Final rehabilitation, decommissioning and mine closure plan · Square Kilometre Array (SKA)...

National Research Foundation: Square Kilometre

Array (SKA) Carnarvon Stone Quarry

Final rehabilitation, decommissioning and mine closure plan

Report date: 5/23/2019

DMR Reference: (NC) 30/5/1/2/2/2041MP

Square Kilometre Array (SKA) Carnarvon Stone Quarry: Final rehabilitation, decommissioning and mine closure plan: 5/23/2019 Page | i

Final rehabilitation, decommissioning and mine

closure plan

COMPILED IN TERMS OF THE MINERAL AND PETROLEUM RESOURCE DEVELOPMENT ACT,

(ACT 28 OF 2002) (MPRDA) AND THE NATIONAL ENVIRONMENTAL MANAGEMENT ACT, 1998

(ACT NO. 107 OF 1998) REGULATIONS PERTAINING TO THE FINANCIAL PROVISION FOR

PROSPECTING, EXPLORATION, MINING OR PRODUCTION OPERATIONS (GN. NO. R. 1147, 20

NOVEMBER 2015 / GN. NO. R. 1228, 10 NOVEMBER 2017)

Name of Applicant

The National Research Foundation: Square Kilometre Array – Carnarvon Stone Quarry

Project Application for a closure certificate

Document Final Rehabilitation , Decommissioning and Mine Closure Plan

DMR Reference no.

(NC) 30/5/1/2/2/2041MP

MP16/2012

Contact Hendrik Hurter

Tel No. +27 (0)12 481 4000

E-mail [email protected]

Postal Address Box 2600

Pretoria

0001

Physical Address NRF Building

South Gate

CSIR Complex

Meiring Naudé Road

Brummeria

Pretoria

Square Kilometre Array (SKA) Carnarvon Stone Quarry: Final rehabilitation, decommissioning and mine closure plan: 5/23/2019 Page | ii

Executive summary

The international bid to construct the Square Kilometre Array (hereafter SKA) radio telescope is

between South Africa and Australia. SKA SA is a business unit of National Research Foundation

(hereafter NRF). The core site in South Africa for the SKA telescope is in the Karoo, approximately 78

km north from the town of Carnarvon in the Northern Cape.

As part of the construction of the telescope, additional infrastructure such as access roads was required.

A mining permit was obtained by the NRF SKA to mine an existing quarry situated in Erf 353,

approximately 4 km south-west of Carnarvon.

Mining of the quarry ceased in August 2016, after which the rehabilitation plan was implemented.

Subsequently, the decision was made to apply for a closure certificate in terms of Section 43 of the

Mineral and Petroleum Resources Development Act (Act No. 28 of 2002) (MPRDA). An application for

a closure certificate should be accompanied by the following, according to Regulation 57:

• A Closure plan as contemplated in Regulation 62 (this document);

• An environmental risk report according to Regulation 60 (Appendix B); and

• A final EMP performance assessment (Appendix C).

The closure vision is to rehabilitate the mining activities to such an extent that the mining area can be

fully utilised as the land use determined, in this case grazing, while the quarry will remain a wilderness

area.

The high risks identified as part of the closure planning process related to sloping and its impact on soil,

land capability and final land use. The impact is mitigated by the implementation of the rehabilitation

measures identified in the approved EMPr (Shangoni, 2011).

The following potential residual impacts have been identified in the approved EMPr (2011):

• Geology

Considering the fact that the mining of the stone goes hand-in-hand with extraction of the ore body, the

impact on the geology (mineral wise) will be permanent. The extraction of ore takes place from the

various areas as described in the mining method.

• Topography

The impact of the quarry alters the topography of that area permanently.

Although the above-mentioned residual risks are defined the post closure impact will not increase.

Once mining stops, the magnitude of the impact ceases. The geology will not continue to be altered

and the mitigation measures will address the impact on the topography by reshaping the side walls and

sloping the external walls to form a whaleback. Thus, no impact would need to be managed post

closure. No potential latent risks have been identified as part of the Environmental Impact Assessment

process (Shangoni 2011).

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Relinquishment criteria have been identified in Section 10 of this report, as a measure of indicating that

the rehabilitation criteria have been implemented. The criteria were measured in line with the final EMP

Performance Assessment (Appendix C). The site will be monitored for erosion and rehabilitation

monitoring will also be implemented by means of monitoring the establishment of vegetation as well as

the presence of alien invasive plant species.

The gaps identified as part of compilation of this closure plan relates to the following:

• The results of the Public Participation Process as part of the application for Environmental

Authorisation for closure of the quarry. This process will be conducted during June / July 2019, after

which the issues raised will be incorporated into this closure plan.

It has been concluded that the NRF / SKA demonstrates a high level of understanding towards the

various risks with management strategies in place. The rehabilitation plan addresses all actions

required to ensure the mine can be closed in line with the MPRDA requirements.

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Table of Contents

1. Details of environmental assessment practitioner .................. 1

1.1. Details of the EAP ........................................................................................ 1

1.2. Expertise of the EAP ................................................................................... 1

2. Material information and issues that have guided the

development of the plan ....................................................................... 1

2.1. Legal Requirements .................................................................................... 1

2.2. Corporate requirements .............................................................................. 2

2.3. Site specific issues ..................................................................................... 2

2.4. Closure requirements ................................................................................. 2

3. Physical context ......................................................................... 7

3.1. Project Background .................................................................................... 7

3.2. Mine locality ................................................................................................. 8

3.3. Mining description ..................................................................................... 10

3.4. Mine plan and schedule ............................................................................ 12

4. Biophysical context ................................................................. 12

5. Social context ........................................................................... 15

5.1. Socio-economic state ............................................................................... 15

5.2. Stakeholder issues that have informed the development of the plan .. 16

6. Design principles ..................................................................... 16

6.1. Closure principles informing the vision .................................................. 16

6.2. Closure vision ............................................................................................ 17

6.3. Closure objectives ..................................................................................... 17

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6.4. Closure outcomes and alternatives ......................................................... 18

6.5. Closure and post-closure period ............................................................. 18

6.6. Investigations, studies and trials ............................................................. 18

6.7. Assumptions .............................................................................................. 18

7. Environmental risk assessment.............................................. 19

7.1. Purpose and methodology ....................................................................... 19

7.2. Risk assessment findings......................................................................... 20

7.3. Residual risks ............................................................................................ 21

8. Final post-mining land use ...................................................... 22

8.1. Final land use ............................................................................................. 22

8.2. Closure criteria .......................................................................................... 23

9. Closure actions & Schedule .................................................... 24

9.1. Closure organisational structure ............................................................. 24

9.2. Closure actions .......................................................................................... 26

9.3. Closure schedule ....................................................................................... 27

10. Relinquishment criteria ........................................................... 27

11. Closure monitoring .................................................................. 31

11.1. Post-rehabilitation and- closure monitoring ........................................... 31

11.2. Auditing and reporting requirements ...................................................... 32

12. Closure cost estimate .............................................................. 32

13. Gap analysis ............................................................................. 32

13.1. Gap analysis .............................................................................................. 32

13.2. Threats, opportunities and uncertainties ................................................ 32

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14. Conclusion ............................................................................... 33

15. Disclaimer ................................................................................. 33

16. Declaration of independence .................................................. 34

Table of Figures

Figure 1: Regional setting of Mine (locality map) .............................................................................. 9

Figure 2: Carnarvon Stone Quarry disturbed area .......................................................................... 11

Figure 3: Summary of mining phases and closure process ........................................................... 18

Figure 4: Impact prediction model .................................................................................................... 19

Figure 5: Land use map ...................................................................................................................... 22

List of Tables

Table 1: EAP expertise ......................................................................................................................... 1

Table 2: Contents of a Closure Plan in terms of NEMA and the MPRDA ........................................ 2

Table 3: Administrative boundaries .................................................................................................... 8

Table 4: Environmental context ......................................................................................................... 12

Table 5: Risk rating matrix ................................................................................................................. 20

Table 6: Sensitive indicators ............................................................................................................. 21

Table 7: Closure criteria ..................................................................................................................... 23

Table 8: Closure organisational structure ........................................................................................ 24

Table 9: Closure success criteria ...................................................................................................... 28

Table 13: Closure gap analysis ......................................................................................................... 32

Table 14: Threats and opportunities identified ................................................................................ 32

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List of appendices

Appendix A – Legislative background

Appendix B – Risk assessment

Appendix C – Final Environmental Performance Assessment report

References

African Heritage Consultants. 2011. Cultural Heritage Resources Impact Assessment for Proposed

Mining of Gravel and Concrete Stone on a number of locations near Carnarvon, Northern Cape

Province. February 2011.

Mucina, L. and Rutherford M.C. 2006: The Vegetation of South Africa, Lesotho and Swaziland. Strelitzia

19, South African National Biodiversity Institute, Pretoria.

Shangoni Management Services. 2011. Environmental Management Programme: SKA SA (Stone

Quarries). May 2011.

Shangoni Management Services, 2015. Rehabilitation Strategy. July 2015.

Shangoni Management Services, 2019. Environmental Audit Report of Environmental Management

Programme. April 2019.

Statistics South Africa. 2016. Community Survey 2016 Provincial Profile: Northern Cape Province.

Published by Statistics South Africa, Private Bag X44, Pretoria, 0001. Report number 03-01-14. 121pp.

ISBN: 978-0-621-44986-0

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Definitions

Term Description

Concurrent rehabilitation Rehabilitation that occurs during the process of mining as the ore body is mined out in parts of a mine.

Decommissioning Take out of active service permanently or dismantle partly or wholly, or closure of a facility to the extent that it cannot be readily re-commissioned.

Decommissioning cost

Costs associated with dismantling of assets i.e. those closure costs that have an underlying asset such as a beneficiation plant or slimes dam that has a capital value (indicated on the asset register whether written off or not)

Environment

The surroundings (biophysical, social and economic) within which humans exist and that are made up of:

the land, water and atmosphere of the earth;

micro-organisms, plant and animal life;

any part or combination of (i) and (ii) and the interrelationships among and between them; and

the physical, chemical, aesthetic and cultural properties and conditions of the foregoing that influence human health and wellbeing.

Environmental Aspects Elements of an organisation’s activities, products or services that can interact with the environment.

Environmental Impacts Any change to the environment, whether adverse or beneficial, wholly or partially resulting from an organisation’s activities, products or services.

Environmental Impact Assessment

A study of the environmental consequences of a proposed course of action.

Final Rehabilitation only those rehabilitation activities that are technically impossible to execute and complete as part of the day to day operations during the active life of such operation, life of the mine or life of the project and which can only take place after such operations have ceased

Financial Provision

Financial provision means the insurance, bank guarantee, trust fund or cash that applicants for an environmental authorisation must provide in terms NEMA, guaranteeing the availability of sufficient funds to undertake the-

rehabilitation of the adverse environmental impacts of the listed or specified activities;

rehabilitation of the impacts of the prospecting, exploration, mining or production activities, including the pumping and treatment of polluted or extraneous water;

decommissioning and closure of the operations;

remediation of latent or residual environmental impacts which become known in the future;

removal of building structures and other objects; or

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Term Description

remediation of any other negative environmental impacts.

Interested and affected parties (IAPs)

A person or an association of persons with a direct interest in a proposed development or existing operation, or who may be affected by such a proposed development or existing operation.

Land use The various ways in which land may be employed or occupied.

Latent environmental impact

Means any environmental impact that may result from natural events or disasters after a closure certificate has been issued.

Local community The communities that live within the same local municipality as that in which the mine is located

Mine Closure

This entails the process of decommissioning and rehabilitation at the end of a mine’s life leading to the issue of a closure certificate in terms of section 12 of the Minerals Act 21 or in terms of section 43 of the MPRDA.

Mine closure certificate

The holder of a prospecting right, mining right, retention permit or mining permit must apply to the Regional Manager for a closure certificate within 180 days of the occurrence of closure. No closure certificate will be issued unless the Chief Inspector and the Department of Water Affairs and Sanitation have confirmed in writing that the provisions relating to health and safety and management of potential pollution to water resources have been addressed.

Mitigate Practical measures that are implemented to reduce or avoid negative effects or enhance positive effects of a development action.

Public Participation Process

A process of involving the public in order to identify needs and address concerns, in order to contribute to more informed decision-making relating to a proposed project, programme or development.

Public sector All government related departments and institutions at national, provincial and local levels.

Rehabilitation The process of reshaping and re-vegetating land to restore it to a stable condition with a land-use that is appropriate for the particular location and is not associated with any pollution issues such as water pollution.

Rehabilitation plan Plan describing and detailing the concrete actions that are required to adequately mitigate environmental impacts and achieve rehabilitation outcomes.

Rehabilitation cost All other costs (those not included in the above definition such as re-sloping and surface rehabilitation)

Residual environmental impact

Means the environmental impact remaining after a closure certificate has been issued.

Reshaping Reshape the topography to serve a landscape function.

Revegetation Re-establish vegetation cover.

Significance A subjective judgement of the importance of an impact to an interested or affected party.

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Term Description

Topography Topography, a term in geography, refers to the "lay of the land” or the physio-geographic characteristics of land in terms of elevation, slope and orientation.

Vegetation All of the plants growing in and characterising a specific area or region; the combination of different plant communities found there.

Waste

As per the definition of the National Environmental Management: Waste Amendment Act, 2014 - means

any substance, material or object, that is unwanted, rejected, abandoned, discarded or disposed of, or that is intended or required to be discarded or disposed of, by the holder of that substance, material or object, whether or not such substance, material or object can be re-used, recycled or recovered and includes all wastes as defined in Schedule 3 to the Act; or

any other substance, material or object that is not included in Schedule 3 that may be defined as a waste by the Minister by notice in the Gazette, but any waste or portion of waste, referred to in paragraphs (a) and (b), ceases to be a waste:

once an application for its re-use, recycling or recovery has been approved or, after such approval, once it is, or has been re-used, recycled or recovered;

where approval is not required, once a waste is, or has been re-used, recycled or recovered;

where the Minister has, in terms of section 74, exempted any waste or a portion of waste generated by a particular process from the definition of waste; or

(where the Minister has, in the prescribed manner, excluded any waste stream or a portion of a waste stream from the definition of waste.

Abbreviations

DMR The Department of Mineral Resources

EAP Environmental Assessment Practitioner

ECA Environmental Conservation Act

ECO Environmental Control Officer

EIA Environmental Impact Assessment

EMPr Environmental Management Programme Report

I&APs Interested and Affected Parties

GN Government Notice

LM Local Municipality

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MPRDA Mineral and Petroleum Resources Development Act

NEMA National Environmental Management Act

NRF National Research Foundation

NWA National Water Act

PPP Public Participation Process

SKA Square Kilometre Array

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1. Details of environmental assessment practitioner

1.1. Details of the EAP

Name of the Practitioner: Shangoni Management Services: Jan Nel / Emma Fourie

Tel No.: (012) 807 7036

Fax No.: (012) 807 1014

E-mail address: [email protected]

1.2. Expertise of the EAP

Table 1: EAP expertise

Name Qualifications Summary of experience

Jan Nel M.Sc. Environmental Management (UFS)

Jan Nel has been actively involved for the past 16 years in environmental management within the mining industry, helping with EMP Compliance, Environmental Impact Assessments (EIA), Financial Provision Calculations, Closure Plans, Rehabilitation Plans, Environmental Management Programme Reports (EMP) and EMP Performance Assessments. Jan is the Technical Director: Rehabilitation and Closure at Shangoni.

Emma Fourie

B.Sc. (Hons): Geography and Environmental Management

Emma obtained a B.Sc. Hons degree in Environmental Management from the University of North West (Potchefstroom). She gained international exposure through participation in Finnish and Russian environmental management courses and conferences in 2010 and is a current member of the Land Rehabilitation Society of Southern Africa (LaRSSA). Emma has been an Environmental Practitioner at Shangoni since 2011, where she is Lead of the Mine Closure and Rehabilitation Department, specialising in the compilation of Closure Plans, Rehabilitation Plans and Financial Provision calculations. She also has experience in Environmental Impact Assessment (EIA), Environmental Management Programme (EMP) compilation and EMP Performance Assessments.

2. Material information and issues that have guided the development of the plan

2.1. Legal Requirements

The controlling legislation is the National Environmental Management Act (Act No. 107 of 998) (NEMA)

and its regulations in which the closure process is prescribed. However, many compliance

requirements originate from the Mineral and Petroleum Resources Development Act (Act No. 28 of

2002) (MPRDA) and the National Water Act (Act No. 36 of 1998) (NWA). The Environmental


Conservation Act (Act No. 73 of 1989) (ECA) has limited application to mines and is applicable mainly

in terms of disposal of hazardous wastes. The interaction between various Acts of parliament that deal

with the environment is varied and complex, as is the range of environmental issues that are regulated.

This discussion is limited to those aspects considered most directly related to this closure cost

assessment and is by no means a complete summary of all applicable environmental legislation nor is

it a compliance register. A full legislative background to this rehabilitation, decommissioning and closure

plan has been attached as Appendix A.

2.2. Corporate requirements

The National Research Foundation (NRF) receives its mandate from the National Research Foundation

Act (Act No 23 of 1998). According to Section 3 of the Act, the objective of the NRF is to:

promote and support research through funding, human resource development and the provision of the

necessary facilities in order to facilitate the creation of knowledge, innovation and development in all

fields of research, including indigenous knowledge, and thereby to contribute to the improvement of the

quality of life of all the people of the Republic.

2.3. Site specific issues

Based on the understanding of the current state of the environment, identified pressures and associated

impacts/challenges, the following aspects are considered as being key for the Carnarvon Stone

Quarry’s closure planning:

• The original quarry and the property are owned by the Kareeberg Local Municipality. There

are still material stockpiles on site that will be used for road construction by the municipality in

the future. The municipality also indicated that the quarry may be mined in the future.

2.4. Closure requirements

Appendix 4 of the Financial Provision Regulations, 2015 under the NEMA, 1998, lists aspects that must

be included in Closure Plans, while Regulation 62 of the MPRDA (2002) stipulates the minimum

contents of a closure plan. Table 8 indicates the sections where the required information has been

provided as part of this Closure Plan:

Table 2: Contents of a Closure Plan in terms of NEMA and the MPRDA

NEMA requirement (EIA Regs. & GN 1147) MPRDA requirement (Reg. 62)

Section in Final Closure Plan

(a) details of─

(i) the person or persons that prepared the plan;

(ii) the professional registrations and experience of the preparers;

Section 1

(b) the context of the project, including─ Section 2




(i) material information and issues that have guided the development of the plan;

(ii) an overview of—

(aa) the environmental context, including but not limited to air quality, quantity and quality of surface and groundwater, land, soils and biodiversity; and

Section 4

(bb) the social context that may influence closure activities and post-mining land use or be influenced by closure activities and post-mining land use;

Section 5.1

(iii) stakeholder issues and comments that have informed the plan;

(j) a record of interested and affected persons consulted; and

Section 5.2

(iv) the mine plan and schedule for the full approved operations, and must include─

(aa) appropriate description of the mine plan;

(bb) drawings and figures to indicate how the mine develops;

(cc) what areas are disturbed; and

(dd) how infrastructure and structures (including ponds, residue stockpiles etc.) develops during operations;

(b) a plan contemplated in regulation 2(2), showing the land or area under closure;

Section 3

(c) findings of an environmental risk assessment leading to the most appropriate closure strategy, including─

(i) a description of the risk assessment methodology including risk identification and quantification, to be undertaken for all areas of infrastructure or activity or aspects for which a holder of a right or permit has a responsibility to mitigate an impact or risk at closure;

(ii) an identification of indicators that are most sensitive to potential risks and the monitoring of such risks with a view to informing rehabilitation and remediation activities;

(iii) an identification of conceptual closure strategies to avoid, manage and mitigate the impacts and risks;

(iv) a reassessment of the risks to determine whether, after the implementation of the closure strategy, the residual risk has been avoided and / or how it has resulted in avoidance, rehabilitation and management

(d) a summary of the results of the environmental risk report and details of identified residual and latent impacts;

Section 7




of impacts and whether this is acceptable to the mining operation and stakeholders; and

(v) an explanation of changes to the risk assessment results, as applicable in annual updates to the plan;

(d) design principles, including─

(i) the legal and governance framework and interpretation of these requirements for the closure design principles;

(ii) closure vision, objectives and targets, which objectives and targets must reflect the local environmental and socio-economic context and reflect regulatory and corporate requirements and stakeholder expectations;

(iii) a description and evaluation of alternative closure and post closure options where these exist that are practicable within the socioeconomic and environmental opportunities and constraints in which the operation is located;

(iv) a motivation for the preferred closure action within the context of the risks and impacts that are being mitigated;

(v) a definition and motivation of the closure and post closure period, taking cognisance of the probable need to implement post closure monitoring and maintenance for a period sufficient to demonstrate that relinquishment criteria have been achieved;

(vi) details associated with any on-going research on closure options;

(vii) a detailed description of the assumptions made to develop closure actions in the absence of detailed knowledge on site conditions, potential impacts, material availability, stakeholder requirements and other factors for which information is lacking;

(a) a description of the closure objectives and how these relate to the prospecting or mine operation and its environmental and social setting;

(c) a summary of the regulatory requirements and conditions for closure negotiated and documented in the environmental management programme or environmental management plan, as the case may be;

Section 2

Section 6

(e) a proposed final post-mining land use which is appropriate, feasible and possible of implementation, including─

(i) descriptions of appropriate and feasible final post-mining land use for the overall project and per infrastructure or activity and a description of the methodology used to identify final post-mining land use, including the requirements of the operations stakeholders;

(i) a sketch plan drawn on an appropriate scale describing the final and future land use proposal and arrangements for the site;

Section 8




(ii) a map of the proposed final post-mining land use;

(f) closure actions, including─

(i) the development and documenting of a description of specific technical solutions related to infrastructure and facilities for the preferred closure option or options, which must include all areas, infrastructure, activities and aspects both within the mine lease area and off of the mine lease area associated with mining for which the mine has the responsibility to implement closure actions;

(ii) the development and maintenance of a list and assessment of threats and opportunities and any uncertainties associated with the preferred closure option, which list will be used to identify and define any additional work that is needed to reduce the level of uncertainty;

(f) a description of the methods to decommission each prospecting or mining component and the mitigation or management strategy proposed to avoid, minimize and manage residual or latent impacts;

Section 9.2

(g) a schedule of actions for final rehabilitation, decommissioning and closure which will ensure avoidance, rehabilitation, management of impacts including pumping and treatment of extraneous water ─

(i) linked to the mine works programme, if greenfields, or to the current mine plan, if brownfields;

(ii) including assumptions and schedule drivers; and

(iii) including a spatial map or schedule, showing planned spatial progression throughout operations;

(e) a summary of the results of progressive rehabilitation undertaken;

Section 9.3

(h) an indication of the organisational capacity that will be put in place to implement the plan, including─

(i) organisational structure as it pertains to the plan;

(ii) responsibilities;

(iii) training and capacity building that may be required to build closure competence;

Section 9.1

(i) an indication of gaps in the plan, including an auditable action plan and schedule to address the gaps;

Section 13




(j) relinquishment criteria for each activity or infrastructure in relation to environmental aspects with auditable indicators;

Section 10

(k) closure cost estimation procedure, which ensures that identified rehabilitation, decommissioning, closure and post-closure costs, whether on-going or once-off, are realistically estimated and incorporated into the estimate, on condition that─

(i) cost estimates for operations, or components of operations that are more than 30 years from closure will be prepared as conceptual estimates with an accuracy of ± 50 percent. Cost estimates will have an accuracy of ± 70 percent for operations, or components of operations, 30 or less years (but more than ten years) from closure and ± 80 percent for operations, or components of operations ten or less years (but more than five years) from closure. Operations with 5 or less years will have an accuracy of ± 90 percent. Motivation must be provided to indicate the accuracy in the reported number and as accuracy improves, what actions resulted in an improvement in accuracy;

(ii) the closure cost estimation must include—

(aa) an explanation of the closure cost methodology;

(bb) auditable calculations of costs per activity or infrastructure;

(cc) cost assumptions;

(iii) the closure cost estimate must be updated annually during the operation’s life to reflect known developments, including changes from the annual review of the closure strategy assumptions and inputs, scope changes, the effect of a further year’s inflation, new regulatory requirements and any other material developments; and

(h) details of a proposed closure cost and financial provision for monitoring, maintenance and post closure management;

Section 12

(l) monitoring, auditing and reporting requirements which relate to the risk assessment, legal requirements and knowledge gaps as a minimum and must include─

(i) a schedule outlining internal, external and legislated audits of the plan for the year, including─

(g) details of any long-term management and maintenance expected;

Section 11




(aa) the person responsible for undertaking the audit(s);

(bb) the planned date of audit and frequency of audit;

(cc) an explanation of the approach that will be taken to address and close out audit results and schedule;

(ii) a schedule of reporting requirements providing an outline of internal and external reporting, including disclosure of updates of the plan to stakeholders;

(iii) a monitoring plan which outlines─

(aa) parameters to be monitored, frequency of monitoring and period of monitoring;

(bb) an explanation of the approach that will be taken to analyse monitoring results and how these results will be used to inform adaptive or corrective management and/or risk reduction activities; and

(m) motivations for any amendments made to the final rehabilitation, decommissioning and mine closure plan, given the monitoring results in the previous auditing period and the identification of gaps as per 2(i).

Section 14

(k) technical appendices, if any.

See appendices

3. Physical context

3.1. Project Background

Shangoni Management Services (Pty) Ltd was appointed by the NRF to conduct the process pertaining

to an application for a closure certificate for the Carnarvon Quarry. The project entails the compilation

of closure documentation per the requirements of the NEMA and the MPRDA.

This document was drawn up after a comprehensive review of all relevant information supplied by the

NRF, focussing on fulfilling the requirements of the NEMA and MPRDA. The process followed focussed

on identifying the risks related to decommissioning, closure and the post closure phase of the stone

quarry. The main focus of the document lies in the rehabilitation and closure execution plan that

provides information on actions required to work towards closure of the stone quarry.

South Africa and Australia have been chosen as the two sites to host the Square Kilometre Array

(hereafter SKA) radio telescope project. Square Kilometre Array South Africa (SKA SA) is a business

unit of the NRF and the NRF is an agency of the Department of Science and Technology. The core site


in South Africa for the SKA is in the Karoo, approximately 80 km North West from the town of Carnarvon

in the Northern Cape.

As part of the construction of the SKA and associated infrastructure, the NRF acquired a mining permit

to mine an existing municipal stone quarry to obtain material for road construction (Permit number

MP16/2012, Office reference number (NC) 30/5/1/3/2/1/2041MP).

3.2. Mine locality

The Carnarvon Stone Quarry is situated within the administrative boundaries as presented in Table 3.

Table 3: Administrative boundaries

Farm Name Erf 353

Province Northern Cape

District Municipality Pixley Ka Seme District Municipality

Local Municipality Kareeberg Local Municipality

Ward Ward 1

Department of Mineral Resources (“DMR”) Local Office

Kimberley

Department of Water and Sanitation (“DWS”) Local Office

Kimberley

Department of Environmental Affairs Local Office

Northern Cape Environmental Affairs and Nature Conservation - Kimberley

Catchment Zone D54B Quaternary Catchment

Water Management Area Lower Orange Water Management Area

The quarry locality is included in Figure 1 below.


Figure 1: Regional setting of Mine (locality map)


3.3. Mining description

The Quarry is located on a dolerite sill that forms a dome-shaped ridge with minimal overburden (less

than 1 m thick) to the west of the Tiervlei road about 4 km outside Carnarvon and extends across the

road in an easterly direction. The major part of the dolerite ridge is located on municipal ground of

Carnarvon. A small quarry operation has been opened in the past at this location to the west of the

road.

The already existing Carnarvon Municipal Stone Quarry is located on land owned by the Kareeberg

Local Municipality. Mining of the stone quarry was done by means of drilling the rock, blasting, loading,

transporting and crushing. The product was transported by trucks between the quarry and the on-site

mobile crusher for crushing and screening. It should be noted that the contractor’s and material laydown

area was never included within the permit area, but was an area leased by SKA from the municipality

for the use as a stockpile area. This stockpile area is still being used by the municipality for the

stockpiling of their roadbuilding materials used during their road rehabilitation works in the municipal

area on an ongoing basis.

Mining of the quarry ceased in August 2016, with rehabilitation completed in October 2016.


Figure 2: Carnarvon Stone Quarry disturbed area


3.4. Mine plan and schedule

Mining of the quarry ceased in August 2016. Below is a description of the rehabilitation phases.

• Phase 1: Concurrent rehabilitation – rehabilitation that takes place during the mining operation i.e.

removal of redundant equipment, demolition of redundant structures and rehabilitation of available

mining areas.

• Phase 2: Rehabilitation during decommissioning of mining operations – once mining operations

have ceased rehabilitation activities take place during the decommissioning of the mining operation.

These activities mainly relate to demolition of remaining infrastructure, removal of movable

structures, sloping, contouring, benching, re-vegetation and maintenance of existing rehabilitated

areas.

• Phase 3: Post closure monitoring and maintenance – monitoring and maintenance of rehabilitated

areas.

4. Biophysical context

This section aims to provide context of the environmental and social status of the region in which the

Carnarvon quarry is situated, in order to establish an overall idea of the current situation of the mining

area, leading to reasoning behind the proposed end land use for the mine. The information in this

section was obtained from the approved Environmental Management Programme (Shangoni, 2011).

Table 4: Environmental context

Aspect Context

Geology

The regional geology is comprised of shales, mudstones and sandstone of the

Tierberg and the Carnarvon Formations that form part of the Ecca Group of

the Karoo Supergroup.

There are igneous dolerite dykes and sills that cover the extensive area which

intrude into both the Tierberg Formation and the Carnarvon Formation rocks.

Extensive outcrops of dolerite also occur in the immediate vicinity of

Carnarvon and along the R361 road from Carnarvon to Van Wyksvlei.

The quarry is located on a dolerite sill that forms a dome-shaped ridge with

minimal overburden (less than 1 m thick) to the west of the Tiervlei road, about

4 km outside Carnarvon and extends across the road in an easterly direction.

Dark grey, closely jointed, moderately weathered hard rock dolerite is located

up to a depth of 1 m on the site. Widely jointed dolerite (hard rock) is located

below this layer up to depths of 10 m. Sandstone layers overlay the dolerite to

the west and southwest of this area. Light grey sandstone is also encountered

on the site. This layer is moderate to slightly weathered, with close to medium


Aspect Context

spaced joints. Dark grey dolerite, which is widely jointed, underlies the

sandstone in these areas and extends to depth of 10 m below the present

surface level. The thickness of the sandstone that overlies the dolerite in the

south west and west of this area is expected to increase in a westerly direction.

Soil

The quarry is situated on a soil type classified as Type R. This indicates the

presence of rocks with limited soils. This quarry has a very low water holding

capacity of less than 20mm. The limited soils are strongly dominated by loamy

sands and are moderately susceptible to wind erosion. The area is covered

by less than 15% clay soils. The clay soils have a low to moderate swelling

capacity. Soils are non-calcareous. The stone quarry does not have saline

soils. It is not structurally favourable for arable farming nor does it have

beneficial water retaining layers. Organic carbon content for the site is very

low (less than 0,5mm). The site has a natural pH of 7.5 to 8.4. The soil is not

susceptible to acidification.

Surface water

The quarry is situated in the D54B Quaternary Catchment area which falls

within the Lower Orange Water Management Area, which forms part of the

Orange River Primary Catchment and the Orange/ Vaal Drainage Region.

Run-off from the Orange Primary Catchment is 1 008 to 7 194 ×106 m3. Run-

off from the Quaternary Catchment is 42 to 84 ×106 m3.

The abstraction of water resources in the Orange sub-WMA is used primarily

for irrigation and livestock feeding.

Groundwater

The depth of the water table around the site is generally around 12 – 20 m.

Although there are a number of boreholes in the area where the water table is

less than 5 m below the surface.

Groundwater utilisation is of major importance across wide areas and often

constitutes the only source of water. It is mainly used for rural domestic

supplies, stock watering and water supplies to towns. As a result of the low

rainfall, recharge of groundwater is limited, and only small quantities can be

abstracted on a sustainable basis. Artificial recharge of groundwater is

practised in some areas where water from small dams is transferred through

pipelines.

Topography The quarry is situated on a morphological unit described as “lowlands with

hills”. The slope index of 6 – 12 % is moderately high.


Aspect Context

Climate

The study area falls within a semi-arid region with very little summer rainfall.

The area experiences typical desert like conditions with extreme temperatures

experienced between day and night as well as summer and winter. Summers

are typically hot and dry, whereas winters are icy and dry with dew and frost

typical during the night.

Carnarvon normally receives approximately 102 mm of rain per year, with

most rainfall occurring mainly during autumn. It receives the lowest rainfall (0

mm) in September and the highest (30 mm) in March. Within approximately

20 years from 1961 to 1990, the area experienced between 2 to 7 days of

rainfall greater or equal to 1 mm per month, with the winter months

experiencing the greatest number of days.

The monthly distribution of average daily maximum temperatures shows that

the average midday temperatures for Carnarvon range from 15.3°C in June to

30.8°C in January. The highest recorded temperature is at 41° C during

February and -7C during June (Data recorded from 1961 to 1990 taken from

Environmental Impact Assessment Report for Proposed Karoo Array

Telescope (MeerKAT) Project on Farms Losberg (73) and Mey’s Dam (68)

near Carnarvon in the Northern Cape).

Detailed analysis of the weather records gathered from 1961 to 1990 at the

nearby weather station at Calvinia, reveal that the annual evaporation rate is

approximately 2 300 mm per annum and frost occurs from April to October.

Flora

The site lies mainly in the general area that supports Bushmanland Basin

Shrubland, according to the new vegetation map of South Africa (Mucina and

Rutherford, 2003). It is dominate by Stipagrostis grass species, surrounded by

homogeneous vegetation impacted on by the already existing stone quarry.

Some of the vegetation species identified on the proposed stone quarry sites

during the surveys include:

Stipagrostis spp;

Aloe spp;

Ganzania krebsiana;

Pentzia incana;

Sutera atropurpurea;

Selago albida;

Sutera virgulosa;

Walafrida geniculata;


Aspect Context

Lightfootia nodosa; and

Tribulus terrestris (invader plant).

The vegetation type at the site is listed as Not Threatened in the South African

National Spatial Biodiversity Assessment (Rouget et al, 2004).

Fauna

Approximately thirty-eight (38) reptiles and eight (8) amphibian species likely

to inhabit the area. During a survey, the following reptiles were observed on

site:

Trachylepis capensis (Cape Skink);

Trachylepis varia (Variable Skink).

The only Red Listed reptile species which may occur within the study area is

the Fisk’s House Snake (Lamprophis fiskii). This species is listed as

vulnerable in the IUCN (2001). No amphibian species were observed on any

of the sites during the surveys. No Red Listed amphibian species are known

to occur in the area of the quarry.

5. Social context

5.1. Socio-economic state

The information presented in this section was taken from the document titled: Community Survey 2016

provincial Profile: Northern Cape, compiled by Statistics South Africa, dated 2016.

The Northern Cape is the largest province in terms of land size and the least densely populated province

in South Africa. The province was formed on 27 April 1994 after the split from the Cape Province. It is

demarcated into five districts and twenty-six local municipalities. The province shares borders with four

other provinces, namely Western Cape, Eastern Cape, Free State and North West. It also shares

borders with the states of Namibia and Botswana, respectively. The Orange River flows through this

province and it forms borders with the Free State and Namibia. The capital of the Northern Cape is

Kimberley.

The Pixley Ka Seme District Municipality had a population of 195 595 n 2016, growing by 1.1% since

the 2011 census. Distribution by population group indicates that 63.4% of the population in the District

Municipality is of the coloured population, 30% black African, 6.3% white and 0.4% Indian or Asian.

The Kareeberg Local Municipality population stood at 12 772 in 2016. The age distribution in the

Kareeberg LM shows that the majority if the population (36.3%) is between the ages of 15 – 34, with

the age bracket 35 – 64 at second highest at 32.6%.

In terms of education, 33.4% of the persons aged 20 years or older in the Kareeberg LM indicated that

they had incomplete secondary education, while 19.7% have completed secondary education, 18.6%


have incomplete primary education, 14.8% have had no schooling, 11.3% have completed primary

education and only 2.2% have a post matric certificate or higher education.

The average household size in Kareeberg LM is 3.5 persons per household. 94.2% of the population

in the Kareeberg LM live in a formal dwelling, of which 39.4% is government subsidised or

Reconstruction and Development Programme (RDP) housing.

97% of the population of the Kareeberg LM has access to safe drinking water, of which 47% has piped

(tap) water inside the dwelling, 36.2% has piped water inside the yard, 12.1% uses borehole water and

the rest utilise other sources such as a neighbour’s tap or rainwater tanks. 87.2% of the total population

within the municipality receives municipal tap water.

According to the CS 2016, 29.8% of the Kareeberg LM households ran out of money to buy food in the

12 months preceding the survey.

At least one member of 2% of the Kareeberg LM households experienced crime in the 12 months

preceding the survey. 97.8% of household members within the LM felt safe when walking alone during

the day, while 81.1% felt safe walking alone in the dark.

According to the 2011 census (StasSA), there are 3 810 people that are economically active in the

Kareeberg LM (employed or unemployed but looking for work), and of these, 25% are unemployed. Of

the 1 631 economically active youth (15–34 years) in the area, 32,1% are unemployed.

5.2. Stakeholder issues that have informed the development of the plan

Consultation with interested and affected parties is scheduled for June 2019 as part of the application

for Environmental Authorisation for decommissioning and a closure certificate. This report will be

updated with the outcome of the consultation process.

6. Design principles

Final closure is defined as the condition whereby the rehabilitated land has reached such stability that

the regulators and the interested communities are satisfied that the land will not pose a significant

additional risk into the long-term future (COM & Coaltech, 2007). The closure vision is specific to the

site/company and it is intended to inform the closure objectives.

6.1. Closure principles informing the vision

The mine closure principles that should be considered in governing the closure process are derived

from the mine closure policy of the Department of Minerals Resources, namely:

• The safety and health of humans and animals are safeguarded from hazards resulting from mining

operations.


• Environmental damage or residual environmental impacts are minimised to such an extent that it is

acceptable to all involved parties.

• The land is rehabilitated to, as far as is practicable, it’s natural state, or to a predetermined and

agreed standard or land use which conforms to the concept of sustainable development.

• The physical and chemical stability of the remaining structures should be such that risk to the

environment is not increased by naturally occurring forces to the extent that such increased risk

cannot be contended with by the installed measures.

• The optimal exploitation and utilisation of South Africa's mineral resources are not adversely

affected.

• Mines are closed efficiently and cost effectively.

• Mines are not abandoned but closed in accordance with this policy.

The following principles were defined in support of the closure vision and applied in the development of

closure success criteria:

• Identified risks (Safety, Health, Environment and social) will be mitigated to acceptable levels;

• Rehabilitation objectives need to be achieved;

• Post closure remnants must confirm to the concept of sustainability; and

• Contribute to local economic development and manage direct socio-economic impact.

6.2. Closure vision

The closure vision is to rehabilitate the mining activities to such an extent that the mining area can be

fully utilised as the land use determined, in this case grazing, while the quarry itself will remain a

wilderness area.

6.3. Closure objectives

The closure objectives as derived from the EMPr compiled in 2011 read as follows:

• The following activities form part of the rehabilitation of the area:

o Sloping the excavated areas. Surface topography should emulate the surrounding areas and

be aligned to the general landscape character.

o Levelling of disturbed areas. Landscaping should facilitate surface runoff and result in free

draining areas.

o Covering disturbed areas with stockpiled topsoil (or imported topsoil should there be need to

do so).

o Preparation of the soil for rehabilitation (for example, by adding fertilizer/ compost and

manure).

o Re-vegetation of the area.


6.4. Closure outcomes and alternatives

The international bid to construct the SKA radio telescope is between South Africa and Australia.

Cabinet has declared the SKA project as a project of national and international importance. The core

site for the SKA project is in the Karoo, approximately 74km from the town of Carnarvon. This

construction included internal gravel roads, new buildings, and antenna foundations, provisions for grid

and backup power and optic fibre network.

The main closure outcome is to make the quarry area safe for animals to return and utilise the area for

grazing. Since the old quarry and the property belongs to the Kareeberg LM, the potential exists that

the quarry may be utilised for future road construction. Subsequently, no alternatives have been

considered.

6.5. Closure and post-closure period

Figures 3 illustrates the process that the mine will follow to decommission and rehabilitate its activities.

Figure 3: Summary of mining phases and closure process

6.6. Investigations, studies and trials

No further studies have been recommended during the compilation of this closure plan.

6.7. Assumptions

This closure plan has been developed based on available information including environmental data.

The assumptions used to prepare this plan include the following:

• Mining has ceased in August 2016, but the quarry will remain for potential future use.

• The quarry walls have been sloped where possible.

• The rehabilitation plan per the EMPr (2011) has been implemented.

Operational (Concurrent

rehabilitation) Cessation of mining

MPRDA (180 days) and NEMA process

start

Decommissioning (Demolition of

infrastructure and final rehabilitation)

Application for closure certificate

Closure certificate Mine ceases to exist


7. Environmental risk assessment

7.1. Purpose and methodology

The scope of the risk assessment includes all decommissioning and post closure activities, to determine

the level of residual and latent risks, as well as risks during operation of decommissioning / demolition

and rehabilitation activities

The environmental risk of any aspect is determined by a combination of parameters associated with

the impact. Each parameter connects the physical characteristics of an impact to a quantifiable value

to rate the environmental risk.

Impact assessments should be conducted based on a methodology that includes the following:

• Clear processes for impact identification, predication and evaluation.

• Specification of the impact identification techniques.

• Criteria to evaluate the significance of impacts.

• Design of mitigation measures to lessen impacts.

• Definition of the different types of impacts (indirect, direct or cumulative).

• Specification of uncertainties.

After all impacts have been identified, the nature and scale of each impact can be predicted. The impact

prediction will consider physical, biological, socio-economic and cultural information and will then

estimate the likely parameters and characteristics of the impacts. The impact prediction will aim to

provide a basis from which the significance of each impact can be determined, and appropriate

mitigation measures can be developed.

The risk assessment methodology is based on defining and understanding the three basic components

of the risk, i.e. the source of the risk, the pathway and the target that experiences the risk (receptor).

Refer to the Figure 4 for a model representing the above principle (as contained in the DWAF’s (now

DWS) Best Practice Guideline: G4 – Impact Prediction).

Figure 4: Impact prediction model


Ratings of the risk was done according to the risk matrix defined in Table 5. The risk rating is based on

the probability of the impact occurring versus the possible magnitude of the impact if it should occur.

The probability of the impact is measured by looking at the average frequency of the aspects, the

availability of the pathway to the receptor and the availability of the receptor. The magnitude of the

impact is based on an average score calculated between the following aspects:

• Duration of the impact;

• Extent of the impact;

• Volume, quantity or intensity;

• Toxicity or destruction effect;

• Reversibility of the impacts; and the

• Sensitivity of the environmental component.

Table 5: Risk rating matrix

Environmental Impact Rating / Priority

MAGNITUDE

PROBABILITY 1

Minor

2

Low

3

Medium

4

High

5

Major

5

Almost Certain Low Medium High High High

4

Likely Low Medium High High High

3

Possible Low Medium Medium High High

2

Unlikely Low Low Medium Medium High

1

Rare Low Low Low Medium Medium

The probability rating shall consider existing controls or mitigation measures. Controls can reduce the

probability of an unwanted event occurring by acting on the occurrence of the hazard release and/or on

the exposure to such hazard release. When considering controls there must be recognition of the quality

of those controls (position in the hierarchy) and their real status/ application. In other words, if controls

are weak by design or application, probability is higher.

7.2. Risk assessment findings

The following section provides a summary of the indicators that are most sensitive to potential risks.

These indicators were abstracted from the high risks identified during the environmental risk


assessment conducted for the mine. The risks envisaged can be managed to ensure an acceptable

end land use. Where a level of uncertainty exists, these risks have been rated as high. Refer Table 6

for the existing sensitive environmental indicators.

Table 6: Sensitive indicators

Environmental component

Impact

Maximum risk rank (before mitigation)

Mitigation (including monitoring)

Maximum risk rank (after mitigation)

Soils Sloping using topsoil

High The general guideline is to regrade spoiled areas to approximate contours and to ensure that the rehabilitated topography links seamlessly to the surrounding topography. Whaleback tops have been established on the side slopes.

A bulldozer tends to create convex slopes when sloping an area. A concave slope is a more stable slope form; therefore, it is advised to rather create concave slopes.

If needed, a network of drainage lines will be incorporated into the sloped areas. These drainage lines will ensure clean water run-off on the rehabilitated areas.

Low

Land capability

Sloping without Considering Final Land Capability

High Low

Land use

Sloping without Considering Final Land Use

High Low

7.3. Residual risks

Residual impacts are defined as those environmental impacts that remain subsequent to the issuing of

a closure certificate. All management actions are launched to limit the potential for residual

environmental impacts. Various actions such as rehabilitation of the areas, assessing appropriate land

uses and identifying practical closure objectives all work towards minimising this risk.

The following potential residual impacts have been identified in the approved EMPr (2011):

• Geology

Considering the fact that the mining of the stone goes hand-in-hand with extraction of the ore body, the

impact on the geology (mineral wise) will be permanent. The extraction of ore takes place from the

various areas as described in the mining method.

• Topography

The impact of the quarry alters the topography of that area permanently.


Although the above-mentioned residual risks are defined the post closure impact will not increase.

Once mining stops, the magnitude of the impact ceases. The geology will not continue to be altered

and the mitigation measures will address the impact on the topography by reshaping the side walls and

sloping the external walls to form a whaleback. Thus, no impact would need to be managed post

closure.

8. Final post-mining land use

8.1. Final land use

According to the approved EMPr (Shangoni, 2011), the area in which the quarry is situated was

previously a municipal quarry used for road construction. The adjacent area was wilderness or natural

land. The post-closure land use will be used for grazing, while the quarry will remain a wilderness area

under control of the local municipality. Figure 5 indicates that the land use potential for the area is

classified as vacant / unspecified.

Figure 5: Land use map

Source: Department of Environmental Affairs and Tourism, University of Pretoria & GIS business solutions, 2000.


8.2. Closure criteria

Table 7 contains the standards and criteria that have been set for closure of the quarry in the approved

EMPr.

Table 7: Closure criteria

Aspect Closure measure

Geology • Limit geological disturbance to the mine plan.

Topography

• During the decommissioning phase all slopes need to be finished to

the prescribed 30-degree slope;

• Reduce the visual impact of the altered topography by a process of

sloping and top-soil application;

• Providing safe slopes at angle of 30 degree providing safe access for

wildlife with minimum impact on topography; and

• Aligning the slopes of the quarry with the natural slopes in the area,

being 30-degree slope.

Water

• To ensure compliance with the GN 704 of 4 June 1999;

• To prevent any impact on drainage lines in the project area;

• To prevent any disturbance to the bed and banks of watercourses;

• To prevent discharges of contaminated water to the environment;

• To ensure that the ground water quality of surrounding ground water

users is not adversely affected, by eliminating any source of the

pollution; remedy the effects of pollution; and to monitor the water

quality so as to identify any sources of pollution; and

• To prevent contaminated soil adversely affecting water courses.

Land capability and land use

• The quarry area will be returned to allow game grazing thus returning

it to a wilderness state;

• The future use of the quarry for resource purposes will be assessed

prior to final sloping of the high-wall and side walls to prevent

sterilization of the mineral; and

• The municipality will remain as the owners of the land on which the

quarry is constructed.

Biodiversity

• To limit the area of disturbance to the mining area;

• To control and eradicate all listed invasive plant species;

• To protect watercourses and prevent alteration of these habitats

directly and indirectly through sedimentation and pollution;

• To maintain the diversity of species;

• Prevent hunting and poaching; and


Aspect Closure measure

• Re-establish or comply with permit conditions with regards to any red-

data species directly affected by the mining activities.

Soils

• To conserve soil resources disturbed by the development of the mine;

• To prevent spillage or leakage of hazardous chemicals onto soils or

into surrounding soils (contamination of soil);

• To stockpile topsoil for future use;

• To prevent erosion on top-soil stockpiles and rehabilitated areas; and

• To clean spillages timeously to minimise the potential impact on soil.

Visual

• To limit the visual impact by applying effective rehabilitation

techniques; and

• To limit the visual impact by applying effective mining techniques i.e.

mining behind the original domed ridge

Air quality • To remove all sources of dust generation.

9. Closure actions & Schedule

9.1. Closure organisational structure

Table 8 gives an overview of the different roles and responsibilities which will outline the Safety, Health

and Environmental Management Structure (EMPr, 2011).

Table 8: Closure organisational structure

Key Function Responsibility

D Developer

Proponent ultimately accountable for ensuring compliance to the EMPr. The ECO must be contracted by SKA (full time or part time depending on the size of the project) as an independent appointment to objectively monitor implementation of relevant environmental legislation, and the EMPr for the project.

The developer is further responsible for providing and giving mandate to enable the ECO to perform responsibilities. The developer must ensure that the ECO is integrated as part of the project team.

CE Consulting Engineer

Contracted by the developer to design and specify the project engineering aspects. Generally, the engineer manages the works contract. The CE may also fulfil the role of PM on the proponent’s behalf (See PM).

PM Project Manager

The PM has over-all responsibility for managing the project, contractors, and consultants and for ensuring that the environmental management requirements are met. The CE may also act as the PM. All decisions regarding environmental procedures must be approved by the PM. The PM has the authority to stop any construction activity



in contravention of the EMPr in accordance with an agreed warning procedure.

ER Engineers Representative

The consulting engineer’s representative on site. Has the power/mandate to issue site instructions and in some instances, variation orders to the contractor, following request by the EO or ECO. The ER oversees site works, liaison with Contractor and ECO.

EO/EM

Environmental Officer /Environmental manager

Appointed by the CE as their environmental representative on site. The EO is not independent but must rather act on behalf of the consulting engineers with the mandate to enforce compliance under the project contract, which must include the EMPr. The EO has the directive to issue non-conformance and hazard certificates. Further, in terms of accepted industry practice the EO could issue the equivalent of a “cease works” instruction only in exceptional circumstances where serious environmental harm has been or is about to be caused i.e. in cases of extreme urgency and then only when the ER is absent.

The EO must form part of the project team and be involved in all aspects of project planning that can influence environmental conditions on the site.

The EO must attend relevant project meetings, conduct daily inspections to monitor compliance with the EMPr, and be responsible for providing reports and feedback on potential environmental problems associated with the development to the project team and ECO.

The EO must convey the contents of this EMPr to the Contractor site team and discuss the contents in detail with the Contractor as well as undertake to conduct an induction and an environmental awareness training session prior to site handover to all contractors and their workforce.

The EO must be suitably experienced with the relevant qualifications and preferably competent in construction related methods and practices.

ECO Environmental Control Officer

An independent appointment to objectively monitor implementation of relevant environmental legislation, and the EMPr for the project. The ECO must be on site prior to any site establishment and must endeavour to form an integral part of the project team.

The ECO must be proactive and have access to specialist expertise as and when required, these include botanist’s, ecologists etc. Further the ECO must also have access to expertise such as game capture, snake catching, etc.

The ECO must conduct audits on compliance to relevant environmental legislation and the EMPr for the project. The size and sensitivity of the development will determine the frequency at which the ECO will be required to conduct audits. (A minimum of a monthly site inspection must be undertaken).

The ECO must be the liaison between the relevant authorities and the project team. The ECO must communicate and inform the developer and consulting engineers of any changes to environmental conditions as required by relevant authoritative bodies. The ECO



must ensure that the registration and updating of all relevant EMPr documentation is carried out.

The ECO must be suitably experienced with the relevant environmental management qualifications and preferably competent in construction related methods and practices. The ECO must handle information received from whistle blowers as confidential and must address and report these incidences to the relevant Authority as soon as possible.

On small projects, where no EO is appointed, the ECO must convey the contents of this EMPr to the Contractor site team and discuss the contents in detail with the Contractor as well as undertake to conduct an induction and an environmental awareness training session prior to site handover to all contractors and their workforce.

C Contractor

The principle contractor, hereafter known as the ‘Contractor’, is responsible for implementation and compliance with the requirements of the EMPr, contract and relevant environmental legislation. The Contractor must ensure that all sub-contractors have a copy of and are fully aware of the content and requirements of this EMPr.

The contractor is required, where specified, to provide Method Statements setting out in detail how the management actions contained in the EMPr will be implemented.

ESO Environmental Site Officer

The ESO is employed by the Contractor as his/her environmental representative to monitor, review and verify compliance with the EMPr by the contractor. This is not an independent appointment; rather the ESO must be a respected member of the contractor’s management team.

Dependent on the size of the development the ESO must be on site one week prior to the commencement of construction. The ESO must ensure that he/she is involved at all phases of the constriction (from site clearance to rehabilitation).

A Lead Authority

The authorities are responsible for ensuring that the monitoring of the EMPr and other authorisation documentation is carried out, this will be achieved by reviewing audit reports submitted by the ECO and conducting regular site visits.

OA Other Authority

Other authorities are those that may be involved in the approval process of an EMPr. Their involvement may include reviewing EMPr’s to ensure the accuracy of the information relevant to their specific mandate.

Other authorities may be involved in the development, review or implementation of an EMPr.

9.2. Closure actions

The actions listed below are recommended as a way forward to ensure that the final post-closure land

use vision for the Carnarvon Stone Quarry is realised.

• Monitoring of the quarry walls for erosion and vegetation establishment.


• Application for a closure certificate, with associated environmental authorisation applications and

public participation.

9.3. Closure schedule

The closure of the quarry entails the following:

• Mining the quarry (completed August 2016);

• Removal of structures (completed October 2016),

• Rehabilitation of sections of the quarry in its final position (sloping, completed October 2016),

• Erosion monitoring for three years after rehabilitation was finalised (October 2016 – October 2019)

and maintenance as required.

• Application for a closure certificate (section 43 of MPRDA).

10. Relinquishment criteria

Closure criteria are the agreed tasks/measures involved in mitigating identified closure risks. This

involves activities such as removal of infrastructure, erecting fencing, installing drainage structures,

reshaping, placement of topsoil, ripping, seeding and planting, maintenance and monitoring.

Success criteria are the agreed standards that must be met to facilitate lease relinquishment. They

include physical, biophysical and socio-economic parameters and are generally defined through

engagement with regulators and other external stakeholders.

The final EMPr Performance Assessment, attached to this report in Appendix C, indicates the level of

implementation of the rehabilitation measures and success criteria. Photographic evidence is also

included in the EMPr Performance Assessment.


Table 9: Closure success criteria

Component Closure criteria Success Criteria Auditable Indicator

Geology • Limit geological disturbance to the mine plan. • The quarry size did not exceed the

plan per the approved mining permit. Approved mining permit.

Topography

• During the decommissioning phase all slopes need to be

finished to the prescribed 30-degree slope;

• Reduce the visual impact of the altered topography by a

process of sloping and top-soil application;

• Providing safe slopes at angle of 30 degree providing

safe access for wildlife with minimum impact on

topography; and

• Aligning the slopes of the quarry with the natural slopes

in the area, being 30-degree slope.

• High walls have been sloped. No

failures 2 years after cessation of

mining.

Final EMPr Performance Assessment per the MPRDA requirement.

Water

• To ensure compliance with the GN 704 of 4 June 1999;

• To prevent any impact on drainage lines in the project

area;

• To prevent any disturbance to the bed and banks of

watercourses;

• To prevent discharges of contaminated water to the

environment;

• To ensure that the ground water quality of surrounding

ground water users is not adversely affected, by

eliminating any source of the pollution; remedy the effects

of pollution; and to monitor the water quality so as to

identify any sources of pollution; and

• Water drainage flows naturally

without pooling or flooding.

• Minimal erosion where water flows

from drainage structures.

• No complaints received from

neighbouring landowners regarding

deterioration in water quality within 2

years after cessation of mining.

Mine plan.

Erosion monitoring.

Complaints register.



• To prevent contaminated soil adversely affecting water

courses.

Land capability and land use

• The quarry area will be returned to allow game grazing

thus returning it to a wilderness state;

• The future use of the quarry for resource purposes will be

assessed prior to final sloping of the high-wall and side

walls to prevent sterilization of the mineral; and

• The municipality will remain as the owners of the land on

which the quarry is constructed.

• Animals using the area for grazing

without any casualties.

• Quarry is not backfilled for potential

future use.

• Property still belongs to the

municipality.

Visual inspections.

Property records.

Biodiversity

• To limit the area of disturbance to the mining area;

• To control and eradicate all listed invasive plant species;

• To protect watercourses and prevent alteration of these

habitats directly and indirectly through sedimentation and

pollution;

• To maintain the diversity of species;

• Prevent hunting and poaching; and

• Re-establish or comply with permit conditions with

regards to any red-data species directly affected by the

mining activities.

• The quarry size did not exceed the

plan per the approved mining permit.

• Little to no alien invasive plant

species observed on site.

• No complaints received regarding

hunting or poaching.

• Natural re-establishment of

vegetation.

Approved mining permit.

Final EMPr Performance Assessment per the MPRDA requirement.

Soils

• To conserve soil resources disturbed by the development

of the mine;

• To prevent spillage or leakage of hazardous chemicals

onto soils or into surrounding soils (contamination of soil);

• To stockpile topsoil for future use;

• Topsoil striping and replacement

implemented per the approved EMPr

procedure.

• Prevention and clean-up of spills as

necessary.

Final EMPr Performance Assessment per the MPRDA requirement



• To prevent erosion on top-soil stockpiles and

rehabilitated areas; and

• To clean spillages timeously to minimise the potential

impact on soil.

Visual

• To limit the visual impact by applying effective

rehabilitation techniques; and

• To limit the visual impact by applying effective mining

techniques i.e. mining behind the original domed ridge.

• The quarry size did not exceed the

plan per the approved mining permit. Approved mining permit.

Air quality • To remove all sources of dust generation. • No complaints received regarding

dust. Complaints register.


11. Closure monitoring

This chapter provides information with regards to the operational, post-rehabilitation and post-closure

monitoring of the various environmental characteristics that will provide an indication of compliance to

performance requirements, closure objectives, closure success criteria, license and permit

requirements, Company requirements and any other requirements that may be applicable to the mine.

The key characteristics are further monitored to ensure that the closure objectives have been achieved

and that compliance to the scheduling of rehabilitation planning takes place.

Monitoring is of utmost importance because closure will only be obtained once evidence can be

presented to the DMR that the closure objectives have been achieved, that closure plans have been

effectively implemented and that rehabilitation is sustained.

The mechanisms applied to monitor the effectiveness of the decommissioning and closure plan and the

system includes the following:

• Internal audits;

• Management review meetings;

• Review of the aspects and impacts register;

• Environmental Management Program (EMP) Performance assessments;

• Physical monitoring (described under Section 11.1);

• Legal compliance audits; and

• Incident and accident reporting and addressing external complaints.

All of the above mechanisms are applied to ensure that the commitments made in the decommissioning

and closure plan are implemented and tracked.

11.1. Post-rehabilitation and- closure monitoring

The following rehabilitation monitoring measures have been identified in the approved EMPr:

• During and after the mining process a monitoring system will be implemented to assess the success

of the re-vegetation. Erosion can be quantified by insertion of marked stakes into the rehabilitated

profile and recording the rate at which the stakes are uncovered.

• Remedial actions such as the replanting or repair of erosion channels will be undertaken as and

when necessary. Erosion control measures include the identification of erosion gullies, covering with

sub-surface soil and the re-vegetation of the area.

• Rehabilitation areas will be inspected and photographed progressively on intervals to monitor

rehabilitation success.

• The type and distribution of weeds within the operation and in the rehabilitated areas during the

closure phase will be mapped and appropriate control methods will be implemented and reported

upon in the EMPr Performance Assessment Report.

• A final weed survey will be conducted during the initiation of the final closure plan for the entire

mining lease area.


11.2. Auditing and reporting requirements

A final EMPr Performance Assessment / Audit was conducted as part of the MPRDA process for the

application for a closure certificate. The audit report is attached to this document in Appendix C.

12. Closure cost estimate

The following information was used to determine whether any further liability exists:

• The quarry will not be backfilled. Instead, benches will be sloped to between 30 degrees as per

the rehabilitation plan. The excavation floor will be sloped to allow the quarry to drain into the

surrounding environment.

• As the stockpile area was never included in the mining permit and instead leased from the local

municipality, the area was excluded from the rehabilitation costs as the area will still be utilised by

the municipality.

• The area will be left to revegetate naturally due to limited rainfall.

• The chemical storage bund wall will not be demolished at the request of the local municipality, who

is the landowner.

• All other structures have been removed from site.

Based on the above, it is concluded that the NRF SKA does not have any further closure liability related

to the Carnarvon Stone Quarry.

13. Gap analysis

13.1. Gap analysis

The table below contains the major gaps identified as part of this closure plan compilation.

Table 10: Closure gap analysis

Gap Description Action required

Schedule

Stakeholder and public input

The public participation process (PPP) as part of the application for Environmental Authorisation may raise issues that have not bene previously identified.

Completion of the PPP. June / July

2019

13.2. Threats, opportunities and uncertainties

The table below lists the main threats and opportunities and any uncertainties associated with the

preferred closure option.

Table 11: Threats and opportunities identified

Opportunity Threat

Internal


Opportunity Threat

Surface infrastructure with a beneficial post-closure re-use potential (bund walls.)

Tillage requirements and ripping requirements have not been implemented

Potential re-use of the quarry for future road construction.

Low rainfall limiting the re-establishment of vegetation.

External

Potential lease of land to third party users for material laydown area and quarrying.

Growth / proliferation of alien invasives

14. Conclusion

Consultation with all the relevant stakeholders (private sector and government sector) will allow for the

setting of acceptable closure objectives. All the relevant parties will be involved in contributing to the

effective closure of the mining operations. Consultation is critical to ensure success in obtaining a

closure certificate.

The NRF / SKA demonstrates a high level of understanding towards the various risks with management

strategies in place. The rehabilitation plan addresses all actions required to ensure the mine can be

closed in line with the MPRDA requirements.

15. Disclaimer

This report has been produced by Shangoni Management Services (Pty) Ltd., (“Shangoni”) with the skill

and care ordinarily exercised by a reasonable Environmental Consultant at the time the services were

performed. Further, and in particular, the Services were performed by Shangoni considering the limits

of the scope of works required by the Client, the time scale involved and the resources, including

financial and manpower resources. None of the work performed during this project shall constitute or

be represented as a legal opinion of any kind or nature but shall be a representation of the findings.

No warranties or guarantees, expressed or implied, are included in or intended by the report, except

that it has been prepared in accordance with the current generally accepted practices and standards

consistent with the level of care and skill exercised under similar circumstances by professional

consultants or firms that perform the same or similar services. Any reference to legislation in this report

should not be perceived as a substitute for the provisions of such legislation. In the event of any

inconsistency between this document and such legislation, the latter would prevail.

Whilst every endeavour has been made by the Shangoni to ensure that information provided is correct

and relevant, this report is, of necessity, based on information that could reasonably have been sourced

within the time period allocated to the assessment, and is, furthermore, of necessity, dependent on

information provided by management and/or its representatives. It should, accordingly, not be assumed

that all possible and applicable findings, observations and/or measures are included in this report as

this report represents a sample of assessable parameters. As a subsequent event, should additional


information become available, Shangoni reserves the right to amend its findings, observations,

measures and executive summary.

16. Declaration of independence

Shangoni hereby declares that it is an independent environmental consultant in that it has no business,

financial, personal or other interest in this project in respect of which Shangoni is appointed.

Furthermore, no circumstances exist that may compromise the objectivity of Shangoni, excluding fair

remuneration for work performed in connection with this environmental audit.

Report compiled

by:

Report reviewed by:

Emma Fourie Jan Nel

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