implemented on site.
Maintain a 100% compliance with the conditions of the ECA permit for the landfill site.
All waste must be removed by licensed contractors and disposed of at a licensed landfill site.
As a duty of care and the cradle to grave principles, the mine should regularly inspect disposal site to ensure that best practices are implemented.
Recycling practices must be investigated and implemented on site where practical.
Maintain a 100% accurate recording of waste and submission of such recording to the Department.
Groundwater monitoring must be undertaken in such a manner as to ensure that any potential impacts from the landfill site can be detected.
Maintain daily covering of the landfill site.
Air Quality No direct impact - - - - - - -
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Name of Activity
Impact Area
Potential Impacts Rating
Prior to Measures
Mitigation Type
Performance Objectives
Goals
Activities Potential Impacts Aspect SbM
Reversible (R),
Irreplaceable Damage (ID)
or Can be Avoided
(CbA)
Mitigation Measures SaM
Heritage No direct impact - - - - - - -
Noise No direct impact - - - - - - -
Visual No direct impact - - - - - - -
Social No direct impact - - - - - - -
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Table 57: Operational Phase Impact Table with Management Measure, Objectives and Standards
Name of Activity
Impact Area
Potential Impacts Mitigation Type
Performance Objectives
Goals Activities Potential Impacts Aspect SbM
Reversible (R),
Irreplaceable Damage (ID)
or Can be Avoided
(CbA)
Mitigation Measures SaM
Operational Phase
Presence of fences in the area.
Geology No impact - - - - - - -
Topography No impact - - - - - - -
Soils Erosion around the fence infrastructure could lead to a loss of soil resources.
Loss of Soil Resources
-13 CbA
The areas where infrastructure are implemented (i.e. fence poles) should be equipped with erosion control measures (gabions) to reduce the potential for erosion. Use of biodegradable hessian sheeting must be made to prevent sedimentation of downstream resources.
-4 Protection of soil resources.
No presence of erosion.
Ecology No impact - - - - - - -
Wetlands No impact - - - - - - -
Riparian Habitat
Impact on the flow of the river could impact the riparian habitat.
Loss of aquatic character.
-10 CbA
Limit vehicle/machinery activity within the active channel as well as in the riparian zone to what is absolutely essential. Disturbances to the riparian zone should be limited as far as possible. Re-fuelling of vehicles to take place outside of the riparian zone & associated buffer zones, on sealed surfaces. Activities should not obstruct flow. Where possible, existing access roads should be used for monitoring purposes so as to minimise the compaction of soils and loss of both riparian and instream habitat. Hot spots for build-up of debris must be identified and debris must be regularly removed to prevent flooding and damage of
-5
Remain within or approve upon the current Aquatic Health and Water Quality baseline conditions.
Improve upon the current aquatic health and water quality baseline conditions.
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Name of Activity
Impact Area
Potential Impacts Mitigation Type
Performance Objectives
Goals Activities Potential Impacts Aspect SbM
Reversible (R),
Irreplaceable Damage (ID)
or Can be Avoided
(CbA)
Mitigation Measures SaM
infrastructure. In this regard, special mention is made of periods following high rainfall and subsequent high instream water volumes. During monitoring, always use the shortest routes possible so as to minimise disturbance and loss of habitat both instream as well as in the riparian zone. The riparian zone must be monitored for alien vegetation encroachment and all alien vegetation/weeds must be removed according to a suitable alien vegetation control plan. Any erosion or gully formation must be identified on an ongoing basis and re-profiled and revegetated accordingly.
Surface Water
Impact of fence collaption during floods.
Both the Groot-Dwars River, as well as the unnamed tributary, are subject to extremely high flow and flood conditions during periods of high rainfall. Thus, each of the fence crossing will need to be designed in
-8 CbA
Each fence will thus need to be designed in such a way as to: o absorb the impact of a flood; and o restore its function post‐flood, with limited repairs.
-4
Adhere to the recommendations of the Aquatic Specialist.
Design and operate the fence in terms of recommendations. Design options to enable a fence to be re‐
established and repaired if necessary post‐flood include: o installing collapsible fences; or o installing sacrificial fences.
The fences must be built independently of other fences, to avoid damage to large lengths of fencing No impact on the aquatic and
surface water characteristics of the system due to the presence of fences.
If possible, the fences should be built in a straight section of the waterway or at the crossover point in the middle of a meander, where the main flow is naturally directed to the centre of the channel
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Name of Activity
Impact Area
Potential Impacts Mitigation Type
Performance Objectives
Goals Activities Potential Impacts Aspect SbM
Reversible (R),
Irreplaceable Damage (ID)
or Can be Avoided
(CbA)
Mitigation Measures SaM
such a way as to be resilient to flood damage.
The point of crossing must consider natural high points on the longitudinal profile, thus reducing the fence height.
Groundwater
No impact - - - - - - -
Heritage No impact - - - - - - -
Air Quality No impact - - - - - - -
Visual No impact - - - - - - -
Noise No impact - - - - - - -
Social No impact - - - - - - -
Operation of Discard Dump and Met Grade Product Stockpile
Geology No direct impact. Impacts are addressed during the construction phase.
- - - - - - -
Topography
The ongoing development of the Discard Dump and Plant Stockpile will result in an ongoing change in the topography.
Ongoing deposition of material (product and discard).
-12 R
The slopes of the Met Grade Plant stockpile should be developed and managed in such a manner that the facility remains within the contained footprint and at a stable slope.
-6
Operating within approved EMP conditions and footprints.
Meeting final land use objectives, by operating stable mining infrastructure (Product Stockpiles and Discard Dumps).
The mine should initiate the site selection process for the long term Discard Dump facility as a matter of urgency.
For the Discard Dump expansion, at closure the side slopes will have been constructed at an angle of no steeper than 1:3. The Discard Dump will be covered with a course (gravel/topsoil) medium or a medium as prescribed by an Ecologist. Should it be determined that vegetation self-succession does not establish, a growth medium will be placed on top of the rock and vegetation re-established.
Ongoing vegetation of slopes should be implemented, this will be specifically required on the side of the current Discard Dump which will be expanded.
ENVIROGISTICS (PTY) LTD 10/12/17
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Name of Activity
Impact Area
Potential Impacts Mitigation Type
Performance Objectives
Goals Activities Potential Impacts Aspect SbM
Reversible (R),
Irreplaceable Damage (ID)
or Can be Avoided
(CbA)
Mitigation Measures SaM
Where possible mine residue should be used to backfill voids according to the approved EMP.
Designs should take cognizance of topographical features of the site.
The Discard Dump should remain within authorised footprint, design and height conditions.
Where possible, and under Environmental Authorisations the mine should implemented the waste hierarchy in an attempt to reduce the disposal of waste rock on site.
Berms will be constructed upstream of the Discard Dump to ensure that clean water is kept separate from dirty water where required.
Soils
The unmanaged disposal of Discard and the overflow of product from the demarcated areas could result in an impact beyond the designated footprints.
Loss of Soil Resources
-13 CbA Stockpiling of waste and product should take place within the demarcated areas.
-5
Proper and planned disposal of Discard and Product.
No exceedances in disposal beyond the approved footprints.
Ecology
The unmanaged disposal of Discard and the overflow of product from the demarcated areas could result in an impact beyond the designated footprints.
Loss of Vegetation
-13 CbA Stockpiling of waste and product should take place within the demarcated areas.
-5
Proper and planned disposal of Discard and Product.
No exceedances in disposal beyond the approved footprints.
Presence of invader species could impact on the natural succession of vegetation on the slopes of Discard Dumps.
Increase in invader species.
-13 CbA
A search must be undertaken prior to clearance for indigenous plants that can be carefully removed and stored for rehabilitation.
-5
Awareness creation on the importance of that natural ecosystem in which the mine operates. Rehabilitation of
Eradication of invasive species within the mining area footprint. Successful self-succession to be achieved. 100% compliance to remain with approved footprint areas.
Where self-succession does not establish, harvested seeds and plants must be used in concurrent rehabilitation for any areas along the area which may be affected.
Compile list of protected and Red Data species, compile relocation programme.
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Name of Activity
Impact Area
Potential Impacts Mitigation Type
Performance Objectives
Goals Activities Potential Impacts Aspect SbM
Reversible (R),
Irreplaceable Damage (ID)
or Can be Avoided
(CbA)
Mitigation Measures SaM
disturbed areas with indigenous vegetation. Smallest possible area of disturbance philosophy.
Initiate rehabilitation of disturbed areas within one year of final activity. The plan for vegetation clearance, must be
developed and implemented prior to site clearance.
Seeds of indigenous plants must also be collected during the clearance activities where practical.
All employees, or contractors on site, involved in this project, must undergo an induction prior to construction where they will be made aware of the footprint, prohibited areas and the importance of compliance with management measures, as well as potential penalties for noncompliance.
No open fires must be allowed.
Vegetation clearance must be limited to within the footprint area
A weed eradication programme must be implemented on site and enforced. This programme must stipulate the monitoring plan, which should include: capturing of areas where invader species are present; action plan to remove these; % successful removal).
Wetlands No direct impact. - - - - - - -
Riparian Habitat
The unmanaged disposal of Discard and the overflow of product from the demarcated areas could result in an impact beyond the designated footprints.
Loss of aquatic character.
-10 CbA
Remain at all times outside of the 1:100 year flood line of the watercourses. Stockpiling of waste and product should take place within the demarcated areas. Ongoing Biomonitoring Monitoring should be undertaken at the upstream and downstream points. Ongoing surface water monitoring should be
-5
Remain within or approve upon the current Aquatic Health and Water Quality baseline conditions.
Improve upon the current aquatic health and water quality baseline conditions.
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Name of Activity
Impact Area
Potential Impacts Mitigation Type
Performance Objectives
Goals Activities Potential Impacts Aspect SbM
Reversible (R),
Irreplaceable Damage (ID)
or Can be Avoided
(CbA)
Mitigation Measures SaM
undertaken at the upstream and downstream monitoring points. The storm water management plans should be implemented in and around the facilities to ensure that dirty water runoff or water with high sediment loads do not enter the existing watercourses. Develop dedicated waste handling areas, fit for purpose and prevent the spread of waste.
Surface Water
Increase in siltation within the internal water circuit reducing existing RWD capacities, which could lead to overflows in the system.
Stockpiling of product at the Met Grade Product Stockpile.
-12 CbA
The product should be stockpiled within a contained facility.
-6
Remain within the footprint of the approved facility.
Implement the SWMP on site. The slopes of the Met Grade Plant stockpile should be developed and managed in such a manner that the facility remains within the contained footprint and at a stable slope.
The slopes of the active Discard Dump should be formed with the placement of material to reduce the potential for erosion Operate the product stockpile in
100% compliance to the allowable footprint.
Surface water monitoring must continue in accordance with the approved WUL.
Maintenance of all SWM systems must be undertaken regularly on site.
Groundwater
Stockpiling of material onto the surfaced (cemented) product stockpile.
Release of Contaminated Water.
-8 R
The groundwater monitoring programme must be implemented and undertaken in accordance to the approved WUL.
-7
Remain within the current baseline groundwater conditions.
Improve of the current baseline groundwater conditions. The product should be stockpiled within a
contained facility, no material to be stored on unsurfaced areas.
Stockpiling of Discard Material onto compacted surfaces. The extension of the Discard dump is expected to have a limited impact and nitrate
Release of Contaminated Water.
-10 R
The groundwater monitoring programme must be implemented and undertaken in accordance to the approved WUL.
-7
Remain within the current baseline groundwater conditions.
Improve of the current baseline groundwater conditions. For the Discard Dump expansion, at closure the
side slopes will have been constructed at an angle of no steeper than 1:3.
ENVIROGISTICS (PTY) LTD 10/12/17
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Name of Activity
Impact Area
Potential Impacts Mitigation Type
Performance Objectives
Goals Activities Potential Impacts Aspect SbM
Reversible (R),
Irreplaceable Damage (ID)
or Can be Avoided
(CbA)
Mitigation Measures SaM
contamination is not expected to extend more than 400m from the Discard dump during the operational phase. The historical impact of the Northern Discard Dump will however dominate groundwater contamination in this area and even if the Discard dump is not extended, there is already a residual impact in this area, as indicated by the DCM monitoring programme. In the long-term, contamination from the Discard dump will migrate towards the Dwarsrivier and may reach this stream within a 100 years after closure. Only a small section of the Dwarsrivier may be affected (<100m in length).
The Discard Dump will be covered with a course (gravel/topsoil) medium or a medium as prescribed by an Ecologist. Should it be determined that vegetation self-succession does not establish, a growth medium will be placed on top of the rock and vegetation re-established.
The groundwater model should be updated annually, at least for five year post the implementation of the WTP, where after the model update schedule can be reassessed.
Ongoing vegetation of slopes should be implemented, this will be specifically required on the side of the current Discard Dump which will be expanded.
The product should be stockpiled within a contained facility, no material to be stored on unsurfaced areas.
Heritage No direct impact - - - - - - -
Air Quality Wind erosion from Stockpiles and Discard Dump may produce fugitive dust.
Dispersion of dust.
-9 R
Install air quality monitoring stations that determine fallout and respirable dust (PM10) concentrations that could arise from the mining activities.
-7
Stable Mine Residue designs.
Zero presence of erosion on site with the successful initiation of self-succession. Construct berms on top of the completed
Discard Dump and vegetate side as much as possible
Dust control measures in the form of slope stability and vegetation (self-succession will be encouraged) will be implemented. Should self-
Recording of dust fall out to determine trends.
Meeting ambient dust fall out limits in terms of applicable NEM:AQA Regulations.
ENVIROGISTICS (PTY) LTD 10/12/17
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Name of Activity
Impact Area
Potential Impacts Mitigation Type
Performance Objectives
Goals Activities Potential Impacts Aspect SbM
Reversible (R),
Irreplaceable Damage (ID)
or Can be Avoided
(CbA)
Mitigation Measures SaM
succession to take place the mine will commit to a vegetation strategy.
Dust suppression should be undertaken if required [(i.e. on recommendation by the Environmental Control Officer and/or if indicated in the monitoring reports, that the current dust fall out results are increasing towards unacceptable levels (non-compliances)].
Visual
Fugitive dust emissions during stockpiling on the dumps and the mere presence of the Mine Residue Stockpiles may have a negative impact on the visual characteristics of the area.
Deterioration of visual character.
-7 R
Any signs of erosion must be rehabilitated immediately.
-5 Stable Mine Residue designs.
Zero presence of erosion on site with the successful initiation of self-succession. Achieving final land use objectives.
A slope of 1:3 should be maintained.
The height of the Discard Dump must not exceed the appropriate height as presented in the pending engineering design of the facility from ground level. At the current time a height of approximately 30m is foreseen, this may be amended based on the Engineering design.
Discard Dump will be subjected to natural vegetation re-establishment, where this is not successful the mine will commit to vegetation strategies.
The slopes of the Discard Dump should be formed with the placement of material to reduce the potential for erosion
Noise No direct impact - - - - - - -
Social
The demand for chrome has increased globally due to the increase in China Markets. No allowing the expansion of the Met Grade Plant Stockpile will result in a restriction on the volume of this material to be produced. This will result in restricting the mine to market supply
Investment into markets and long term operational mine.
-16 CbA
The approval of the project will allow the mine to continue at least for another 10 years in terms of the Discard Capacity. The mine should immediately commence with the assessment of alternatives for long terms discard disposal.
15 Ongoing chrome supply into the market.
Zero cessation of mining activities.
ENVIROGISTICS (PTY) LTD 10/12/17
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Name of Activity
Impact Area
Potential Impacts Mitigation Type
Performance Objectives
Goals Activities Potential Impacts Aspect SbM
Reversible (R),
Irreplaceable Damage (ID)
or Can be Avoided
(CbA)
Mitigation Measures SaM
available reserves, and could impact on the economics of scale of the mining operation. The load out facility is an ancillary infrastructure to this product stockpile and is required to allow for the movement of the product off site. Not allowing this facility will restrict the logistics of supply to the various markets. The Discard Dump is a key component to the mining operation, with all Discard from the Plant deposited on this site. The capacity of the Discard Dump is fast reaching its capacity and for this reason additional capacity is required. The Discard Dump extension will only provide approximately four (4) years of life of facility, however, by not allowing this extension the opportunity to assess a new site in terms of detailed specialist studies are lost, as the requirement for capacity is immediate.
Transportation (Load out area, roads)
Geology No direct impact. Impacts are addressed during the construction phase.
- - - - - - -
ENVIROGISTICS (PTY) LTD 10/12/17
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Name of Activity
Impact Area
Potential Impacts Mitigation Type
Performance Objectives
Goals Activities Potential Impacts Aspect SbM
Reversible (R),
Irreplaceable Damage (ID)
or Can be Avoided
(CbA)
Mitigation Measures SaM
Soil
Contamination of Soil due to hydrocarbon spills
Loss of Soil Resources
-11 CbA
Vehicles and Machinery will be regularly maintained. Maintenance programmes will be established and implemented.
-5
Protecting of soil integrity.
Zero presence of contaminated land due to early detection and implementation of actions.
All refuelling of vehicles and equipment maintenance must be done within designated bunded areas.
If necessary, the polluted soils will be remediated and affected areas rehabilitated.
Spills from conveyors. Contamination of Soils.
-11 CbA
Ongoing maintenance around transfer points should be undertaken.
-5 Any spills of Discard or Product around the conveyor systems should be collected and taken to designated stockpile areas.
Ecology
The establishment of Weeds and Invader Species.
Loss of Vegetation
-13 CBA
A weed eradication programme will be developed and implemented to eradicate weeds and invader plants and to prevent new invasions during the ongoing mining operation.
-5
Limit the impact of the mining operation on the Ecological Setting of the area.
Reduce the presence of invader species by 90% on site. Where self-succession does not establish,
harvested seeds and plants must be used in concurrent rehabilitation for any areas along the area which may be affected.
Accidental death of animals on the roads.
Loss of Animal -13 CbA
Clearly marked signs will be erected along the transportation routes to create awareness of animal crossings.
-10
Awareness creation on the importance of that natural ecosystem in which the mine operates. Implementation of safe operation practices.
Zero animal fatality.
A clearly marked and enforced vehicle speed will be implemented on the internal mine and transportation routes.
A detailed induction programme will be in place to ensure that all parties are aware of the rules and regulations on site in terms of the use of roads.
Vehicles may only travel on demarcated roads on site.
Riparian Habitats
No direct impact - - - - - - -
ENVIROGISTICS (PTY) LTD 10/12/17
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Name of Activity
Impact Area
Potential Impacts Mitigation Type
Performance Objectives
Goals Activities Potential Impacts Aspect SbM
Reversible (R),
Irreplaceable Damage (ID)
or Can be Avoided
(CbA)
Mitigation Measures SaM
Surface & Groundwater Water
Contamination of surface water resources. There are no surface water resources in the area, however, the natural runoff, which must be managed internally on site could become impacted
Spill and Release of Waste Material and Contaminated Water.
-9 CbA
Clean and Dirty water separation systems should be maintained.
-5 Operate the site to limit the presence of spills.
Implement the SWMP on site.
Manage storm water flow with temporary erosion control measures where possible (cut-off trenches or berms)
Conveyors will be maintained and constructed with the appropriate culverts and drains, levelling and surfacing to ensure adequate drainage.
Vehicles/machinery will be regularly monitored and maintained. Maintenance programmes will be established and implemented.
All used oils must be removed from site by a licensed company and disposed of at a suitably licensed site
Any spills occurring during the collection process must be cleaned up immediately.
Maintain a 100% no-spill record. Soil that has been contaminated by spillages, seepages and leachates will be sampled and analysed. If necessary, the soils will be treated, ameliorated or removed for safe disposal.
Any significant spills must be captured in the incident reports and must be reported to the relevant department. In this event a remediation strategy should be developed and enforced.
Clean spills, if occur witan 24 hours.
A clean up procedure (i.e. Works Instruction) must be in place.
Air Quality The use of unsurfaced roads may lead to an increase of dust emissions in the area.
Dispersion of dust.
-9 CbA
Install air quality monitoring stations that determine fallout and respirable dust (PM10) concentrations that could arise from the mining activities.
-5 Reducing dust emissions on site.
Zero complaints from surrounding landowners regarding dust. Dust suppression should be undertaken if
required [(i.e. on recommendation by the Environmental Control Officer and/or if indicated in the monitoring reports, that the
ENVIROGISTICS (PTY) LTD 10/12/17
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Name of Activity
Impact Area
Potential Impacts Mitigation Type
Performance Objectives
Goals Activities Potential Impacts Aspect SbM
Reversible (R),
Irreplaceable Damage (ID)
or Can be Avoided
(CbA)
Mitigation Measures SaM
current dust fall out results are increasing towards unacceptable levels (non-compliances)].
During operational phase of the mine, haulage roads will be treated with dust suppression techniques such as wet to reduce dust creation.
Recording of dust fall out to determine trends. Meeting ambient dust fall out limits in terms of applicable NEM:AQA Regulations.
Tarpaulins will be placed over all vehicles transporting product.
Heritage No direct impact - - - - - - -
Noise Noise of vehicles traversing the access roads will be almost constant
Increase in noise levels.
-10 CbA
Machinery and vehicles will be well maintained to prevent excessive nose and to comply with national and provincial regulations.
-8
Protect the ambiance of the area, as well as maintain good relationships with surrounding land users.
Implement a noise monitoring network.
All vehicles will have muffles to minimise noise emissions, where necessary.
Where noise becomes a nuisance nose management measures will be investigated and implemented to address these concerns.
Noise monitoring will be undertaken (ambient conditions) to ensure that noise levels comply with Health and Safety Standards.
Visual No direct impact - - - - - - -
Social No direct impact - - - - - - -
Operation of Workshop and Sewage Plant
Geology No direct impact. Impacts are addressed during the construction phase.
- - - - - - -
Topography No direct impact. Impacts are addressed during the construction phase.
- - - - - - -
Soils Contamination of soils in the event of an emergency overflow.
Loss of Soil Resources
-9 CbA
Clean and Dirty water separation systems should be incorporated and maintained.
-5
Operate the water management circuit on site to increase mining efficiency and reduce the need
Implement the SWMP on site. All containment facilities should cater for 110% capacity.
Any spills occurring during an emergency or maintenance procedure should be cleaned immediately.
Maintain a 100% no-spill record.
ENVIROGISTICS (PTY) LTD 10/12/17
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Name of Activity
Impact Area
Potential Impacts Mitigation Type
Performance Objectives
Goals Activities Potential Impacts Aspect SbM
Reversible (R),
Irreplaceable Damage (ID)
or Can be Avoided
(CbA)
Mitigation Measures SaM
Contaminated soils should be stockpiled in contained areas temporarily until remediation has taken place, or the soil has been removed by a licensed contractor to a lawful disposal facility.
for maintenance of these facilities.
Maintain the integrity of soils on site.
A clean up procedure (i.e. Works Instruction) must be in place.
Clean spills, if occur within 24 hours.
Ecology No direct impact. Impacts are addressed during the construction phase.
- - - - - - -
Wetlands and Riparian Habitats
No direct impact. Impacts are addressed during the construction phase.
- - - - - - -
Groundwater
The sewage treatment plant will be operated as a closed circuit within the mining area. All treated water will report to the existing RWDs on site, from where water will be reused in the system. No drying beds are present. For this reason no areas of groundwater contamination are expected.
- - - - - - -
Surface Water
Contamination of surface water resources.
Contamination of Surface Water
-8 CbA
Clean and Dirty water separation systems should be incorporated and maintained.
-4
Operate the water management circuit on site to increase mining efficiency and reduce the need for maintenance of these facilities.
Implement the SWMP on site. All containment facilities should cater for 110% capacity.
Any spills occurring during an emergency or maintenance producer should be cleaned immediately.
Maintain a 100% no-spill record.
A clean up procedure (i.e. Works Instruction) must be in place.
Clean spills, if occur within 24 hours.
Heritage No direct impact - - - - - - -
Noise No direct impact - - - - - - -
Visual No direct impact - - - - - - -
ENVIROGISTICS (PTY) LTD 10/12/17
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Name of Activity
Impact Area
Potential Impacts Mitigation Type
Performance Objectives
Goals Activities Potential Impacts Aspect SbM
Reversible (R),
Irreplaceable Damage (ID)
or Can be Avoided
(CbA)
Mitigation Measures SaM
Social No direct impact - - - - - - -
Waste Management and Handling Hydrocarbon spills within the Mining Area and the management of Domestic and Hazardous Waste
Geology No direct impact. - - - - - - -
Topography No direct impact. - - - - - - -
Soils Contamination of soil resources due to hydrocarbon spills.
Spills and Release of Contaminants.
-11 CBA
Storage of fuels and oils, the refuelling of vehicles and equipment maintenance must be limited to designated, bunded (bunds to be 110% of volume of the materials stored) areas.
-5
Protecting of soil integrity.
Zero presence of contaminated land due to early detection and implementation of actions.
All fuels and soils must be stored in appropriate containers.
Chemicals and hazardous material must be stored in suitable containers, fit for purpose and in line with SDS requirements.
Where drip trays are too small, specially prepared, non-pervious bunds with solution trenches must be used to capture spillages
Oils and potentially hazardous materials must be disposed of at a licensed facility and waste certificates obtained.
A spill kit must be provided to be used in the event of a spill.
Awareness creation on site regarding duty of care and waste management.
If a spill occurs, the contaminated soil must be removed immediately. Contaminated soil must be stored according to best practices until it can be disposed of at a suitably licensed facility.
Safety signage must be used at designated storage areas.
All workers must undergo an induction which includes environmental awareness training to make them aware of the environmental incident management procedures as well as the importance of complying with management measures.
Ecology The unmanaged disposal of waste, could result in the spread of invader species, as
Loss of Ecology and the influx of
-12 CbA Develop dedicated waste handling areas; prevent access to rodents and opportunistic species; prevent the spread of waste.
-5 Proper waste management practices on site.
No unlawful disposal of waste.
ENVIROGISTICS (PTY) LTD 10/12/17
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Name of Activity
Impact Area
Potential Impacts Mitigation Type
Performance Objectives
Goals Activities Potential Impacts Aspect SbM
Reversible (R),
Irreplaceable Damage (ID)
or Can be Avoided
(CbA)
Mitigation Measures SaM
well as the influx of opportunistic species.
Opportunistic Species.
Develop dedicated waste handling areas, fit for purpose and prevent the spread of waste.
Registration of all waste handling and/or storage areas on site.
Wetlands No direct impact. - - - - - - -
Riparian Habitat
The Sprinkaan Spruit is located just 100m to the south of the proposed infrastructure construction (workshops, loadout and sewage facilities). The Dwarsrivier is located to the west of the proposed loadout facility (520m) and Discard Dump (220m). The presence of littering could enter the watercourses in the area if not managed.
Airborne littering
-10 CbA
Remain at all times outside of the 1:100 year flood line of the watercourses. Ongoing Biomonitoring Monitoring should be undertaken at the upstream and downstream points. Ongoing surface water monitoring should be undertaken at the upstream and downstream monitoring points. The storm water management plans should be implemented in and around the facilities to ensure that dirty water runoff or water with high sediment loads do not enter the existing watercourses. Develop dedicated waste handling areas, fit for purpose and prevent the spread of waste.
-5
Remain within or approve upon the current Aquatic Health and Water Quality baseline conditions.
Improve upon the current aquatic health and water quality baseline conditions.
Surface Water
Handling of Hazardous Waste within workshops and general mine area could contaminate the dirty water storage areas. The water is then reused in the system and could have impacts on the integrity of the storm water system and also the production.
Spill and Release of Waste Material and Contaminated Water.
-11 CbA
Clean and Dirty water separation systems should be incorporated in terms of the 2016 SWMP or any approved update thereafter.
-6
Protect the integrity of the Storm Water Management System.
Implement the SWMP on site. A detailed waste management strategy will be established and implemented, which will clearly demarcate the containments for different waste streams.
Waste management training must be implemented on site.
Maintain a 100% no-spill record.
Clear signs informing staff of waste management practices must be implemented on site.
Clean spills, if occur witan 24 hours.
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Name of Activity
Impact Area
Potential Impacts Mitigation Type
Performance Objectives
Goals Activities Potential Impacts Aspect SbM
Reversible (R),
Irreplaceable Damage (ID)
or Can be Avoided
(CbA)
Mitigation Measures SaM
Hazardous waste handling should only take place within bunded and/or lined areas.
Maintain a 100% safe disposal record on the disposal of hazardous waste.
Hazardous waste should be removed by a licenced removal company and taken to a suitable and licenced landfill site.
Provide training to all staff on best practices regarding waste management every year.
Documentation of removal and safe disposal must be kept on record and in good order.
The mine will adopt a cradle-to grave (inspection of disposal sites) approach to ensure that the waste is removed and disposed of in a legally compliant manner.
Weekly inspections of Storm Water Management Systems must be undertaken. Any blockages or maintenance requirements must be documented and an action plan developed.
Handling and Storing of Domestic Waste should have no impact on the surface water resources due to the location of the facility. However, incorrect disposal of waste could hamper the integrity of the storm water system.
Spill and Release of Waste Material and Contaminated Water.
-9 CbA
Clean and Dirty water separation systems should be incorporated in terms of the 2016 SWMP or any approved update thereafter.
-5
Maintain a 100% compliance with the conditions of the NEM:WA Permit on site for the Salvage Yards.
Waste management training must be implemented on site.
Weekly inspections of Storm Water Management Systems must be undertaken. Any blockages or maintenance requirements must be documented and an action plan developed.
Clear signs informing staff of waste management practices must be implemented on site.
Access control must be strictly enforced.
The berm around upstream of the facility must be maintained.
Recycling practices must be investigated and implemented on site.
Groundwater
Large scale hydrocarbon spills could be present at the mining area
Spill and Release of
-10 R Clean and Dirty water separation systems should be incorporated in terms of the 2016 SWMP or any approved update thereafter.
-5 Protect the groundwater resources to
Achieve 100% compliance to the water quality objectives as agreed to between the mine and the DWS
ENVIROGISTICS (PTY) LTD 10/12/17
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Name of Activity
Impact Area
Potential Impacts Mitigation Type
Performance Objectives
Goals Activities Potential Impacts Aspect SbM
Reversible (R),
Irreplaceable Damage (ID)
or Can be Avoided
(CbA)
Mitigation Measures SaM
Waste Material.
No activities associated with hydrocarbons and/or chemicals may be undertaken outside of an effectively designed and contained area.
ensure that limited to no impact on groundwater resources occur as a result of the mining operations.
based on the discussions within this IWWMP.
All used oils must be removed from site by a licensed company and disposed of at a suitably licensed site.
Any spills occurring during the collection process must be cleaned up immediately.
Implement the SWMP on site.
Any significant spills must be captured in the incident reports and must be reported to the relevant department (LDEDET, Catchment Management Agency/DWS).
Maintain a 100% no-spill record.
All equipment and machinery should be kept in good working order.
A clean up procedure (i.e. Works Instruction) must be in place.
Clean spills, if occur witan 24 hours.
Handling or Hazardous Waste within workshops and general mine area.
Spill and Release of Waste Material and Contaminated Water.
-10 CbA
Clean and Dirty water separation systems should be incorporated in terms of the 2016 SWMP or any approved update thereafter.
-6
Protect the groundwater resources to ensure that limited to no impact on groundwater resources occur as a result of the mining operations.
Achieve 100% compliance to the water quality objectives as agreed to between the mine and the DWS based on the discussions within this IWWMP.
The workshop should be designed with the suitable waste containment measures (berms, sumps, oil separators).
Waste management training must be implemented on site.
Clear signs informing staff of waste management practices must be implemented on site.
Maintain a 100% safe disposal record on the disposal of hazardous waste.
Hazardous waste handling should only take place within bunded and/or lined areas, with a capacity of at least 110% of the volume stored.
Hazardous waste should be removed by a licenced removal company and taken to a suitable and licenced landfill site.
Documentation of removal and safe disposal must be available on site.
ENVIROGISTICS (PTY) LTD 10/12/17
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Name of Activity
Impact Area
Potential Impacts Mitigation Type
Performance Objectives
Goals Activities Potential Impacts Aspect SbM
Reversible (R),
Irreplaceable Damage (ID)
or Can be Avoided
(CbA)
Mitigation Measures SaM
Handling and Storing of Domestic Waste
Spill and Release of Waste Material and Contaminated Water.
-12 CbA
Clean and Dirty water separation systems should be incorporated in terms of the 2016 SWMP or any approved update thereafter.
-9
Achieve 100% compliance to the water quality objectives as agreed to between the mine and the DWS based on the discussions within this IWWMP.
Waste management training must be implemented on site.
Clear signs informing staff of waste management practices must be implemented on site.
Maintain a 100% compliance with the conditions of the ECA permit for the landfill site.
All waste must be removed by licensed contractors and disposed of at a licensed landfill site.
As a duty of care and the cradle to grave principles, the mine should regularly inspect disposal site to ensure that best practices are implemented.
Recycling practices must be investigated and implemented on site.
Maintain a 100% accurate recording of waste and submission of such recording to the Department.
Records and manifests of waste disposal should be kept on file and in good order.
Groundwater monitoring must be undertaken in such a manner as to ensure that any potential impacts from the landfill site can be detected.
Maintain daily covering of the landfill site.
Air Quality No direct impact - - - - - - -
Heritage No direct impact - - - - - - -
Noise No direct impact - - - - - - -
Visual No direct impact - - - - - - -
Social No direct impact - - - - - - -
ENVIROGISTICS (PTY) LTD 10/12/17
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Table 58: Decommissioning and Closure Phase Impact Table with Management Measure, Objectives and Standards
Name of Activity
Impact Area
Potential Impacts Mitigation Type
Performance Objectives
Goals Activities Potential Impacts Aspect SbM
Reversible (R),
Irreplaceable Damage (ID)
or Can be Avoided
(CbA)
Mitigation Measures SaM
Decommissioning and Closure Phase
Legal Requirements (Environmental Permits)
South Africa Enviro-Legal Requirements
Unlawful activities could lead to NWA Directives and Section 24G Rectification fines.
Legal Compliance.
-14 CbA
A legal assessment of all activities must be undertaken annually to ensure that all are licensed.
17
To operate within the enviro-legal ambits of South Africa.
Ensure that all activities undertaken by the mine are lawful with the required environmental licences in place.
A detailed closure plan must be developed and submitted to the relevant departments for approval.
To be aware of the latest environmental legal requirements.
Ensure that all environmental authorisations on site is implemented on site and ongoing monitoring of compliance are undertaken to reach 100% compliance.
All legally appointed personnel responsible or involved in activities on site must receive training on the requirements of the Environmental Authorisations and EMPs
All Departments responsible for development of the mine, must understand the requirements of the environmental legislation and must involve this into their planning processes.
Quarterly (construction); Biannually (after construction) integral audits must be undertaken during the construction phase, where after biannual audits can be undertaken, on the lawful implementation of the Environmental Authorisation
Environmental Authorisations must be available on site at all times.
The legal register must be updated to indicate all updated activities.
Rehabilitation of Waste Rock Dumps
Geology No direct impact. - - - - - - -
Topography Returning the area to be stable and free draining.
Shaping and landscaping
-12 CbA
Existing waste rock dumps will be used to fill the existing voids and excess material will be employed for mining and vent shaft closure.
13 Free draining environment.
Achieve 100% compliance with post land use commitment.
All remaining waste disposal facilities, must be capped (could only include vegetation to reduce recharge), rehabilitated and closed in compliance with the relevant provisions of Section 11 of the DWA Minimum Requirements
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Name of Activity
Impact Area
Potential Impacts Mitigation Type
Performance Objectives
Goals Activities Potential Impacts Aspect SbM
Reversible (R),
Irreplaceable Damage (ID)
or Can be Avoided
(CbA)
Mitigation Measures SaM
for Waste Disposal by Landfill, or any future amendments thereto/new legislation applicable to such (such as Reg 634-636 of the NEM:WA)
The side slopes of steep areas are to be graded to a slope of approximately 1:3 (or unless otherwise stated) in order to prevent excessive erosion and to allow vegetation to establish sufficient root growth and in line with Health and safety requirements for closure
Side slopes of the rehabilitation area are to be covered by topsoil sourced from the topsoil stockpiles which were created during the clearing of the open pit areas, construction of new activities and tailings areas
Along the crest of steep gradients a 1 meter high Hessian screen should be placed around the facility to assist with the trapping of seeds and to protect the crest from wind erosion
All mine residue deposits should be effectively fenced off to avoid access thereto by unauthorised parties.
Soils No direct impact. - - - - - -
Ecology No direct impact. Loss of ecology and end land use objectives.
-14 CbA
A grass mixture off endemic grasses recommended by an ecologist should be utilised in the seeding process. Note that hydro-seeding is primarily for grasses and smaller shrubs. Larger shrubs and trees will need to be hand-planned.
14 To achieve final land use
The primary goal is to achieve a stable, climax state, representative of the Sekhukhune Mountain Bushveld vegetation type where the ecological function of the plant community is tolerant of most environmental conditions it encounters
The seed mixture should be incorporated into mulch which includes fertiliser and germination acceleration agents where required.
Regular application of fertiliser should take place in order to ensure efficient establishment of vegetation cover until such time as sufficient organic matter is being produced by the established grasses to allow for self-sustaining growth
ENVIROGISTICS (PTY) LTD 10/12/17
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Name of Activity
Impact Area
Potential Impacts Mitigation Type
Performance Objectives
Goals Activities Potential Impacts Aspect SbM
Reversible (R),
Irreplaceable Damage (ID)
or Can be Avoided
(CbA)
Mitigation Measures SaM
If re-seeding for basal cover establishment was not effective during 1st application, a second application of hydro-seed mixture may have to be applied in certain areas. The application of hydro-seed should be at the discretion of the specialist contractor.
No grazing on rehabilitated areas is to occur within three years of reseeding completion
Once sufficient basal cover has been established, the introduction of species representative of the Sekhukhune Mountain Bushveld vegetation type may commence.
Once sufficient basal cover has been established, the introduction of species representative of the Sekhukhune Mountain Bushveld vegetation type may commence.
Introduction of these species should commence through the stages of natural succession, i.e. Pioneer species (grasses, herbaceous species), Secondary species (grasses, small shrubs, and small trees) and Climax state (larger shrubs, large trees). This process will also occur naturally as seeds from the neighbouring Sekhukhune Mountain Bushveld areas are introduced and germinate
Certain tree species can be selectively introduced, however consideration will need to be given to rooting depths and soil stability as well as the ability of the trees to establish on the subject area
Wetlands No direct impact. - - - - - - -
Surface Water
Erosion of the side walls of the Discard Dump could lead not only to instability, but also siltation of water resources.
Contamination of Surface Water
-11 CbA The side walls should be sloped to a degree which will allow stability and self-succession of vegetation.
-5
Final Land Use to have no impact on the surrounding or underlying water resource.
Ensure to utilise Discard Dump material lawfully in an attempt to reduce the presence thereof on site, by either backfilling voids or future adits where possible or sell if correctly classified to lawful users.
ENVIROGISTICS (PTY) LTD 10/12/17
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Name of Activity
Impact Area
Potential Impacts Mitigation Type
Performance Objectives
Goals Activities Potential Impacts Aspect SbM
Reversible (R),
Irreplaceable Damage (ID)
or Can be Avoided
(CbA)
Mitigation Measures SaM
Where self-succession does not establish, it is recommended that the mine investigate a seeding programme.
Achieve 100% compliance to the water quality objectives as agreed to between the mine and the DWS based on the discussions within this report
Clean and dirty water measures must be implemented around and on top of the facilities to manage water and runoff on and around the facility.
Final land use to receive signoff from all stakeholders.
No unnatural ponding of water on site should occur.
Self-succession of vegetation should establish within the first rainy season after construction has been completed.
Groundwater
The extension of the Northern Discard Dump is expected to have a limited impact and nitrate contamination is not expected to extend more than 400m from the Discard Dump during the operational phase. The historical impact of the Northern Discard Dump will however dominate groundwater contamination in this area and even if the Discard Dump is not extended, there is already a residual impact in this area, as indicated by the DCM monitoring programme. In the long-term, contamination from the Northern Discard Dump will
Contamination of Groundwater Resources
-9 Cba
Engineering design drawings for capping and closure of the aforementioned facilities, as developed by a competent civil engineer, must be submitted to the DWS, as well as the DMR, for approval prior to commencing with the closure thereof. Recharge through this facility must be limited through capping to reduce the potential seep of contaminated water. Continuous update of the groundwater numerical model.
-7
Protection of the Groundwater resources.
Improvement of the baseline groundwater quality.
ENVIROGISTICS (PTY) LTD 10/12/17
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Name of Activity
Impact Area
Potential Impacts Mitigation Type
Performance Objectives
Goals Activities Potential Impacts Aspect SbM
Reversible (R),
Irreplaceable Damage (ID)
or Can be Avoided
(CbA)
Mitigation Measures SaM
migrate towards the Dwarsrivier and may reach this stream within a 100 years after closure. Only a small section of the Dwarsrivier may be affected (<100m in length).
Heritage No direct impact. - - - - - - -
Visual No direct impact. - - - - - - -
Noise No direct impact. - - - - - - -
Social No direct impact. - - - - - - -
Dismantling and decommissioning of infrastructure and buildings, including product stockpiles
Geology No direct impact - 0 CbA - 0 - -
Topography Removal of infrastructure may impact on the topography.
Alteration of surface topography.
-13 R
Linear Infrastructure constructed by the mine will be removed if it proves to inhibit land use at decommissioning. Where possible infrastructure will remain for social investment opportunities, this will be decided in conjunction with the Integrated Development Plan of the area ant eh local authorities.
14
Lawful removal of all infrastructure. Achieving final land use objectives.
Availability of safe disposal certificates. Free draining environment, with successful self-succession establishment.
Ensure the entire site remains fenced for the duration of rehabilitation. 2. Retain security access control to the site for the duration of rehabilitation.
All product stockpile to be removed from site.
All fixed assets that can be profitably removed will be removed for salvage or resale (the salvage and resale value have however not been incorporated into the closure cost estimate as per the legislative requirements)
All surface structures, infrastructure and ‘hard surfaces’ (inter alia, redundant surfaced roads, parking and paved areas) are to be demolished and removed from the disturbed mine footprint; unless an alternative/continued use for any such
ENVIROGISTICS (PTY) LTD 10/12/17
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Name of Activity
Impact Area
Potential Impacts Mitigation Type
Performance Objectives
Goals Activities Potential Impacts Aspect SbM
Reversible (R),
Irreplaceable Damage (ID)
or Can be Avoided
(CbA)
Mitigation Measures SaM
items is agreed upon, in writing, with the Department of Mineral Resources (DMR).
All surface infrastructure would be demolished and removed to a depth of 500mm. Any infrastructure below 500mm will be sealed, made safe and left in situ.
All fences erected around the infrastructure be dismantled and either disposed of at a permitted disposal site or sold off as scrap (provided that these structures will no longer be required by the post mining land owner). Fences erected to cordon off dangerous excavations will remain in place and will be maintained as and when required.
Water pollution control structures will remain until the completion of all demolition and associated rehabilitation activities where after these will be rehabilitated.
Soil, Land Use and Land Capability
Spills around the workshops, sewage facilities and stockpiles may result in the contamination of soils.
Operational activities
-11 CbA Any hydrocarbon, effluent or other contaminants should be collected and the soils remediated immediately.
-5
Protection of Soil Integrity.
Zero presence of contaminated land due to early detection and implementation of actions.
Loss of soils due to decommissioning activities present on site.
Operational activities
-11 CbA
Draw up a plan clearly defining the area where the removal of infrastructure should take place. Implement the plan with sufficient measures in place not to compact new areas.
-5 Maintaining soil integrity, with successful vegetation establishment.
Implement a strict penalty fine system for rule breaking with regard to vehicular movement.
Maintain clean and dirty water systems and undertake regular monitoring and maintenance thereof.
ENVIROGISTICS (PTY) LTD 10/12/17
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Name of Activity
Impact Area
Potential Impacts Mitigation Type
Performance Objectives
Goals Activities Potential Impacts Aspect SbM
Reversible (R),
Irreplaceable Damage (ID)
or Can be Avoided
(CbA)
Mitigation Measures SaM
Ecology
The establishment of Weeds and Invader Species.
Loss of Vegetation
-13 CBA
A weed eradication programme will be developed and implemented to eradicate weeds and invader plants and to prevent new invasions during the ongoing mining operation.
-5
Limit the impact of the mining operation on the Ecological Setting of the area.
Reduce the presence of invader species by 90% on site. Where self-succession does not establish,
harvested seeds and plants must be used in concurrent rehabilitation for any areas along the area which may be affected.
Direct impact: Unplanned loss of floral and faunal species of conservation importance
Footprint clearance
-14 CbA
Prior to the removal of plant species, an ecologist should investigate the site (if not already done) to record all species of importance and which should be removed under tree removal permits. All such species should be demarcated by signage or tape.
-6 Achieving final land use commitments.
Self-succession of vegetation should establish within the first rainy season after construction has been completed. Zero removal of species of conservation importance without the necessary permits in place.
Obtain tree removal permit prior to the removal of any protected species.
All employees, or contractors on site, involved in this project, should receive a detailed induction on the expectations for the protection of fauna and flora on site.
Weed eradication should be implemented on site.
Accidental death of animals on the roads.
Loss of Animal -13 CbA
Clearly marked signs will be erected along the transportation routes to create awareness of animal crossings.
-10
Awareness creation on the importance of that natural ecosystem in which the mine operates. Implementation of safe
Zero animal fatality.
A clearly marked and enforced vehicle speed will be implemented on the internal mine and transportation routes.
A detailed induction programme will be in place to ensure that all parties are aware of the rules and regulations on site in terms of the use of roads.
ENVIROGISTICS (PTY) LTD 10/12/17
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Name of Activity
Impact Area
Potential Impacts Mitigation Type
Performance Objectives
Goals Activities Potential Impacts Aspect SbM
Reversible (R),
Irreplaceable Damage (ID)
or Can be Avoided
(CbA)
Mitigation Measures SaM
Vehicles may only travel on demarcated roads on site.
operation practices.
Riparian Habitat
The Sprinkaan Spruit is located just 100m to the south of the proposed infrastructure (workshops, loadout and sewage facilities). The Dwarsrivier is located to the west of the proposed loadout facility (520m) and Discard Dump (220m).
Decommissioning and Closure Activities
-10 CbA
Remain at all times outside of the 1:100 year flood line of the watercourses. Ongoing Biodiversity Monitoring should be undertaken at the upstream and downstream points. Ongoing surface water monitoring should be undertaken at the upstream and downstream monitoring points. The storm water management plans should be retained in and around the facilities to ensure that dirty water runoff or water with high sediment loads do not enter the existing watercourses.
-5
Remain within or approve upon the current Aquatic Health and Water Quality baseline conditions.
Improve upon the current aquatic health and water quality baseline conditions.
Wetland Loss or Impact on NEFPA Sites
Footprint clearance
-13 CbA No activities are planned within 500m from any NEFPA sites. This restriction should be maintained.
-4 Protect sensitive ecosystems.
Remain within the designated footprints at all times.
Hydrology
Erosion control over rehabilitated areas and the prevention of erosion gullies.
Active Rehabilitation
-8 CbA
The topography of all disturbed areas must be rehabilitated in such a manner that the surrounding natural area blends naturally with the rehabilitated areas well as to be free-draining. This will reduce soil erosion and improve natural re-vegetation.
-6
Protect the water resources within the area in which the mine operates.
Maintenance of storm water management systems. Meeting the conditions in terms of Section 21c & of the WUL.
Contamination of surface water as a result of removal of infrastructure.
Operation of machinery and vehicle
-11 R
The detailed waste management strategy implemented during the construction and operation phases must be continuously implemented throughout the closure and decommissioning phase.
-6
Rubble and waste from site could pollute local water resources.
Waste generation and disposal
-8 CbA Waste that is not removed from site should be spread, covered and suitably rehabilitated.
-6
Geohydrology No direct impact - 0 CbA - 0 - -
Heritage No direct impact - 0 CbA - 0 - -
ENVIROGISTICS (PTY) LTD 10/12/17
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Name of Activity
Impact Area
Potential Impacts Mitigation Type
Performance Objectives
Goals Activities Potential Impacts Aspect SbM
Reversible (R),
Irreplaceable Damage (ID)
or Can be Avoided
(CbA)
Mitigation Measures SaM
Visual
Fugitive dust emissions as a result of infrastructure removal and associated exposed/bare areas may have an impact in terms of air quality and visual characteristics.
Vehicle movement and active rehabilitation
-11 R
The dust monitoring network and dust suppression programme established during the construction phase of the project will be maintained throughout the closure phase of the mine. With respect to haul road dust levels, it is recommended to limit vehicle speeds, especially during high risk periods of high winds, high temperature and low humidity.
-5
Remain within the regulated guidelines and limits.
Recording of dust fall out to determine trends.
Establish and implement a dust suppression plan in consultation with the environmental control officer and an air quality specialist as part of the contractor’s responsibility.
Air Quality
All activities associated with the removal of infrastructure and rehabilitation has the potential to release dust.
Active Rehabilitation
-7 R
The dust monitoring network and dust suppression programme established during the construction phase of the project will be maintained throughout the closure phase of the mine. With respect to haul road dust levels, it is recommended to limit vehicle speeds, especially during high risk periods of high winds, high temperature and low humidity.
-5
Remain within the regulated guidelines and limits.
Recording of dust fall out to determine trends.
Meeting ambient dust fall out limits in terms of applicable NEM:AQA Regulations.
Noise
All activities associated with the removal of infrastructure and rehabilitation has the potential to generate noise.
Active Rehabilitation
-7 CbA
The removal of all infrastructure is to take place during daytime periods only.
-5
Remain within the regulated guidelines and limits.
Machinery with low noise levels and maintained in a good order to be used and to comply with the IFC’s Health and Safety Regulations.
Health and Safety Regulations in terms of noise monitoring should be met.
Where noise becomes a nuisance, management measures will be investigated and implemented to address these.
Social
Disruption and nuisance factors associated with the actual decommissioning such as noise, visual and traffic related impacts.
Active Rehabilitation
-7 CbA
Local residents, with the focus on the surrounding landowners, should receive accurate information with regards to the project status, timeframes for decommissioning and other relevant information about issues that could influence their daily living and movement patterns.
-5
Remain within the regulated guidelines and limits.
The community forum established should continue, through which issues can be addressed, and a representative from Khumani should become involved.
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Name of Activity
Impact Area
Potential Impacts Mitigation Type
Performance Objectives
Goals Activities Potential Impacts Aspect SbM
Reversible (R),
Irreplaceable Damage (ID)
or Can be Avoided
(CbA)
Mitigation Measures SaM
Earth Moving, shaping and ripping of ground
Geology No direct impact - 0 - - 0 - -
Topography
The shaping of the site should be undertaken in such a manner that it improves the overall topography of the site.
Active Rehabilitation
13 CbA
Pre-mining topography should be reasonably restored through shaping and landscaping, such that the topography of rehabilitated areas will ultimately be commensurate with that of adjacent, non-disturbed areas.
14
Develop the area to its intended final land use.
Implement an action plan to systematically plan for closure.
Soil erosion
Wind and water erosion in
unvegetated areas
-16 CbA Re-vegetate as soon as possible -5
Develop the area to its intended final land use.
Continuous rehabilitation of the decommissioning area will be conducted in line with the Best Practice Guidelines released by the DWA.
Ripping and topsoil replacement will restore the soil physical characteristics prior to re-vegetation.
Active Rehabilitation
13 CbA
Compacted soils will be ripped and topsoil will be replaced. After the topsoil has been replaced the area should be ameliorated and seeded, should self-succession of vegetation not take place. Only species indigenous to the area will be included.
14
Where sites have been alienated of vegetation or where soils have been compacted or covered with concretes, these sites will be ripped and ploughed.
The topsoil and sub-soils with the appropriate seedbed as stripped during the construction and operational phases will be placed over these areas to a depth as specified by a qualified specialist. The topsoil shall be appropriately ameliorated to allow vegetation to grow rapidly if required – it should be noted that the mine will encourage self-succession of vegetation, if this does not take place effectively a re-vegetation project will be implemented
Terrestrial Ecology (Fauna & Flora)
The rehabilitation of the site will allow reestablishment of natural vegetation.
Rehabilitation 10 CbA
Compacted soils will be ripped and topsoil will be replaced. After the topsoil has been replaced the area should be ameliorated and seeded, should self-succession of vegetation not take place. Only species indigenous to the area will be included. Remove alien vegetation post
13
Protect the Ecology within which the mine operates
Free draining environment with successful self-succession in place.
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Name of Activity
Impact Area
Potential Impacts Mitigation Type
Performance Objectives
Goals Activities Potential Impacts Aspect SbM
Reversible (R),
Irreplaceable Damage (ID)
or Can be Avoided
(CbA)
Mitigation Measures SaM
decommissioning, with long term follow-up afterwards.
On-going alien and invasive floral species control is required through all phases of rehabilitation.
If a reasonable assessment indicates that the re-establishment of vegetation is unacceptable slow, the soil need to be analysed and any deleterious effects must be corrected and the area be seeded with a seed mix to specification
Access to rehabilitated areas should be restricted to vehicles/machinery specifically required for the implementation of the closure plan.
Wetland No direct impact - 0 CbA - - - -
Hydrology
The areas will be landscaped to be free draining in line with the approved storm water management plan.
Runoff from rehabilitated areas will impact on watercourses especially during intensive rainstorms especially if the area are not free draining.
-5 CbA
Berms, should they be necessary, must remain upstream and downstream of the dumps and stockpiles to ensure that clean water is kept separate from dirty water until the area is free draining and re-vegetation has occurred.
-8
Protect the water resources within the area in which the mine operates.
Continuous rehabilitation of the decommissioning area will be conducted in line with the Best Practice Guidelines released by the DWA.
Geohydrology No direct impact - 0 CbA 0
Protect the groundwater resources to ensure that
limited to no impact on
groundwater resources occur
as a result of the mining operations.
Implement and operate a detailed waste manifest on site and
maintain a 100% safe disposal record on the disposal of waste on
site.
Heritage No direct impact - 0 CbA - 0 - -
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Name of Activity
Impact Area
Potential Impacts Mitigation Type
Performance Objectives
Goals Activities Potential Impacts Aspect SbM
Reversible (R),
Irreplaceable Damage (ID)
or Can be Avoided
(CbA)
Mitigation Measures SaM
Visual
The rehabilitation (ripping, topsoil replacement and landscaping) will remove the visual incongruity.
Infrastructure removal
11 CbA
An overall visual improvement will be noticed once all mining related infrastructure has been demolished and the area has been landscaped and re-vegetated.
13 Successful establishment of vegetation.
Remain within the designated area demarcated for activities. Remain within the National Environmental Management: Air Quality Act, 2004 Dust Regulation guidelines for rural communities.
Demarcate the decommissioning area and limit the decommissioning activities as far as possible.
Final shaping will be implemented such that the final profile of the rehabilitated areas are formed to emulate natural contours of the area.
Foundations will be removed to a depth of 1 m below the surface and the area rehabilitated.
All material recovered from the demolition of buildings and/or structures will either be transported to a permitted disposal site, or made available to the local community as building materials (provided they are in a satisfactory condition following demolition).
Linear infrastructure constructed by the mine (i.e. roads, conveyors and power lines) will be removed if it proves to inhibit land use at decommissioning.
All fences erected around the mine will be dismantled and disposed of at a permitted disposal site.
Air Quality
All activities associated with the removal of infrastructure has the potential to release dust.
Infrastructure removal
-7 CbA
Dust sampling will be undertaken on a monthly basis.
-5
No concerns raised by surrounding landowners
Remain within the designated area demarcated for activities.
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Name of Activity
Impact Area
Potential Impacts Mitigation Type
Performance Objectives
Goals Activities Potential Impacts Aspect SbM
Reversible (R),
Irreplaceable Damage (ID)
or Can be Avoided
(CbA)
Mitigation Measures SaM
Monthly monitoring reports will be generated by the mine or through a suitably qualified air quality specialist.
regarding air quality.
Remain within the National Environmental Management: Air Quality Act, 2004 Dust Regulation guidelines for rural communities.
In the event that air quality or dust issues are identified based on the monitoring programme, an independent specialist should be appointed to determine the best course of action to ameliorate the situation.
Noise
All activities associated with the removal of infrastructure and rehabilitation has the potential to generate noise.
Infrastructure removal
-4 CbA
The removal of all infrastructure is to take place during daytime periods only. Where noise becomes a nuisance, management measures will be investigated and implemented to address these.
-5
No concerns raised by surrounding landowners regarding air quality.
Remain within the designated area demarcated for activities.
Machinery with low noise levels and maintained in a good order to be used and to comply with the IFC’s Health and Safety Regulations.
Speed control measures will be implemented by the mine through the placement of adequate signage. Remain within the National
Environmental Management: Air Quality Act, 2004 Dust Regulation guidelines for rural communities.
Implement a penalty system for non-compliance to speed control measures and ensure that all workers are made aware of the penalty systems.
Gravel roads to be maintained in as good and smooth a condition as possible.
Social - 0 - - 0 - -
Cessation of
Labour Contracts
Geology No direct impact - 0 - - - - -
Topography No direct impact - 0 - - - - -
Soil, Land Use and Land Capability
No direct impact - 0 - - - - -
Terrestrial Ecology (Fauna & Flora)
No direct impact - 0
- - - - -
Wetland No direct impact - 0 - - - - -
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Name of Activity
Impact Area
Potential Impacts Mitigation Type
Performance Objectives
Goals Activities Potential Impacts Aspect SbM
Reversible (R),
Irreplaceable Damage (ID)
or Can be Avoided
(CbA)
Mitigation Measures SaM
Hydrology No direct impact - 0 - - - - -
Geohydrology No direct impact - 0 - - - - -
Heritage No direct impact - 0 - - - - -
Visual No direct impact - 0 - - - - -
Air Quality No direct impact - 0 - - - - -
Noise No direct impact - 0 - - - - -
Socio-Economic
Plant, store and workshop areas could benefit the local community.
Opportunity to improve economic conditions.
-15 CbA
Instead of demolition of certain areas, these areas could be sold off as commercial property for use in the local community. All surface structures, infrastructure and ‘hard surfaces’ (inter alia, redundant surfaced roads, parking and paved areas) are to be demolished and removed from the disturbed mine footprint; unless an alternative/continued use for any such items is agreed upon, in writing, with the Department of Mineral Resources (DMR).
14
Optimally utilise buildings and infrastructure.
Safe disposal and lawful operation of infrastructure.
Loss of Employment.
Reduction in Economic Activities and Job Opportunities on site.
-15 CbA
The mine should continue with the skills development programme and Social and Labour Plan commitments to empower the workforce to undertake other economically viable activities.
11
Ensuring successful skills development to allow for continued economically active people and opportunities in the area post mining.
Successful implementation of skills development and opportunities on site.
Waste Management
Groundwater Handling or Hazardous Waste within workshops and general mine area.
Spill and Release of Waste Material and Contaminated Water.
-10 CbA
Clean and Dirty water separation systems should be incorporated in terms of the 2016 SWMP or any approved update thereafter.
-6
Protect the groundwater resources to ensure that limited to no impact on groundwater resources occur as a result of
Achieve 100% compliance to the water quality objectives as agreed to between the mine and the DWS based on the discussions within this IWWMP.
Waste management training must be implemented on site.
Clear signs informing staff of waste management practices must be implemented on site.
Maintain a 100% safe disposal record on the disposal of hazardous waste.
Hazardous waste handling should only take place within bunded and/or lined areas.
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Name of Activity
Impact Area
Potential Impacts Mitigation Type
Performance Objectives
Goals Activities Potential Impacts Aspect SbM
Reversible (R),
Irreplaceable Damage (ID)
or Can be Avoided
(CbA)
Mitigation Measures SaM
Hazardous waste should be removed by a licenced removal company and taken to a suitable and licenced landfill site.
the mining operations.
Documentation of removal and safe disposal must be available on site.
Handling of Building Rubble
Disposal of demolished infrastructure and the potential impact on groundwater resources.
-9 CbA
All infrastructure will be removed and rehabilitated, should no alternative use be found for the structures.
-6
Foundations will be removed to a depth of 500cm below surface.
All building rubble will follow the waste hierarchy and will therefore either be sold for reuse where possible or as a last option be disposed of at a licensed facility suitable for such waste.
Implement and operate a detailed waste manifest on site and maintain a 100% safe disposal record on the disposal of waste on site.
Handling and Storing of Domestic Waste
Spill and Release of Waste Material and Contaminated Water.
-12 CbA
Clean and Dirty water separation systems should be maintained.
-9
Achieve 100% compliance to the water quality objectives as agreed to between the mine and the DWS based on the discussions within this IWWMP.
Waste management training must be implemented on site.
Clear signs informing staff of waste management practices must be implemented on site. Maintain a 100% compliance with
the conditions of the ECA permit for the landfill site.
Groundwater monitoring must be undertaken in such a manner as to ensure that any potential impacts from the site can be detected.
Recycling practices must be investigated and implemented on site.
Maintain a 100% accurate recording of waste and submission of such recording to the Department.
Maintain daily covering of the landfill site.
Surface Water
Handling of Hazardous Waste within workshops and general mine area could contaminate the
Spill and Release of Waste Material and
-11 CbA
Clean and Dirty water separation systems should be maintained up until closure.
-6
Develop the area to its intended final land use.
Maintain the SWMP on site.
Waste management training must be implemented on site.
Maintain a 100% no-spill record.
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Name of Activity
Impact Area
Potential Impacts Mitigation Type
Performance Objectives
Goals Activities Potential Impacts Aspect SbM
Reversible (R),
Irreplaceable Damage (ID)
or Can be Avoided
(CbA)
Mitigation Measures SaM
dirty water storage areas. The water is then reused in the system and could have impacts on the integrity of the storm water system and also the production.
Contaminated Water.
Clear signs informing staff of waste management practices must be implemented on site.
Clean spills, if occur witan 24 hours.
Hazardous waste handling should only take place within bunded and/or lined areas.
Maintain a 100% safe disposal record on the disposal of hazardous waste.
Hazardous waste and contaminated materials should be removed by a licenced removal company and taken to a suitable and licenced landfill site.
Provide training to all staff on best practices regarding waste management every year.
Documentation of removal and safe disposal must be available on site.
Weekly inspections of Storm Water Management Systems must be undertaken. Any blockages or maintenance requirements must be documented and an action plan developed.
Handling and Storing of Domestic Waste should have no impact on the surface water resources due to the location of the facility. However, incorrect disposal of waste could hamper the integrity of the storm water system.
Spill and Release of Waste Material and Contaminated Water.
-9 CbA
Clean and Dirty water separation systems should be maintained up until closure.
-5
Maintain a 100% compliance with the conditions of the ECA permit for the landfill site.
Waste management training must be implemented on site.
Weekly inspections of Storm Water Management Systems must be undertaken. Any blockages or maintenance requirements must be documented and an action plan developed.
Clear signs informing staff of waste management practices must be implemented on site.
Recycling practices must be investigated and implemented on site.
Building rubble must be disposed of in line with the requirements of the NEM: WA. Maintain daily covering of the
landfill site up until final covering.
Access control must be strictly enforced. Self-succession of vegetation should establish within the first rainy season after construction has been completed.
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Name of Activity
Impact Area
Potential Impacts Mitigation Type
Performance Objectives
Goals Activities Potential Impacts Aspect SbM
Reversible (R),
Irreplaceable Damage (ID)
or Can be Avoided
(CbA)
Mitigation Measures SaM
Air Quality
The area is located within the mining area and neighbouring the Village Opencast Pit. Dust emissions is not considered to be significant but can occur during excavation and construction activities.
Removal of topsoil.
-8 CbA
Dust suppression should be undertaken if required [(i.e. on recommendation by the Environmental Control Officer and/or if indicated in the monitoring reports, that the current dust fall out results are increasing towards unacceptable levels (non-compliances)].
-6
Remain within the designated area demarcated for activities. Remain within the National Environmental Management: Air Quality Act, 2004 Dust Regulation guidelines for rural communities.
Remain within the regulated guidelines and limits.
Noise
The area is located within the mining area and neighbouring the Village Opencast Pit. Noise impacts are not considered to be significant but can occur during excavation and construction activities.
Removal of topsoil.
-8 CbA
Equipment will be well maintained to reduce excessive noise creation.
-6
Remain within the designated area demarcated for activities. Remain within the National Environmental Management: Air Quality Act, 2004 Dust Regulation guidelines for rural communities.
Remain within the regulated guidelines and limits.
Activities will be restricted to the day time.
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1.e Impact Management Outcomes
Please refer to the previous section and Table 56 to Table 58 providing a detailed description of the management objectives and the standards required to be achieved.
1.f Impact Management Actions
Please refer to the previous section and Table 56 to Table 58 providing a detailed description of the management objectives and the standards required to be achieved.
1.f.i Financial Provision
The rehabilitation and liability estimation for the proposed infrastructure related to this application only was determined as a clean closure estimate – no allowance for off-sets or salvage value. The assessment was conducted in accordance with the DMR Guideline and best current practice.
A Sub Total 1 Amount of approximately R 7 828 425, 87 (excluding VAT, P&Gs and Contingencies), will be required. With the inclusion of Vat, Contingencies and Preliminary and Generals, the Sub Total 3 will arise to R 10 020 385,12.
The financial provision required by the holder of the mining right must be provided for by one or more of the following methods in order to achieve the total quantum of rehabilitation and remediation of environmental impacts and damage as well as final closure:
Approved dedicated trust fund; Financial guarantee from a South African registered bank or any other approved financial institution; Cash deposit to be deposited at the office of the Regional Manager; or Any other manner determined by the Minister.
The client is required to annually assess the total quantum of environmental liability for the operation and ensure that financial provision is sufficient to cover the current liability (in the event of premature closure), as well as the end of life liability.
As per Government Legislature, the client is required to ensure full financial cover for the current liability at any point in the life of the operation. Pecuniary provision must be made for the shortfall between the existing trust fund balance and the premature closure or current environmental rehabilitation liability if applicable.
Please refer to Section 3t of Part A for the detail discussion.
1.f.i.1.a Describe the Closure Objectives and the Extent to which they have been aligned to the
Baseline Environment described under the Regulation
The closure objectives of this project, therefore will tie into the overall mine’s closure objectives, which includes:
To operate within the enviro-legal ambits of South Africa. To be aware of the latest environmental legal requirements. Limit the impact of the activities on the Ecological Setting of the area. Operate the water management circuit on site to increase mining efficiency and reduce the need for
maintenance of these facilities. Limit the loss of soils as far as possible and ensure that the integrity remains during stockpiling for the
purposes of successful rehabilitation. Protect the soil resources within the area in which the mine operates. Remain within the designated area demarcated for activities. Remain within the National Environmental Management: Air Quality Act, 2004 Dust Regulation guidelines
for rural communities. Protect heritage resources for future generations.
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Protect the groundwater resources to ensure that limited to no impact on groundwater resources occur as a result of the mining operations.
Follow the waste hierarchy approach. Develop the area to its intended final land use.
The closure objectives have been developed to reach the final land use as defined in the mines rehabilitation plan, December 2016. The overall objectives of the closure plan is to achieve the following:
“The proposed final land use would be to return the area to wilderness area. This would include demolishing all infrastructure that will not be handed over to a third party and promoting the growth of the surrounding Sekhukhune Mountain Bushveld species. It is evident that the re-establishment of this vegetation biome on site will not be difficult as areas that have already undergone rehabilitation have seen a large success in terms of the revegetation.”
Please refer to the previous section and Table 56 to Table 58 providing a detailed description of the management objectives and the standards required to be achieved.
1.f.i.1.b Confirm specifically that the Environmental Objectives in relation to Closure have been
consulted with Landowner and Interested and Affected Parties
Please refer to Part A, 3.i for the detailed discussion regarding I&AP Consultation.
The current Stakeholder Database on the mine was utilised as a basis for the development of the consultation register for this project. In addition, relevant government departments, municipalities and affected ward councillors were contacted to inform them of the proposed project and to obtain their issues and comments in this regard. The following stakeholders were consulted as part of the project:
DWS; DMR; LDEDET; Local Municipality; Districts Municipality; Ward Councillor; Surrounding Landowners; and Other Identified Stakeholders.
Please refer to Annexure 5 for the list of stakeholders consulted.
Stakeholder Identification and Notification
Notification of I&APs commenced on 06 July 2017. The notification process was undertaken by means of the following:
Newspaper advertisements; Site Notices; Direct Notifications through a Background Information Document.
All registered stakeholders were informed of the availability of the draft BAR on 11 September 2017 for the opportunity to review this document.
1.f.i.1.c Provide a Rehabilitation Plan that Describes and Shows the Scale and Aerial Extent of the
Main Mining Activities, including the anticipated Mining area at the time of Closure
The NEMA regulations for financial provision aim to ensure that operating mines have a clearer understanding of what their operations will look like at the Life of Mine (LOM) and the risks associated with this. The overall goal is to ensure that there is adequate financial provision for rehabilitation if the mine undergoes sudden closure or once mining activities cease. The closure vision, closure actions, post-closure monitoring and associated costs should be covered by the final rehabilitation plan.
It is the requirement of the Regulations, that all mines have the required plans in place by February 2019:
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A final rehabilitation plan; An annual rehabilitation plan; and An environmental risk assessment report
As part of the operations duty of care, the Financial Rehabilitation Plan has been initiated and the first report compiled during December 2017. This report has been utilised as a baseline to develop the closure plan for this project.
Refer to the following table, which is included to present the rehabilitation plan for the listed activities in question.
The intention of the rehabilitation plan is that the mining area is fully rehabilitated to its intended final land use.
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Table 59: Rehabilitation Plan
Requirement Target Responsible Person Timeframes
General Surface Rehabilitation
A Planning
A1 The closure plan will be reviewed during the life of the mine (closure, operational and decommissioning phases) as part of the NEMA Regulations for financial provision.
Legal closure review compliance.
Environmental Specialist
Annually during operational phase.
A2 Notify the DMR of intended cessation of mining activities and rehabilitation in accordance with the NEMA.
Notification Environmental Department
Five years prior to closure
A3 Apply for the necessary Environmental Authorisation for the decommissioning of activities in terms of the NEMA, NEM: WA and NWA.
Environmental Authorisation.
Environmental Department
At least 2 years prior to intended decommissioning.
A4 Appoint a project manager to oversee the process Appointment of suitably qualified project manager.
Mine Manager Prior to the commencement of closure planning and implementation.
A5 Where still present, asbestos roofs and materials containing asbestos must be identified and removed by a person competent to do so. Asbestos waste must be disposed of at an appropriately licenced facility.
Disposal of waste in terms of Asbestos regulations and the NEM: WA.
Engineering Manager and Environmental Department.
Demolition phase
A6 Identify any protected species that may require permitting prior to disturbing. Biodiversity Permits Environmental Specialist
Prior to commencement of rehabilitation.
A7 A storm water management plan (clean and dirty water separation) for the purposes of rehabilitating towards the final land use should be developed.
Free draining environment
Hydrologist/Engineer Prior to commencement of rehabilitation.
A8 If any archaeological artefacts of potential significance are identified at any stage, work must cease and SAHRA must be notified for instruction on how to proceed.
Protection of artefacts Environmental Specialist
Ongoing
A9
If an agreement is to be reached with the community and or any other organization to take over the occupation of one or more buildings, then a formal agreement to that extent needs to be entered into and signed by all parties concerned. The DMR also needs to be alerted to this fact, and adequate legal arrangements need to be made in this regard.
Optimal use of infrastructure to the benefit of the IDP.
Mine Manager and HR Department
Five years prior to closure
A10 Rehabilitation should preferably be undertaken before the first rains start in order to prevent erosion
Prevent Erosion. Project Manager Start of rehabilitation
B Removal of Surface Infrastructure and Structures
B1 Photographs of the infrastructure, before, during and after rehabilitation will be taken at selected fixed points and kept on record for the Manager (Group Environmental Department) and the DMR purpose
Documentation of rehabilitation process.
Environmental Department
Ongoing
B2 All temporary buildings (pre-fabricated buildings) should be removed and their footprints rehabilitated.
Surface rights area cleared up of all mining related infrastructure and structures.
Project Manager Ongoing
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Requirement Target Responsible Person Timeframes
B3 All fixed assets that can be profitably removed will be removed for salvage or resale (the salvage and resale value have however not been incorporated into the closure cost estimate as per the legislative requirements)
Surface rights area cleared up of all mining related infrastructure and structures.
Project Manager Ongoing
B4
All surface structures, infrastructure and ‘hard surfaces’ (inter alia, redundant surfaced roads, parking and paved areas) are to be demolished and removed from the disturbed mine footprint; unless an alternative/continued use for any such items is agreed upon, in writing, with the Department of Mineral Resources (DMR).
Surface rights area cleared up of all mining related infrastructure and structures.
Project Manager Ongoing
B5 Any item that has no salvage value to the mine but could be of value to individuals will be treated as waste, unless otherwise defined in terms of the NEM:WA
Surface rights area cleared up of all mining related infrastructure and structures.
Project Manager Ongoing
B6 All surface infrastructure would be demolished and removed to a depth of 500mm. Any infrastructure below 500mm will be sealed, made safe and left in situ.
No remaining sub-surface structures that may impede further phases of rehabilitation or vegetation establishment.
Project Manager Ongoing
B7 Dismantle and remove redundant fencing for salvage
Surface rights area cleared up of all mining related infrastructure and structures.
Project Manager Ongoing
B8 Water pollution control structures will remain until the completion of all demolition and associated rehabilitation activities where after these will be rehabilitated.
Free draining environment
Hydrologist/Engineer Prior to commencement of rehabilitation.
B9 The soils beneath any structures used for the bulk storage of hazardous substances (i.e. bulk fuel and oil storage facilities, oil-water separators/sumps), must be made subject to a hydrocarbon contamination screening exercise undertaken by a suitably qualified, independent, professional.
Documented proof of contamination assessments on record. Compliance with any further recommendations from appointed specialist prior to further rehabilitation of contaminated site(s).
Project Manager Ongoing
C Discard Dump and Slope Preparation (where Discard remains)
C1 Existing waste rock dumps will be used to fill the existing voids and excess material will be employed for mining and vent shaft closure.
Free draining environment
Hydrologist/Engineer Ongoing
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Requirement Target Responsible Person Timeframes
C2
All remaining waste disposal facilities, must be capped (could only include vegetation to reduce recharge), rehabilitated and closed in compliance with the relevant provisions of Section 11 of the DWA Minimum Requirements for Waste Disposal by Landfill, or any future amendments thereto/new legislation applicable to such (such as Reg 634-636 of the NEM:WA)
Ultimate compliance with stated general closure objectives for the greater site.
Mine, Contractor Once-off. Within at least 24 months of last deposition/disposal thereto.
C3
Engineering design drawings for capping and closure of the aforementioned facilities, as developed by a competent civil engineer, must be submitted to the DWS, as well as the DMR, for approval prior to commencing with the closure thereof.
Ultimate compliance with stated general closure objectives for the greater site.
Mine, civil engineer Once Off
C4 The side slopes of steep areas are to be graded to a slope of approximately 1:3 (or unless otherwise stated) in order to prevent excessive erosion and to allow vegetation to establish sufficient root growth and in line with Health and safety requirements for closure
Slope stability/safety, effective plant establishment and no signs of erosion.
Mine Once-Off
C5 Side slopes of the rehabilitation area are to be covered by topsoil sourced from the topsoil stockpiles which were created during the clearing of the open pit areas, construction of new activities and tailings areas
Slope stability/safety, effective plant establishment and no signs of erosion.
Mine Once-Off
C6 Along the crest of steep gradients a 1 meter high Hessian screen should be placed around the facility to assist with the trapping of seeds and to protect the crest from wind erosion
Slope stability/safety, effective plant establishment and no signs of erosion.
Mine Once-Off
C7
All mine residue deposits should be effectively fenced off to avoid access thereto by unauthorised parties.
Mine residue deposits made safe and inaccessible to the general public at closure. Mie residue deposits effectively fenced-off with controlled access.
Mine, Contractor Immediately. Once-off
D Surface and Soil Preparation
D1 Existing waste rock dumps will be entirely used to fill the existing voids and excess material will be employed for mining and vent shaft closure
Area to be fee draining Mine Ongoing
D2 Where sites have been alienated of vegetation or where soils have been compacted or covered with concretes, these sites will be ripped and ploughed.
No topsoil replacement on compacted soil horizons.
Project Manager Ongoing
D3 The topsoil and sub-soils with the appropriate seedbed as stripped during the construction and operational phases will be placed over these areas to a depth as specified by a qualified specialist. The topsoil shall be appropriately ameliorated to allow vegetation to grow rapidly if required – it
Replacement of fertile topsoil.
Environmental Scientist
Ongoing
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Requirement Target Responsible Person Timeframes should be noted that the mine will encourage self-succession of vegetation, if this does not take place effectively a re-vegetation project will be implemented
D4 On-going alien and invasive floral species control is required through all phases of rehabilitation. No establishment of weeds or invasive species.
Environmental Scientist
Ongoing inspections.
D5 Pre-mining topography should be reasonably restored through shaping and landscaping, such that the topography of rehabilitated areas will ultimately be commensurate with that of adjacent, non-disturbed areas.
No evidence of significant alteration.
Project Manager Ongoing
D6
A post rehabilitation surface contour plan should be developed by the mine in consultation with a specialist surface water hydrologist, such that would then inform implementation of the point above.
Post-mining contour plan on record. Said plan mitigates potentially significant impacts of surface hydrology.
Mine, Specialist Hydrologist
Once-off, within 12 months of EMP approval.
D7 The areas will be landscaped to be free draining in line with the approved storm water management plan.
Area to be fee draining Project Manager Ongoing
D8 If a reasonable assessment indicates that the re-establishment of vegetation is unacceptable slow, the soil need to be analysed and any deleterious effects must be corrected and the area be seeded with a seed mix to specification
Successful vegetation establishment
Ecologist Ongoing inspections.
D9 Appropriate erosion control measures (i.e. contour banks) must be taken where required No evidence of significant alteration.
Project Manager Ongoing
D10 Care should be taken in choosing a method/machinery to implement the above, such that ripped soils are not re-compacted through efforts to appropriately shape the disturbed sites.
No topsoil replacement on compacted soil horizons.
Project Manager Ongoing
D11 Access to rehabilitated areas should be restricted to vehicles/machinery specifically required for the implementation of the closure plan.
No unauthorised access. Project Manager Ongoing
E Soil and Basal Cover replacement
E1
A topsoil/gravel mixture should be replaced over all rehabilitated area. Where topsoil is insufficient, subsoil must be treated in accordance with the specification of a soil specialist. The layer of topsoil on the side slopes and other areas should be at least 300 mm thick to aid plant growth and assist in re-generation of indigenous plants.
Replacement of fertile topsoil.
Environmental Scientist
Ongoing
E2 Topsoil should be screened, as necessary, to remove any foreign objects, rocks, etc., prior to the replacement thereof.
Replacement of topsoil that is fit for purpose.
Project Manager Ongoing
E3 After application of the topsoil, Hessian socks should be installed in order to prevent erosion of the topsoil, increase soil stability and supply secure substrate for seed germination on any area which
Slope stability/safety, effective plant
Mine Once-Off
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Requirement Target Responsible Person Timeframes has a slope of greater than 1:4. These Hessian socks should be placed at 500mm intervals along the contours which are filled with a hydro seeding mixture
establishment and no signs of erosion.
E4 Any areas with slope ≥ 3° should be inspected weekly for signs of topsoil erosion following the replacement thereof, and appropriate action taken to curb any problematic areas.
No evidence of significant alteration.
Project Manager Ongoing
E5 Self-succession should be encouraged. One rainy season will be allowed for self-succession to take place.
Successful vegetation establishment
Ecologist Ongoing inspections.
E6
If a reasonable assessment indicates that the re-establishment of vegetation is unacceptable slow, the soil need to be analysed and any deleterious effects must be corrected and the area be seeded with a seed mix to specification. Should self-succession of vegetation not take place, the mine will implement a vegetation strategy (hydro seeding) to establish vegetation on these disturbed areas. Appropriate erosion control measures (i.e. contour banks) must be taken where required.
Successful vegetation establishment
Ecologist Ongoing inspections.
E7 A suitably qualified hydro-seeding specialist should be contracted to perform the seeding process. Successful vegetation establishment
Ecologist Start of rehabilitation.
E8 A grass mixture utilising endemic (Sekhukhune Bushveld) grasses should be utilised in the seeding process. Note that hydro-seeding is primarily for grasses and smaller shrubs. Larger shrubs and trees will need to be hand-planned.
Successful vegetation establishment
Ecologist Start of rehabilitation.
E9 The seed mixture should be incorporated into mulch which includes fertiliser and germination acceleration agents
Successful vegetation establishment
Ecologist Start of rehabilitation.
E10 The seed mulch should then be used to fill the Hessian socks Successful vegetation establishment
Ecologist Start of rehabilitation.
E11 The seeded areas should then be irrigated according to the recommendation of the hydro-seeding specialist
Successful vegetation establishment
Ecologist Start of rehabilitation.
E12 Weekly monitoring should take place in order to ascertain the efficacy of the hydro seeding and to repair any areas where gullies or rills are forming
Successful vegetation establishment
Ecologist Weekly
E13 Regular application of fertiliser should take place in order to ensure efficient establishment of vegetation cover until such time as sufficient organic matter is being produced by the established grasses to allow for self-sustaining growth
Successful vegetation establishment
Ecologist When required.
E14
Weekly monitoring should take place in order to ascertain the efficacy of the seeding, and to repair any areas where gullies or rills are forming. Appropriate interventions to be adopted where basal cover establishment fails.
Documented records of weekly inspections. Basal cover establishments commensurate with adjacent undisturbed areas over the surface rights areas (i.e. %cover relative to exposed soil surfaces)
Mine. Contractor Weekly monitoring until adequate basal cover establishment has been confirmed by ecological specialist.
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Requirement Target Responsible Person Timeframes
E15
Regular application of fertiliser, under the guidance of a suitable qualified soil scientist, should take place in order to ensure efficient establishment of vegetation cover until such time as sufficient organic matter is being produced by the established grasses to allow for self-sustaining growth.
Basal cover establishment commensurate with adjacent undisturbed areas over the surface rights areas (i.e. %cover relative to exposed soil surfaces).
Mine. Soil Scientist On-going as per specialist recommendations.
E16
If re-seeding for basal cover establishment was not effective during 1st application, a second application of hydro-seed mixture may have to be applied in certain areas. The application of hydro-seed should be at the discretion of the specialist contractor.
Basal cover establishment commensurate with adjacent undisturbed areas over the surface rights areas (i.e. % cover relative to exposed soil surfaces).
Mine. Contractor As necessary, per specialist recommendations.
E17 No grazing on rehabilitated areas is to occur within three years of reseeding completion. Documentation of rehabilitation process.
Project Manager Three years from re-seeding.
F Establishment of Natural Sekhukhune Mountain Bushveld on the Rehabilitated Areas
F1 Once sufficient basal cover has been established, the introduction of species representative of the Sekhukhune Mountain Bushveld vegetation type may commence.
The primary goal is to achieve a stable, climax state, representative of the Sekhukhune Mountain Bushveld vegetation type where the ecological function of the plant community is tolerant of most environmental conditions it encounters
Ecologist Upon successful establishment of basal cover.
F2
Introduction of these species should commence through the stages of natural succession, i.e. Pioneer species (grasses, herbaceous species), Secondary species (grasses, small shrubs, and small trees) and Climax state (larger shrubs, large trees). This process will also occur naturally as seeds from the neighbouring Sekhukhune Mountain Bushveld areas are introduced and germinate
Mine
F3
Certain tree species can be selectively introduced, however consideration will need to be given to rooting depths and soil stability as well as the ability of the trees to establish on the subject area
Ecologist, Mine Immediately
F4
A test area should be designated to test possible tree species to be introduced for their ability to grow in different substrates. This should commence immediately in order to allow informed decision making once rehabilitation commences
Ecologist, Mine Immediately
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Requirement Target Responsible Person Timeframes
E Disposal of Material
E1 Waste will be classified in terms of the NEM: WA to determine the required waste disposal strategies.
Classification of waste in terms of the NEM:WA
Environmental Specialist
Prior to the commencement of closure planning and implementation.
E2
Rubble will be disposed of at a suitable site which will be rehabilitated once it serves its purpose. As per the 2009 EMP, the objective was made that the rubble shall be dumped in the waste landfill site on the mine with approval by the relevant authorities. This activity should also comply with the relevant NEM:WA requirements
Safe disposal certificates. Environmental Department
Ongoing
E3 All types of waste shall be removed entirely from the area and appropriately dealt with in respect of the general waste handling procedure
Safe disposal certificates. Environmental Department
Ongoing
E4 Inert ceramics such as bricks, concrete, gravel etc. will be used as backfill or disposed of in a permitted waste disposal site according to the approved EMP, 2009
Disposal of waste in terms of the NEM: WA.
Environmental Department
Ongoing
E5 Inert waste, which is more than 1m underground, such as pipes will be left in place Disposal of waste in terms of the NEM: WA.
Environmental Department
Ongoing
E6 Inert ceramic and buried waste with a salvage value to individuals such as scrap metal, building materials, etc. will be removed and disposed of at a proper facility
Disposal of waste in terms of the NEM: WA.
Environmental Department
Ongoing
F Ongoing monitoring and maintenance
F1 All rehabilitated areas will be fenced off up until the area is regarded as stable No unauthorised access. Project Manager Ongoing
F2 All illegal invader plants and weeds shall be dealt with as required in terms of the relevant legislation
No establishment of weeds or invasive species.
Environmental Scientist
Ongoing inspections.
F3
External, independent, ‘Mine Rehabilitation’ compliance audits must be undertaken by a competent auditor for all areas where rehabilitation is being implemented at the mine at least quarterly. Audit to at least document compliance with this plan, as well as any other relevant provisions of the EMP revision approval by the DMR.
Compliance with closure plan
External Auditor Quarterly
F4 The mine should undertake monthly internal compliance audits for all areas where rehabilitation is being implemented at the Mine.
Compliance with closure plan
Environmental Department
Monthly
F5
Monitoring and maintenance of all natural physical, chemical and biological processes for which a closure condition has been specified must be monitored for three (3) years after closure or as long as required by the relevant authorities. Such processes include erosion of the rehabilitated surfaces, surface water drainage, air quality, surface water quality, groundwater quality, vegetative re-growth, weed encroachment and colonisation by animals
Compliance with closure plan with at least 90% sustainable establishment of vegetation.
Environmental Department
Ongoing
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1.f.i.1.d Explain why it can be confirmed that the Rehabilitation Plan is Compatible with the Closure
Objectives
The closure plan is based on the intended final land use and specifically based on the mines final rehabilitation plan dated December 2016. The rehabilitation plan and commitments are based on the approved financial provision objectives of the mine, as well as the approved EMP.
1.f.i.1.e Calculate and State the Quantum of the Financial Provision required to manage and
rehabilitate the environment in accordance with the applicable Guideline
Please refer to PART A, Section 3.t for the detailed presentation of the Financial Provision and Calculation.
The rehabilitation and liability estimation for the proposed infrastructure related to this application only was determined as a clean closure estimate – no allowance for off-sets or salvage value. The assessment was conducted in accordance with the DMR Guideline and best current practice.
A Sub Total 1 Amount of approximately R 7 337 690,26 (excluding VAT, P&Gs and Contingencies), will be required. With the inclusion of Vat, Contingencies and Preliminary and Generals, the Sub Total 3 will arise to R 9 392 243,53.
The financial provision required by the holder of the mining right must be provided for by one or more of the following methods in order to achieve the total quantum of rehabilitation and remediation of environmental impacts and damage as well as final closure:
Approved dedicated trust fund; Financial guarantee from a South African registered bank or any other approved financial institution; Cash deposit to be deposited at the office of the Regional Manager; or Any other manner determined by the Minister.
The client is required to annually assess the total quantum of environmental liability for the operation and ensure that financial provision is sufficient to cover the current liability (in the event of premature closure), as well as the end of life liability.
As per Government Legislature, the client is required to ensure full financial cover for the current liability at any point in the life of the operation. Pecuniary provision must be made for the shortfall between the existing trust fund balance and the premature closure or current environmental rehabilitation liability if applicable.
1.f.i.1.f Confirm the Financial Provision will be provided as Determined
The mine has a trust fund in place to cater for the financial provision of rehabilitation activities. This is assessed annually to ensure that suitable funds are available. The next assessment will be undertaken in March 2018 and annually thereafter.
In addition to this the client has also signed the undertaking to commit to the conditions as presented in this report.
1.f.i.1.g Mechanisms for Monitoring Compliance with the Performance Assessment against the
Environmental Management Programme, including Monitoring of Impact Management
Actions
The following sections present the monitoring requirements of the mine.
Based on the results of the recent numerical groundwater modelling undertaken for the operations (iLEH, 2015), it is recommended that a better understanding of the impact of the backfilled opencast pits is obtained. This can be achieved by drilling specialised boreholes into the deepest section of each pit. Material drilled from the boreholes can be submitted for analysis and water that may have accumulated in the pits can be sampled. Both analyses can be used to characterise the pollution potential of the pits with more confidence. For this reason,
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additional monitoring positions will be included in the current monitoring programme. It is recommended that boreholes are drilled into North and South Pits initially. Based on the results of analysis from these boreholes, additional boreholes into the other three pits situated north of North Pit, can be considered.
As discussed above, the monitoring frequency can be revised from monthly to quarterly, without reducing the effectiveness of the monitoring programme.
It is crucial that rainfall is monitored on a daily basis at the operations and that this information is maintained in the monitoring database. On-site rainfall can be used to interpret the groundwater level monitoring information and will assist in improving the mine water balance.
The proposed revised groundwater monitoring programme is presented in Table 63.
In addition to these monitoring boreholes, two boreholes are recommended in the numerical model to assess potential pollution from the Discard Dump. These are:
Dwarsrivier established a surface water monitoring network in 2000 and consisted out of four (4) monitoring locations, spatially distributed along the Groot Dwars River and Klein Dwars River flow systems. In 2009/2010 the monitoring network were augmented to include the monitoring of water associated with selective mine infrastructures, i.e. return water dams, tailings storage facility and classifier.
The Table below summarises the surface water monitoring network, while Figure 25 presents their spatial distribution with respect to Project infrastructure.
Table 61: Current Monitoring Network Summary
Sample Point ID
Coordinates Description Monitoring Period
Longitude Latitude From To
S1 30ᵒ07'21.88''E 24ᵒ56'43.56''S Groot Dwarsrivier: Upstream of Project site. 2000 ongoing
S2 30ᵒ06'02.57''E 24ᵒ55'44.71''S Klein Dwarsrivier: Upstream of Project site. 2000 ongoing
S3 30ᵒ06'20.44''E 24ᵒ55'24.72''S Groot Dwarsrivier: Downstream of Project site, after confluence with Springkaanspruit.
2000 ongoing
S4 30ᵒ06'19.90''E 24ᵒ54'30.13''S Groot Dwarsrivier: Downstream of Project site. 2000 ongoing
S6 30ᵒ06'41.28''E 24ᵒ55'39.94''S Return Water Dam – Lower 2009 ongoing
S7 30ᵒ06'58.28''E 24ᵒ55'54.71''S Return Water Dam – Upper 2009 ongoing
Based on the specialist findings, it is recommended that the following monitoring points be included into the monitoring schedule:
The surface water sampling programme was conducted during June 2015, during which a total of 10 surface water samples were collected from selected mine-related surface water bodies.
The surface water sample points are summarised in the table overleaf; while the Figure below presents its spatial distribution with respect to the Project infrastructure.
Table 62: Additional Surface Water Points Summary
Sample Point ID Description Coordinates
S11 Water Collection Sump 24°55'9.28"S 30° 7'26.41"E
S12 Plant 24ᵒ55'46.39''S 30ᵒ7'3.47''E
S14 Dewatering Storage Dam 24°56'19.74"S 30° 7'14.67"E
S16 New RWD 24°55'29.00"S 30° 7'11.63"E
S17 North Shaft Settling Dams 24°55'38.32"S 30° 7'17.00"E
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The following table presents the monitoring compliance including the responsible persons, implementation period, and mechanist for monitoring compliance
The current water monitoring program requires water quality analysis. The surface and groundwater-monitoring programme is assessed on an annual basis. Based on these assessments, new monitoring sites may be included in the monitoring programme. Chemical analyses to be conducted include, inter alia: TDS, pH, EC, Alkalinity, SO4, Ca, Mg, K, CI, Na, Fe, and Mn. An annual will be generated detailing water quality trends experienced during the operational phase, and highlighting areas of concern. This annual report will be submitted to DWS. The water quality and quantity trends will be presented to the DMR, National Department of Agriculture and LDEDET as part of the relevant Environmental Auditing processes.
Water quality monitoring results will be stored on a database for use determining water quality trends. The results will be used to update and confirm the groundwater model at the end of the operational phase. Trend analysis will also assist to determine if additional management measures are required.
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Table 63: Proposed Ground Water Monitoring Programme
Point East South Description Elements Frequency
(WGS84, LO31)
(WGS84, LO31)
DRM1 -89 803 -2 758 421 Down gradient of Lower RWD Ca, K, Mg, Na, SO4, Nitrate-NO3, Total Inorganic Nitrogen –N, Cl, F, pH, EC, TDS, Cr, Cu, Cd, Fe, V, Total alkalinity.
Total Petroleum hydrocarbon (TPH)
Quarterly
Annually
DRM2 -89 789 -2 758 349 Down gradient of Lower RWD
DRM3 -89 676 -2 757 996 West of quarry
DRM4 -89 203 -2 758 623 In plant area
DRM5 -89 422 -2 758 739 Down gradient of Upper RWD
DRM6 -88 639 -2 760 019 South of explosives bay
DRO4/DRO -89 936 -2 758 363 In floodplain, close to S3
ASDWBH1 -88 527 -2 758 376 Inside north pit area Ca, K, Mg, Na, SO4, Nitrate-NO3, Total Inorganic Nitrogen –N, Cl, F, pH, EC, TDS, Cr, Cu, Cd, Fe, V, Total Petroleum hydrocarbon
(TPH), Total alkalinity.
Quarterly (TPH annually)
ASDWBH10 -89 274 -2 758 136 North of old TSF
ASDWBH11 -88 525 -2 759 132 Inside office complex
ASDWBH2 -88 545 -2 757 234 Northern part of North Pit area
ASDWBH3 -88 950 -2 758 090 South West of the North Pit
ASDWBH4 -88 487 -2 757 923 East of the North Pit
ASDWBH5 -89 194 -2 759 159 Down gradient of Dam26
ASDWBH6 -89 080 -2 759 200 Up-gradient of Dam26
ASDWBH9 -89 567 -2 758 424 Up-gradient of Lower RWD
MCC -89 156 -2 759 118 Hazardous storage area
Sewage BH/SWBH -88 881 -2 759 030 Down gradient of main sewage works
North Pit -88 848 -2 758 112 Borehole drilled into the deepest section of North Pit. Coordinates must be confirmed once on-site conditions have been evaluated.
Ca, K, Mg, Na, SO4, Nitrate-NO3, Total Inorganic Nitrogen –N, Cl, F, pH, EC, TDS, Cr, Cu, Cd, Fe, V, Total Petroleum hydrocarbon
(TPH), Total alkalinity.
Leach tests on material drilled from borehole
Quarterly (TPH annually)
South Pit -88 801 -2 759 047 Borehole drilled into the deepest section of South Pit. Coordinates must be confirmed once on-site conditions have been evaluated.
Ca, K, Mg, Na, SO4, Nitrate-NO3, Total Inorganic Nitrogen –N, Cl, F, pH, EC, TDS, Cr, Cu, Cd, Fe, V, Total Petroleum hydrocarbon
(TPH), Total alkalinity.
Leach tests on material drilled from boreholes
Quarterly (TPH annually)
Rainfall TBC TBC Rainfall station at offices or new TSF Not applicable Daily
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Figure 25: Surface Water Monitoring Points
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1.f.i.1.g.3 Storm Water and Clean and Dirty Water Infrastructure
The monitoring of surface water management infrastructure must be undertaken as follows:
Silt traps must be inspected monthly during the wet season (September – April). A record must be kept with regards to the remaining capacity and when the next cleaning action is required;
Record each time the a silt trap is emptied/dredged of sediment; The integrity of all dirty water containment structures need to be inspected on an annual basis; A maintenance program will be followed as part of the storm water and clean and dirty water
infrastructure monitoring; and An updated plan of the layout of the storm water channels and silt traps must be kept.
1.f.i.1.g.4 Aquatic Bio-monitoring
Section 1.9.1 of Appendix VI of the WUL states that:
“An aquatic scientist approved by the Regional Director must establish a monitoring programme for the following indices: Invertebrate Habitat Assessment System (IHAS) and the latest South African Scoring System (SASS). Sampling must be done once during the high flow season and once during low flow period annually to reflect the status of the river upstream and downstream of the mining activities. This report aims to address the above mentioned conditions of the Dwars River Chrome Mine WUL. “
Further objectives of the current biomonitoring program are to:
comply with Assmang Chrome Environmental policy and Dwars River Mine EMPR water monitoring requirements;
assess the impacts on the aquatic ecosystem in areas which are affected by the activities associated to the Dwars River Mine;
monitor spatial and temporal trends in aquatic resource integrity in the vicinity of the mine; report any emerging issues and Preserve the aquatic ecosystem.
Two sites are assessed as specified in the WUL, one site up- and one downstream of the current mining operations in the Groot Dwars River. In addition, two sites are selected in the process water system of the Dwars River Mine for toxicological testing. Please refer to Figure 29 for an indication of the positions of the monitoring points.
The table below contains geographic information with regards to the monitoring points. The monitoring program focused on the Groot Dwars River, as it is this system which would be affected by impacting activities from the DRM and not the Klein Dwars River.
Aquatic bio-monitoring is undertaken to determine the impact of Dwarsrivier Mine’s activities on the integrity and diversity of the aquatic ecology within the affected surface water resources.
Table 64: Monitoring points for Biomonitoring at Dwarsrivier Mine
Id Description Coordinates Period Parameter
S1 Upstream of mine 24° 56’ 41.7” S 30° 07’ 20.0” E
Bi-annual (wet and dry season) IHAS*
S2 Downstream of mine 24° 55’ 45.3” S 30° 06’ 03.4” E
Bi-annual (wet and dry season) SASS**
Dam 26
Situated within the ACDRM complex
S24°56'5.61"S E30° 7'3.35"E
Bi-annual (wet and dry season) Toxicity
Lower RWD Situated within the ACDRM complex
S24°55'44.80" E30° 6'42.60"
Bi-annual (wet and dry season) Toxicity
*Instream Habitat Assessment System **South African Scoring System
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Figure 26: Biomonitoring Points
1.f.i.1.g.5 Waste Monitoring
On 2 June 2014 the National Environmental Management: Waste Amendment Act came into force. With various amendments brought by this amendment, the most significant, and still most controversial change is the blanket inclusion of mine residue stockpiles as hazardous waste under the Schedule 3: Defined Wastes Definitions. Section 4 of the act has also been amended to remove the previous exclusion of mine residue deposits and stockpiles from the act’s ambit. Mine residue deposits and stockpiles are accordingly no longer governed by the MPRDA, but are subject to all the provisions of the National Environmental Management: Waste Act, 2008 (NEM:WA).
Schedule 3: Defined Wastes have been broken down into two categories: Category A being hazardous wastes and category B being general wastes. Under Category a (hazardous wastes) the act makes allowance for “Wastes resulting from exploration, mining, quarrying, and physical and chemical treatment of minerals”.
In order to attempt to understand the implications of this on a mining operation, it is important to ensure that the definitions of all the relevant terminologies are defined:
Hazardous waste: means “ any waste that contains organic or inorganic elements or compounds that may, owning to the inherent physical, chemical or toxicological characteristic of that waste, have a detrimental impact on health and the environment and includes hazardous substances, materials or objects within business waste, residue deposits and residue stockpiles.”
Residue deposits: means “any residue stockpile remaining at the termination, cancellation or expiry of a prospecting right, mining right, mining permit, exploration right or production right.”
Residue stockpile: means “any debris, discard, tailings, slimes, screening, slurry, waste rock, foundry sand, mineral processing plant waste, ash or any other product derived from or incidental to a mining operation and which is stockpiled, stored or accumulated within the mining area for potential re-use, or which is disposed of, by the holder of a mining right, mining permit or, production right or an old order right, including historic mines and dumps created before the implementation of this Act.”
Various regulations have been drafted in support of the NEM: WA, some of which are already in effect, and then there are also those still proposed.
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Chapter 9 of the above-mentioned Regulations stipulates the requirements for a motivation for and consideration of listed Waste Management Activities that do not require a Waste Management License. The motivation must:
Demonstrate that the waste management activity can be implemented without unacceptable impacts on, or risk to, the environment or health;
Must provide a description of the waste; Description of waste minimisation or waste management plans; Description of potential impacts, etc.
The transitional provisions under Chapter 6 of this regulations prescribes timeframes in which all wastes must be classified within 18 months from the date of commencement of these regulations (23 August 2013) and every five years thereafter or should the process be changed or altered.
For the above purposes, Dwarsrivier must implement and undertake a Waste Classification System in accordance with the NEM: WA
The following table presents the monitoring compliance including the responsible persons, implementation period, and mechanist for monitoring compliance
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Table 65: Monitoring Compliance during Construction Phase
Name of Activity
Impact Area
Potential Impacts
Mitigation Type
Performance Objectives
Goals
Timeframes Monitoring Requirements
Activities Potential Impacts
Mitigation Measures
Short Term (1-12 months)
Medium Term (1-5 years)
Long Term (5 Years +)
Throughout Life of Mine
Impacts Requiring Monitoring Programmes
Functional Requirements for Monitoring
Roles and Responsibilities
Monitoring and Reporting Frequency
Planning Phase
Legal Requirements (Environmental Permits)
Legal Compliance
Unlawful water and waste (mine residue) activities, which could lead to NWA Directives and Section 24G Rectification fines.
A legal assessment of all activities and future planned activities must be undertaken annually to ensure that all activities are authorised.
To operate within the enviro-legal ambits of South Africa.
Ensure that all activities undertaken by the mine are lawful with the required environmental licences in place.
x
x
Compliance in terms of Regulatory Requirements and the implementation of the EMP.
Appointment of an Independent Environmental Control Officer to assess compliance with the EMP.
Independent ECO
Monthly for the construction phase. Thereafter annual external audits can be undertaken.
The mine must familiarise themselves with the NEM: WA Regulations for the management of Mine Residue Deposits. Those included in previous approved EMPs are considered lawful under the NEM:WA, however where reworking, rehabilitation, stockpiling is taking place, not included into the previous EMP, these activities are unlawful and may require a Waste License.
To be aware of the latest environmental legal requirements.
Ensure that all environmental authorisations on site is implemented on site and ongoing monitoring of compliance are undertaken to reach 100% compliance.
x
x
Compliance in terms of Regulatory Requirements and the implementation of the EMP.
Quarterly (construction); Biannually (after construction) internal audits must be undertaken during the construction phase, where after biannual internal audits can be undertaken, to ensure compliance with the Environmental Authorisation and EMP. This should be undertaken by means of a thorough site
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Name of Activity
Impact Area
Potential Impacts
Mitigation Type
Performance Objectives
Goals
Timeframes Monitoring Requirements
Activities Potential Impacts
Mitigation Measures
Short Term (1-12 months)
Medium Term (1-5 years)
Long Term (5 Years +)
Throughout Life of Mine
Impacts Requiring Monitoring Programmes
Functional Requirements for Monitoring
Roles and Responsibilities
Monitoring and Reporting Frequency
visit, record keeping of findings in a checklist format, issuing of non-conformances to responsible parties, listing thereof on the Isometrics or similar reporting system and feedback to the management team.
All legally appointed personnel responsible or involved in water use activities and activities associated in the Environmental Authorisations on site must receive training on the requirements of the Environmental Authorisations and relevant Environmental Legislation.
All Departments responsible for development of the mine, must understand the requirements of the environmental legislation and must involve this into their planning processes.
x x
Compliance in terms of Regulatory Requirements and the implementation of the EMP.
Monthly environmental meetings must be implemented to discuss the mining plan, implementation thereof, implication on current Environmental Regulations and potential constraints and liabilities. Minutes must be kept of these meetings and action plans with
SHEQ, Engineering and Mining/Geology Department.
Monthly
Quarterly (construction); Biannually (after
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Name of Activity
Impact Area
Potential Impacts
Mitigation Type
Performance Objectives
Goals
Timeframes Monitoring Requirements
Activities Potential Impacts
Mitigation Measures
Short Term (1-12 months)
Medium Term (1-5 years)
Long Term (5 Years +)
Throughout Life of Mine
Impacts Requiring Monitoring Programmes
Functional Requirements for Monitoring
Roles and Responsibilities
Monitoring and Reporting Frequency
construction) integral audits must be undertaken during the construction phase, where after biannual audits can be undertaken, on the lawful implementation of the Environmental Authorisation
responsibilities must be drafted.
Water Use Licence must be available on site at all times.
The legal register must be updated to indicate all activities associated with Environmental Authorisations.
Proactive knowledge of potential system errors and/or constraints will avoid potential non-compliance or process delays.
Operational Environmental Management System that addresses the needs and responsibilities of all departments.
x x
Relocation of Eskom Powerline
Socio-Economic
The relocation of the Eskom 33kV powerlines feeding towards the Two Rivers Mine could temporarily disrupt Economic Activities in the
The mine should obtain approval from Eskom and affected parties regarding the relocation of the powerlines.
Maintain good relationship with surrounding mines.
Approved operating procedure for the relocation of the powerline.
x x
Continuation of economic activities in the area resulting from the powerline.
Initiate discussions with Eskom regarding the procedures for the relocation process.
Engineering Manager.
Immediately
The mine should enter into discussions with Eskom and the
Initiate discussions with the impacted parties.
Engineering Manager.
Immediately
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Name of Activity
Impact Area
Potential Impacts
Mitigation Type
Performance Objectives
Goals
Timeframes Monitoring Requirements
Activities Potential Impacts
Mitigation Measures
Short Term (1-12 months)
Medium Term (1-5 years)
Long Term (5 Years +)
Throughout Life of Mine
Impacts Requiring Monitoring Programmes
Functional Requirements for Monitoring
Roles and Responsibilities
Monitoring and Reporting Frequency
area which the powerline supplies.
affected parties to develop an operating procedure and time line for the removal of the powerlines.
The powerlines may not be removed without the required approvals by Eskom.
No impact on economic activities in the area.
Good relationship with surrounding mines.
Monitor the implementation of the Operating procedure during the relocation of the powerline (powerline relocation will be undertaken under Eskom environmental procedures).
Environmental Department.
During planning phase
Development of Test Pits and additional investigations (geophysics and geotechnical investigations).
Ecology Removal of vegetation.
Restrict clearance to demarcated areas within the area of disturbance.
No additional impact on surface area.
Remain within approved footprints.
x Loss of soils and ecology
The necessary vegetation relocation should be undertaken. Appointment of an Independent Environmental Control Officer to assess compliance with the EMP. The SHEQ department should
Independent ECO and SHEQ Department.
ECO: Monthly during this phase. Thereafter annual external audits can be undertaken. SHEQ: Weekly monitoring
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Name of Activity
Impact Area
Potential Impacts
Mitigation Type
Performance Objectives
Goals
Timeframes Monitoring Requirements
Activities Potential Impacts
Mitigation Measures
Short Term (1-12 months)
Medium Term (1-5 years)
Long Term (5 Years +)
Throughout Life of Mine
Impacts Requiring Monitoring Programmes
Functional Requirements for Monitoring
Roles and Responsibilities
Monitoring and Reporting Frequency
undertake ongoing site monitoring to determine whether activities on site are undertaken in accordance with the EMP Requirements.
Construction Phase
Land and Footprint Clearance Topsoil Stripping and Stockpiling
Geology
No direct impact - Activities will not be constructed over future planned mining areas.
- - - - - - - - - - -
Topography
Direct impact: Alteration of topography. Removal of vegetation and the associated shaping of the area will lead to change in topographical characteristics of the area. The impact is not considered significant due to the fairly flat nature of the topography and the location of
Construction areas must be clearly demarcated to control movement of personnel and vehicles, providing clear boundaries for construction sites in order to limit the spread of impacts. Markers and pegs will be erected and maintained along the boundaries of the working areas, access roads, haul roads and paths before
Remain within demarcated areas. Design facilities to blend into the existing site character as far as practically possible.
No disturbed areas should remain beyond the demarcated areas. 100% compliance to remain with approved footprint areas.
x
Soil Erosion and incorrect
stockpiling of topsoil.
Appointment of an Independent Environmental Control Officer to assess compliance with the EMP. The SHEQ department should undertake ongoing site monitoring to determine whether activities on site are undertaken in accordance
Independent ECO and SHEQ Department.
ECO: Monthly for the construction phase. Thereafter annual external audits can be undertaken. SHEQ: Weekly monitoring
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Name of Activity
Impact Area
Potential Impacts
Mitigation Type
Performance Objectives
Goals
Timeframes Monitoring Requirements
Activities Potential Impacts
Mitigation Measures
Short Term (1-12 months)
Medium Term (1-5 years)
Long Term (5 Years +)
Throughout Life of Mine
Impacts Requiring Monitoring Programmes
Functional Requirements for Monitoring
Roles and Responsibilities
Monitoring and Reporting Frequency
the activities in the immediate vicinity of the existing plant area.
commencing any work. If proved insufficient for control, these shall be replaced by fencing.
with the EMP Requirements.
Designs of the facilities (Stockpile and Discard Dump) must be undertaken by a registered Engineer.
Draw up a procedure clearly reflecting the method and phases of clearance of vegetation only in areas where construction will take place.
Removal of vegetation must be undertaken in a phased approach to limit surface exposure.
Erosion control measures must be implemented early in the construction phase.
Clean and dirty water separation must be
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Name of Activity
Impact Area
Potential Impacts
Mitigation Type
Performance Objectives
Goals
Timeframes Monitoring Requirements
Activities Potential Impacts
Mitigation Measures
Short Term (1-12 months)
Medium Term (1-5 years)
Long Term (5 Years +)
Throughout Life of Mine
Impacts Requiring Monitoring Programmes
Functional Requirements for Monitoring
Roles and Responsibilities
Monitoring and Reporting Frequency
implemented early in the construction phase, especially down-gradient of construction areas to ensure that the natural runoff patterns are impacted as little as possible.
Where possible existing roads must be utilised.
Linear infrastructure must follow for as far as practically possible the natural contours of the area.
Soil, Land Use and Land Capability
Direct impact: The removal and stockpiling of topsoil may lead to a loss of soil resource and land capability through erosion of the stockpiles and chemical and physical degradation. This impact is considered important due to the fact that the mine may
Adhere to Soil Stripping, Soil Stockpiling and Soil Management Plan as part of the original EMP (Soil Utilisation Guideline). Prior to construction of the road the soil will be stripped and placed on a soil stockpile. Remove at least 30cm of soil or until hard rock is reached.
Limit the loss of soils as far as possible and ensure that the integrity remains during stockpiling for the purposes of successful rehabilitation. Protect the soil resources within the area in which
The integrity of the soils stockpiled must remain suitable for the purposes of rehabilitation. No disturbed areas should remain beyond the demarcated areas. 100% compliance to remain with
x x
Soil Erosion and incorrect stockpiling of topsoil.
Appointment of an Independent Environmental Control Officer to assess compliance with the EMP. The SHEQ department should undertake ongoing site monitoring to determine whether activities on site are undertaken
Independent ECO and SHEQ Department.
ECO: Monthly for the construction phase. Thereafter annual external audits can be undertaken. SHEQ: Weekly monitoring. Induction Updates: Every 18 months
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Name of Activity
Impact Area
Potential Impacts
Mitigation Type
Performance Objectives
Goals
Timeframes Monitoring Requirements
Activities Potential Impacts
Mitigation Measures
Short Term (1-12 months)
Medium Term (1-5 years)
Long Term (5 Years +)
Throughout Life of Mine
Impacts Requiring Monitoring Programmes
Functional Requirements for Monitoring
Roles and Responsibilities
Monitoring and Reporting Frequency
be operating on a negative topsoil balance and therefore the retaining of suitable topsoil is important for successful rehabilitation.
Topsoil should be stockpiled on designated topsoil stockpiles, unless around linear infrastructure, where the topsoil could be stockpiled next to the linear structure. The topsoil management plan, 2016 should be implemented on all topsoil’s immediately to ensure that the integrity of the soils are maintained. Any new topsoil stockpiles should not exceed the recommended height in terms of the Topsoil Management Plan, 2016 of 2-4m. Where exceedance is present on existing facilities, erosion control measures should be implemented
the mine operates.
approved footprint areas.
in accordance with the EMP Requirements. Erosion protection measures should be implemented and monitored on areas identified. Photographic records of assessments must be kept. Induction should be reviewed and updated biannually.
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Name of Activity
Impact Area
Potential Impacts
Mitigation Type
Performance Objectives
Goals
Timeframes Monitoring Requirements
Activities Potential Impacts
Mitigation Measures
Short Term (1-12 months)
Medium Term (1-5 years)
Long Term (5 Years +)
Throughout Life of Mine
Impacts Requiring Monitoring Programmes
Functional Requirements for Monitoring
Roles and Responsibilities
Monitoring and Reporting Frequency
and vegetation establishment should be encouraged to assist in maintaining the structure of the soils for rehabilitation.
Direct impact: Soil compaction
The contractor will ensure that all activities, material and equipment storage and personnel movement take place within the designated area.
A site plan must be developed, indicating the following: Location of all approved activities; 1:100 year buffer around all watercourses; Location of the CBA and mark this as a no-go zone; All vegetation management zones as per the Biodiversity Action Plan.
All contractors must receive
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Name of Activity
Impact Area
Potential Impacts
Mitigation Type
Performance Objectives
Goals
Timeframes Monitoring Requirements
Activities Potential Impacts
Mitigation Measures
Short Term (1-12 months)
Medium Term (1-5 years)
Long Term (5 Years +)
Throughout Life of Mine
Impacts Requiring Monitoring Programmes
Functional Requirements for Monitoring
Roles and Responsibilities
Monitoring and Reporting Frequency
induction. The induction should be updated on site, to make provision for the site plan and a detailed explanation on the purpose of the no-go zones, presence of protected species, presence of the CBA and ESAs and the meeting thereof.
The management of topsoil stockpiles should be undertaken in terms of the Topsoil Management Plan, 2016 to ensure that the topsoil stockpiles maintain its integrity and are not subjected to compaction.
A fine system/disciplinary system must be implemented on site for all significant or recurring environmental non-compliances.
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Name of Activity
Impact Area
Potential Impacts
Mitigation Type
Performance Objectives
Goals
Timeframes Monitoring Requirements
Activities Potential Impacts
Mitigation Measures
Short Term (1-12 months)
Medium Term (1-5 years)
Long Term (5 Years +)
Throughout Life of Mine
Impacts Requiring Monitoring Programmes
Functional Requirements for Monitoring
Roles and Responsibilities
Monitoring and Reporting Frequency
Site clearance and activities should be restricted to the approved footprint. Contractor’s areas should be established on already disturbed footprints.
Direct impact: Clearing vegetation will result in the exposure of soil, which may in turn lead to soil erosion. This impact is considered important due to the fact that the mine may be operating on a negative topsoil balance and therefore the retaining of suitable topsoil is important for successful rehabilitation.
Adhere to Storm water Management Plan, developed by SWS, 2016 or any approved update thereafter.
Limit the loss of soils as far as possible and ensure that the integrity remains during stockpiling for the purposes of successful rehabilitation. Protect the soil resources within the area in which the mine operates.
The integrity of the soils stockpiled must remain suitable for the purposes of rehabilitation.
x x
Soil Erosion and incorrect stockpiling of topsoil.
Appointment of an Independent Environmental Control Officer to assess compliance with the EMP. The SHEQ department should undertake ongoing site monitoring to determine whether activities on site are undertaken in accordance with the EMP Requirements. Erosion protection measures should be implemented and monitored on areas
Independent ECO and SHEQ Department.
ECO: Monthly for the construction phase. Thereafter annual external audits can be undertaken. SHEQ: Weekly monitoring
Ensure that all design drawings include effective erosion control measures.
Ensure the required erosion protection measures are monitored and corrected where necessary.
Natural vegetation establishment (self-succession) will be encouraged on cleared areas, topsoil stockpiles
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Name of Activity
Impact Area
Potential Impacts
Mitigation Type
Performance Objectives
Goals
Timeframes Monitoring Requirements
Activities Potential Impacts
Mitigation Measures
Short Term (1-12 months)
Medium Term (1-5 years)
Long Term (5 Years +)
Throughout Life of Mine
Impacts Requiring Monitoring Programmes
Functional Requirements for Monitoring
Roles and Responsibilities
Monitoring and Reporting Frequency
and the Discard Dump slopes.
identified. Photographic records of assessments must be kept.
If natural succession of vegetation is not established within one rainy season after the 1:3 slope of the Discard Dump has been achieved, hydro seeding will be undertaken.
The mine will investigate an appropriate seed mix for the rehabilitation purposes should self-succession not establish on rehabilitated sites.
Areas of construction must be clearly demarcated.
No construction or project related activities may be undertaken outside of the demarcated areas.
Clean and dirty water systems must be established prior to construction.
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Name of Activity
Impact Area
Potential Impacts
Mitigation Type
Performance Objectives
Goals
Timeframes Monitoring Requirements
Activities Potential Impacts
Mitigation Measures
Short Term (1-12 months)
Medium Term (1-5 years)
Long Term (5 Years +)
Throughout Life of Mine
Impacts Requiring Monitoring Programmes
Functional Requirements for Monitoring
Roles and Responsibilities
Monitoring and Reporting Frequency
Where vegetation cannot be established during the life of construction and operations, appropriate measure will be taken to control erosion. These will include grading of surfaces to prevent rapid run-off of storm water and / or the use of energy dissipaters. Retaining soil
integrity for rehabilitation.
Maintaining soil integrity, with successful vegetation establishment.
x x
Soil Erosion and incorrect stockpiling of topsoil.
Appointment of an Independent Environmental Control Officer to assess compliance with the EMP. The SHEQ department should undertake ongoing site monitoring to determine whether activities on site are undertaken in accordance with the EMP Requirements.
Independent ECO and SHEQ Department.
ECO: Monthly for the construction phase. Thereafter annual external audits can be undertaken. SHEQ: Weekly monitoring
The mine will ensure that erosion controls are included in the designs of all linear infrastructure (roads, conveyors, pipelines or open channels) and points of water discharge (where required).
Terrestrial Ecology (Fauna & Flora)
Direct & Cumulative impact: Unplanned loss of floral and
Prior to the removal of plant species, the mine should appoint an ecologist to
Limit the impact of the mining operation on the Ecological
No unlawful removal of flora of conservation importance should take
x x
Limit the impact of the construction on the Ecological
Appointment of an Independent Environmental Control Officer to assess
Independent ECO and SHEQ Department.
ECO: Monthly for the construction phase. Thereafter
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Name of Activity
Impact Area
Potential Impacts
Mitigation Type
Performance Objectives
Goals
Timeframes Monitoring Requirements
Activities Potential Impacts
Mitigation Measures
Short Term (1-12 months)
Medium Term (1-5 years)
Long Term (5 Years +)
Throughout Life of Mine
Impacts Requiring Monitoring Programmes
Functional Requirements for Monitoring
Roles and Responsibilities
Monitoring and Reporting Frequency
faunal species of conservation importance is an important activity to assess and manage due to the fact that the planned activities are located within a CBA. The activity is regarded as a direct and cumulative impact as the loss of species will restrict the purpose and philosophy of the Regional Biodiversity Management Plans. However, saying this it is important to understand that the planned activities are not located within pristine environments, but rather directly adjacent to the approved and
monitor and oversee the removal of all identified protected species, which should be removed under tree removal permits. All such species should be demarcated by signage or tape.
Setting of the area.
place. Initiate rehabilitation of disturbed areas once the construction phase has been completed. Successful self-succession to be achieved. Eradication of invasive species within the mining area footprint.
Setting of the area.
compliance with the EMP. The SHEQ department should undertake ongoing site monitoring to determine whether activities on site are undertaken in accordance with the EMP Requirements.
annual external audits can be undertaken. SHEQ: Weekly monitoring
Natural vegetation establishment (self-succession) will be encouraged on cleared areas, topsoil stockpiles and the Discard Dump slopes.
If natural succession of vegetation is not established within one rainy season, after the 1:3 slope of the Discard Dump has been achieved, hydro seeding will be undertaken.
Obtain tree removal permit prior to the removal of any protected species,
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Name of Activity
Impact Area
Potential Impacts
Mitigation Type
Performance Objectives
Goals
Timeframes Monitoring Requirements
Activities Potential Impacts
Mitigation Measures
Short Term (1-12 months)
Medium Term (1-5 years)
Long Term (5 Years +)
Throughout Life of Mine
Impacts Requiring Monitoring Programmes
Functional Requirements for Monitoring
Roles and Responsibilities
Monitoring and Reporting Frequency
operational plant, stockpiles and Discard Dump.
in the event that the existing permit (valid until 26 June 2018) has lapsed.
A fine system/disciplinary system must be implemented on site for all significant or recurring environmental non-compliances.
Site clearance and activities should be restricted to the approved footprint. Contractor’s areas should be established on already disturbed footprints.
All employees, or contractors on site, involved in this project, should receive a detailed induction on the expectations for the protection of fauna and flora on site.
Weed eradication should be implemented on site.
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Name of Activity
Impact Area
Potential Impacts
Mitigation Type
Performance Objectives
Goals
Timeframes Monitoring Requirements
Activities Potential Impacts
Mitigation Measures
Short Term (1-12 months)
Medium Term (1-5 years)
Long Term (5 Years +)
Throughout Life of Mine
Impacts Requiring Monitoring Programmes
Functional Requirements for Monitoring
Roles and Responsibilities
Monitoring and Reporting Frequency
Direct impact: Displacement of faunal species and human/animal conflict. Due to the fact that the site is located within an existing operation mining footprint, and directly adjacent to the plant and perimeter of the existing water management facilities, the impact is not regarded to be as significant as it would have been for a green field’s site.
A record of any animal fatalities should be kept on site. The reason for the fatality and action to avoid such in the future (if possible) should be stated.
Limit the impact of the mining operation on the Ecological Setting of the area.
Zero animal fatality rates should be achieved. No unlawful removal of flora of conservation importance should take place. Offset area should be in place and efficiently operated for the intended purpose of conservation.
x x
Limit the impact of the construction on the Ecological Setting of the area.
Appointment of an Independent Environmental Control Officer to assess compliance with the EMP. The SHEQ department should undertake ongoing site monitoring to determine whether activities on site are undertaken in accordance with the EMP Requirements.
Independent ECO and SHEQ Department.
ECO: Monthly for the construction phase. Thereafter annual external audits can be undertaken. SHEQ: Weekly monitoring
Construction and site clearance should be undertaken in a systematic approach to allow animals to relocate from the site where construction will take place.
All employees, or contractors on site, involved in this project, should receive a detailed induction on the expectations for the protection of fauna and flora on site.
Clearance of vegetation must be undertaken in such a manner as to provide sufficient time for animals to relocate.
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Name of Activity
Impact Area
Potential Impacts
Mitigation Type
Performance Objectives
Goals
Timeframes Monitoring Requirements
Activities Potential Impacts
Mitigation Measures
Short Term (1-12 months)
Medium Term (1-5 years)
Long Term (5 Years +)
Throughout Life of Mine
Impacts Requiring Monitoring Programmes
Functional Requirements for Monitoring
Roles and Responsibilities
Monitoring and Reporting Frequency
Direct impact: Loss of ecological connectivity and ecosystem functioning. Due to the fact that the site is located within an existing operation mining footprint, and directly adjacent to the plant and perimeter of the existing water management facilities, the impact is not regarded to be as significant as it would have been for a green field’s site.
No construction or project related activities may be undertaken outside of the demarcated areas.
Limit the impact of the mining operation on the Ecological Setting of the area.
Zero animal fatality rates should be achieved.
x x
Limit the impact of the construction on the Ecological Setting of the area.
Appointment of an Independent Environmental Control Officer to assess compliance with the EMP. The SHEQ department should undertake ongoing site monitoring to determine whether activities on site are undertaken in accordance with the EMP Requirements.
Independent ECO and SHEQ Department.
ECO: Monthly for the construction phase. Thereafter annual external audits can be undertaken. SHEQ: Weekly monitoring
The construction area can be isolated by means of a chain link fence in order to prevent animals on local migrations entering the area and being killed. Restriction of
access.
The Project Manager should implement the necessary design concepts to limit the impact on the ecological connectivity and functioning of the ecosystem.
Project Manager
As part of the project design. Prior to construction.
In the establishment of fences, erect fences in such a manner as to limit the potential of animals to enter the plant and silo areas. This could
ENVIROGISTICS (PTY) LTD 10/12/17
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Name of Activity
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Potential Impacts
Mitigation Type
Performance Objectives
Goals
Timeframes Monitoring Requirements
Activities Potential Impacts
Mitigation Measures
Short Term (1-12 months)
Medium Term (1-5 years)
Long Term (5 Years +)
Throughout Life of Mine
Impacts Requiring Monitoring Programmes
Functional Requirements for Monitoring
Roles and Responsibilities
Monitoring and Reporting Frequency
involve the placement of rocks and materials at on the surface of the fences.
Direct impact: The disturbance of the cleared areas may allow the establishment of alien invasive vegetation. Increased prevalence of exotic invasive species: The fact that the area will be cleared for construction creates niches that can be colonised by exotic and/or invasive species. This is compounded by the fact that trucks and other heavy machinery often act as vectors for seeds of these species.
Weed eradication should be implemented on site.
Awareness creation on the importance of that natural ecosystem in which the mine operates. Rehabilitation of disturbed areas with indigenous vegetation. Smallest possible area of disturbance philosophy.
Eradication of invasive species within the mining area footprint. Successful self-succession to be achieved. 100% compliance to remain with approved footprint areas. Initiate rehabilitation of disturbed areas within one year of final activity.
x x Invasion of Weeds and Alien Vegetation.
A weed eradication plan must be implemented on site in line with the current Khumani monitoring programme. This must be undertaken prior to the growing season.
SHEQ Department and a Specialised Ecologist.
Weed monitoring (monthly); Weed eradication (annually or as required); Ecological Study (Biodiversity Action Plan) (annually)
Areas of construction must be clearly demarcated.
No construction or project related activities may be undertaken outside of the demarcated areas.
Direct impact: Increased
Equipment will be well maintained to
Limit the impact of the
Remain within the regulated
x x Elevated Noise Levels.
Ambient noise monitoring
SHEQ Department.
Once a month (during the day
ENVIROGISTICS (PTY) LTD 10/12/17
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Name of Activity
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Potential Impacts
Mitigation Type
Performance Objectives
Goals
Timeframes Monitoring Requirements
Activities Potential Impacts
Mitigation Measures
Short Term (1-12 months)
Medium Term (1-5 years)
Long Term (5 Years +)
Throughout Life of Mine
Impacts Requiring Monitoring Programmes
Functional Requirements for Monitoring
Roles and Responsibilities
Monitoring and Reporting Frequency
vibration and noise will have a significant effect mainly on fauna species in the immediate vicinity of the development, due to the heavy machinery utilised, and the presence of the activities towards the Springkaanspruit and Dwarsrivier. Direct impact: Vibration can also affect a number of subterranean fauna taxa, such as burrowing mammals, reptiles and arthropods. Vibration affects these animals by causing the collapsing of burrows, and causing these animals to leave the area due to
reduce excessive noise creation.
mining operation on the Ecological Setting of the area. Remain within the current ambient character of the site.
guidelines and limits as required by the Mine Health and Safety Act. Zero complaints from surrounding landowners regarding noise levels
should be undertaken in line with the current mines monitoring programme. Biodiversity Action Plans should be continued and assessed/audited.
Ecologist
and during the night). Annual assessments and audits.
Activities should remain within the demarcated sites.
Activities will be restricted to the day time.
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Name of Activity
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Potential Impacts
Mitigation Type
Performance Objectives
Goals
Timeframes Monitoring Requirements
Activities Potential Impacts
Mitigation Measures
Short Term (1-12 months)
Medium Term (1-5 years)
Long Term (5 Years +)
Throughout Life of Mine
Impacts Requiring Monitoring Programmes
Functional Requirements for Monitoring
Roles and Responsibilities
Monitoring and Reporting Frequency
the vibration. Direct impact: Noise will also affect a wide range of taxa including avifauna, mammals, reptiles, amphibians and arthropods.
Direct and Cumulative Impact: Habitat degradation due to dust: Increased dust will occur in all areas where vegetation is cleared. Dust will be caused by excavation, and construction. Dust in the area will be greatly increased due to the dry weather conditions and the nature of the soil in the area. Dust settling on plant material can reduce the
Maintain the current air quality monitoring stations that determine fallout and implement respirable dust (PM10) monitoring that could arise from the mining activities. Implement dust suppression in and around the construction area where required.
Recording of dust fall out to determine trends.
Meeting ambient dust fall out limits in terms of applicable NEM: AQA Regulations.
x x Dust dispersion.
Dust dispersion will be monitored in line with the current dust monitoring programme
SHEQ Department.
Monthly Monitoring with Annual Reporting.
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Mitigation Type
Performance Objectives
Goals
Timeframes Monitoring Requirements
Activities Potential Impacts
Mitigation Measures
Short Term (1-12 months)
Medium Term (1-5 years)
Long Term (5 Years +)
Throughout Life of Mine
Impacts Requiring Monitoring Programmes
Functional Requirements for Monitoring
Roles and Responsibilities
Monitoring and Reporting Frequency
amount of light reaching the chlorophyll in the leaves, thereby reducing photosynthesis, which in turn reduces plant productivity, growth and recruitment.
Direct Impact: Increased erosion can eventually lead to the loss of vegetation and habitats for further species. Soils in the area are prone to erosion in areas where vegetation is cleared, this is further compounded by the fact that precipitation in the area occurs through heavy rainfall events in in the form of thundershowers in summer. Furthermore large areas will
Ensure the required erosion protection measures are monitored and corrected where necessary.
Limit the impact of the mining operation on the Ecological Setting of the area. Maintaining soil
integrity, with successful vegetation establishment.
x x Soil Erosion
Appointment of an Independent Environmental Control Officer to assess compliance with the EMP. The SHEQ department should undertake ongoing site monitoring to determine whether activities on site are undertaken in accordance with the EMP Requirements.
ECO and SHEQ Department
ECO: Monthly for the construction phase. Thereafter annual external audits can be undertaken. SHEQ: Weekly monitoring. Rectification of erosion gulley should be undertaken immediately upon observation.
Storm water management plan should be implemented prior to construction to ensure that runoff does not lead to the formation of erosion gulleys.
Where vegetation cannot be established during the life of construction and operations, appropriate measure will be taken to control erosion. These will
Limited to no presence of erosion gulleys.
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Potential Impacts
Mitigation Type
Performance Objectives
Goals
Timeframes Monitoring Requirements
Activities Potential Impacts
Mitigation Measures
Short Term (1-12 months)
Medium Term (1-5 years)
Long Term (5 Years +)
Throughout Life of Mine
Impacts Requiring Monitoring Programmes
Functional Requirements for Monitoring
Roles and Responsibilities
Monitoring and Reporting Frequency
be cleared before construction leaving these areas prone to erosion.
include grading of surfaces to prevent rapid run-off of storm water and / or the use of energy dissipaters.
An erosion monitoring and mitigation plan should be put in place.
Retaining soil integrity for rehabilitation.
Wetland
No direct impact. The National Freshwater Ecosystem Priority Areas (NFEPA) wetlands present on site, is in fact the mines' dirty water RWDs and not wetlands. No activities will be undertaken within 500m of any wetland system based on the NFEPA sites, if the RWDs are not considered.
- - - - - - - - - - -
Riparian Habitat
The Sprinkaan Spruit is located just 100m to the south of the
Remain at all times outside of the 1:100 year flood line of the
Remain within or approve upon the current
Improve upon the current aquatic health and water
x x
Compliance in terms of the current Water Use License.
Ongoing Biodiversity and water quality assessments.
Aquatic Specialist.
Surface and Biomonitoring in line with the current
ENVIROGISTICS (PTY) LTD 10/12/17
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Name of Activity
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Potential Impacts
Mitigation Type
Performance Objectives
Goals
Timeframes Monitoring Requirements
Activities Potential Impacts
Mitigation Measures
Short Term (1-12 months)
Medium Term (1-5 years)
Long Term (5 Years +)
Throughout Life of Mine
Impacts Requiring Monitoring Programmes
Functional Requirements for Monitoring
Roles and Responsibilities
Monitoring and Reporting Frequency
proposed infrastructure construction (workshops, loadout and sewage facilities). The Dwarsrivier is located to the west of the proposed loadout facility (520m) and Discard Dump (220m).
watercourses. Ongoing Biodiversity Monitoring should be undertaken at the upstream and downstream points. Ongoing surface water monitoring should be undertaken at the upstream and downstream monitoring points. The storm water management plans should be implemented in and around the facilities to ensure that dirty water runoff or water with high sediment loads do not enter the existing watercourses.
Aquatic Health and Water Quality baseline conditions.
quality baseline conditions.
monitoring programme.
Hydrology
Direct impact: The removal of vegetation can lead to increased surface runoff, which may in turn alter
Rehabilitate open areas as soon as practically possible. Self-succession should be encouraged.
Operate the water management circuit on site to increase mining efficiency and reduce the
Implement the SWMP on site.
x x Compliance in terms of the WUL and the SWMP.
Annual compliance in terms of the designs of the facility and compliance in terms of the WUL must be
SHEQ Department and Hydrologist
Surface Water Monitoring in line with the current monitoring programme The storm water
management plans
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Name of Activity
Impact Area
Potential Impacts
Mitigation Type
Performance Objectives
Goals
Timeframes Monitoring Requirements
Activities Potential Impacts
Mitigation Measures
Short Term (1-12 months)
Medium Term (1-5 years)
Long Term (5 Years +)
Throughout Life of Mine
Impacts Requiring Monitoring Programmes
Functional Requirements for Monitoring
Roles and Responsibilities
Monitoring and Reporting Frequency
natural surface water flows and increase siltation of watercourses as well as pollution control facilities.
should be implemented in and around the facilities to ensure that dirty water runoff or water with high sediment loads do not enter the existing watercourses.
need for maintenance of these facilities.
undertaken. The water quality (constituents listed in the WUL) for the mine must be monitored monthly and records must be kept of these result in a centralised system. Analysis of results must be undertaken by an accredited laboratory.
Limit the areas to be cleared to the demarcated sites.
Geohydrology
No direct impact during the construction phase.
- - - - - - - - - - -
Heritage
No direct impact is foreseen in this area. However, due to the nature of heritage sites, graves may be uncovered during the clearance activities.
In the event that heritage artefacts or graves are encountered during the excavation activities, all activities must cease and the SAHRA should be contacted to determine the way
Protect heritage resources for future generations.
Ensure that there is a 100% non-occurrence of impacts to heritage resources.
x
x Presence of archaeological artefacts.
Training of all contractors and responsible parties must be undertaken to ensure that all parties are aware of the need to protect these resources and what to observe for.
Engineering Department.
Daily
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Name of Activity
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Potential Impacts
Mitigation Type
Performance Objectives
Goals
Timeframes Monitoring Requirements
Activities Potential Impacts
Mitigation Measures
Short Term (1-12 months)
Medium Term (1-5 years)
Long Term (5 Years +)
Throughout Life of Mine
Impacts Requiring Monitoring Programmes
Functional Requirements for Monitoring
Roles and Responsibilities
Monitoring and Reporting Frequency
forward before construction may continue.
Daily inspections must be undertaken during the site clearance and excavation phases.
Visual
Direct impact: soil stripping and footprint clearance
Stripping of vegetation and soils should be undertaken within the demarcated areas.
Retain the aesthetics of the area as far as practically possible.
Design and construction infrastructure to blend in with the general topography as far as practically possible. No encroachment outside of demarcated areas.
x
x Demarcated areas.
The Project Manager should implement the necessary design concepts to limit the impact on the soil resources and ecological connectivity and functioning of the ecosystem.
Project Manager
As part of the project design. Prior to construction.
Air Quality Direct impact: Dust-fallout
Utilised the existing monitoring network to monitor dust fall out in and around the construction area.
Recording of dust fall out to determine trends.
Meeting ambient dust fall out limits in terms of applicable NEM: AQA Regulations.
x Dust dispersion.
Dust dispersion will be monitored as part of the overall mine dust monitoring programme.
SHEQ Department.
Dust monitoring to be done in line with the current monitoring programme
Strictly enforced speed limits on all roads
Limit site clearance to designated areas.
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Name of Activity
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Potential Impacts
Mitigation Type
Performance Objectives
Goals
Timeframes Monitoring Requirements
Activities Potential Impacts
Mitigation Measures
Short Term (1-12 months)
Medium Term (1-5 years)
Long Term (5 Years +)
Throughout Life of Mine
Impacts Requiring Monitoring Programmes
Functional Requirements for Monitoring
Roles and Responsibilities
Monitoring and Reporting Frequency
Noise
The area is located within the mining area. Noise impacts are not considered to be significant but can occur during excavation and construction activities.
Equipment will be well maintained to reduce excessive noise creation.
Remain with the required health and safety standards.
Remain within the regulated guidelines and limits as required by the Mine Health and Safety Act.
x x
Adjacent landowners will be informed of the planned dates of the significant land clearance activities where applicable. Daily noise monitoring will be undertaken in the areas where high levels of noise take place.
SHEQ Department.
Ongoing consultation with surrounding landowners. Regular noise monitoring in terms of Mine Health and Safety Standards.
Activities will be restricted to the day time.
Social No direct impact
- - - - - - - - - - -
Establishment of Surface Infrastructure
Geology
No direct impact - Activities will not be constructed over future planned mining areas.
- - - - - - - - - - -
Topography
During the site clearance activity, the required storm water management systems and shaping of land would have been completed. Therefore no
- - - - - - - - - - -
ENVIROGISTICS (PTY) LTD 10/12/17
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Name of Activity
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Potential Impacts
Mitigation Type
Performance Objectives
Goals
Timeframes Monitoring Requirements
Activities Potential Impacts
Mitigation Measures
Short Term (1-12 months)
Medium Term (1-5 years)
Long Term (5 Years +)
Throughout Life of Mine
Impacts Requiring Monitoring Programmes
Functional Requirements for Monitoring
Roles and Responsibilities
Monitoring and Reporting Frequency
further impact on the topography is expected
Soil, Land Use and Land Capability
No further impact on soil compaction is expected as all soils would have been removed during the site clearance activities.
- - - - - - - - - - -
Direct impact: Construction activities with surrounding exposed soil may in turn lead to soil erosion.
Ensure that all design drawings include effective erosion control measures and that these are implemented during the establishment of the infrastructure.
Limit the loss of soils as far as possible and ensure that the integrity remains during stockpiling for the purposes of successful rehabilitation.
The integrity of the soils stockpiled must remain suitable for the purposes of rehabilitation.
x x
Soil Erosion and incorrect stockpiling of topsoil.
Appointment of an Independent Environmental Control Officer to assess compliance with the EMP. The SHEQ department should undertake ongoing site monitoring to determine whether activities on site are undertaken in accordance with the EMP Requirements. Erosion protection
Independent ECO and SHEQ Department.
ECO: Monthly for the construction phase. Thereafter annual external audits can be undertaken. SHEQ: Weekly monitoring Erosion gulleys should be rehabilitated immediately upon observation.
Ensure the required erosion protection measures are monitored and corrected where necessary.
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Name of Activity
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Potential Impacts
Mitigation Type
Performance Objectives
Goals
Timeframes Monitoring Requirements
Activities Potential Impacts
Mitigation Measures
Short Term (1-12 months)
Medium Term (1-5 years)
Long Term (5 Years +)
Throughout Life of Mine
Impacts Requiring Monitoring Programmes
Functional Requirements for Monitoring
Roles and Responsibilities
Monitoring and Reporting Frequency
measures should be implemented and monitored on areas identified. Photographic records of assessments must be kept.
Vegetation established as part of the site clearance activities, will be monitored and assessed to ensure that these remain well established.
Retaining soil integrity for rehabilitation.
x x
Soil Erosion and incorrect stockpiling of topsoil.
Appointment of an Independent Environmental Control Officer to assess compliance with the EMP. The SHEQ department should undertake ongoing site monitoring to determine whether activities on site are undertaken in accordance with the EMP Requirements.
Independent ECO and SHEQ Department.
ECO: Monthly for the construction phase. Thereafter annual external audits can be undertaken. SHEQ: Weekly monitoring
Areas of construction must be clearly demarcated. No construction or project related activities may be
Soil integrity analysis.
Assessment of the fertility of Soils
Soil Scientist. Prior to placement of soils.
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Mitigation Type
Performance Objectives
Goals
Timeframes Monitoring Requirements
Activities Potential Impacts
Mitigation Measures
Short Term (1-12 months)
Medium Term (1-5 years)
Long Term (5 Years +)
Throughout Life of Mine
Impacts Requiring Monitoring Programmes
Functional Requirements for Monitoring
Roles and Responsibilities
Monitoring and Reporting Frequency
undertaken outside of the demarcated areas.
Clean and dirty water systems must be established prior to construction and must be maintained throughout the life of mine.
Where vegetation cannot be established during the life of construction and operations, appropriate measure will be taken to control erosion. These will include grading of surfaces to prevent rapid run-off of storm water and / or the use of energy dissipaters.
Where erosion gulley are formed, these will be recorded on the IsoMetrix system for immediate action.
Vegetation Establishment.
The success of self-succession of vegetation.
SHEQ Department
Monthly
Terrestrial Ecology
All impacts are assessed under
- - - - - - - - - - -
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Name of Activity
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Potential Impacts
Mitigation Type
Performance Objectives
Goals
Timeframes Monitoring Requirements
Activities Potential Impacts
Mitigation Measures
Short Term (1-12 months)
Medium Term (1-5 years)
Long Term (5 Years +)
Throughout Life of Mine
Impacts Requiring Monitoring Programmes
Functional Requirements for Monitoring
Roles and Responsibilities
Monitoring and Reporting Frequency
(Fauna & Flora)
Footprint Clearance.
Wetland No direct impact
- - - - - - - - - - -
Hydrology
All impacts are assessed under Footprint Clearance.
- - - - - - - - - - -
Geohydrology
Direct impact. The use of waste rock in the compaction of the Discard Dump should not lead to an impact on the groundwater resources as the material is not considered a pollutant. According to Ivusi [Ivusi 2009] the outcome of acid-base accounting (ABA) leach tests results undertaken on tailings and waste rock samples at Dwarsrivier in 2006 was that the material is relatively inert.
In order to reduce long-term impacts associated with the Discard Dump extension, it is recommended that the base of the facility is compacted and that the site is rehabilitated to reduce the rate of recharge to near-natural conditions upon closure. The design of the Discard Dump Footprint should be undertaken in terms of signed of engineering drawings. The correct compaction of the footprint should be undertaken to ensure that the liner is fit for
Remain within or approve upon the current groundwater quality.
Improve upon the current groundwater quality.
x x Groundwater Pollution and potential trends.
Construction of the liners will be undertaken under the supervision of a registered engineer. Groundwater monitoring will be undertaken as per the current groundwater monitoring network on site. Application for GN704 Regulation 5 should be obtained prior to construction.
SHEQ Department & Engineering Department
Engineering supervision: During Construction. Groundwater monitoring: As per current monitoring network. Application for GN704: To be undertaken as part of WUL Amendment, 2017
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Mitigation Type
Performance Objectives
Goals
Timeframes Monitoring Requirements
Activities Potential Impacts
Mitigation Measures
Short Term (1-12 months)
Medium Term (1-5 years)
Long Term (5 Years +)
Throughout Life of Mine
Impacts Requiring Monitoring Programmes
Functional Requirements for Monitoring
Roles and Responsibilities
Monitoring and Reporting Frequency
purpose. Exemption in terms of GN704 (Regulation 5) should be obtained from the DWS for the use of the Waste Rock in the construction of the facility. Groundwater monitoring should be undertaken to ensure that the facilities are operated in a manner as not contributed to the current and historic pollution plumes - this should include the implementation of the two new monitoring boreholes as proposed in the numerical model.
Heritage No direct impact
- - - - - - - - - - -
Visual
Direct impact: Establishment of infrastructure.
Activities should be restricted within the approved footprints.
Retain the aesthetics of the area as far as practically possible.
Design and construction infrastructure to blend in with the general topography as
x
x Demarcated areas.
The Project Manager should implement the necessary design concepts to limit the
Project Manager
As part of the project design. Prior to construction.
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Name of Activity
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Potential Impacts
Mitigation Type
Performance Objectives
Goals
Timeframes Monitoring Requirements
Activities Potential Impacts
Mitigation Measures
Short Term (1-12 months)
Medium Term (1-5 years)
Long Term (5 Years +)
Throughout Life of Mine
Impacts Requiring Monitoring Programmes
Functional Requirements for Monitoring
Roles and Responsibilities
Monitoring and Reporting Frequency
far as practically possible. No encroachment outside of demarcated areas.
impact on the soil resources and ecological connectivity and functioning of the ecosystem.
Air Quality
All impacts are assessed under Footprint Clearance.
- - - - - - - - - - -
Noise
All impacts are assessed under Footprint Clearance.
- - - - - - - - - - -
Social No direct impact
- - - - - - - - - - -
Waste Management and Handling Hydrocarbon spills within the Mining Area and the management of Domestic and Hazardous Waste
Geology No direct impact.
- - - - - - - - - - -
Topography No direct impact.
- - - - - - - - - - -
Soils
Contamination of soil resources due to hydrocarbon spills.
Storage of fuels and oils, the refuelling of vehicles and equipment maintenance must be limited to designated, bunded (bunds to be 110% of volume of the materials stored) areas.
Protecting of soil integrity.
Zero presence of contaminated land due to early detection and implementation of actions.
x x Soil Pollution
The SHEQ department should undertake ongoing site monitoring to determine whether activities on site are undertaken in accordance with the EMP Requirements. This should be
SHEQ Department
ECO: Annual external audits can be undertaken. SHEQ: Weekly monitoring
All fuels and soils must be stored in
ENVIROGISTICS (PTY) LTD 10/12/17
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Potential Impacts
Mitigation Type
Performance Objectives
Goals
Timeframes Monitoring Requirements
Activities Potential Impacts
Mitigation Measures
Short Term (1-12 months)
Medium Term (1-5 years)
Long Term (5 Years +)
Throughout Life of Mine
Impacts Requiring Monitoring Programmes
Functional Requirements for Monitoring
Roles and Responsibilities
Monitoring and Reporting Frequency
appropriate containers.
undertaken by means of a thorough site visit, record keeping of findings in a checklist format, issuing of non-conformances to responsible parties, listing thereof on the Isometrics or similar reporting system and feedback to the management team.
Chemicals and hazardous material must be stored in suitable containers, fit for purpose and in line with SDS requirements.
Where drip trays are too small, specially prepared, non-pervious bunds with solution trenches must be used to capture spillages
Oils and potentially hazardous materials must be disposed of at a licensed facility and waste certificates obtained.
A spill kit must be provided to be used in the event of a spill.
Awareness creation on site regarding duty of care and waste management.
Induction with the view on creating environmental awareness.
SHEQ Department
Annually for permanent staff. Start of each visit for contractors.
If a spill occurs, the contaminated soil must be removed immediately. Contaminated soil must be stored
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Performance Objectives
Goals
Timeframes Monitoring Requirements
Activities Potential Impacts
Mitigation Measures
Short Term (1-12 months)
Medium Term (1-5 years)
Long Term (5 Years +)
Throughout Life of Mine
Impacts Requiring Monitoring Programmes
Functional Requirements for Monitoring
Roles and Responsibilities
Monitoring and Reporting Frequency
according to best practices until it can be disposed of at a suitably licensed facility.
Safety signage must be used at designated storage areas.
All workers must undergo an induction which includes environmental awareness training to make them aware of the environmental incident management procedures as well as the importance of complying with management measures.
Ecology
The unmanaged disposal of waste, could result in the spread of invader species, as well as the influx of opportunistic species.
Develop dedicated waste handling areas; prevent access to rodents and opportunistic species; prevent the spread of waste.
Proper waste management practices on site.
No unlawful disposal of waste. Registration of all waste handling and/or storage areas on site.
x x Ongoing Rehabilitation
Ongoing waste classification and management processes to be implemented.
SHEQ Department
SHEQ: Weekly inspections.
Develop dedicated waste handling areas, fit for purpose and
ENVIROGISTICS (PTY) LTD 10/12/17
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Name of Activity
Impact Area
Potential Impacts
Mitigation Type
Performance Objectives
Goals
Timeframes Monitoring Requirements
Activities Potential Impacts
Mitigation Measures
Short Term (1-12 months)
Medium Term (1-5 years)
Long Term (5 Years +)
Throughout Life of Mine
Impacts Requiring Monitoring Programmes
Functional Requirements for Monitoring
Roles and Responsibilities
Monitoring and Reporting Frequency
prevent the spread of waste.
Wetlands No direct impact.
- - - - - - - - - - -
Riparian Habitat
The Sprinkaan Spruit is located just 100m to the south of the proposed infrastructure construction (workshops, loadout and sewage facilities). The Dwarsrivier is located to the west of the proposed loadout facility (520m) and Discard Dump (220m). The presence of littering could enter the watercourses in the area if not managed.
Remain at all times outside of the 1:100 year flood line of the watercourses. Ongoing Biomonitoring Monitoring should be undertaken at the upstream and downstream points. Ongoing surface water monitoring should be undertaken at the upstream and downstream monitoring points. The storm water management plans should be implemented in and around the facilities to ensure that dirty water runoff or water with high sediment loads do not enter the existing watercourses.
Remain within or approve upon the current Aquatic Health and Water Quality baseline conditions.
Improve upon the current aquatic health and water quality baseline conditions.
x x
Compliance in terms of the current Water Use License.
Ongoing Biodiversity and water quality assessments.
Aquatic Specialist.
Surface and Biomonitoring in line with the current monitoring programme.
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Name of Activity
Impact Area
Potential Impacts
Mitigation Type
Performance Objectives
Goals
Timeframes Monitoring Requirements
Activities Potential Impacts
Mitigation Measures
Short Term (1-12 months)
Medium Term (1-5 years)
Long Term (5 Years +)
Throughout Life of Mine
Impacts Requiring Monitoring Programmes
Functional Requirements for Monitoring
Roles and Responsibilities
Monitoring and Reporting Frequency
Develop dedicated waste handling areas, fit for purpose and prevent the spread of waste.
Surface Water
Handling of Hazardous Waste within workshops and general mine area could contaminate the dirty water storage areas. The water is then reused in the system and could have impacts on the integrity of the storm water system and also the production.
Clean and Dirty water separation systems should be incorporated in terms of the 2016 SWMP or any approved update thereafter.
Protect the integrity of the Storm Water Management System.
Implement the SWMP on site.
x
Surface Water Pollution & Soil Assessments.
To ensure a proactive approach, the SHEQ department should undertake ongoing site monitoring to determine whether activities on site are undertaken in accordance with the EMP Requirements. The water quality (constituents listed in the WUL) must be monitored and records must be kept of these result in a centralised system. Analysis of results must be
SHEQ Department
Assessments: Weekly. Monitoring: As per approved WUL
A detailed waste management strategy will be established and implemented, which will clearly demarcate the containments for different waste streams.
Waste management training must be implemented on site.
Maintain a 100% no-spill record.
x
Clear signs informing staff of waste management practices must be implemented on site.
Clean spills, if occur witan 24 hours.
x
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Name of Activity
Impact Area
Potential Impacts
Mitigation Type
Performance Objectives
Goals
Timeframes Monitoring Requirements
Activities Potential Impacts
Mitigation Measures
Short Term (1-12 months)
Medium Term (1-5 years)
Long Term (5 Years +)
Throughout Life of Mine
Impacts Requiring Monitoring Programmes
Functional Requirements for Monitoring
Roles and Responsibilities
Monitoring and Reporting Frequency
Hazardous waste handling should only take place within bunded and/or lined areas.
Maintain a 100% safe disposal record on the disposal of hazardous waste.
x
undertaken by an accredited laboratory.
Hazardous waste should be removed by a licenced removal company and taken to a suitable and licenced landfill site.
Provide training to all staff on best practices regarding waste management every year.
x x
Documentation of removal and safe disposal must be available on site.
The mine will adopt a cradle-to grave approach to ensure that the waste is removed and disposed of in a legally compliant manner.
Weekly inspections of Storm Water Management Systems must be undertaken. Any blockages or maintenance requirements must be documented and an action plan developed.
ENVIROGISTICS (PTY) LTD 10/12/17
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Name of Activity
Impact Area
Potential Impacts
Mitigation Type
Performance Objectives
Goals
Timeframes Monitoring Requirements
Activities Potential Impacts
Mitigation Measures
Short Term (1-12 months)
Medium Term (1-5 years)
Long Term (5 Years +)
Throughout Life of Mine
Impacts Requiring Monitoring Programmes
Functional Requirements for Monitoring
Roles and Responsibilities
Monitoring and Reporting Frequency
Handling and Storing of Domestic Waste should have no impact on the surface water resources due to the location of the facility. However, incorrect disposal of waste could hamper the integrity of the storm water system.
Clean and Dirty water separation systems should be incorporated in terms of the 2016 SWMP or any approved update thereafter.
Maintain a 100% compliance with the conditions of the NEM: WA Permit on site for the Salvage Yards.
x x
Waste management training must be implemented on site.
Weekly inspections of Storm Water Management Systems must be undertaken. Any blockages or maintenance requirements must be documented and an action plan developed.
Clear signs informing staff of waste management practices must be implemented on site.
Access control must be strictly enforced.
The berm around upstream of the
ENVIROGISTICS (PTY) LTD 10/12/17
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Name of Activity
Impact Area
Potential Impacts
Mitigation Type
Performance Objectives
Goals
Timeframes Monitoring Requirements
Activities Potential Impacts
Mitigation Measures
Short Term (1-12 months)
Medium Term (1-5 years)
Long Term (5 Years +)
Throughout Life of Mine
Impacts Requiring Monitoring Programmes
Functional Requirements for Monitoring
Roles and Responsibilities
Monitoring and Reporting Frequency
facility must be maintained.
Recycling practices must be investigated and implemented on site.
Groundwater
Large scale hydrocarbon spills could be present at the mining area
Clean and Dirty water separation systems should be incorporated in terms of the 2016 SWMP.
Protect the groundwater resources to ensure that limited to no impact on groundwater resources occur as a result of the mining operations.
Achieve 100% compliance to the water quality objectives as agreed to between the mine and the DWS based on the discussions within this IWWMP.
x x
Groundwater Pollution and potential trends & Soil Assessments.
To ensure a proactive approach, the SHEQ department should undertake ongoing site monitoring to determine whether activities on site are undertaken in accordance with the EMP Requirements. The groundwater quality (constituents listed in the WUL) must be monitored monthly and records must be kept of these result in a centralised system.
No activities associated with hydrocarbons and/or chemicals may be undertaken outside of an effectively designed and contained area.
All used oils must be removed from site by a licensed company and disposed of at a suitably licensed site.
Any spills occurring during the collection process must be cleaned up immediately.
Implement the SWMP on site.
x
Any significant spills must be
x x
ENVIROGISTICS (PTY) LTD 10/12/17
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Name of Activity
Impact Area
Potential Impacts
Mitigation Type
Performance Objectives
Goals
Timeframes Monitoring Requirements
Activities Potential Impacts
Mitigation Measures
Short Term (1-12 months)
Medium Term (1-5 years)
Long Term (5 Years +)
Throughout Life of Mine
Impacts Requiring Monitoring Programmes
Functional Requirements for Monitoring
Roles and Responsibilities
Monitoring and Reporting Frequency
captured in the incident reports and must be reported to the relevant department (LDEDET, Catchment Management Agency/DWS).
Maintain a 100% no-spill record.
Analysis of results must be undertaken by an accredited laboratory
All equipment and machinery should be kept in good working order.
A clean up procedure (i.e. Works Instruction) must be in place.
Clean spills, if occur witan 24 hours.
x x
Handling or Hazardous Waste within workshops and general mine area.
Clean and Dirty water separation systems should be incorporated in terms of the 2016 SWMP or any approved update thereafter.
Protect the groundwater resources to ensure that limited to no impact on groundwater resources occur as a result of the mining operations.
Achieve 100% compliance to the water quality objectives as agreed to between the mine and the DWS based on the discussions within this IWWMP.
x x
Groundwater Pollution and potential trends & Soil Assessments.
To ensure a proactive approach, the SHEQ department should undertake ongoing site monitoring to determine whether activities on site are undertaken in accordance with the EMP Requirements. The groundwater quality
The workshop should be designed with the suitable waste containment measures (berms, sumps, oil separators).
Waste management training must be
ENVIROGISTICS (PTY) LTD 10/12/17
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Name of Activity
Impact Area
Potential Impacts
Mitigation Type
Performance Objectives
Goals
Timeframes Monitoring Requirements
Activities Potential Impacts
Mitigation Measures
Short Term (1-12 months)
Medium Term (1-5 years)
Long Term (5 Years +)
Throughout Life of Mine
Impacts Requiring Monitoring Programmes
Functional Requirements for Monitoring
Roles and Responsibilities
Monitoring and Reporting Frequency
implemented on site.
(constituents listed in the WUL) must be monitored monthly and records must be kept of these result in a centralised system. Analysis of results must be undertaken by an accredited laboratory
Clear signs informing staff of waste management practices must be implemented on site.
Maintain a 100% safe disposal record on the disposal of hazardous waste.
x x
Hazardous waste handling should only take place within bunded and/or lined areas, with a capacity of at least 110% of the volume stored.
Hazardous waste should be removed by a licenced removal company and taken to a suitable and licenced landfill site.
Documentation of removal and safe disposal must be available on site.
Handling and Storing of Domestic Waste
Clean and Dirty water separation systems should be incorporated in terms of the 2016 SWMP or any approved update thereafter.
Achieve 100% compliance to the water quality objectives as agreed to between the mine and the
x x
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Dwarsrivier Chrome Mine: Basic Assessment Report and Management Plan for the Expansion of the Met Grade Chrome Stockpile and Discard Dump with Ancillary Infrastructure Mining Right Ref: 30/5/1/3/2/1(179) EM Project Ref: 21714 Version: FINAL
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Name of Activity
Impact Area
Potential Impacts
Mitigation Type
Performance Objectives
Goals
Timeframes Monitoring Requirements
Activities Potential Impacts
Mitigation Measures
Short Term (1-12 months)
Medium Term (1-5 years)
Long Term (5 Years +)
Throughout Life of Mine
Impacts Requiring Monitoring Programmes
Functional Requirements for Monitoring
Roles and Responsibilities
Monitoring and Reporting Frequency
Waste management training must be implemented on site.
DWS based on the discussions within this IWWMP.
Clear signs informing staff of waste management practices must be implemented on site.
Maintain a 100% compliance with the conditions of the ECA permit for the landfill site.
x x
All waste must be removed by licensed contractors and disposed of at a licensed landfill site.
As a duty of care and the cradle to grave principles, the mine should regularly inspect disposal site to ensure that best practices are implemented.
Recycling practices must be investigated and implemented on site where practical.
Maintain a 100% accurate recording of waste and submission of such recording to the Department.
x x
ENVIROGISTICS (PTY) LTD 10/12/17
Dwarsrivier Chrome Mine: Basic Assessment Report and Management Plan for the Expansion of the Met Grade Chrome Stockpile and Discard Dump with Ancillary Infrastructure Mining Right Ref: 30/5/1/3/2/1(179) EM Project Ref: 21714 Version: FINAL
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Name of Activity
Impact Area
Potential Impacts
Mitigation Type
Performance Objectives
Goals
Timeframes Monitoring Requirements
Activities Potential Impacts
Mitigation Measures
Short Term (1-12 months)
Medium Term (1-5 years)
Long Term (5 Years +)
Throughout Life of Mine
Impacts Requiring Monitoring Programmes
Functional Requirements for Monitoring
Roles and Responsibilities
Monitoring and Reporting Frequency
Groundwater monitoring must be undertaken in such a manner as to ensure that any potential impacts from the landfill site can be detected.
Maintain daily covering of the landfill site.
x x
Air Quality No direct impact
- - - - - - - - - - -
Heritage No direct impact
- - - - - - - - - - -
Noise No direct impact
- - - - - - - - - - -
Visual No direct impact
- - - - - - - - - - -
Social No direct impact
- - - - - - - - - - -
ENVIROGISTICS (PTY) LTD 10/12/17
Dwarsrivier Chrome Mine: Basic Assessment Report and Management Plan for the Expansion of the Met Grade Chrome Stockpile and Discard Dump with Ancillary Infrastructure Mining Right Ref: 30/5/1/3/2/1(179) EM Project Ref: 21714 Version: FINAL
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Table 66: Monitoring Compliance during Operational Phase
Name of Activity
Impact Area
Potential Impacts
Mitigation Type
Performance Objectives
Goals
Timeframes Monitoring Requirements
Activities Potential Impacts
Mitigation Measures
Short Term (1-12 months)
Medium Term (1-5 years)
Long Term (5 Years +)
Throughout Life of Mine
Impacts Requiring Monitoring Programmes
Functional Requirements for Monitoring
Roles and Responsibilities
Monitoring and Reporting Frequency
Operational Phase
Presence of fences in the area.
Geology No impact - - - - - - - - - - -
Topography No impact - - - - - - - - - - -
Soils
Erosion around the fence infrastructure could lead to a loss of soil resources.
The areas where infrastructure are implemented (i.e. fence poles) should be equipped with erosion control measures (gabions) to reduce the potential for erosion. Use of biodegradable hessian sheeting must be made to prevent sedimentation of downstream resources.
Protection of soil resources.
No presence of erosion.
x x x Erosion control
Inspections should be undertaken to ensure that measures are effective in the reduction or elimination of erosion.
Environmental Department.
As part of the current monitoring and maintenance protocol (but at least monthly).
Ecology No impact - - - - - - - - - - -
Wetlands No impact - - - - - - - - - - -
Riparian Habitat
Impact on the flow of the river could impact the riparian habitat.
Limit vehicle/machinery activity within the active channel as well as in the riparian zone to what is absolutely essential. Disturbances to the riparian zone
Remain within or approve upon the current Aquatic Health and Water Quality baseline conditions.
Improve upon the current aquatic health and water quality baseline conditions.
x x
Compliance in terms of GN704 and the aquatic monitoring requirements.
Construction and maintenance of the fences. Aquatic Habitat Characteristics.
Engineering department & Environmental Department.
Ongoing 6 monthly monitoring of the trends in ecological integrity of the Groot Dwars River is recommended for a period of three years, in
ENVIROGISTICS (PTY) LTD 10/12/17
Dwarsrivier Chrome Mine: Basic Assessment Report and Management Plan for the Expansion of the Met Grade Chrome Stockpile and Discard Dump with Ancillary Infrastructure Mining Right Ref: 30/5/1/3/2/1(179) EM Project Ref: 21714 Version: FINAL
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Name of Activity
Impact Area
Potential Impacts
Mitigation Type
Performance Objectives
Goals
Timeframes Monitoring Requirements
Activities Potential Impacts
Mitigation Measures
Short Term (1-12 months)
Medium Term (1-5 years)
Long Term (5 Years +)
Throughout Life of Mine
Impacts Requiring Monitoring Programmes
Functional Requirements for Monitoring
Roles and Responsibilities
Monitoring and Reporting Frequency
should be limited as far as possible. Re-fuelling of vehicles to take place outside of the riparian zone & associated buffer zones, on sealed surfaces. Activities should not obstruct flow. Where possible, existing access roads should be used for monitoring purposes so as to minimise the compaction of soils and loss of both riparian and instream habitat. Hot spots for build-up of debris must be identified and debris must be regularly removed to prevent flooding and damage of infrastructure. In this regard, special mention is made of periods following high rainfall and
order to monitor the potential impacts of the fence crossings at each point.
ENVIROGISTICS (PTY) LTD 10/12/17
Dwarsrivier Chrome Mine: Basic Assessment Report and Management Plan for the Expansion of the Met Grade Chrome Stockpile and Discard Dump with Ancillary Infrastructure Mining Right Ref: 30/5/1/3/2/1(179) EM Project Ref: 21714 Version: FINAL
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Name of Activity
Impact Area
Potential Impacts
Mitigation Type
Performance Objectives
Goals
Timeframes Monitoring Requirements
Activities Potential Impacts
Mitigation Measures
Short Term (1-12 months)
Medium Term (1-5 years)
Long Term (5 Years +)
Throughout Life of Mine
Impacts Requiring Monitoring Programmes
Functional Requirements for Monitoring
Roles and Responsibilities
Monitoring and Reporting Frequency
subsequent high instream water volumes. During monitoring, always use the shortest routes possible so as to minimise disturbance and loss of habitat both instream as well as in the riparian zone. The riparian zone must be monitored for alien vegetation encroachment and all alien vegetation/weeds must be removed according to a suitable alien vegetation control plan. Any erosion or gully formation must be identified on an ongoing basis and re-profiled and revegetated accordingly.
Surface Water
Impact of fence collaption during floods.
Each fence will thus need to be designed in such a way as to:
Adhere to the recommendations of the
Design and operate the fence in terms of recommendations.
x
Compliance in terms of GN704 and the aquatic
Construction and maintenance of the fences.
Engineering Department, SHEQ Department
At least monthly monitoring for the integrity of
ENVIROGISTICS (PTY) LTD 10/12/17
Dwarsrivier Chrome Mine: Basic Assessment Report and Management Plan for the Expansion of the Met Grade Chrome Stockpile and Discard Dump with Ancillary Infrastructure Mining Right Ref: 30/5/1/3/2/1(179) EM Project Ref: 21714 Version: FINAL
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Name of Activity
Impact Area
Potential Impacts
Mitigation Type
Performance Objectives
Goals
Timeframes Monitoring Requirements
Activities Potential Impacts
Mitigation Measures
Short Term (1-12 months)
Medium Term (1-5 years)
Long Term (5 Years +)
Throughout Life of Mine
Impacts Requiring Monitoring Programmes
Functional Requirements for Monitoring
Roles and Responsibilities
Monitoring and Reporting Frequency
o absorb the impact of a flood; and o restore its function post‐flood, with limited repairs.
Aquatic Specialist.
monitoring requirements.
and Hydrologist (for the GN704 Compliance)
the infrastructure.
Design options to enable a fence to be re‐established and repaired if necessary post‐flood include: o installing collapsible fences; or o installing sacrificial fences.
The fences must be built independently of other fences, to avoid damage to large lengths of fencing
No impact on the aquatic and surface water characteristics of the system due to the presence of fences.
x x
If possible, the fences should be built in a straight section of the waterway or at the crossover point in the middle of a meander, where the main flow is naturally directed to the centre of the channel
The point of crossing must
ENVIROGISTICS (PTY) LTD 10/12/17
Dwarsrivier Chrome Mine: Basic Assessment Report and Management Plan for the Expansion of the Met Grade Chrome Stockpile and Discard Dump with Ancillary Infrastructure Mining Right Ref: 30/5/1/3/2/1(179) EM Project Ref: 21714 Version: FINAL
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Name of Activity
Impact Area
Potential Impacts
Mitigation Type
Performance Objectives
Goals
Timeframes Monitoring Requirements
Activities Potential Impacts
Mitigation Measures
Short Term (1-12 months)
Medium Term (1-5 years)
Long Term (5 Years +)
Throughout Life of Mine
Impacts Requiring Monitoring Programmes
Functional Requirements for Monitoring
Roles and Responsibilities
Monitoring and Reporting Frequency
consider natural high points on the longitudinal profile, thus reducing the fence height.
Groundwater No impact - - - - - - - - - - -
Heritage No impact - - - - - - - - - - -
Air Quality No impact - - - - - - - - - - -
Visual No impact - - - - - - - - - - -
Noise No impact - - - - - - - - - - -
Social No impact - - - - - - - - - - -
Operation of Discard Dump and Met Grade Product Stockpile
Geology
No direct impact. Impacts are addressed during the construction phase.
- - - - - - - - - - -
Topography
The ongoing development of the Discard Dump and Plant Stockpile will result in an ongoing change in the topography.
The slopes of the Met Grade Plant stockpile should be developed and managed in such a manner that the facility remains within the contained footprint and at a stable slope.
Operating within approved EMP conditions and footprints.
Meeting final land use objectives, by operating stable mining infrastructure (Product Stockpiles and Discard Dumps).
x Ongoing rehabilitation.
An operational rehabilitation plan must be implemented and audited by the SHEQ department.
SHEQ Department
Audit: Monthly Updated: Annually
The mine should initiate the site selection process for the long term Discard Dump facility as a matter of urgency.
ENVIROGISTICS (PTY) LTD 10/12/17
Dwarsrivier Chrome Mine: Basic Assessment Report and Management Plan for the Expansion of the Met Grade Chrome Stockpile and Discard Dump with Ancillary Infrastructure Mining Right Ref: 30/5/1/3/2/1(179) EM Project Ref: 21714 Version: FINAL
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Name of Activity
Impact Area
Potential Impacts
Mitigation Type
Performance Objectives
Goals
Timeframes Monitoring Requirements
Activities Potential Impacts
Mitigation Measures
Short Term (1-12 months)
Medium Term (1-5 years)
Long Term (5 Years +)
Throughout Life of Mine
Impacts Requiring Monitoring Programmes
Functional Requirements for Monitoring
Roles and Responsibilities
Monitoring and Reporting Frequency
For the Discard Dump expansion, at closure the side slopes will have been constructed at an angle of no steeper than 1:3. The Discard Dump will be covered with a course (gravel/topsoil) medium or a medium as prescribed by an Ecologist. Should it be determined that vegetation self-succession does not establish, a growth medium will be placed on top of the rock and vegetation re-established.
Ongoing vegetation of slopes should be implemented, this will be specifically required on the side of the current Discard Dump which will be expanded.
Where possible mine residue should be used to backfill voids
ENVIROGISTICS (PTY) LTD 10/12/17
Dwarsrivier Chrome Mine: Basic Assessment Report and Management Plan for the Expansion of the Met Grade Chrome Stockpile and Discard Dump with Ancillary Infrastructure Mining Right Ref: 30/5/1/3/2/1(179) EM Project Ref: 21714 Version: FINAL
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Name of Activity
Impact Area
Potential Impacts
Mitigation Type
Performance Objectives
Goals
Timeframes Monitoring Requirements
Activities Potential Impacts
Mitigation Measures
Short Term (1-12 months)
Medium Term (1-5 years)
Long Term (5 Years +)
Throughout Life of Mine
Impacts Requiring Monitoring Programmes
Functional Requirements for Monitoring
Roles and Responsibilities
Monitoring and Reporting Frequency
according to the approved EMP.
Designs should take cognizance of topographical features of the site.
The Discard Dump should remain within authorised footprint, design and height conditions.
Where possible, and under Environmental Authorisations the mine should implemented the waste hierarchy in an attempt to reduce the disposal of waste rock on site.
Berms will be constructed upstream of the Discard Dump to ensure that clean water is kept separate from dirty water where required.
Soils
The unmanaged disposal of Discard and the overflow
Stockpiling of waste and product should take place within the demarcated areas.
Proper and planned disposal of Discard and Product.
No exceedances in disposal beyond the approved footprints.
x x
Compliance in terms of approved footprint.
The capacity of the facility should be monitored and managed to
Engineering department.
Capacity monitoring: Daily. Surface Water Monitoring: In
ENVIROGISTICS (PTY) LTD 10/12/17
Dwarsrivier Chrome Mine: Basic Assessment Report and Management Plan for the Expansion of the Met Grade Chrome Stockpile and Discard Dump with Ancillary Infrastructure Mining Right Ref: 30/5/1/3/2/1(179) EM Project Ref: 21714 Version: FINAL
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Name of Activity
Impact Area
Potential Impacts
Mitigation Type
Performance Objectives
Goals
Timeframes Monitoring Requirements
Activities Potential Impacts
Mitigation Measures
Short Term (1-12 months)
Medium Term (1-5 years)
Long Term (5 Years +)
Throughout Life of Mine
Impacts Requiring Monitoring Programmes
Functional Requirements for Monitoring
Roles and Responsibilities
Monitoring and Reporting Frequency
of product from the demarcated areas could result in an impact beyond the designated footprints.
ensure that no overflows are present.
line with approved WUL GN704 Compliance: Annually
Ecology
The unmanaged disposal of Discard and the overflow of product from the demarcated areas could result in an impact beyond the designated footprints.
Stockpiling of waste and product should take place within the demarcated areas.
Proper and planned disposal of Discard and Product.
No exceedances in disposal beyond the approved footprints.
x x
Compliance in terms of approved footprint.
The capacity of the facility should be monitored and managed to ensure that no overflows are present.
Engineering department.
Capacity monitoring: Daily. Surface Water Monitoring: In line with approved WUL GN704 Compliance: Annually
Presence of invader species could impact on the natural succession of vegetation on the slopes of Discard Dumps.
A search must be undertaken prior to clearance for indigenous plants that can be carefully removed and stored for rehabilitation.
Awareness creation on the importance of that natural ecosystem in which the mine operates. Rehabilitation of disturbed areas with indigenous vegetation.
Eradication of invasive species within the mining area footprint. Successful self-succession to be achieved. 100% compliance to remain with approved footprint areas. Initiate
x x
Invasion of Weeds and Alien Vegetation.
A weed eradication plan must be implemented on site. This must be undertaken prior to the growing season. An ecological study should be undertaken to determine the status of revegetation on
SHEQ Department and a Specialised Ecologist.
Weed monitoring (monthly); Weed eradication (annually or as required); Ecological Study (annually)
Where self-succession does not establish, harvested seeds and plants must be used in concurrent
ENVIROGISTICS (PTY) LTD 10/12/17
Dwarsrivier Chrome Mine: Basic Assessment Report and Management Plan for the Expansion of the Met Grade Chrome Stockpile and Discard Dump with Ancillary Infrastructure Mining Right Ref: 30/5/1/3/2/1(179) EM Project Ref: 21714 Version: FINAL
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Name of Activity
Impact Area
Potential Impacts
Mitigation Type
Performance Objectives
Goals
Timeframes Monitoring Requirements
Activities Potential Impacts
Mitigation Measures
Short Term (1-12 months)
Medium Term (1-5 years)
Long Term (5 Years +)
Throughout Life of Mine
Impacts Requiring Monitoring Programmes
Functional Requirements for Monitoring
Roles and Responsibilities
Monitoring and Reporting Frequency
rehabilitation for any areas along the area which may be affected.
Smallest possible area of disturbance philosophy.
rehabilitation of disturbed areas within one year of final activity.
the site especially around the rehabilitated areas. Compile list of
protected and Red Data species, compile relocation programme.
The plan for vegetation clearance, must be developed and implemented prior to site clearance.
Seeds of indigenous plants must also be collected during the clearance activities where practical.
All employees, or contractors on site, involved in this project, must undergo an induction prior to construction where they will be made aware of the footprint, prohibited areas and the importance of compliance with management measures, as well as potential
ENVIROGISTICS (PTY) LTD 10/12/17
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Name of Activity
Impact Area
Potential Impacts
Mitigation Type
Performance Objectives
Goals
Timeframes Monitoring Requirements
Activities Potential Impacts
Mitigation Measures
Short Term (1-12 months)
Medium Term (1-5 years)
Long Term (5 Years +)
Throughout Life of Mine
Impacts Requiring Monitoring Programmes
Functional Requirements for Monitoring
Roles and Responsibilities
Monitoring and Reporting Frequency
penalties for noncompliance.
No open fires must be allowed.
Vegetation clearance must be limited to within the footprint area
A weed eradication programme must be implemented on site and enforced. This programme must stipulate the monitoring plan, which should include: capturing of areas where invader species are present; action plan to remove these; % successful removal).
Wetlands No direct impact.
- - - - - - - - - - -
Riparian Habitat
The unmanaged disposal of Discard and the overflow of product from the demarcated areas could result in an impact beyond the
Remain at all times outside of the 1:100 year flood line of the watercourses. Stockpiling of waste and product should take place within the demarcated areas.
Remain within or approve upon the current Aquatic Health and Water Quality baseline conditions.
Improve upon the current aquatic health and water quality baseline conditions.
x x
Compliance in terms of approved footprint.
The capacity of the facility should be monitored and managed to ensure that no overflows are present.
Engineering department.
Capacity monitoring: Daily. Surface Water Monitoring: In line with approved WUL GN704 Compliance: Annually
ENVIROGISTICS (PTY) LTD 10/12/17
Dwarsrivier Chrome Mine: Basic Assessment Report and Management Plan for the Expansion of the Met Grade Chrome Stockpile and Discard Dump with Ancillary Infrastructure Mining Right Ref: 30/5/1/3/2/1(179) EM Project Ref: 21714 Version: FINAL
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Name of Activity
Impact Area
Potential Impacts
Mitigation Type
Performance Objectives
Goals
Timeframes Monitoring Requirements
Activities Potential Impacts
Mitigation Measures
Short Term (1-12 months)
Medium Term (1-5 years)
Long Term (5 Years +)
Throughout Life of Mine
Impacts Requiring Monitoring Programmes
Functional Requirements for Monitoring
Roles and Responsibilities
Monitoring and Reporting Frequency
designated footprints.
Ongoing Biomonitoring Monitoring should be undertaken at the upstream and downstream points. Ongoing surface water monitoring should be undertaken at the upstream and downstream monitoring points. The storm water management plans should be implemented in and around the facilities to ensure that dirty water runoff or water with high sediment loads do not enter the existing watercourses. Develop dedicated waste handling areas, fit for purpose and prevent the spread of waste.
Surface Water Increase in siltation
The product should be stockpiled
Remain within the
Implement the SWMP on site.
x Compliance in terms of
The capacity of the facility
Engineering Department,
Capacity monitoring:
ENVIROGISTICS (PTY) LTD 10/12/17
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Name of Activity
Impact Area
Potential Impacts
Mitigation Type
Performance Objectives
Goals
Timeframes Monitoring Requirements
Activities Potential Impacts
Mitigation Measures
Short Term (1-12 months)
Medium Term (1-5 years)
Long Term (5 Years +)
Throughout Life of Mine
Impacts Requiring Monitoring Programmes
Functional Requirements for Monitoring
Roles and Responsibilities
Monitoring and Reporting Frequency
within the internal water circuit reducing existing RWD capacities, which could lead to overflows in the system.
within a contained facility.
footprint of the approved facility.
GN704 and the SWMP; as well as Surface Water Contamination.
should be monitored and managed to ensure that no overflows are present. Annual compliance in terms of the designs of the facility and compliance in terms of GN704 must be undertaken. The water quality (constituents listed in the WUL) of the dam must be monitored monthly and records must be kept of these result in a centralised system.
SHEQ Department and Hydrologist (for the GN704 Compliance)
Daily. Surface Water Monitoring: In line with approved WUL GN704 Compliance: Annually
The slopes of the Met Grade Plant stockpile should be developed and managed in such a manner that the facility remains within the contained footprint and at a stable slope.
The slopes of the active Discard Dump should be formed with the placement of material to reduce the potential for erosion
Operate the product stockpile in 100% compliance to the allowable footprint.
x x Surface water monitoring must continue in accordance with the approved WUL.
Maintenance of all SWM systems must be undertaken regularly on site.
Groundwater
Stockpiling of material onto the surfaced (cemented) product stockpile.
The groundwater monitoring programme must be implemented and undertaken in accordance to the approved WUL.
Remain within the current baseline groundwater conditions.
Improve of the current baseline groundwater conditions.
x x Remain within designed capacity.
The capacity of the facility should be monitored and managed to ensure that no
Engineering Department,
Capacity monitoring: Daily
ENVIROGISTICS (PTY) LTD 10/12/17
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Name of Activity
Impact Area
Potential Impacts
Mitigation Type
Performance Objectives
Goals
Timeframes Monitoring Requirements
Activities Potential Impacts
Mitigation Measures
Short Term (1-12 months)
Medium Term (1-5 years)
Long Term (5 Years +)
Throughout Life of Mine
Impacts Requiring Monitoring Programmes
Functional Requirements for Monitoring
Roles and Responsibilities
Monitoring and Reporting Frequency
The product should be stockpiled within a contained facility, no material to be stored on unsurfaced areas.
overflows are present.
Stockpiling of Discard Material onto compacted surfaces. The extension of the Discard dump is expected to have a limited impact and nitrate contamination is not expected to extend more than 400m from the Discard dump during the operational phase. The historical impact of the Northern Discard Dump will however dominate groundwater contamination in this area and even if
The groundwater monitoring programme must be implemented and undertaken in accordance to the approved WUL.
Remain within the current baseline groundwater conditions.
Improve of the current baseline groundwater conditions.
x x Groundwater Quality
Water Quality constituents in terms of the WUL should be monitored for groundwater. Vegetation establishment on the slopes of the Discard Dump should be monitored.
SHEQ Department
Groundwater Monitoring: In line with approved WUL. Vegetation establishment: Weekly by SHEQ
For the Discard Dump expansion, at closure the side slopes will have been constructed at an angle of no steeper than 1:3. The Discard Dump will be covered with a course (gravel/topsoil) medium or a medium as prescribed by an Ecologist. Should it be determined that vegetation self-succession does not establish, a growth medium will be placed on top of the rock and vegetation re-established.
ENVIROGISTICS (PTY) LTD 10/12/17
Dwarsrivier Chrome Mine: Basic Assessment Report and Management Plan for the Expansion of the Met Grade Chrome Stockpile and Discard Dump with Ancillary Infrastructure Mining Right Ref: 30/5/1/3/2/1(179) EM Project Ref: 21714 Version: FINAL
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Name of Activity
Impact Area
Potential Impacts
Mitigation Type
Performance Objectives
Goals
Timeframes Monitoring Requirements
Activities Potential Impacts
Mitigation Measures
Short Term (1-12 months)
Medium Term (1-5 years)
Long Term (5 Years +)
Throughout Life of Mine
Impacts Requiring Monitoring Programmes
Functional Requirements for Monitoring
Roles and Responsibilities
Monitoring and Reporting Frequency
the Discard dump is not extended, there is already a residual impact in this area, as indicated by the DCM monitoring programme. In the long-term, contamination from the Discard dump will migrate towards the Dwarsrivier and may reach this stream within a 100 years after closure. Only a small section of the Dwarsrivier may be affected (<100m in length).
The groundwater model should be updated annually, at least for five year post the implementation of the WTP, where after the model update schedule can be revisits.
Ongoing vegetation of slopes should be implemented, this will be specifically required on the side of the current Discard Dump which will be expanded.
The product should be stockpiled within a contained facility, no material to be stored on unsurfaced areas.
Heritage No direct impact
- - - - - - - - - - -
Air Quality
Wind erosion from Stockpiles and Discard Dump
Install air quality monitoring stations that determine fallout and
Stable Mine Residue designs.
Zero presence of erosion on site with the successful
x Dust dispersion.
Vegetation establishment on the slopes of the Discard
SHEQ Department.
Vegetation establishment: Weekly by SHEQ
ENVIROGISTICS (PTY) LTD 10/12/17
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Name of Activity
Impact Area
Potential Impacts
Mitigation Type
Performance Objectives
Goals
Timeframes Monitoring Requirements
Activities Potential Impacts
Mitigation Measures
Short Term (1-12 months)
Medium Term (1-5 years)
Long Term (5 Years +)
Throughout Life of Mine
Impacts Requiring Monitoring Programmes
Functional Requirements for Monitoring
Roles and Responsibilities
Monitoring and Reporting Frequency
may produce fugitive dust.
respirable dust (PM10) concentrations that could arise from the mining activities.
initiation of self-succession.
Dump should be monitored.
Construct berms on top of the completed Discard Dump and vegetate side as much as possible
Dust control measures in the form of slope stability and vegetation (self-succession will be encouraged) will be implemented. Should self-succession to take place the mine will commit to a vegetation strategy.
Recording of dust fall out to determine trends.
Meeting ambient dust fall out limits in terms of applicable NEM: AQA Regulations.
Ongoing rehabilitation.
An operational rehabilitation plan must be implemented and audited by the SHEQ department.
SHEQ Department
Monthly
Dust suppression should be undertaken if required [(i.e. on recommendation by the Environmental Control Officer and/or if indicated in the monitoring reports, that the current dust fall
ENVIROGISTICS (PTY) LTD 10/12/17
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Name of Activity
Impact Area
Potential Impacts
Mitigation Type
Performance Objectives
Goals
Timeframes Monitoring Requirements
Activities Potential Impacts
Mitigation Measures
Short Term (1-12 months)
Medium Term (1-5 years)
Long Term (5 Years +)
Throughout Life of Mine
Impacts Requiring Monitoring Programmes
Functional Requirements for Monitoring
Roles and Responsibilities
Monitoring and Reporting Frequency
out results are increasing towards unacceptable levels (non-compliances)].
Visual
Fugitive dust emissions during stockpiling on the dumps and the mere presence of the Mine Residue Stockpiles may have a negative impact on the visual characteristics of the area.
Any signs of erosion must be rehabilitated immediately.
Stable Mine Residue designs.
Zero presence of erosion on site with the successful initiation of self-succession. Achieving final land use objectives.
x
Ongoing rehabilitation.
An operational rehabilitation plan must be implemented and audited by the SHEQ department.
SHEQ Department
Monthly A slope of 1:3 should be maintained.
The height of the Discard Dump must not exceed the appropriate height as presented in the pending engineering design of the facility from ground level. At the current time a height of approximately 30m is foreseen, this may be amended based on the Engineering design.
Dust dispersion.
Dust dispersion will be monitored as part of the overall mine dust monitoring programme.
SHEQ Department.
Monthly Monitoring with Annual Reporting.
Discard Dump will be subjected to natural vegetation re-establishment, where this is not successful the mine will commit to vegetation strategies.
ENVIROGISTICS (PTY) LTD 10/12/17
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Name of Activity
Impact Area
Potential Impacts
Mitigation Type
Performance Objectives
Goals
Timeframes Monitoring Requirements
Activities Potential Impacts
Mitigation Measures
Short Term (1-12 months)
Medium Term (1-5 years)
Long Term (5 Years +)
Throughout Life of Mine
Impacts Requiring Monitoring Programmes
Functional Requirements for Monitoring
Roles and Responsibilities
Monitoring and Reporting Frequency
The slopes of the Discard Dump should be formed with the placement of material to reduce the potential for erosion
Vegetation Establishment.
The success of self-succession of vegetation.
SHEQ Department
Monthly
Noise No direct impact
- - - - - - - - - - -
Social
The demand for chrome has increased globally due to the increase in China Markets. No allowing the expansion of the Met Grade Plant Stockpile will result in a restriction on the volume of this material to be produced. This will result in restricting the mine to market supply available reserves, and could impact on the economics of scale of the mining
The approval of the project will allow the mine to continue at least for another 10 years in terms of the Discard Capacity. The mine should immediately commence with the assessment of alternatives for long terms discard disposal.
Ongoing chrome supply into the market.
Zero cessation of mining activities.
- - - x
Economic Growth and Investment. Operating facilities in and environmentally lawful manner.
Obtain approval for this project in terms of all environmental authorisations.
SHEQ Department
Up until approval and ongoing assessment of compliance thereafter.
ENVIROGISTICS (PTY) LTD 10/12/17
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Name of Activity
Impact Area
Potential Impacts
Mitigation Type
Performance Objectives
Goals
Timeframes Monitoring Requirements
Activities Potential Impacts
Mitigation Measures
Short Term (1-12 months)
Medium Term (1-5 years)
Long Term (5 Years +)
Throughout Life of Mine
Impacts Requiring Monitoring Programmes
Functional Requirements for Monitoring
Roles and Responsibilities
Monitoring and Reporting Frequency
operation. The load out facility is an ancillary infrastructure to this product stockpile and is required to allow for the movement of the product off site. Not allowing this facility will restrict the logistics of supply to the various markets. The Discard Dump is a key component to the mining operation, with all Discard from the Plant deposited on this site. The capacity of the Discard Dump is fast reaching its capacity and for this reason additional capacity is required. The
ENVIROGISTICS (PTY) LTD 10/12/17
Dwarsrivier Chrome Mine: Basic Assessment Report and Management Plan for the Expansion of the Met Grade Chrome Stockpile and Discard Dump with Ancillary Infrastructure Mining Right Ref: 30/5/1/3/2/1(179) EM Project Ref: 21714 Version: FINAL
P a g e 301 | 393
Name of Activity
Impact Area
Potential Impacts
Mitigation Type
Performance Objectives
Goals
Timeframes Monitoring Requirements
Activities Potential Impacts
Mitigation Measures
Short Term (1-12 months)
Medium Term (1-5 years)
Long Term (5 Years +)
Throughout Life of Mine
Impacts Requiring Monitoring Programmes
Functional Requirements for Monitoring
Roles and Responsibilities
Monitoring and Reporting Frequency
Discard Dump extension will only provide approximately four (4) years of life of facility, however, by not allowing this extension the opportunity to assess a new site in terms of detailed specialist studies are lost, as the requirement for capacity is immediate.
Transportation (Load out area, roads)
Geology
No direct impact. Impacts are addressed during the construction phase.
- - - - - - - - - - -
Soil
Contamination of Soil due to hydrocarbon spills
Vehicles and Machinery will be regularly maintained. Maintenance programmes will be established and implemented.
Protecting of soil integrity.
Zero presence of contaminated land due to early detection and implementation of actions.
x x Soil Pollution
Appointment of an Independent Environmental Control Officer to assess compliance with the EMP. The SHEQ department should
SHEQ Department
Annual External Audit. Daily internal inspections. Recording of incidents when occurring.
All refuelling of vehicles and
ENVIROGISTICS (PTY) LTD 10/12/17
Dwarsrivier Chrome Mine: Basic Assessment Report and Management Plan for the Expansion of the Met Grade Chrome Stockpile and Discard Dump with Ancillary Infrastructure Mining Right Ref: 30/5/1/3/2/1(179) EM Project Ref: 21714 Version: FINAL
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Name of Activity
Impact Area
Potential Impacts
Mitigation Type
Performance Objectives
Goals
Timeframes Monitoring Requirements
Activities Potential Impacts
Mitigation Measures
Short Term (1-12 months)
Medium Term (1-5 years)
Long Term (5 Years +)
Throughout Life of Mine
Impacts Requiring Monitoring Programmes
Functional Requirements for Monitoring
Roles and Responsibilities
Monitoring and Reporting Frequency
equipment maintenance must be done within designated bunded areas.
undertake ongoing site monitoring to determine whether activities on site are undertaken in accordance with the EMP Requirements. This should be undertaken by means of a thorough site visit, record keeping of findings in a checklist format, issuing of non-conformances to responsible parties, listing thereof on the Isometrics or similar reporting system and feedback to the management team.
If necessary, the polluted soils will be remediated and affected areas rehabilitated.
Spills from conveyors.
Ongoing maintenance around transfer points should be undertaken.
Any spills of Discard or Product around the conveyor systems should be collected and taken to designated stockpile areas.
Ecology
The establishment of Weeds and Invader Species.
A weed eradication programme will be developed and implemented to eradicate weeds and invader plants and to prevent new
Limit the impact of the mining operation on the Ecological Setting of the area.
Reduce the presence of invader species by 90% on site.
x x
Invasion of Weeds and Alien Vegetation.
A weed eradication plan must be implemented on site. This must be undertaken
SHEQ Department and a Specialised Ecologist.
Weed monitoring (monthly); Weed eradication (annually or as required);
ENVIROGISTICS (PTY) LTD 10/12/17
Dwarsrivier Chrome Mine: Basic Assessment Report and Management Plan for the Expansion of the Met Grade Chrome Stockpile and Discard Dump with Ancillary Infrastructure Mining Right Ref: 30/5/1/3/2/1(179) EM Project Ref: 21714 Version: FINAL
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Name of Activity
Impact Area
Potential Impacts
Mitigation Type
Performance Objectives
Goals
Timeframes Monitoring Requirements
Activities Potential Impacts
Mitigation Measures
Short Term (1-12 months)
Medium Term (1-5 years)
Long Term (5 Years +)
Throughout Life of Mine
Impacts Requiring Monitoring Programmes
Functional Requirements for Monitoring
Roles and Responsibilities
Monitoring and Reporting Frequency
invasions during the ongoing mining operation.
prior to the growing season. An ecological study should be undertaken to determine the status of revegetation on the site especially around the rehabilitated areas.
Ecological Study (annually)
Where self-succession does not establish, harvested seeds and plants must be used in concurrent rehabilitation for any areas along the area which may be affected.
Accidental death of animals on the roads.
Clearly marked signs will be erected along the transportation routes to create awareness of animal crossings.
Awareness creation on the importance of that natural ecosystem in which the mine operates. Implementation of safe operation practices.
Zero animal fatality.
x x Creation of Awareness.
Induction with the view on creating environmental awareness.
SHEQ Department
Annually for permanent staff. Start of each visit for contractors.
A clearly marked and enforced vehicle speed will be implemented on the internal mine and transportation routes.
A detailed induction programme will be in place to ensure that all parties are aware of the rules and regulations on site in terms of the use of roads.
ENVIROGISTICS (PTY) LTD 10/12/17
Dwarsrivier Chrome Mine: Basic Assessment Report and Management Plan for the Expansion of the Met Grade Chrome Stockpile and Discard Dump with Ancillary Infrastructure Mining Right Ref: 30/5/1/3/2/1(179) EM Project Ref: 21714 Version: FINAL
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Name of Activity
Impact Area
Potential Impacts
Mitigation Type
Performance Objectives
Goals
Timeframes Monitoring Requirements
Activities Potential Impacts
Mitigation Measures
Short Term (1-12 months)
Medium Term (1-5 years)
Long Term (5 Years +)
Throughout Life of Mine
Impacts Requiring Monitoring Programmes
Functional Requirements for Monitoring
Roles and Responsibilities
Monitoring and Reporting Frequency
Vehicles may only travel on demarcated roads on site.
Riparian Habitats
No direct impact
- - - - - - - - - - -
Surface & Groundwater Water
Contamination of surface water resources. There are no surface water resources in the area, however, the natural runoff, which must be managed internally on site could become impacted
Clean and Dirty water separation systems should be maintained.
Operate the site to limit the presence of spills.
Implement the SWMP on site.
x Surface and Groundwater Pollution.
The water quality (constituents listed in the WUL) of the surface water resources must be monitored monthly and records must be kept of these result in a centralised system. Analysis of results must be undertaken by an accredited laboratory.
SHEQ Department
Monthly
Manage storm water flow with temporary erosion control measures where possible (cut-off trenches or berms)
Conveyors will be maintained and constructed with the appropriate culverts and drains, levelling and surfacing to ensure adequate drainage.
Vehicles/machinery will be regularly monitored and maintained. Maintenance programmes will be established and implemented.
All used oils must be removed from site by a licensed company and
ENVIROGISTICS (PTY) LTD 10/12/17
Dwarsrivier Chrome Mine: Basic Assessment Report and Management Plan for the Expansion of the Met Grade Chrome Stockpile and Discard Dump with Ancillary Infrastructure Mining Right Ref: 30/5/1/3/2/1(179) EM Project Ref: 21714 Version: FINAL
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Name of Activity
Impact Area
Potential Impacts
Mitigation Type
Performance Objectives
Goals
Timeframes Monitoring Requirements
Activities Potential Impacts
Mitigation Measures
Short Term (1-12 months)
Medium Term (1-5 years)
Long Term (5 Years +)
Throughout Life of Mine
Impacts Requiring Monitoring Programmes
Functional Requirements for Monitoring
Roles and Responsibilities
Monitoring and Reporting Frequency
disposed of at a suitably licensed site
Any spills occurring during the collection process must be cleaned up immediately.
Maintain a 100% no-spill record.
x x
Soil that has been contaminated by spillages, seepages and leachates will be sampled and analysed. If necessary, the soils will be treated, ameliorated or removed for safe disposal.
Any significant spills must be captured in the incident reports and must be reported to the relevant department. In this event a remediation strategy should be developed and enforced.
Clean spills, if occur witan 24 hours.
x x
A clean up procedure (i.e. Works Instruction) must be in place.
ENVIROGISTICS (PTY) LTD 10/12/17
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Name of Activity
Impact Area
Potential Impacts
Mitigation Type
Performance Objectives
Goals
Timeframes Monitoring Requirements
Activities Potential Impacts
Mitigation Measures
Short Term (1-12 months)
Medium Term (1-5 years)
Long Term (5 Years +)
Throughout Life of Mine
Impacts Requiring Monitoring Programmes
Functional Requirements for Monitoring
Roles and Responsibilities
Monitoring and Reporting Frequency
Air Quality
The use of unsurfaced roads may lead to an increase of dust emissions in the area.
Install air quality monitoring stations that determine fallout and respirable dust (PM10) concentrations that could arise from the mining activities.
Reducing dust emissions on site.
Zero complaints from surrounding landowners regarding dust.
x x Dust dispersion.
Dust dispersion will be monitored as part of the overall mine dust monitoring programme.
SHEQ Department.
Monthly Monitoring with Annual Reporting.
Dust suppression should be undertaken if required [(i.e. on recommendation by the Environmental Control Officer and/or if indicated in the monitoring reports, that the current dust fall out results are increasing towards unacceptable levels (non-compliances)].
During operational phase of the mine, haulage roads will be treated with dust suppression techniques such as wet to reduce dust creation.
Recording of dust fall out to determine trends. Meeting ambient dust fall out limits in terms of applicable NEM: AQA Regulations.
x x Complaints Register.
A complaints register should be in place on site.
SHEQ Department.
Ongoing
Tarpaulins will be placed over all vehicles
Complaints should be acknowledged
SHEQ Department
Acknowledgement within 24 hours, with an
ENVIROGISTICS (PTY) LTD 10/12/17
Dwarsrivier Chrome Mine: Basic Assessment Report and Management Plan for the Expansion of the Met Grade Chrome Stockpile and Discard Dump with Ancillary Infrastructure Mining Right Ref: 30/5/1/3/2/1(179) EM Project Ref: 21714 Version: FINAL
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Name of Activity
Impact Area
Potential Impacts
Mitigation Type
Performance Objectives
Goals
Timeframes Monitoring Requirements
Activities Potential Impacts
Mitigation Measures
Short Term (1-12 months)
Medium Term (1-5 years)
Long Term (5 Years +)
Throughout Life of Mine
Impacts Requiring Monitoring Programmes
Functional Requirements for Monitoring
Roles and Responsibilities
Monitoring and Reporting Frequency
transporting product.
with an action plan recommended.
action plan within 7 days.
Heritage No direct impact
- - - - - - - - - - -
Noise
Noise of vehicles traversing the access roads will be almost constant
Machinery and vehicles will be well maintained to prevent excessive nose and to comply with national and provincial regulations.
Protect the ambiance of the area, as well as maintain good relationships with surrounding land users.
Implement a noise monitoring network.
x x Elevated Noise Levels.
Ambient noise monitoring should be undertaken
SHEQ Department
Monthly (during the day and during the night)
All vehicles will have muffles to minimise noise emissions, where necessary.
Where noise becomes a nuisance nose management measures will be investigated and implemented to address these concerns.
Noise monitoring will be undertaken (ambient conditions) to ensure that noise levels comply with Health and Safety Standards.
Visual No direct impact
- - - - - - - - - - -
ENVIROGISTICS (PTY) LTD 10/12/17
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Name of Activity
Impact Area
Potential Impacts
Mitigation Type
Performance Objectives
Goals
Timeframes Monitoring Requirements
Activities Potential Impacts
Mitigation Measures
Short Term (1-12 months)
Medium Term (1-5 years)
Long Term (5 Years +)
Throughout Life of Mine
Impacts Requiring Monitoring Programmes
Functional Requirements for Monitoring
Roles and Responsibilities
Monitoring and Reporting Frequency
Social No direct impact
- - - - - - - - - - -
Operation of Workshop and Sewage Plant
Geology
No direct impact. Impacts are addressed during the construction phase.
- - - - - - - - - - -
Topography
No direct impact. Impacts are addressed during the construction phase.
- - - - - - - - - - -
Soils
Contamination of soils in the event of an emergency overflow.
Clean and Dirty water separation systems should be incorporated and maintained.
Operate the water management circuit on site to increase mining efficiency and reduce the need for maintenance of these facilities.
Implement the SWMP on site.
x x
Soil Pollution Remediation of soils
SHEQ Department
Undertaken when spill has taken place.
All containment facilities should cater for 110% capacity.
Any spills occurring during an emergency or maintenance producer should be cleaned immediately.
Maintain a 100% no-spill record.
x x
Contaminated soils should be stockpiled in contained areas temporarily until
Maintain the integrity of soils on site.
x x
ENVIROGISTICS (PTY) LTD 10/12/17
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Name of Activity
Impact Area
Potential Impacts
Mitigation Type
Performance Objectives
Goals
Timeframes Monitoring Requirements
Activities Potential Impacts
Mitigation Measures
Short Term (1-12 months)
Medium Term (1-5 years)
Long Term (5 Years +)
Throughout Life of Mine
Impacts Requiring Monitoring Programmes
Functional Requirements for Monitoring
Roles and Responsibilities
Monitoring and Reporting Frequency
remediation has taken place, or the soil has been removed by a licensed contractor to a lawful disposal facility.
A clean up procedure (i.e. Works Instruction) must be in place.
Clean spills, if occur within 24 hours.
x x
Ecology
No direct impact. Impacts are addressed during the construction phase.
- - - - - - - - - - -
Wetlands and Riparian Habitats
No direct impact. Impacts are addressed during the construction phase.
- - - - - - - - - - -
Groundwater
The sewage treatment plant will be operated as a closed circuit within the mining area. All treated water will report to the existing RWDs on site, from where water
- - - - - - - - - - -
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Name of Activity
Impact Area
Potential Impacts
Mitigation Type
Performance Objectives
Goals
Timeframes Monitoring Requirements
Activities Potential Impacts
Mitigation Measures
Short Term (1-12 months)
Medium Term (1-5 years)
Long Term (5 Years +)
Throughout Life of Mine
Impacts Requiring Monitoring Programmes
Functional Requirements for Monitoring
Roles and Responsibilities
Monitoring and Reporting Frequency
will be reused in the system. No drying beds are present. For this reason no areas of groundwater contamination are expected.
Surface Water
Contamination of surface water resources.
Clean and Dirty water separation systems should be incorporated and maintained. Operate the
water management circuit on site to increase mining efficiency and reduce the need for maintenance of these facilities.
Implement the SWMP on site.
x x
Surface and Groundwater Pollution.
The water quality (constituents listed in the WUL) of the surface water resources must be monitored monthly and records must be kept of these result in a centralised system. Analysis of results must be undertaken by an accredited laboratory.
SHEQ Department
Water Monitoring in line with approved WUL.
All containment facilities should cater for 110% capacity.
Any spills occurring during an emergency or maintenance producer should be cleaned immediately.
Maintain a 100% no-spill record.
x x
A clean up procedure (i.e. Works Instruction) must be in place.
Clean spills, if occur within 24 hours.
x x
Heritage No direct impact
- - - - - - - - - - -
Noise No direct impact
- - - - - - - - - - -
Visual No direct impact
- - - - - - - - - - -
ENVIROGISTICS (PTY) LTD 10/12/17
Dwarsrivier Chrome Mine: Basic Assessment Report and Management Plan for the Expansion of the Met Grade Chrome Stockpile and Discard Dump with Ancillary Infrastructure Mining Right Ref: 30/5/1/3/2/1(179) EM Project Ref: 21714 Version: FINAL
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Name of Activity
Impact Area
Potential Impacts
Mitigation Type
Performance Objectives
Goals
Timeframes Monitoring Requirements
Activities Potential Impacts
Mitigation Measures
Short Term (1-12 months)
Medium Term (1-5 years)
Long Term (5 Years +)
Throughout Life of Mine
Impacts Requiring Monitoring Programmes
Functional Requirements for Monitoring
Roles and Responsibilities
Monitoring and Reporting Frequency
Social No direct impact
- - - - - - - - - - -
Waste Management and Handling Hydrocarbon spills within the Mining Area and the management of Domestic and Hazardous Waste
Geology No direct impact.
- - - - - - - - - - -
Topography No direct impact.
- - - - - - - - - - -
Soils
Contamination of soil resources due to hydrocarbon spills.
Storage of fuels and oils, the refuelling of vehicles and equipment maintenance must be limited to designated, bunded (bunds to be 110% of volume of the materials stored) areas.
Protecting of soil integrity.
Zero presence of contaminated land due to early detection and implementation of actions.
x x Soil Pollution
The SHEQ department should undertake ongoing site monitoring to determine whether activities on site are undertaken in accordance with the EMP Requirements. This should be undertaken by means of a thorough site visit, record keeping of findings in a checklist format, issuing of non-conformances to responsible parties, listing thereof on the Isometrics or similar reporting system and
SHEQ Department
ECO: Annual external audits can be undertaken. SHEQ: Weekly monitoring
All fuels and soils must be stored in appropriate containers.
Chemicals and hazardous material must be stored in suitable containers, fit for purpose and in line with SDS requirements.
Where drip trays are too small, specially prepared, non-pervious bunds with solution trenches must be used to capture spillages
ENVIROGISTICS (PTY) LTD 10/12/17
Dwarsrivier Chrome Mine: Basic Assessment Report and Management Plan for the Expansion of the Met Grade Chrome Stockpile and Discard Dump with Ancillary Infrastructure Mining Right Ref: 30/5/1/3/2/1(179) EM Project Ref: 21714 Version: FINAL
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Name of Activity
Impact Area
Potential Impacts
Mitigation Type
Performance Objectives
Goals
Timeframes Monitoring Requirements
Activities Potential Impacts
Mitigation Measures
Short Term (1-12 months)
Medium Term (1-5 years)
Long Term (5 Years +)
Throughout Life of Mine
Impacts Requiring Monitoring Programmes
Functional Requirements for Monitoring
Roles and Responsibilities
Monitoring and Reporting Frequency
Oils and potentially hazardous materials must be disposed of at a licensed facility and waste certificates obtained.
feedback to the management team.
A spill kit must be provided to be used in the event of a spill.
Awareness creation on site regarding duty of care and waste management.
Induction with the view on creating environmental awareness.
SHEQ Department
Annually for permanent staff. Start of each visit for contractors.
If a spill occurs, the contaminated soil must be removed immediately. Contaminated soil must be stored according to best practices until it can be disposed of at a suitably licensed facility.
Safety signage must be used at designated storage areas.
All workers must undergo an induction which includes environmental awareness training to make them aware of the environmental incident management procedures as well
ENVIROGISTICS (PTY) LTD 10/12/17
Dwarsrivier Chrome Mine: Basic Assessment Report and Management Plan for the Expansion of the Met Grade Chrome Stockpile and Discard Dump with Ancillary Infrastructure Mining Right Ref: 30/5/1/3/2/1(179) EM Project Ref: 21714 Version: FINAL
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Name of Activity
Impact Area
Potential Impacts
Mitigation Type
Performance Objectives
Goals
Timeframes Monitoring Requirements
Activities Potential Impacts
Mitigation Measures
Short Term (1-12 months)
Medium Term (1-5 years)
Long Term (5 Years +)
Throughout Life of Mine
Impacts Requiring Monitoring Programmes
Functional Requirements for Monitoring
Roles and Responsibilities
Monitoring and Reporting Frequency
as the importance of complying with management measures.
Ecology
The unmanaged disposal of waste, could result in the spread of invader species, as well as the influx of opportunistic species.
Develop dedicated waste handling areas; prevent access to rodents and opportunistic species; prevent the spread of waste.
Proper waste management practices on site.
No unlawful disposal of waste. Registration of all waste handling and/or storage areas on site.
x x Ongoing Rehabilitation
Ongoing waste classification and management processes to be implemented.
SHEQ Department
SHEQ: Weekly inspections.
Develop dedicated waste handling areas, fit for purpose and prevent the spread of waste.
Wetlands No direct impact.
- - - - - - - - - - -
Riparian Habitat
The Sprinkaan Spruit is located just 100m to the south of the proposed infrastructure construction (workshops, loadout and sewage facilities). The Dwarsrivier is located to the west of the proposed loadout facility (520m)
Remain at all times outside of the 1:100 year flood line of the watercourses. Ongoing Biomonitoring Monitoring should be undertaken at the upstream and downstream points. Ongoing surface water monitoring should be undertaken at the
Remain within or approve upon the current Aquatic Health and Water Quality baseline conditions.
Improve upon the current aquatic health and water quality baseline conditions.
x x
Compliance in terms of the current Water Use License.
Ongoing Biodiversity and water quality assessments.
Aquatic Specialist.
Surface and Biomonitoring in line with the current monitoring programme.
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Name of Activity
Impact Area
Potential Impacts
Mitigation Type
Performance Objectives
Goals
Timeframes Monitoring Requirements
Activities Potential Impacts
Mitigation Measures
Short Term (1-12 months)
Medium Term (1-5 years)
Long Term (5 Years +)
Throughout Life of Mine
Impacts Requiring Monitoring Programmes
Functional Requirements for Monitoring
Roles and Responsibilities
Monitoring and Reporting Frequency
and Discard Dump (220m). The presence of littering could enter the watercourses in the area if not managed.
upstream and downstream monitoring points. The storm water management plans should be implemented in and around the facilities to ensure that dirty water runoff or water with high sediment loads do not enter the existing watercourses. Develop dedicated waste handling areas, fit for purpose and prevent the spread of waste.
Surface Water
Handling of Hazardous Waste within workshops and general mine area could contaminate the dirty water storage areas. The water is then reused in the system and could have
Clean and Dirty water separation systems should be incorporated in terms of the 2016 SWMP or any approved update thereafter.
Protect the integrity of the Storm Water Management System.
Implement the SWMP on site.
x Surface Water Pollution & Soil Assessments.
To ensure a proactive approach, the SHEQ department should undertake ongoing site monitoring to determine whether activities on site are undertaken in accordance with the EMP
SHEQ Department
Assessments: Weekly. Monitoring: As per approved WUL
A detailed waste management strategy will be established and implemented, which will clearly demarcate the
ENVIROGISTICS (PTY) LTD 10/12/17
Dwarsrivier Chrome Mine: Basic Assessment Report and Management Plan for the Expansion of the Met Grade Chrome Stockpile and Discard Dump with Ancillary Infrastructure Mining Right Ref: 30/5/1/3/2/1(179) EM Project Ref: 21714 Version: FINAL
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Name of Activity
Impact Area
Potential Impacts
Mitigation Type
Performance Objectives
Goals
Timeframes Monitoring Requirements
Activities Potential Impacts
Mitigation Measures
Short Term (1-12 months)
Medium Term (1-5 years)
Long Term (5 Years +)
Throughout Life of Mine
Impacts Requiring Monitoring Programmes
Functional Requirements for Monitoring
Roles and Responsibilities
Monitoring and Reporting Frequency
impacts on the integrity of the storm water system and also the production.
containments for different waste streams.
Requirements. The water quality (constituents listed in the WUL) must be monitored and records must be kept of these result in a centralised system. Analysis of results must be undertaken by an accredited laboratory.
Waste management training must be implemented on site.
Maintain a 100% no-spill record.
x
Clear signs informing staff of waste management practices must be implemented on site.
Clean spills, if occur witan 24 hours.
x
Hazardous waste handling should only take place within bunded and/or lined areas.
Maintain a 100% safe disposal record on the disposal of hazardous waste.
x
Hazardous waste should be removed by a licenced removal company and taken to a suitable and licenced landfill site.
Provide training to all staff on best practices regarding waste management every year.
x x Documentation of removal and safe disposal must be kept on record and in good order.
The mine will adopt a cradle-to grave (inspection of disposal sites)
ENVIROGISTICS (PTY) LTD 10/12/17
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Name of Activity
Impact Area
Potential Impacts
Mitigation Type
Performance Objectives
Goals
Timeframes Monitoring Requirements
Activities Potential Impacts
Mitigation Measures
Short Term (1-12 months)
Medium Term (1-5 years)
Long Term (5 Years +)
Throughout Life of Mine
Impacts Requiring Monitoring Programmes
Functional Requirements for Monitoring
Roles and Responsibilities
Monitoring and Reporting Frequency
approach to ensure that the waste is removed and disposed of in a legally compliant manner.
Weekly inspections of Storm Water Management Systems must be undertaken. Any blockages or maintenance requirements must be documented and an action plan developed.
Handling and Storing of Domestic Waste should have no impact on the surface water resources due to the location of the facility. However, incorrect disposal of waste could hamper the integrity of the storm water system.
Clean and Dirty water separation systems should be incorporated in terms of the 2016 SWMP or any approved update thereafter.
Maintain a 100% compliance with the conditions of the NEM: WA Permit on site for the Salvage Yards.
x x
Waste management training must be implemented on site.
Weekly inspections of Storm Water Management Systems must be undertaken. Any blockages or maintenance requirements must
ENVIROGISTICS (PTY) LTD 10/12/17
Dwarsrivier Chrome Mine: Basic Assessment Report and Management Plan for the Expansion of the Met Grade Chrome Stockpile and Discard Dump with Ancillary Infrastructure Mining Right Ref: 30/5/1/3/2/1(179) EM Project Ref: 21714 Version: FINAL
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Name of Activity
Impact Area
Potential Impacts
Mitigation Type
Performance Objectives
Goals
Timeframes Monitoring Requirements
Activities Potential Impacts
Mitigation Measures
Short Term (1-12 months)
Medium Term (1-5 years)
Long Term (5 Years +)
Throughout Life of Mine
Impacts Requiring Monitoring Programmes
Functional Requirements for Monitoring
Roles and Responsibilities
Monitoring and Reporting Frequency
be documented and an action plan developed.
Clear signs informing staff of waste management practices must be implemented on site.
Access control must be strictly enforced.
The berm around upstream of the facility must be maintained.
Recycling practices must be investigated and implemented on site.
Groundwater
Large scale hydrocarbon spills could be present at the mining area
Clean and Dirty water separation systems should be incorporated in terms of the 2016 SWMP or any approved update thereafter.
Protect the groundwater resources to ensure that limited to no impact on groundwater resources occur as a result of the mining operations.
Achieve 100% compliance to the water quality objectives as agreed to between the mine and the DWS based on the discussions within this IWWMP.
x x
Groundwater Pollution and potential trends & Soil Assessments.
To ensure a proactive approach, the SHEQ department should undertake ongoing site monitoring to determine whether activities on site are undertaken in accordance with the EMP
No activities associated with hydrocarbons and/or chemicals may be undertaken outside of an effectively
ENVIROGISTICS (PTY) LTD 10/12/17
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Name of Activity
Impact Area
Potential Impacts
Mitigation Type
Performance Objectives
Goals
Timeframes Monitoring Requirements
Activities Potential Impacts
Mitigation Measures
Short Term (1-12 months)
Medium Term (1-5 years)
Long Term (5 Years +)
Throughout Life of Mine
Impacts Requiring Monitoring Programmes
Functional Requirements for Monitoring
Roles and Responsibilities
Monitoring and Reporting Frequency
designed and contained area.
Requirements. The groundwater quality (constituents listed in the WUL) must be monitored monthly and records must be kept of these result in a centralised system. Analysis of results must be undertaken by an accredited laboratory
All used oils must be removed from site by a licensed company and disposed of at a suitably licensed site.
Any spills occurring during the collection process must be cleaned up immediately.
Implement the SWMP on site.
x
Any significant spills must be captured in the incident reports and must be reported to the relevant department (LDEDET, Catchment Management Agency/DWS).
Maintain a 100% no-spill record.
x x
All equipment and machinery should be kept in good working order.
A clean up procedure (i.e. Works Instruction) must be in place.
Clean spills, if occur witan 24 hours.
x x
Handling or Hazardous Waste within
Clean and Dirty water separation systems should be
Protect the groundwater resources to
Achieve 100% compliance to the water quality
x x Groundwater Pollution and potential
To ensure a proactive approach, the
SHEQ Department
Assessments: Weekly. Monitoring:
ENVIROGISTICS (PTY) LTD 10/12/17
Dwarsrivier Chrome Mine: Basic Assessment Report and Management Plan for the Expansion of the Met Grade Chrome Stockpile and Discard Dump with Ancillary Infrastructure Mining Right Ref: 30/5/1/3/2/1(179) EM Project Ref: 21714 Version: FINAL
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Name of Activity
Impact Area
Potential Impacts
Mitigation Type
Performance Objectives
Goals
Timeframes Monitoring Requirements
Activities Potential Impacts
Mitigation Measures
Short Term (1-12 months)
Medium Term (1-5 years)
Long Term (5 Years +)
Throughout Life of Mine
Impacts Requiring Monitoring Programmes
Functional Requirements for Monitoring
Roles and Responsibilities
Monitoring and Reporting Frequency
workshops and general mine area.
incorporated in terms of the 2016 SWMP or any approved update thereafter.
ensure that limited to no impact on groundwater resources occur as a result of the mining operations.
objectives as agreed to between the mine and the DWS based on the discussions within this IWWMP.
trends & Soil Assessments.
SHEQ department should undertake ongoing site monitoring to determine whether activities on site are undertaken in accordance with the EMP Requirements. The groundwater quality (constituents listed in the WUL) must be monitored monthly and records must be kept of these result in a centralised system. Analysis of results must be undertaken by an accredited laboratory
The workshop should be designed with the suitable waste containment measures (berms, sumps, oil separators).
Waste management training must be implemented on site.
Clear signs informing staff of waste management practices must be implemented on site.
Maintain a 100% safe disposal record on the disposal of hazardous waste.
x x
Hazardous waste handling should only take place within bunded and/or lined areas, with a capacity of at least 110% of the volume stored.
Hazardous waste should be removed by a licenced removal company and taken to a
ENVIROGISTICS (PTY) LTD 10/12/17
Dwarsrivier Chrome Mine: Basic Assessment Report and Management Plan for the Expansion of the Met Grade Chrome Stockpile and Discard Dump with Ancillary Infrastructure Mining Right Ref: 30/5/1/3/2/1(179) EM Project Ref: 21714 Version: FINAL
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Name of Activity
Impact Area
Potential Impacts
Mitigation Type
Performance Objectives
Goals
Timeframes Monitoring Requirements
Activities Potential Impacts
Mitigation Measures
Short Term (1-12 months)
Medium Term (1-5 years)
Long Term (5 Years +)
Throughout Life of Mine
Impacts Requiring Monitoring Programmes
Functional Requirements for Monitoring
Roles and Responsibilities
Monitoring and Reporting Frequency
suitable and licenced landfill site.
Documentation of removal and safe disposal must be available on site.
Handling and Storing of Domestic Waste
Clean and Dirty water separation systems should be incorporated in terms of the 2016 SWMP or any approved update thereafter.
Achieve 100% compliance to the water quality objectives as agreed to between the mine and the DWS based on the discussions within this IWWMP.
x x
Waste management training must be implemented on site.
Clear signs informing staff of waste management practices must be implemented on site. Maintain a 100%
compliance with the conditions of the ECA permit for the landfill site.
x x All waste must be removed by licensed contractors and disposed of at a licensed landfill site.
As a duty of care and the cradle to grave principles,
ENVIROGISTICS (PTY) LTD 10/12/17
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Name of Activity
Impact Area
Potential Impacts
Mitigation Type
Performance Objectives
Goals
Timeframes Monitoring Requirements
Activities Potential Impacts
Mitigation Measures
Short Term (1-12 months)
Medium Term (1-5 years)
Long Term (5 Years +)
Throughout Life of Mine
Impacts Requiring Monitoring Programmes
Functional Requirements for Monitoring
Roles and Responsibilities
Monitoring and Reporting Frequency
the mine should regularly inspect disposal site to ensure that best practices are implemented.
Recycling practices must be investigated and implemented on site.
Maintain a 100% accurate recording of waste and submission of such recording to the Department.
x x Records and manifests of waste disposal should be kept on file and in good order.
Groundwater monitoring must be undertaken in such a manner as to ensure that any potential impacts from the landfill site can be detected.
Maintain daily covering of the landfill site.
x x
Air Quality No direct impact
- - - - - - - - - - -
Heritage No direct impact
- - - - - - - - - - -
Noise No direct impact
- - - - - - - - - - -
Visual No direct impact
- - - - - - - - - - -
Social No direct impact
- - - - - - - - - - -
ENVIROGISTICS (PTY) LTD 10/12/17
Dwarsrivier Chrome Mine: Basic Assessment Report and Management Plan for the Expansion of the Met Grade Chrome Stockpile and Discard Dump with Ancillary Infrastructure Mining Right Ref: 30/5/1/3/2/1(179) EM Project Ref: 21714 Version: FINAL
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Table 67: Monitoring Compliance during Decommissioning and Closure Phase
Name of Activity
Impact Area
Potential Impacts
Mitigation Type
Performance Objectives
Goals
Timeframes Monitoring Requirements
Activities Potential Impacts
Mitigation Measures
Short Term (1-12 months)
Medium Term (1-5 years)
Long Term (5 Years +)
Throughout Life of Mine
Impacts Requiring Monitoring Programmes
Functional Requirements for Monitoring
Roles and Responsibilities
Monitoring and Reporting Frequency
Decommissioning and Closure Phase
Legal Requirements (Environmental Permits)
South Africa Enviro-Legal Requirements
Unlawful activities could lead to NWA Directives and Section 24G Rectification fines.
A legal assessment of all activities must be undertaken annually to ensure that all are licensed.
To operate within the enviro-legal ambits of South Africa.
Ensure that all activities undertaken by the mine are lawful with the required environmental licences in place.
x
Compliance in terms of Regulatory Requirements and the implementation of the EMP.
Appointment of an Independent Environmental Control Officer to assess compliance with the EMP. Quarterly (construction); Biannually (after construction) internal audits must be undertaken during the construction phase, where after biannual internal audits can be undertaken, to ensure compliance with the Environmental Authorisation and EMP. This should be undertaken by means of a thorough site visit, record keeping of findings in a checklist format, issuing of non-
Independent ECO & SHEQ
ECO: Weekly; SHEQ: Daily
A detailed closure plan must be developed and submitted to the relevant departments for approval.
To be aware of the latest environmental legal requirements.
Ensure that all environmental authorisations on site is implemented on site and ongoing monitoring of compliance are undertaken to reach 100% compliance.
x
All legally appointed personnel responsible or involved in activities on site must receive training on the requirements of the Environmental Authorisations and EMPs
All Departments responsible for development of the mine, must understand the requirements of the environmental legislation and must involve this into their planning processes.
x
Quarterly (construction);
ENVIROGISTICS (PTY) LTD 10/12/17
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Name of Activity
Impact Area
Potential Impacts
Mitigation Type
Performance Objectives
Goals
Timeframes Monitoring Requirements
Activities Potential Impacts
Mitigation Measures
Short Term (1-12 months)
Medium Term (1-5 years)
Long Term (5 Years +)
Throughout Life of Mine
Impacts Requiring Monitoring Programmes
Functional Requirements for Monitoring
Roles and Responsibilities
Monitoring and Reporting Frequency
Biannually (after construction) integral audits must be undertaken during the construction phase, where after biannual audits can be undertaken, on the lawful implementation of the Environmental Authorisation
conformances to responsible parties, listing thereof on the Isometrics or similar reporting system and feedback to the management team.
Environmental Authorisations must be available on site at all times.
The legal register must be updated to indicate all updated activities.
Rehabilitation of Waste Rock Dumps
Geology No direct impact. - - - - - - - - - - -
Topography
Returning the area to be stable and free draining.
Existing waste rock dumps will be used to fill the existing voids and excess material will be employed for mining and vent shaft closure.
Free draining environment.
Achieve 100% compliance with post land use commitment.
x Ongoing rehabilitation
Appointment of an Engineer who will facilitate and manage the landscaping of the Environment.
SHEQ Department
Survey of the area: monthly
ENVIROGISTICS (PTY) LTD 10/12/17
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Name of Activity
Impact Area
Potential Impacts
Mitigation Type
Performance Objectives
Goals
Timeframes Monitoring Requirements
Activities Potential Impacts
Mitigation Measures
Short Term (1-12 months)
Medium Term (1-5 years)
Long Term (5 Years +)
Throughout Life of Mine
Impacts Requiring Monitoring Programmes
Functional Requirements for Monitoring
Roles and Responsibilities
Monitoring and Reporting Frequency
All remaining waste disposal facilities, must be capped (could only include vegetation to reduce recharge), rehabilitated and closed in compliance with the relevant provisions of Section 11 of the DWA Minimum Requirements for Waste Disposal by Landfill, or any future amendments thereto/new legislation applicable to such (such as Reg 634-636 of the NEM:WA)
The side slopes of steep areas are to be graded to a slope of approximately 1:3 (or unless otherwise stated) in order to prevent excessive erosion and to
Appoint and Ecologist to initiate the revegetation of the slopes.
SHEQ Department
Ecological Study (annually) Weekly assessments of vegetation establishment: SHEQ
ENVIROGISTICS (PTY) LTD 10/12/17
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Name of Activity
Impact Area
Potential Impacts
Mitigation Type
Performance Objectives
Goals
Timeframes Monitoring Requirements
Activities Potential Impacts
Mitigation Measures
Short Term (1-12 months)
Medium Term (1-5 years)
Long Term (5 Years +)
Throughout Life of Mine
Impacts Requiring Monitoring Programmes
Functional Requirements for Monitoring
Roles and Responsibilities
Monitoring and Reporting Frequency
allow vegetation to establish sufficient root growth and in line with Health and safety requirements for closure
Side slopes of the rehabilitation area are to be covered by topsoil sourced from the topsoil stockpiles which were created during the clearing of the open pit areas, construction of new activities and tailings areas
Along the crest of steep gradients a 1 meter high Hessian screen should be placed around the facility to assist with the trapping of seeds and to protect the crest from wind erosion
ENVIROGISTICS (PTY) LTD 10/12/17
Dwarsrivier Chrome Mine: Basic Assessment Report and Management Plan for the Expansion of the Met Grade Chrome Stockpile and Discard Dump with Ancillary Infrastructure Mining Right Ref: 30/5/1/3/2/1(179) EM Project Ref: 21714 Version: FINAL
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Name of Activity
Impact Area
Potential Impacts
Mitigation Type
Performance Objectives
Goals
Timeframes Monitoring Requirements
Activities Potential Impacts
Mitigation Measures
Short Term (1-12 months)
Medium Term (1-5 years)
Long Term (5 Years +)
Throughout Life of Mine
Impacts Requiring Monitoring Programmes
Functional Requirements for Monitoring
Roles and Responsibilities
Monitoring and Reporting Frequency
All mine residue deposits should be effectively fenced off to avoid access thereto by unauthorised parties.
Soils No direct impact. - - - - - - - - - -
Ecology No direct impact.
A grass mixture off endemic grasses recommended by an ecologist should be utilised in the seeding process. Note that hydro-seeding is primarily for grasses and smaller shrubs. Larger shrubs and trees will need to be hand-planned.
To achieve final land use
The primary goal is to achieve a stable, climax state, representative of the Sekhukhune Mountain Bushveld vegetation type where the ecological function of the plant community is tolerant of most environmental conditions it encounters
x Ongoing rehabilitation
Appoint and Ecologist to initiate the revegetation of the slopes.
SHEQ Department.
Weed monitoring (monthly); Weed eradication (annually or as required); Ecological Study (annually)
The seed mixture should be incorporated into mulch which includes fertiliser and germination acceleration agents where required.
Regular application of fertiliser should
ENVIROGISTICS (PTY) LTD 10/12/17
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Name of Activity
Impact Area
Potential Impacts
Mitigation Type
Performance Objectives
Goals
Timeframes Monitoring Requirements
Activities Potential Impacts
Mitigation Measures
Short Term (1-12 months)
Medium Term (1-5 years)
Long Term (5 Years +)
Throughout Life of Mine
Impacts Requiring Monitoring Programmes
Functional Requirements for Monitoring
Roles and Responsibilities
Monitoring and Reporting Frequency
take place in order to ensure efficient establishment of vegetation cover until such time as sufficient organic matter is being produced by the established grasses to allow for self-sustaining growth
If re-seeding for basal cover establishment was not effective during 1st application, a second application of hydro-seed mixture may have to be applied in certain areas. The application of hydro-seed should be at the discretion of the specialist contractor.
No grazing on rehabilitated areas is to occur within three
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Short Term (1-12 months)
Medium Term (1-5 years)
Long Term (5 Years +)
Throughout Life of Mine
Impacts Requiring Monitoring Programmes
Functional Requirements for Monitoring
Roles and Responsibilities
Monitoring and Reporting Frequency
years of reseeding completion
Once sufficient basal cover has been established, the introduction of species representative of the Sekhukhune Mountain Bushveld vegetation type may commence.
Once sufficient basal cover has been established, the introduction of species representative of the Sekhukhune Mountain Bushveld vegetation type may commence.
Introduction of these species should commence through the stages of natural succession, i.e. Pioneer species (grasses, herbaceous species),
ENVIROGISTICS (PTY) LTD 10/12/17
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Mitigation Measures
Short Term (1-12 months)
Medium Term (1-5 years)
Long Term (5 Years +)
Throughout Life of Mine
Impacts Requiring Monitoring Programmes
Functional Requirements for Monitoring
Roles and Responsibilities
Monitoring and Reporting Frequency
Secondary species (grasses, small shrubs, and small trees) and Climax state (larger shrubs, large trees). This process will also occur naturally as seeds from the neighbouring Sekhukhune Mountain Bushveld areas are introduced and germinate
Certain tree species can be selectively introduced, however consideration will need to be given to rooting depths and soil stability as well as the ability of the trees to establish on the subject area
Wetlands No direct impact. - - - - - - - - - - -
Surface Water
Erosion of the side walls of the Discard Dump could lead not only to instability, but
The side walls should be sloped to a degree which will allow stability and self-succession of vegetation.
Final Land Use to have no impact on the surrounding or underlying water resource.
Ensure to utilise Discard Dump material lawfully in an attempt to reduce the presence thereof on site, by either
x x Surface Water Runoff
To ensure a proactive approach, the SHEQ department should undertake ongoing site monitoring to
SHEQ Department
Assessments: Weekly. Monitoring: Monthly
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Goals
Timeframes Monitoring Requirements
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Mitigation Measures
Short Term (1-12 months)
Medium Term (1-5 years)
Long Term (5 Years +)
Throughout Life of Mine
Impacts Requiring Monitoring Programmes
Functional Requirements for Monitoring
Roles and Responsibilities
Monitoring and Reporting Frequency
also siltation of water resources.
backfilling voids or future adits where possible or sell if correctly classified to lawful users.
determine whether activities on site are undertaken in accordance with the EMP Requirements. The water quality (constituents listed in the WUL) must be monitored monthly and records must be kept of these result in a centralised system. Analysis of results must be undertaken by an accredited laboratory. Monitoring of the effectiveness of the rehabilitation programme must be undertaken. This should be undertaken by means of weekly inspections and keeping a photographic record.
Where self-succession does not establish, it is recommended that the mine investigate a seeding programme.
Achieve 100% compliance to the water quality objectives as agreed to between the mine and the DWS based on the discussions within this report
x x
Clean and dirty water measures must be implemented around and on top of the facilities to manage water and runoff on and around the facility.
Final land use to receive signoff from all stakeholders.
x
No unnatural ponding of water on site should occur.
x
Self-succession of vegetation should establish within the first rainy season after construction has been completed.
x
Groundwater
The extension of the Northern Discard Dump is expected to have
Engineering design drawings for capping and closure of the
Protection of the Groundwater resources.
Improvement of the baseline groundwater quality.
x Ongoing rehabilitation.
An operational rehabilitation plan must be implemented and
SHEQ Department
Monthly Inspection.
ENVIROGISTICS (PTY) LTD 10/12/17
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Goals
Timeframes Monitoring Requirements
Activities Potential Impacts
Mitigation Measures
Short Term (1-12 months)
Medium Term (1-5 years)
Long Term (5 Years +)
Throughout Life of Mine
Impacts Requiring Monitoring Programmes
Functional Requirements for Monitoring
Roles and Responsibilities
Monitoring and Reporting Frequency
a limited impact and nitrate contamination is not expected to extend more than 400m from the Discard Dump during the operational phase. The historical impact of the Northern Discard Dump will however dominate groundwater contamination in this area and even if the Discard Dump is not extended, there is already a residual impact in this area, as indicated by the DCM monitoring programme. In the long-term, contamination from the Northern Discard Dump will migrate towards the Dwarsrivier and may reach this stream within a 100 years after
aforementioned facilities, as developed by a competent civil engineer, must be submitted to the DWS, as well as the DMR, for approval prior to commencing with the closure thereof. Recharge through this facility must be limited through capping to reduce the potential seep of contaminated water. Continuous update of the groundwater numerical model.
audited by the SHEQ department. Groundwater Monitoring. Update of groundwater model.
Monitoring Specialist Hydrogeologist
Monitoring in line with WUL Requirements. Annually
ENVIROGISTICS (PTY) LTD 10/12/17
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Short Term (1-12 months)
Medium Term (1-5 years)
Long Term (5 Years +)
Throughout Life of Mine
Impacts Requiring Monitoring Programmes
Functional Requirements for Monitoring
Roles and Responsibilities
Monitoring and Reporting Frequency
closure. Only a small section of the Dwarsrivier may be affected (<100m in length).
Heritage No direct impact. - - - - - - -
Visual No direct impact. - - - - - - - - - - -
Noise No direct impact. - - - - - - - - - - -
Social No direct impact. - - - - - - - - - - -
Dismantling and decommissioning of infrastructure and buildings, including product stockpiles
Geology No direct impact - - - - - - - - - - -
Topography
Removal of infrastructure may impact on the topography.
Linear Infrastructure constructed by the mine will be removed if it proves to inhibit land use at decommissioning. Where possible infrastructure will remain for social investment opportunities, this will be decided in conjunction with the Integrated Development Plan of the area ant eh local authorities.
Lawful removal of all infrastructure. Achieving final land use objectives.
Availability of safe disposal certificates. Free draining environment, with successful self-succession establishment.
x
Waste Disposal Ongoing Rehabilitation
Audits on safe disposal records and inspections at disposal sites. Inspections in terms of compliance with EMP commitments.
SHEQ Department
Monthly inspection of waste disposal records Biannual inspections of disposal sites Weekly inspections of rehabilitation progress.
Ensure the entire site remains fenced for the
ENVIROGISTICS (PTY) LTD 10/12/17
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Goals
Timeframes Monitoring Requirements
Activities Potential Impacts
Mitigation Measures
Short Term (1-12 months)
Medium Term (1-5 years)
Long Term (5 Years +)
Throughout Life of Mine
Impacts Requiring Monitoring Programmes
Functional Requirements for Monitoring
Roles and Responsibilities
Monitoring and Reporting Frequency
duration of rehabilitation. 2. Retain security access control to the site for the duration of rehabilitation.
All product stockpile to be removed from site.
All fixed assets that can be profitably removed will be removed for salvage or resale (the salvage and resale value have however not been incorporated into the closure cost estimate as per the legislative requirements)
All surface structures, infrastructure and ‘hard surfaces’ (inter alia, redundant surfaced roads, parking and paved areas) are
ENVIROGISTICS (PTY) LTD 10/12/17
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Timeframes Monitoring Requirements
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Mitigation Measures
Short Term (1-12 months)
Medium Term (1-5 years)
Long Term (5 Years +)
Throughout Life of Mine
Impacts Requiring Monitoring Programmes
Functional Requirements for Monitoring
Roles and Responsibilities
Monitoring and Reporting Frequency
to be demolished and removed from the disturbed mine footprint; unless an alternative/continued use for any such items is agreed upon, in writing, with the Department of Mineral Resources (DMR).
All surface infrastructure would be demolished and removed to a depth of 500mm. Any infrastructure below 500mm will be sealed, made safe and left in situ.
All fences erected around the infrastructure be dismantled and either disposed of at a permitted disposal site or sold off as scrap (provided that these structures
ENVIROGISTICS (PTY) LTD 10/12/17
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Goals
Timeframes Monitoring Requirements
Activities Potential Impacts
Mitigation Measures
Short Term (1-12 months)
Medium Term (1-5 years)
Long Term (5 Years +)
Throughout Life of Mine
Impacts Requiring Monitoring Programmes
Functional Requirements for Monitoring
Roles and Responsibilities
Monitoring and Reporting Frequency
will no longer be required by the post mining land owner). Fences erected to cordon off dangerous excavations will remain in place and will be maintained as and when required.
Water pollution control structures will remain until the completion of all demolition and associated rehabilitation activities where after these will be rehabilitated.
Soil, Land Use and Land Capability
Spills around the workshops, sewage facilities and stockpiles may result in the contamination of soils.
Any hydrocarbon, effluent or other contaminants should be collected and the soils remediated immediately.
Protection of Soil Integrity.
Zero presence of contaminated land due to early detection and implementation of actions.
x Soil Integrity
Appointment of an Independent Environmental Control Officer to assess compliance with the EMP. The SHEQ department should undertake ongoing site monitoring to determine whether activities on site are
SHEQ Department
Annual External Audit. Daily internal inspections. Recording of incidents when occurring.
ENVIROGISTICS (PTY) LTD 10/12/17
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Goals
Timeframes Monitoring Requirements
Activities Potential Impacts
Mitigation Measures
Short Term (1-12 months)
Medium Term (1-5 years)
Long Term (5 Years +)
Throughout Life of Mine
Impacts Requiring Monitoring Programmes
Functional Requirements for Monitoring
Roles and Responsibilities
Monitoring and Reporting Frequency
undertaken in accordance with the EMP Requirements. This should be undertaken by means of a thorough site visit, record keeping of findings in a checklist format, issuing of non-conformances to responsible parties, listing thereof on the Isometrics or similar reporting system and feedback to the management team.
Loss of soils due to decommissioning activities present on site.
Draw up a plan clearly defining the area where the removal of infrastructure should take place. Implement the plan with sufficient measures in place not to compact new areas.
Maintaining soil integrity, with successful vegetation establishment.
x
Soil Erosion and incorrect stockpiling of topsoil.
Appointment of an Independent Environmental Control Officer to assess compliance with the EMP. The SHEQ department should undertake ongoing site monitoring to determine whether activities on site are
Independent ECO and SHEQ Department.
ECO: Annual external audits can be undertaken. SHEQ: Weekly monitoring
ENVIROGISTICS (PTY) LTD 10/12/17
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Goals
Timeframes Monitoring Requirements
Activities Potential Impacts
Mitigation Measures
Short Term (1-12 months)
Medium Term (1-5 years)
Long Term (5 Years +)
Throughout Life of Mine
Impacts Requiring Monitoring Programmes
Functional Requirements for Monitoring
Roles and Responsibilities
Monitoring and Reporting Frequency
Implement a strict penalty fine system for rule breaking with regard to vehicular movement.
undertaken in accordance with the EMP Requirements.
Maintain clean and dirty water systems and undertake regular monitoring and maintenance thereof.
Soil integrity analysis
Assessment of the fertility of Soils
Soil Scientist Prior to placement of soils.
Ecology
The establishment of Weeds and Invader Species.
A weed eradication programme will be developed and implemented to eradicate weeds and invader plants and to prevent new invasions during the ongoing mining operation.
Limit the impact of the mining operation on the Ecological Setting of the area.
Reduce the presence of invader species by 90% on site.
x
Invasion of Weeds and Alien Vegetation.
A weed eradication plan must be implemented on site. This must be undertaken prior to the growing season. An ecological study should be undertaken to determine the status of revegetation on the site especially around the rehabilitated areas.
SHEQ Department and a Specialised Ecologist.
Weed monitoring (monthly); Weed eradication (annually or as required); Ecological Study (annually)
Where self-succession does not establish, harvested seeds and plants must be used in concurrent rehabilitation for any areas along
ENVIROGISTICS (PTY) LTD 10/12/17
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Performance Objectives
Goals
Timeframes Monitoring Requirements
Activities Potential Impacts
Mitigation Measures
Short Term (1-12 months)
Medium Term (1-5 years)
Long Term (5 Years +)
Throughout Life of Mine
Impacts Requiring Monitoring Programmes
Functional Requirements for Monitoring
Roles and Responsibilities
Monitoring and Reporting Frequency
the area which may be affected.
Direct impact: Unplanned loss of floral and faunal species of conservation importance
Prior to the removal of plant species, an ecologist should investigate the site (if not already done) to record all species of importance and which should be removed under tree removal permits. All such species should be demarcated by signage or tape.
Achieving final land use commitments.
Self-succession of vegetation should establish within the first rainy season after construction has been completed. Zero removal of species of conservation importance without the necessary permits in place.
x
Ongoing rehabilitation.
An operational rehabilitation plan must be implemented and audited by the SHEQ department.
SHEQ Department
Monthly
Obtain tree removal permit prior to the removal of any protected species.
Vegetation Establishment.
An ecological study should be undertaken to determine the status of revegetation on the site especially around the rehabilitated areas.
SHEQ Department
Monthly
All employees, or contractors on site, involved in
Invasion of Weeds and
A weed eradication plan must be
SHEQ Department and a
Weed monitoring (monthly);
ENVIROGISTICS (PTY) LTD 10/12/17
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Performance Objectives
Goals
Timeframes Monitoring Requirements
Activities Potential Impacts
Mitigation Measures
Short Term (1-12 months)
Medium Term (1-5 years)
Long Term (5 Years +)
Throughout Life of Mine
Impacts Requiring Monitoring Programmes
Functional Requirements for Monitoring
Roles and Responsibilities
Monitoring and Reporting Frequency
this project, should receive a detailed induction on the expectations for the protection of fauna and flora on site.
Alien Vegetation.
implemented on site. This must be undertaken prior to the growing season.
Specialised Ecologist.
Weed eradication (annually or as required); Ecological Study (annually)
Weed eradication should be implemented on site.
Accidental death of animals on the roads.
Clearly marked signs will be erected along the transportation routes to create awareness of animal crossings.
Awareness creation on the importance of that natural ecosystem in which the mine operates. Implementation of safe operation practices.
Zero animal fatality.
x Creation of Awareness.
Induction with the view on creating environmental awareness.
SHEQ Department
Annually for permanent staff. Start of each visit for contractors.
A clearly marked and enforced vehicle speed will be implemented on the internal mine and transportation routes.
A detailed induction programme will be in place to ensure that all parties are aware of the rules and
ENVIROGISTICS (PTY) LTD 10/12/17
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Goals
Timeframes Monitoring Requirements
Activities Potential Impacts
Mitigation Measures
Short Term (1-12 months)
Medium Term (1-5 years)
Long Term (5 Years +)
Throughout Life of Mine
Impacts Requiring Monitoring Programmes
Functional Requirements for Monitoring
Roles and Responsibilities
Monitoring and Reporting Frequency
regulations on site in terms of the use of roads.
Vehicles may only travel on demarcated roads on site.
Riparian Habitat
The Sprinkaan Spruit is located just 100m to the south of the proposed infrastructure (workshops, loadout and sewage facilities). The Dwarsrivier is located to the west of the proposed loadout facility (520m) and Discard Dump (220m).
Remain at all times outside of the 1:100 year flood line of the watercourses. Ongoing Biodiversity Monitoring should be undertaken at the upstream and downstream points. Ongoing surface water monitoring should be undertaken at the upstream and downstream monitoring points. The storm water management plans should be retained in and around the facilities to
Remain within or approve upon the current Aquatic Health and Water Quality baseline conditions.
Improve upon the current aquatic health and water quality baseline conditions.
x x
Compliance in terms of the current Water Use License.
Ongoing Biodiversity and water quality assessments.
Aquatic Specialist.
Surface and Biomonitoring in line with the current monitoring programme.
ENVIROGISTICS (PTY) LTD 10/12/17
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Goals
Timeframes Monitoring Requirements
Activities Potential Impacts
Mitigation Measures
Short Term (1-12 months)
Medium Term (1-5 years)
Long Term (5 Years +)
Throughout Life of Mine
Impacts Requiring Monitoring Programmes
Functional Requirements for Monitoring
Roles and Responsibilities
Monitoring and Reporting Frequency
ensure that dirty water runoff or water with high sediment loads do not enter the existing watercourses.
Wetland Loss or Impact on NEFPA Sites
No activities are planned within 500m from any NEFPA sites. This restriction should be maintained.
Protect sensitive ecosystems.
Remain within the designated footprints at all times.
x Location of approved activities.
Appointment of an Independent Environmental Control Officer to assess compliance with the EMP. The SHEQ department should undertake ongoing site monitoring to determine whether activities on site are undertaken in accordance with the EMP Requirements.
ECO and SHEQ Department
ECO: Monthly for the decommissioning phase. . SHEQ: Weekly monitoring
Hydrology
Erosion control over rehabilitated areas and the prevention of erosion gullies.
The topography of all disturbed areas must be rehabilitated in such a manner that the surrounding natural area blends naturally with the rehabilitated areas well as to be free-draining.
Protect the water resources within the area in which the mine operates.
Maintenance of storm water management systems. Meeting the conditions in terms of Section 21c & of the WUL.
Surface Water Pollution & Soil Assessments.
To ensure a proactive approach, the SHEQ department should undertake ongoing site monitoring to determine whether activities on site are undertaken in accordance with the EMP
SHEQ Department
Assessments: Weekly. Monitoring: Monthly
ENVIROGISTICS (PTY) LTD 10/12/17
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Goals
Timeframes Monitoring Requirements
Activities Potential Impacts
Mitigation Measures
Short Term (1-12 months)
Medium Term (1-5 years)
Long Term (5 Years +)
Throughout Life of Mine
Impacts Requiring Monitoring Programmes
Functional Requirements for Monitoring
Roles and Responsibilities
Monitoring and Reporting Frequency
This will reduce soil erosion and improve natural re-vegetation.
Requirements. The water quality (constituents listed in the WUL) must be monitored monthly and records must be kept of these result in a centralised system. Analysis of results must be undertaken by an accredited laboratory. Monitoring of the effectiveness of the rehabilitation programme must be undertaken. This should be undertaken by means of weekly inspections and keeping a photographic record.
Contamination of surface water as a result of removal of infrastructure.
The detailed waste management strategy implemented during the construction and operation phases must be continuously implemented throughout the closure and decommissioning phase.
x
Rubble and waste from site could pollute local water resources.
Waste that is not removed from site should be spread, covered and suitably rehabilitated.
x
Geohydrology No direct impact - - - - - - - - - - -
Heritage No direct impact - - - - - - - - - - -
Visual
Fugitive dust emissions as a result of infrastructure removal and associated exposed/bare areas may have
The dust monitoring network and dust suppression programme established during the construction
Remain within the regulated guidelines and limits.
Recording of dust fall out to determine trends.
x Dust dispersion.
Dust dispersion will be monitored as part of the overall mine dust monitoring programme.
SHEQ Department.
Monthly Monitoring with Annual Reporting.
ENVIROGISTICS (PTY) LTD 10/12/17
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Timeframes Monitoring Requirements
Activities Potential Impacts
Mitigation Measures
Short Term (1-12 months)
Medium Term (1-5 years)
Long Term (5 Years +)
Throughout Life of Mine
Impacts Requiring Monitoring Programmes
Functional Requirements for Monitoring
Roles and Responsibilities
Monitoring and Reporting Frequency
an impact in terms of air quality and visual characteristics.
phase of the project will be maintained throughout the closure phase of the mine. With respect to haul road dust levels, it is recommended to limit vehicle speeds, especially during high risk periods of high winds, high temperature and low humidity.
Establish and implement a dust suppression plan in consultation with the environmental control officer and an air quality specialist as part of the contractor’s responsibility.
Air Quality
All activities associated with the removal of infrastructure and rehabilitation
The dust monitoring network and dust suppression programme established
Remain within the regulated guidelines and limits.
Recording of dust fall out to determine trends.
x Dust dispersion.
Dust dispersion will be monitored as part of the overall mine dust monitoring programme.
SHEQ Department.
Monthly Monitoring with Annual Reporting. Meeting ambient
dust fall out x
ENVIROGISTICS (PTY) LTD 10/12/17
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Performance Objectives
Goals
Timeframes Monitoring Requirements
Activities Potential Impacts
Mitigation Measures
Short Term (1-12 months)
Medium Term (1-5 years)
Long Term (5 Years +)
Throughout Life of Mine
Impacts Requiring Monitoring Programmes
Functional Requirements for Monitoring
Roles and Responsibilities
Monitoring and Reporting Frequency
has the potential to release dust.
during the construction phase of the project will be maintained throughout the closure phase of the mine. With respect to haul road dust levels, it is recommended to limit vehicle speeds, especially during high risk periods of high winds, high temperature and low humidity.
limits in terms of applicable NEM: AQA Regulations.
Noise
All activities associated with the removal of infrastructure and rehabilitation has the potential to generate noise.
The removal of all infrastructure is to take place during daytime periods only.
Remain within the regulated guidelines and limits.
Machinery with low noise levels and maintained in a good order to be used and to comply with the IFC’s Health and Safety Regulations.
x
Noise Monitoring.
Adjacent landowners will be informed of the planned dates of the significant demolition activities where applicable. Daily noise monitoring will be undertaken in the areas where high levels of noise take place during decommissioning.
SHEQ Department.
Ongoing consultation with surrounding landowners. Daily noise monitoring.
Health and Safety Regulations in terms of noise monitoring should be met.
x
Where noise becomes a nuisance, management measures will be investigated and
ENVIROGISTICS (PTY) LTD 10/12/17
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Timeframes Monitoring Requirements
Activities Potential Impacts
Mitigation Measures
Short Term (1-12 months)
Medium Term (1-5 years)
Long Term (5 Years +)
Throughout Life of Mine
Impacts Requiring Monitoring Programmes
Functional Requirements for Monitoring
Roles and Responsibilities
Monitoring and Reporting Frequency
implemented to address these.
Social
Disruption and nuisance factors associated with the actual decommissioning such as noise, visual and traffic related impacts.
Local residents, with the focus on the surrounding landowners, should receive accurate information with regards to the project status, timeframes for decommissioning and other relevant information about issues that could influence their daily living and movement patterns.
Remain within the regulated guidelines and limits.
The community forum established should continue, through which issues can be addressed, and a representative from Khumani should become involved.
x Ongoing stakeholder consultation
Adjacent landowners will be informed of the planned dates of the significant demolition activities where applicable.
SHEQ Department.
Ongoing consultation with surrounding landowners.
Earth Moving, shaping and ripping of ground
Geology No direct impact - - - - - - - - - - -
Topography
The shaping of the site should be undertaken in such a manner that it improves the overall topography of the site.
Pre-mining topography should be reasonably restored through shaping and landscaping, such that the topography of rehabilitated areas will ultimately be commensurate with that of
Develop the area to its intended final land use.
Implement an action plan to systematically plan for closure.
x Final Land use
An operational rehabilitation plan must be implemented and audited by the SHEQ department.
SHEQ Department.
Monthly monitoring.
ENVIROGISTICS (PTY) LTD 10/12/17
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P a g e 346 | 393
Name of Activity
Impact Area
Potential Impacts
Mitigation Type
Performance Objectives
Goals
Timeframes Monitoring Requirements
Activities Potential Impacts
Mitigation Measures
Short Term (1-12 months)
Medium Term (1-5 years)
Long Term (5 Years +)
Throughout Life of Mine
Impacts Requiring Monitoring Programmes
Functional Requirements for Monitoring
Roles and Responsibilities
Monitoring and Reporting Frequency
adjacent, non-disturbed areas.
Soil erosion Re-vegetate as soon as possible
Develop the area to its intended final land use.
Continuous rehabilitation of the decommissioning area will be conducted in line with the Best Practice Guidelines released by the DWA.
x x
Soil Erosion and incorrect stockpiling of topsoil.
Erosion protection measures should be implemented and monitored on areas identified. Photographic records of assessments must be kept.
Independent ECO and SHEQ Department.
ECO: Weekly for the decommissioning phase. Thereafter annual external audits can be undertaken. SHEQ: Weekly monitoring Pedologist: Weekly assessment of soil rehabilitation.
Ripping and topsoil replacement will restore the soil physical characteristics prior to re-vegetation.
Compacted soils will be ripped and topsoil will be replaced. After the topsoil has been replaced the area should be ameliorated and seeded, should self-succession of vegetation not take place. Only species indigenous to the area will be included.
Where sites have been alienated of vegetation or where soils have been compacted or covered with concretes, these sites will be ripped and ploughed.
The topsoil and sub-soils with the appropriate seedbed as stripped during the construction
ENVIROGISTICS (PTY) LTD 10/12/17
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Name of Activity
Impact Area
Potential Impacts
Mitigation Type
Performance Objectives
Goals
Timeframes Monitoring Requirements
Activities Potential Impacts
Mitigation Measures
Short Term (1-12 months)
Medium Term (1-5 years)
Long Term (5 Years +)
Throughout Life of Mine
Impacts Requiring Monitoring Programmes
Functional Requirements for Monitoring
Roles and Responsibilities
Monitoring and Reporting Frequency
and operational phases will be placed over these areas to a depth as specified by a qualified specialist. The topsoil shall be appropriately ameliorated to allow vegetation to grow rapidly if required – it should be noted that the mine will encourage self-succession of vegetation, if this does not take place effectively a re-vegetation project will be implemented
Terrestrial Ecology (Fauna & Flora)
The rehabilitation of the site will allow reestablishment of natural vegetation.
Compacted soils will be ripped and topsoil will be replaced. After the topsoil has been replaced the area should be ameliorated and seeded, should self-succession of vegetation not take place. Only
Protect the Ecology within which the mine operates
Free draining environment with successful self-succession in place.
x
Invasion of Weeds and Alien Vegetation.
A weed eradication plan must be implemented on site. This must be undertaken prior to the growing season. An ecological study should be undertaken to determine the status of
SHEQ Department and a Specialised Ecologist.
Weed monitoring (monthly); Weed eradication (annually or as required); Ecological Study (annually)
ENVIROGISTICS (PTY) LTD 10/12/17
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Name of Activity
Impact Area
Potential Impacts
Mitigation Type
Performance Objectives
Goals
Timeframes Monitoring Requirements
Activities Potential Impacts
Mitigation Measures
Short Term (1-12 months)
Medium Term (1-5 years)
Long Term (5 Years +)
Throughout Life of Mine
Impacts Requiring Monitoring Programmes
Functional Requirements for Monitoring
Roles and Responsibilities
Monitoring and Reporting Frequency
species indigenous to the area will be included. Remove alien vegetation post decommissioning, with long term follow-up afterwards.
revegetation on the site especially around the rehabilitated areas.
On-going alien and invasive floral species control is required through all phases of rehabilitation.
If a reasonable assessment indicates that the re-establishment of vegetation is unacceptable slow, the soil need to be analysed and any deleterious effects must be corrected and the area be seeded with a seed mix to specification
Access to rehabilitated areas should be restricted to
ENVIROGISTICS (PTY) LTD 10/12/17
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P a g e 349 | 393
Name of Activity
Impact Area
Potential Impacts
Mitigation Type
Performance Objectives
Goals
Timeframes Monitoring Requirements
Activities Potential Impacts
Mitigation Measures
Short Term (1-12 months)
Medium Term (1-5 years)
Long Term (5 Years +)
Throughout Life of Mine
Impacts Requiring Monitoring Programmes
Functional Requirements for Monitoring
Roles and Responsibilities
Monitoring and Reporting Frequency
vehicles/machinery specifically required for the implementation of the closure plan.
Wetland No direct impact - - - - - - - - - - -
Hydrology
The areas will be landscaped to be free draining in line with the approved storm water management plan.
Runoff from rehabilitated areas will impact on watercourses especially during intensive rainstorms especially if the area are not free draining.
Berms, should they be necessary, must remain upstream and downstream of the dumps and stockpiles to ensure that clean water is kept separate from dirty water until the area is free draining and re-vegetation has occurred.
Protect the water resources within the area in which the mine operates.
Continuous rehabilitation of the decommissioning area will be conducted in line with the Best Practice Guidelines released by the DWA.
x
Surface Water Pollution & Soil Assessments.
To ensure a proactive approach, the SHEQ department should undertake ongoing site monitoring to determine whether activities on site are undertaken in accordance with the EMP Requirements. The water quality (constituents listed in the WUL) must be monitored monthly and records must be kept of these result in a
SHEQ Department
Assessments: Weekly. Monitoring: Monthly
ENVIROGISTICS (PTY) LTD 10/12/17
Dwarsrivier Chrome Mine: Basic Assessment Report and Management Plan for the Expansion of the Met Grade Chrome Stockpile and Discard Dump with Ancillary Infrastructure Mining Right Ref: 30/5/1/3/2/1(179) EM Project Ref: 21714 Version: FINAL
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Name of Activity
Impact Area
Potential Impacts
Mitigation Type
Performance Objectives
Goals
Timeframes Monitoring Requirements
Activities Potential Impacts
Mitigation Measures
Short Term (1-12 months)
Medium Term (1-5 years)
Long Term (5 Years +)
Throughout Life of Mine
Impacts Requiring Monitoring Programmes
Functional Requirements for Monitoring
Roles and Responsibilities
Monitoring and Reporting Frequency
centralised system. Analysis of results must be undertaken by an accredited laboratory. Monitoring of the effectiveness of the rehabilitation programme must be undertaken. This should be undertaken by means of weekly inspections and keeping a photographic record.
Geohydrology No direct impact
Protect the groundwater resources to ensure that
limited to no impact on
groundwater resources occur
as a result of the mining operations.
Implement and operate a
detailed waste manifest on site and maintain a
100% safe disposal record on the disposal
of waste on site.
x x
Groundwater Pollution
and potential trends.
The groundwater quality
(constituents listed in the WUL)
must be monitored
monthly and records must be
kept of these result in a centralised
system. Analysis of results must be undertaken by an
accredited laboratory
SHEQ Department
Quarterly (construction);
Biannually (after
construction)
Heritage No direct impact - - - - - - - - - - -
Visual The rehabilitation
An overall visual improvement
Remain within the designated
x Dust
dispersion. Dust dispersion
will be monitored SHEQ
Department. Monthly Monitoring with
ENVIROGISTICS (PTY) LTD 10/12/17
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Name of Activity
Impact Area
Potential Impacts
Mitigation Type
Performance Objectives
Goals
Timeframes Monitoring Requirements
Activities Potential Impacts
Mitigation Measures
Short Term (1-12 months)
Medium Term (1-5 years)
Long Term (5 Years +)
Throughout Life of Mine
Impacts Requiring Monitoring Programmes
Functional Requirements for Monitoring
Roles and Responsibilities
Monitoring and Reporting Frequency
(ripping, topsoil replacement and landscaping) will remove the visual incongruity.
will be noticed once all mining related infrastructure has been demolished and the area has been landscaped and re-vegetated.
Successful establishment of vegetation.
area demarcated for activities. Remain within the National Environmental Management: Air Quality Act, 2004 Dust Regulation guidelines for rural communities.
as part of the overall mine dust
monitoring programme.
Annual Reporting.
Demarcate the decommissioning area and limit the decommissioning activities as far as possible.
Final shaping will be implemented such that the final profile of the rehabilitated areas are formed to emulate natural contours of the area.
Foundations will be removed to a depth of 1 m below the surface and the area rehabilitated.
Vegetation Establishment.
An ecological study should be undertaken to determine the status of revegetation on the site especially around the rehabilitated areas.
SHEQ Department
Monthly
All material recovered from the demolition of buildings
ENVIROGISTICS (PTY) LTD 10/12/17
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Name of Activity
Impact Area
Potential Impacts
Mitigation Type
Performance Objectives
Goals
Timeframes Monitoring Requirements
Activities Potential Impacts
Mitigation Measures
Short Term (1-12 months)
Medium Term (1-5 years)
Long Term (5 Years +)
Throughout Life of Mine
Impacts Requiring Monitoring Programmes
Functional Requirements for Monitoring
Roles and Responsibilities
Monitoring and Reporting Frequency
and/or structures will either be transported to a permitted disposal site, or made available to the local community as building materials (provided they are in a satisfactory condition following demolition).
Linear infrastructure constructed by the mine (i.e. roads, conveyors and power lines) will be removed if it proves to inhibit land use at decommissioning.
All fences erected around the mine will be dismantled and disposed of at a permitted disposal site.
Air Quality All activities associated with
Dust sampling will be
No concerns raised by
Remain within the designated
x x Dust dispersion.
Dust dispersion will be monitored
SHEQ Department.
Monthly Monitoring with
ENVIROGISTICS (PTY) LTD 10/12/17
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Name of Activity
Impact Area
Potential Impacts
Mitigation Type
Performance Objectives
Goals
Timeframes Monitoring Requirements
Activities Potential Impacts
Mitigation Measures
Short Term (1-12 months)
Medium Term (1-5 years)
Long Term (5 Years +)
Throughout Life of Mine
Impacts Requiring Monitoring Programmes
Functional Requirements for Monitoring
Roles and Responsibilities
Monitoring and Reporting Frequency
the removal of infrastructure has the potential to release dust.
undertaken on a monthly basis.
surrounding landowners regarding air quality.
area demarcated for activities.
as part of the overall mine dust monitoring programme.
Annual Reporting.
Monthly monitoring reports will be generated by the mine or through a suitably qualified air quality specialist.
Remain within the National Environmental Management: Air Quality Act, 2004 Dust Regulation guidelines for rural communities.
In the event that air quality or dust issues are identified based on the monitoring programme, an independent specialist should be appointed to determine the best course of action to ameliorate the situation.
Noise
All activities associated with the removal of infrastructure and rehabilitation has the potential to generate noise.
The removal of all infrastructure is to take place during daytime periods only. Where noise becomes a nuisance, management measures will be investigated and implemented to address these.
No concerns raised by surrounding landowners regarding air quality.
Remain within the designated area demarcated for activities.
x x Noise Monitoring.
Adjacent landowners will be informed of the planned dates of the significant demolition activities where applicable. Daily noise monitoring will be undertaken in the areas where high levels of noise
SHEQ Department.
Ongoing consultation with surrounding landowners. Daily noise monitoring.
ENVIROGISTICS (PTY) LTD 10/12/17
Dwarsrivier Chrome Mine: Basic Assessment Report and Management Plan for the Expansion of the Met Grade Chrome Stockpile and Discard Dump with Ancillary Infrastructure Mining Right Ref: 30/5/1/3/2/1(179) EM Project Ref: 21714 Version: FINAL
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Name of Activity
Impact Area
Potential Impacts
Mitigation Type
Performance Objectives
Goals
Timeframes Monitoring Requirements
Activities Potential Impacts
Mitigation Measures
Short Term (1-12 months)
Medium Term (1-5 years)
Long Term (5 Years +)
Throughout Life of Mine
Impacts Requiring Monitoring Programmes
Functional Requirements for Monitoring
Roles and Responsibilities
Monitoring and Reporting Frequency
Machinery with low noise levels and maintained in a good order to be used and to comply with the IFC’s Health and Safety Regulations.
take place during decommissioning.
Speed control measures will be implemented by the mine through the placement of adequate signage.
Remain within the National Environmental Management: Air Quality Act, 2004 Dust Regulation guidelines for rural communities.
Implement a penalty system for non-compliance to speed control measures and ensure that all workers are made aware of the penalty systems.
Gravel roads to be maintained in as good and smooth a condition as possible.
Social - - - - - - - - - - -
Cessation of
Geology No direct impact - - - - - - - - - - -
Topography No direct impact - - - - - - - - - - -
ENVIROGISTICS (PTY) LTD 10/12/17
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Name of Activity
Impact Area
Potential Impacts
Mitigation Type
Performance Objectives
Goals
Timeframes Monitoring Requirements
Activities Potential Impacts
Mitigation Measures
Short Term (1-12 months)
Medium Term (1-5 years)
Long Term (5 Years +)
Throughout Life of Mine
Impacts Requiring Monitoring Programmes
Functional Requirements for Monitoring
Roles and Responsibilities
Monitoring and Reporting Frequency
Labour Contracts
Soil, Land Use and Land Capability
No direct impact - - - - - - - - - - -
Terrestrial Ecology (Fauna & Flora)
No direct impact
- - - - - - - - - - -
Wetland No direct impact - - - - - - - - - - -
Hydrology No direct impact - - - - - - - - - - -
Geohydrology No direct impact - - - - - - - - - - -
Heritage No direct impact - - - - - - - - - - -
Visual No direct impact - - - - - - - - - - -
Air Quality No direct impact - - - - - - - - - - -
Noise No direct impact - - - - - - - - - - -
Socio-Economic
Plant, store and workshop areas could benefit the local community.
Instead of demolition of certain areas, these areas could be sold off as commercial property for use in the local community. All surface structures, infrastructure and ‘hard surfaces’ (inter alia, redundant surfaced roads, parking and paved areas) are to be demolished and removed from the disturbed
Optimally utilise buildings and infrastructure.
Safe disposal and lawful operation of infrastructure.
x x Socio-Economic Character
Engage in consultation with municipalities and local industries to determine the need and recycling of existing infrastructure.
SHEQ Department. Ongoing consultation prior to demolition.
ENVIROGISTICS (PTY) LTD 10/12/17
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Name of Activity
Impact Area
Potential Impacts
Mitigation Type
Performance Objectives
Goals
Timeframes Monitoring Requirements
Activities Potential Impacts
Mitigation Measures
Short Term (1-12 months)
Medium Term (1-5 years)
Long Term (5 Years +)
Throughout Life of Mine
Impacts Requiring Monitoring Programmes
Functional Requirements for Monitoring
Roles and Responsibilities
Monitoring and Reporting Frequency
mine footprint; unless an alternative/continued use for any such items is agreed upon, in writing, with the Department of Mineral Resources (DMR).
Loss of Employment.
The mine should continue with the skills development programme and Social and Labour Plan commitments to empower the workforce to undertake other economically viable activities.
Ensuring successful skills development to allow for continued economically active people and opportunities in the area post mining.
Successful implementation of skills development and opportunities on site.
x x x Socio-Economic Character
Compliance with the Social and Labour Plan.
HR Department
Biannually up until closure has been achieved.
Waste Management
Groundwater
Handling or Hazardous Waste within workshops and general mine area.
Clean and Dirty water separation systems should be incorporated in terms of the 2016 SWMP or any approved update thereafter.
Protect the groundwater resources to ensure that limited to no impact on groundwater resources occur as a result of the mining operations.
Achieve 100% compliance to the water quality objectives as agreed to between the mine and the DWS based on the discussions within this IWWMP.
x x
Groundwater Pollution and potential trends.
The groundwater quality (constituents listed in the WUL) must be monitored monthly and records must be kept of these result in a centralised system. Analysis of results must be undertaken by an
Waste management training must be implemented on site.
ENVIROGISTICS (PTY) LTD 10/12/17
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P a g e 357 | 393
Name of Activity
Impact Area
Potential Impacts
Mitigation Type
Performance Objectives
Goals
Timeframes Monitoring Requirements
Activities Potential Impacts
Mitigation Measures
Short Term (1-12 months)
Medium Term (1-5 years)
Long Term (5 Years +)
Throughout Life of Mine
Impacts Requiring Monitoring Programmes
Functional Requirements for Monitoring
Roles and Responsibilities
Monitoring and Reporting Frequency
Clear signs informing staff of waste management practices must be implemented on site.
Maintain a 100% safe disposal record on the disposal of hazardous waste.
x
accredited laboratory
Hazardous waste handling should only take place within bunded and/or lined areas.
Hazardous waste should be removed by a licenced removal company and taken to a suitable and licenced landfill site.
Documentation of removal and safe disposal must be available on site.
Handling of Building Rubble
All infrastructure will be removed and rehabilitated, should no alternative use be found for the structures.
Foundations will be removed to a
ENVIROGISTICS (PTY) LTD 10/12/17
Dwarsrivier Chrome Mine: Basic Assessment Report and Management Plan for the Expansion of the Met Grade Chrome Stockpile and Discard Dump with Ancillary Infrastructure Mining Right Ref: 30/5/1/3/2/1(179) EM Project Ref: 21714 Version: FINAL
P a g e 358 | 393
Name of Activity
Impact Area
Potential Impacts
Mitigation Type
Performance Objectives
Goals
Timeframes Monitoring Requirements
Activities Potential Impacts
Mitigation Measures
Short Term (1-12 months)
Medium Term (1-5 years)
Long Term (5 Years +)
Throughout Life of Mine
Impacts Requiring Monitoring Programmes
Functional Requirements for Monitoring
Roles and Responsibilities
Monitoring and Reporting Frequency
depth of 500cm below surface.
All building rubble will follow the waste hierarchy and will therefore either be sold for reuse where possible or as a last option be disposed of at a licensed facility suitable for such waste.
Implement and operate a detailed waste manifest on site and maintain a 100% safe disposal record on the disposal of waste on site.
x x
Handling and Storing of Domestic Waste
Clean and Dirty water separation systems should be maintained.
Achieve 100% compliance to the water quality objectives as agreed to between the mine and the DWS based on the discussions within this IWWMP.
x x Waste management training must be implemented on site.
Clear signs informing staff of waste management practices must be implemented on site.
Maintain a 100% compliance with the conditions of the ECA permit for the landfill site.
x
Groundwater monitoring must be undertaken in such a manner as to ensure that
ENVIROGISTICS (PTY) LTD 10/12/17
Dwarsrivier Chrome Mine: Basic Assessment Report and Management Plan for the Expansion of the Met Grade Chrome Stockpile and Discard Dump with Ancillary Infrastructure Mining Right Ref: 30/5/1/3/2/1(179) EM Project Ref: 21714 Version: FINAL
P a g e 359 | 393
Name of Activity
Impact Area
Potential Impacts
Mitigation Type
Performance Objectives
Goals
Timeframes Monitoring Requirements
Activities Potential Impacts
Mitigation Measures
Short Term (1-12 months)
Medium Term (1-5 years)
Long Term (5 Years +)
Throughout Life of Mine
Impacts Requiring Monitoring Programmes
Functional Requirements for Monitoring
Roles and Responsibilities
Monitoring and Reporting Frequency
any potential impacts from the site can be detected.
Recycling practices must be investigated and implemented on site.
Maintain a 100% accurate recording of waste and submission of such recording to the Department.
x
Maintain daily covering of the landfill site.
x x
Surface Water
Handling of Hazardous Waste within workshops and general mine area could contaminate the dirty water storage areas. The water is then reused in the system and could have impacts on the integrity of the storm water system and also the production.
Clean and Dirty water separation systems should be maintained up until closure.
Develop the area to its intended final land use.
Maintain the SWMP on site.
x
Surface Water Pollution & Soil Assessments.
To ensure a proactive approach, the SHEQ department should undertake ongoing site monitoring to determine whether activities on site are undertaken in accordance with the EMP Requirements. The water quality (constituents listed in the WUL) of the dam must be monitored monthly and records must be kept of these result in a
SHEQ Department
Assessments: Weekly. Monitoring: Monthly
Waste management training must be implemented on site.
Maintain a 100% no-spill record.
x
Clear signs informing staff of waste management practices must be implemented on site.
Clean spills, if occur witan 24 hours.
x
Hazardous waste handling should only take place within bunded and/or lined areas.
Maintain a 100% safe disposal record on the disposal of hazardous waste.
x
ENVIROGISTICS (PTY) LTD 10/12/17
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Name of Activity
Impact Area
Potential Impacts
Mitigation Type
Performance Objectives
Goals
Timeframes Monitoring Requirements
Activities Potential Impacts
Mitigation Measures
Short Term (1-12 months)
Medium Term (1-5 years)
Long Term (5 Years +)
Throughout Life of Mine
Impacts Requiring Monitoring Programmes
Functional Requirements for Monitoring
Roles and Responsibilities
Monitoring and Reporting Frequency
Hazardous waste and contaminated materials should be removed by a licenced removal company and taken to a suitable and licenced landfill site.
Provide training to all staff on best practices regarding waste management every year.
x x
centralised system. Analysis of results must be undertaken by an accredited laboratory.
Documentation of removal and safe disposal must be available on site.
Weekly inspections of Storm Water Management Systems must be undertaken. Any blockages or maintenance requirements must be documented and an action plan developed.
Handling and Storing of Domestic Waste should have no impact on the surface water resources due to the location of
Clean and Dirty water separation systems should be maintained up until closure.
Maintain a 100% compliance with the conditions of the ECA permit for the landfill site.
x x
Waste management training must be
ENVIROGISTICS (PTY) LTD 10/12/17
Dwarsrivier Chrome Mine: Basic Assessment Report and Management Plan for the Expansion of the Met Grade Chrome Stockpile and Discard Dump with Ancillary Infrastructure Mining Right Ref: 30/5/1/3/2/1(179) EM Project Ref: 21714 Version: FINAL
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Name of Activity
Impact Area
Potential Impacts
Mitigation Type
Performance Objectives
Goals
Timeframes Monitoring Requirements
Activities Potential Impacts
Mitigation Measures
Short Term (1-12 months)
Medium Term (1-5 years)
Long Term (5 Years +)
Throughout Life of Mine
Impacts Requiring Monitoring Programmes
Functional Requirements for Monitoring
Roles and Responsibilities
Monitoring and Reporting Frequency
the facility. However, incorrect disposal of waste could hamper the integrity of the storm water system.
implemented on site.
Weekly inspections of Storm Water Management Systems must be undertaken. Any blockages or maintenance requirements must be documented and an action plan developed.
Clear signs informing staff of waste management practices must be implemented on site.
Recycling practices must be investigated and implemented on site.
Building rubble must be disposed of in line with the requirements of the NEM: WA.
Maintain daily covering of the landfill site up until final covering.
x x
ENVIROGISTICS (PTY) LTD 10/12/17
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Name of Activity
Impact Area
Potential Impacts
Mitigation Type
Performance Objectives
Goals
Timeframes Monitoring Requirements
Activities Potential Impacts
Mitigation Measures
Short Term (1-12 months)
Medium Term (1-5 years)
Long Term (5 Years +)
Throughout Life of Mine
Impacts Requiring Monitoring Programmes
Functional Requirements for Monitoring
Roles and Responsibilities
Monitoring and Reporting Frequency
Access control must be strictly enforced.
Self-succession of vegetation should establish within the first rainy season after construction has been completed.
x x
Air Quality
The area is located within the mining area and neighbouring the Village Opencast Pit. Dust emissions is not considered to be significant but can occur during excavation and construction activities.
Dust suppression should be undertaken if required [(i.e. on recommendation by the Environmental Control Officer and/or if indicated in the monitoring reports, that the current dust fall out results are increasing towards unacceptable levels (non-compliances)].
Remain within the designated area demarcated for activities. Remain within the National Environmental Management: Air Quality Act, 2004 Dust Regulation guidelines for rural communities.
Remain within the regulated guidelines and limits.
x
x Dust dispersion.
Dust dispersion will be monitored as part of the overall mine dust monitoring programme.
SHEQ Department.
Monthly Monitoring with Annual Reporting.
Noise
The area is located within the mining area and neighbouring the Village Opencast Pit. Noise impacts are not considered to be significant but
Equipment will be well maintained to reduce excessive noise creation.
Remain within the designated area demarcated for activities. Remain within the National Environmental Management: Air Quality Act,
Remain within the regulated guidelines and
limits.
x x Noise Monitoring.
Adjacent landowners will be informed of the planned dates of the significant demolition activities where applicable. Daily noise monitoring will be
SHEQ Department.
Ongoing consultation with surrounding landowners. Daily noise monitoring.
Activities will be restricted to the day time.
ENVIROGISTICS (PTY) LTD 10/12/17
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Name of Activity
Impact Area
Potential Impacts
Mitigation Type
Performance Objectives
Goals
Timeframes Monitoring Requirements
Activities Potential Impacts
Mitigation Measures
Short Term (1-12 months)
Medium Term (1-5 years)
Long Term (5 Years +)
Throughout Life of Mine
Impacts Requiring Monitoring Programmes
Functional Requirements for Monitoring
Roles and Responsibilities
Monitoring and Reporting Frequency
can occur during excavation and construction activities.
2004 Dust Regulation guidelines for rural communities.
undertaken in the areas where high levels of noise take place during decommissioning.
ENVIROGISTICS (PTY) LTD 10/12/17
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1.f.i.1.h Mechanisms for Monitoring Compliance with the Performance Assessment against the
Environmental Management Programme, including Monitoring and Reporting Frequency
Please refer to Table 65 to Table 67.
1.f.i.1.i Mechanisms for Monitoring Compliance with the Performance Assessment against the
Environmental Management Programme, including Responsible Persons
Please refer to Table 65 to Table 67.
1.f.i.1.j Mechanisms for Monitoring Compliance with the Performance Assessment against the
Environmental Management Programme, including Time Period for Implementing Impact
Management Actions
Please refer to Table 65 to Table 67.
1.f.i.1.k Mechanisms for Monitoring Compliance with the Performance Assessment against the
Environmental Management Programme, including Mechanism for Monitoring
Compliance
Please refer to Table 65 to Table 67.
1.f.i.1.l Indicate the Frequency of the Submission of the Performance Assessment/Environmental
Audit Report
Please refer to Table 65 to Table 67.
1.f.i.1.l.1 Internal Audits
Quarterly internal audits should be undertaken during the construction phase, thereafter biannual internal audit can be undertaken to ensure that the conditions of this EMP are implemented.
1.f.i.1.l.2 External Performance Assessments
During the construction and closure phases it is recommended that the independent external performance assessments be undertaken biannually.
After the construction activities have been completed, independent external performance assessments should be undertaken annually.
The external performance assessments must also include the overall mine assessment of the financial provision and EMP commitment. The report should be submitted to the DMR within 30 days of finalisation.
1.f.i.1.l.3 Other Performance Indicator Assessments
Due to the dynamic nature in which the mine is addressing the water management on site and considering the near-future projects that are planned, the following measure to ensure that performance measures are reached are recommended:
Ongoing water monitoring in terms of the monitoring protocol. Annual update of the IWWMP. Annual update of the Water Balance. Annual update of the Salt Balance.
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1.f.i.1.m Environmental Awareness Plan
The Environmental Awareness and Emergency Response Procedures as developed by Assore for the Dwarsrivier Mine will be followed.
1.f.i.1.m.1 Manner in which the Applicant intends to inform his or her Employees of any Environmental Risk which may result from their work
An Environmental Awareness and Risk Assessment Schedule have been developed and is outline in Table 68. The purpose of this schedule is to ensure that employees are not only trained but that the principles are continuously re-enforced.
Table 68: Environmental Training and Awareness Schedule
Type of Forum Frequency Time allocation Objective
Internal Management Meetings
Monthly One hour workshop A workshop session in which the following is discussed:
1. Current status of environmental compliance;
2. Environmental concerns and non-compliances recorded;
3. Weekly, monthly, quarterly, annually and 5 year mine plan;
4. Environmental risks and requirements; 5. Action plan.
Induction (all staff and workers)
Prior to first time site access, and biannually thereafter
1 hour training on environmental awareness training as part of site induction
1. Develop an understanding of what is meant by the natural environmental and social environment and establish a common language as it relates to environmental, health, safety and community aspects.
2. Establish a basic knowledge of the environmental legal framework and consequences of non-compliance.
3. Clarify the content and required actions for the implementation of the EMP.
4. Confirm the spatial extent of areas regarded as sensitive and clarify restrictions.
5. Provide a detailed understanding of the definition, the method for identification and required response to emergency incidents.
Awareness Talks (all staff and workers)
Weekly 30 minute awareness talks 1. Current status of environmental compliance;
2. Environmental concerns and non-compliances recorded;
3. Based on actual identified risks and incidents (if occurred) reinforce legal requirements, appropriate responses and measures for the adaptation of mitigation and/or management practices.
Risk Assessments (supervisor and workers involved in task)
Daily Daily task based risk assessment
1. Establish an understanding of the risks associated with a specific task and the required mitigation and management measures on a daily basis as part of daily tool box talks.
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1.f.i.1.m.2 Manner in which Risks will be dealt with in order to avoid Pollution or the Degradation of the Environment
As prescribed in Table 68 before, Task / Issue Based Risk Assessments must be undertaken with all worker involved in the specific task in order to establish an understanding of the risks associated with a specific task and the required mitigation and management measures.
Environmental emergencies occur over the short term and require an immediate response. A mine, as part of its management tools, especially if it is ISO 9000 and ISO 14001 compliant, should have an Emergency Response Plan.
This plan should be placed around the mine where it will be easily viewed. The plan should contain a list of procedures, evacuation routes and a list of emergency contact numbers. It is advisable that the mine tests the emergency response plan in order to identify any areas for improvement.
If the emergency has the potential to affect surrounding communities, they should be alerted via alarm signals or contacted in person. The surrounding community will be informed, prior to mining taking place, of the potential dangers and emergencies that exist, and the actions to be taken in such emergencies.
Communication is vital in an emergency and thus communication devices, such as mobile phones, two-way radios, pagers or telephones, must be placed around the mine.
Dwarsrivier has an Emergency Preparedness and Response Plan in place on site. This plan specifically addresses the following:
Procedures applicable to all surface areas; Procedures applicable to veldt fires; Procedures applicable to underground fires; Damage to a Radio Active source; Radioactive source and fires; Major fall of ground accidents; Major power failure; Tailings Dam collapse; Flooding in the underground workings; Labour unrest; Handling petrochemical spills; Lightning detector warning alarm within the mining area, surface and underground; Safety harness fall rescue plan; Rescue and response capability; and Management of Emergencies.
1.f.i.1.n Specific Information required by the Competent Authority
To date no specific information was required by the Competent Authority.
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2 UNDERTAKING
The EAP herewith confirms:
2.a The correctness of the Information provided in the Reports
2.b The inclusion of Comments and Inputs from Stakeholders and I&APs
2.c The inclusion of Inputs and Recommendations from the Specialist Reports where relevant
2.d That the Information provided by the EAP to I&APs and any Responses by the EAP to Comments and Inputs made by I&AP are correctly reflected herein
Signature of the Environmental Assessment Practitioner
EnviroGistics (Pty) Ltd
Name of company
Date
Undertaking by the client:
Herewith I, the person whose name and identity number is stated below, confirm that I am the person authorised to act as representative of the applicant in terms of the resolution submitted with the application, and confirm that the above report comprises EIA and EMP compiled in accordance with the guideline on the Departments official website and the directive in terms of sections 29 and 39 (5) in that regard, and the applicant undertakes to execute the Environmental management plan as proposed.
Full Names and Surname
Identity Number
Designation
Signature
Date
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Annexures
Annexure 1: DMR Acknowledgment of Receipt
Annexure 2: EAP Curriculum Vitae
Annexure 3: List of Environmental Authorisations
Annexure 4: Title Deeds
Annexure 5: Met Grade Plant Stockpile Design
Annexure 6: Leach Study Results
Annexure 7: Tree Removal Permit and Supporting Study
Dwarsrivier Chrome Mine: Basic Assessment Report and Management Plan for the Expansion of the Met Grade Chrome Stockpile and Discard Dump with Ancillary Infrastructure Mining Right Ref: 30/5/1/3/2/1(179) EM Project Ref: 21714 Version: FINAL
ANNEXURES
Annexure 1: DMR Acknowledgment of Receipt
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ANNEXURES
Annexure 2: EAP Curriculum Vitae
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ANNEXURES
Annexure 3: List of Environmental Authorisations
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ANNEXURES
Annexure 4: Title Deeds
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ANNEXURES
Annexure 5: Metallurgical Grade Stockpile Design
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ANNEXURES
Annexure 6: Leach Study Results
ENVIROGISTICS (PTY) LTD 10/12/17
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ANNEXURES
Annexure 7: Tree Removal Permit and Supporting Study
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ANNEXURES
Annexure 8: Stakeholder Consultation
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ANNEXURES
Database
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ANNEXURES
BID
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Dwarsrivier Chrome Mine: Basic Assessment Report and Management Plan for the Expansion of the Met Grade Chrome Stockpile and Discard Dump with Ancillary Infrastructure Mining Right Ref: 30/5/1/3/2/1(179) EM Project Ref: 21714 Version: FINAL
ANNEXURES
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ENVIROGISTICS (PTY) LTD 10/12/17
Dwarsrivier Chrome Mine: Basic Assessment Report and Management Plan for the Expansion of the Met Grade Chrome Stockpile and Discard Dump with Ancillary Infrastructure Mining Right Ref: 30/5/1/3/2/1(179) EM Project Ref: 21714 Version: FINAL
ANNEXURES
Annexure 9: Wetland Study
ENVIROGISTICS (PTY) LTD 10/12/17
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Annexure 10: Topsoil Management Plan
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ANNEXURES
Annexure 11: Groundwater Report (Draft)
ENVIROGISTICS (PTY) LTD 10/12/17
Dwarsrivier Chrome Mine: Basic Assessment Report and Management Plan for the Expansion of the Met Grade Chrome Stockpile and Discard Dump with Ancillary Infrastructure Mining Right Ref: 30/5/1/3/2/1(179) EM Project Ref: 21714 Version: FINAL
