2017 Water Use Licence Internal Audit...2019/05/05 · An internal audit was done on the Water Use...

Nkomati Anthracite Mine

2017 Water Use Licence

Internal Audit

PO Box 76 The Woodlands Office Park Woodmead 2052 Co. Reg 80/08581/07 Vat Reg 472 012 0221 Phone: 013 691 1144 (Ext 111)

Fax: 013 691 1148

NKOMATI ANTHRACITE (PTY) Ltd


Sentula Mining

Nkomati Anthracite Mine

2017 Water Use Licence

Internal Audit


Page ii

Contents

1 Background Information ................................................................................................................................. 1

1.1.1 Underground Mine Area ................................................................................................................... 1

1.1.2 Void North of Komati River ............................................................................................................... 3

1.1.3 Processing Plant Area ....................................................................................................................... 3

1.1.4 Madadeni Opencast .......................................................................................................................... 5

2 Internal Water Use License Audit ................................................................................................................... 7

2.1 Mine representatives who conducted the audit ................................................................................... 7

2.2 Water Use Licence................................................................................................................................. 7

2.3 Legend to Audit ..................................................................................................................................... 7

3 Nkomati Anthracite Mine – Audit Observations ............................................................................................ 8

4 GN704 Audit ................................................................................................................................................. 33

5 Site Inspection and Findings ......................................................................................................................... 38

Page iii

Tables Table 1:2: Property Information for the Project ................................................................................................ 1

Table 1:3: Details of Landowners ...................................................................................................................... 1

Table 1:1 Contact Details .................................................................................................................................. 7

Table 1:2 Audit Colour Coding – Compliance Status ........................................................................................ 7

Table 2:2:1 Audit Observations ..................................................................................................................... 8

Table 4:1 Findings from Site Inspection ......................................................................................................... 38

1 Background Information

Nkomati Anthracite Mine is an operational mine south east of Komatipoort in the

Mpumalanga Province. Nkomati Anthracite Mine operates on the following properties.

Table 1:1: Property Information for the Project

Property Description tied to the Mining Right Surface Right Owner

Unsurveyed State Land Mawewe Tribal Authority

Unsurveyed State Land Matsamo Tribal Authority

Rusplek 495 JU Kwalugedlane Tribal Authority

Rusplek 495 JU Kwalugedlane Tribal Authority

Wildebeest 494 JU Kwalugedlane Tribal Authority

Sweet Home 496 JU Kwalugedlane Tribal Authority

The property owners are set out in the table below:

Table 1:2: Details of Landowners

Surface Owner Contact Person Contact Details

Mawewe Tribal Authority Mrs. Mkhatshwa

(Acting Chief)

P.O. Box 99, Manzolwandle, 1444

Tel: 072 0756426; Alt: 076 285 1648

Matsamo Tribal Authority Mr. Shongwe

(Chief)

P.O. Box 601, Shongwe Mission, 1331

Tel: (013) 781 0657; Alt: 079 405 4194

Kwalugedlane Tribal Authority Mr Ngomane

(Chief)

P.O. Box 027, Kwa-Lugedlane, 1541

Tel: 072 947 5334; Alt: 071 201 4237

Nkomati Anthracite Mine thus consists of a few sections making up the entire mining area:

Underground Mining Operations;

Void north-east of the processing plant on the other side of the Komati River;

Processing and Filtering Plant;

Old Opencast mining area adjacent to the processing plant; and

Madadeni Opencast.

For ease of reference in this report a layout of Nkomati Mine is provided and infrastructure labelled.

1.1.1 Underground Mine Area

The Underground Mine Workings is located North-East of the processing plant on the other

side of the Komati River.

Infrastructure

Overburden Stockpile;

Offices;

Change Houses;

Workshop;

Septic Tanks;

Figure 1:1 Underground Mine Area

1.1.2 Void North of Komati River

A void is located North-East of the processing plant on the other side of the Nkomati River.

This void is filled with water.

Infrastructure

Pump House;

Generator;

Pipeline from the underground into the void;

Pipeline from the void to the processing plant;

Figure 1:2: Void North of Komati River

1.1.3 Processing Plant Area

The Processing Plant includes the old opencast area.

Infrastructure Plant Area

Processing Plant;

Product Stockpile Area;

Coarse Discard;

Slurry Settling Ponds;

Slurry Stockpile;

Sump;

Processing Plant Pollution Control Dams;

Fuel Bunker;

Workshop;

Offices.

Infrastructure Old Opencast Area

Old Void 1;

Old Void 2;

Rehabilitated Area;

Explosives Storage Area.

Figure 1:3 Processing Plant and adjacent Old Opencast Area

1.1.4 Madadeni Opencast

Infrastructure

Run of Mine Stockpile

Topsoil Stockpile

Waste Rock Dump

Existing Clean Water Trench / River Diversion

Existing Dirty Water Trench

Madadeni Pollution Control Dam

Figure 1:4 Madadeni Opencast Area

2 Internal Water Use License Audit

2.1 Mine representatives who conducted the audit

Nkomati Anthracite Mine has recently undergone significant changes to the structure and

make up of senior mine management and as such, a number of new staff have been brought

on board to replace those no longer employed by the Mine. This has meant that time has

been spent familiarising new staff with the Mine and associated environmental requirements.

The below staff were responsible for the 2017 Internal Water Use License Audit.

Table 2:1 Contact Details

Name Designation Telephone Number

Andy Johnson Mine Manager 076 958 98 93

Son Setumo Project Manager 011 656 1303

2.2 Water Use Licence

Water Use Licence 05/X13J/ACGIJ/1864 was issued to Nkomati Anthracite Mine on 24 October 2012 and was amended on 13 February 2014. Yearly internal audit reports are required in order to remain compliant with the conditions of the License. An internal audit was done on the Water Use License (05/X13J/ACGIJ/1864) in 2015 and 2016. This Internal Water Use License Audit Report is the annual 2017 audit report.

2.3 Legend to Audit

The table below provides the colour used in the audit.

Table 2:2 Audit Colour Coding – Compliance Status

Legend Colour Coding

Compliant

Partially compliant. Management measures being set in place

Not Compliant

Not Applicable to the site

Not Implementable

3 Nkomati Anthracite Mine – Audit Observations

Table 3:1 Audit Observations

No Condition Compliance

Status Observation

1.

Licensee: Nkomati Anthracite Mine (Pty) Ltd Postal Address: P.O. Box 76, The Woodlands Office Park Woodmead 2050

This is the correct information.

2 Water Uses

2.1 Section 21(a) of the Act: Taking of water from a water resource, subject to the conditions set out in Appendices I and II

2.2 Section 21(c) of the Act: Impeding or diverting the flow of water in a watercourse, subject to the conditions set out in appendices I and III

2.3 Section 21(g) of the Act: Discharging waste or water containing waste into a water resource, subject to the conditions set out in appendices I and IV.

2.4 Section 21(i) of the Act: Altering the bed, banks, course or characteristics of a watercourse, subject to the conditions set out in appendices I and III.

2.5 Section 21(j) of the Act: Removing, discharging or disposing of water found underground, subject to the conditions set out in appendices I and V.

3 Properties of which the use will be exercised

3.1 Section 21(a):

Unsurveyed State land owned by Matsamo tribal authority


Unsurveyed state land owned by Mawewe Tribal Authority

Wildebeest 494 JU

Rustplek 495 JU

Sweet home 496 JU

3.2 Section 21 (c) and (i)

Unsurveyed state land owned by Matsamo tribal authority

Unsurveyed state land owned by Kwalughedlane

Sweet home 469 JU

3.4 Section 21 (g)

Unsurveyed state land owned by Matsamo tribal authority

Unsurveyed state land owned by Mawewe tribal authority

Wildebeest 494 JU

Rustplek 495 JU

Sweet home 494 JU

3.5 Section 21 (j) Wildebeest 494 JU

4

Registered owners of the property


Owners Name Farm Portion and Portion Number

Matsamo Tribal Authority Unsurveyed state land

Mawewe Tribal Authority Unsurveyed state land

Kwalughedlane Tribal Authority Wildebeest 494 JU

Rustplek 495 JU

Sweet home 496 JU

5 Licence and Review Period

5.1 This licence is issued for a period of ten (10) years from the date of the issuance and may be reviewed every five (5) years.

6 Definitions

7

Description of the activity The Licensee, Nkomati Anthracite Mine (Pty) Ltd is licenced for an Integrated Water Use Licence (IWUL) in terms of Section 40 of the National Water Act, 1998 (36 of 1998) for section 21 (a) of the National Water Act (Act 36 of 1998) taking water from a water resource (1320 m

3/a) for domestic use and 124 100 m

3/a for reuse in process plant and dust suppression, section 21(c) of the National Water

Act for disposing of waste in a manner which may detrimentally impact on a water resource, (229 506 m3/a) into pollution controlled

dams, return water dams, sewage disposal and slurry settling dams), coal stockpiling of 360 000 tones, 179 200 m3/a of dry slurry and

runoff mine product coal on the Madadeni stockpile area, and 407 762.64 m3/a Backfilling of Madadeni opencast pit, old void pit 1 and

2. Section 21 (i) of the National Water Act for altering the river beds, banks, course or characteristics of a watercourse, and Section 21 (j) of the National Water Act for removing, discharging or disposing of water found underground if it is necessary for the effective continuation of an activity or for the safety of people (58 400 m

3/a).

Discussed in further detail under Appendix I to V

Appendix I: General Conditions for the licence

1 This license is subject to all applicable provisions of the National Water Act, 1998 (Act 36 of 1998).

Noted – Compliance with Section 19 of the NWA.

Compliance with GN704.

Revision of Storm Water Management Plan (SWMP);

Revision of Rehabilitation Implementation Strategy Plan (RISP);

Compilation of Dynamic Water Balance.

2 The responsibility for complying with the provisions of the license is vested in the Licensee and not any other person or body. Noted

3 The Licensee must immediately inform the Regional Head of any change of name, address, premises and/or legal status. Noted

4 If the property in respect of which this license is issued is subdivided or consolidated, the Licensee must provide full details of all changes in respect of the properties to the Regional Head of the Department within 60 days of the said change taking place.

Noted

5 If a water user association is established in the area to manage the resource, membership of the Licensee is compulsory.

6 While the effect must be given to the Reserve as determined in terms of the Act, where a desktop determination of the reserve has been used in issuance of a license, when a comprehensive determination of the Reserve has been made, it shall be given effect to.

Noted

7 The license shall not be construed as exempting the Licensee from compliance with the provisions any other applicable Act, Ordinance, Regulation or By-law

Noted

8 The license and amendment of this license are also subject to all the applicable procedural requirements and other applicable provisions of the Act, as amended from time to time.

Noted. Compliance with GN704.

9 The Licensee shall conduct an annual internal audit on compliance with the conditions of license. A report on the audit shall be submitted to the Regional Head within one month of the finalisation of the audit.

An internal report was undertaken in 2015 and 2016. This is the 2017 report.

10 The Licensee shall appoint an independent external auditor to conduct an annual audit on compliance with the conditions of this An external audit was conducted in May

license. 2016. A follow up audit was conducted in August 2016 to monitor the implementation of recommendations. An external audit was conducted in September 2017. These were conducted by an independent external auditor.

11 Any incident that causes or may cause water pollution shall be reported to the Regional Head or his/her designated representative within 24 hours.

The mine has been placed on care and maintenance during 2014. Operations commenced in 2015. No incidents have been reported up to date (November 2017).

12 The Licensee shall establish and implement a continual process of raising awareness amongst itself, its workers and stakeholders for the need for Water Conservation and Water Demand Management.

The mine is currently including water conservation and demand management notes into the inductions and safety talks.

13 Notices prohibiting unauthorised persons from entering water use premises must be displayed.

14

The Department accepts no liability for any damage, loss or inconvenience of whatever nature, suffered as a result of/ amongst other things:

Noted 14.1 Any force majeure event;

14.2 Siltation of the river or dam basin; and

14.3 Required Reserve released

Appendix II: Section 21 (a) of the Act: Taking water from a water resource

1

This licence authorises the taking of a maximum quantity of water as reflected in table 1 below:

Activities Purpose Properties Total Water (m3/a)

Flow meters have been installed in accordance with the previous audit reports recommendation. The borehole is used for domestic purposes such as cleaning, showering and servicing the toilets. This water is not used for human consumption. Bottled water is used for drinking purposes. There is a second borehole located at the underground operations that will be used in future. This abstraction will require licensing. The new mine management has had a number of meetings to determine the most effective way use water around the mine and is developing a future plan for this.

Section 21(a) Taking water from borehole for domestic use.

Un-surveyed state land owned by Matsamo Tribal Authority

1320 m3/a

Section 21(a) Taking water from Madadeni Opencast pit for reuse in the processing plant

Un-surveyed state land owned by Mawewe Tribal Authority

3650 m3/a

Water use has not commenced. Currently no water is being transferred from Madadeni to the processing plant. The water balance should confirm the

amount of water that will be transferred to the processing plant as to determine if the volume of water in the licence should be amended.in the future. The new mine management has had a number of meetings to determine the most effective way use water around the mine and is developing a future plan for this.

Section 21(a) Taking water from underground as make up water

Wildebeest 494 JU 54 750 m3/a

Water from underground is pumped to an open void before it is used during process. The Mine is in the process of developing a water balance to confirm exact volumes abstracted. The water balance should confirm the volume of water abstracted. The new mine management has had a number of meetings to determine the most effective way use water around the mine and is developing a future plan for this.

Section 21(a) Taking water from Defunct open cast pit as make-up water

Rustlplek 495 JU Sweethome 496 JU

65 700 m3/a

Assumed that this refers to the old Opencast Void 2 from which there is water drawn occasionally. The volume of abstraction could not be confirmed due to the fact that no water meter is installed. Minimal water was abstracted from this void The new mine management has had a number of meetings to determine the most effective way use water around the mine and is developing a future plan for this.

2 The quantity of water authorised to be taken in terms of this licence may not be exceeded without prior authorisation by the Minister.

Flow meter readings have commenced and this will feed into a water balance. The next step is to establish a database to determine the exact extraction amounts The new mine management has had a number of meetings to determine the most effective way use water around the mine and is developing a future plan for this.

3 This licence does not imply any guarantee that the said quantities and qualities of water will be available at present or at any time in the future.

Noted

4 The above mentioned volume may be reduced when the licence is reviewed or during compulsory licensing. Noted

5 The Licensee shall continually investigate new and emerging technologies and put into practise water efficient devices or apply technique for the efficient use of water containing waste, in an endeavour to conserve water at all times.

Noted – improved management practises forms part for the IWWMP.

6 The licensee shall be responsible for any water use charges or levies, which may be imposed from time to time by the Department or responsible authority in terms of the Department’s Raw Water Pricing Strategy.

Noted

7

The Department accepts no liability for any damage, loss or inconvenience, of whatever nature, suffered as a result of: 7.1 shortage of water 7.2 inundations of flood 7.3 siltation of the resource; and 7.4 required reserve releases.

Noted

Appendix III – Section 21 (c) of the Act: Impeding or diverting the flow of water in a watercourse and Section 21 (i) of the Act: Altering the beds, banks, course or characteristics of a watercourse

1 General

1.1

This licence authorises Nkomati Anthracite Mine (Pty) Ltd for the water activities as set out in Table 2 below and in the water use licence application reports submitted to the Department (refer to condition 1.2) for:

Activity Property Width Length Coordinates

The pipeline has been constructed according to this condition and the co-ordinates are correct

Pipeline crossing on Nkomati River, transporting water from the underground mine to the processing plant

Sweethome 496 JU Unsurveyed state land owned by Matsamo Tribal Authority

S 25º46’12.2” E31º48’04.3” S25º46’10.8” E31º48’04.3”

Diverting the Madadeni Drainage Channel

Un-surveyed state land owned by Matsamo Tribal Authority

2 meters 1300 meters

S25º50’03.97” E31º47’30.7” S25º50’05.92” E31º48’10.54”

The Mine has conducted significant maintenance on the river diversion to ensure its functionality. This practise must continue as the river diversion will need to be kept in a good state.

1.2 The licensee shall carry out and complete all activities listed under condition 1.1 according to the following: Noted

1.2.1

Reports submitted to the Department, specifically:

Noted 1.2.1.1 Integrated Waste Water Management Plan report dated March 2011, Compiled by Geovicon Environmental (Pty) Ltd

1.2.1.2 Madadeni Wetland Assessment Report; compiled by Geovicon Environmental (Pty) Ltd

1.2.1.3 Approved EMPR dated 30 September 2010;

1.2.2 Conditions of this licence Noted

1.2.3 Any other written direction issued by the Regional Head in relation to this licence. Noted

1.3 No activity must take place within the 1:100 year flood line or the delineated riparian habitat, whichever is the greatest, or within 500m radius from the boundary of any wetland unless authorised by this licence.

Noted for future activities

1.4 The conditions of the authorisation must be brought to the attention of all persons (employees, sub-consultants, contractors etc.) associated with the undertaking of these activities and the Licensee must take such measures that are necessary to bind such persons to the conditions of this licence.

Compliant

1.5 A copy of the water use licence and reports set out under condition 1.2 of Appendix III above must be on site at all times. Compliant

1.6 A suitably qualified person(s), appointed by the Licensee, and approved in writing by the Regional Head must be responsible for ensuring that the activities are undertaken in compliance with the specifications as set out in reports submitted to the Department or the Regional Head and the conditions of this licence.

Suitably qualified person(s) such as engineers, environmental lawyers and consultants have been appointed.

2 Further studies and Information Requirements

2.1 For water use activities in Table 2: 2.1.1 An environmental Management Plan and rehabilitation plan for the decommissioning of any of the water use activities as listed

Noted

in Table 2 must be submitted five (5) years before commencing with closure to the Regional Head for written approval.

3 Protective Measures

3.1 Stormwater Management

These conditions specifically refer to the river diversion at Madadeni Opencast and the pipeline crossing from the underground void to the processing plant. Significant maintenance has been undertaken at the River Diversion to ensure its functionality. The dirty water trench intercepting water from the waste rock dump has eroded its way into the banks, bringing it closer to the river diversion. This means during a flood clean and dirty water are likely to mix. A rehabilitation plan for the life of Madadeni is currently being drafted which will feed into the stormwater management of the site. An engineer has been appointed and designed a PCD to handle contain he dirty stormwater from the opencast area. Stormwater management at the pipeline crossing is sufficient and compliant.

3.1.1 Storm water management practices must be constructed, operated and maintained in a sustainable manner throughout the project and for the water use activities set out in Condition 1.1 of Appendix III and must include but are not limited to the following:

3.1.1.1 Increased runoff due to vegetation clearance and/or soil compaction must be managed, and steps must be taken to ensure that storm water does not lead to bank instability and excessive levels of silt entering the watercourse(s);

3.1.1.2 The velocity of storm water discharges must be attenuated and the banks of the watercourses protected;

3.1.1.3 Storm water leaving the Licensee’s premises must in no way be contaminated by any substance, whether such substance is a solid, liquid, vapour or gas or a combination thereof which is produced, used, stored, dumped or spilled on the premises.

3.1.1.4 Drainage next to construction works and mining area must be diverted away from the watercourse(s) to ensure that any contaminated runoff does not flow directly into the watercourse as storm water discharge.

3.2 Structures, Construction Plant and Materials

Significant maintenance has been undertaken to ensure the functionality of the river diversion. A concurrent rehabilitation and stormwater management plan for the life of Madadeni is currently being implemented. Stormwater management at the pipeline crossing is sufficient and compliant. The dirty water trench is at risk of joining into the river diversion during high rainfall events and attention is being given to rectifying this.

3.2.1 The necessary erosion prevention measures must be employed to ensure the sustainability of all structures

3.2.2 The height, width and length of structures must be limited to the minimum dimension necessary to accomplish the intended function.

3.2.3 Structures must not be damaged by floods exceeding the magnitude of floods occurring on average once in every 100 years.

3.2.4 Structures must be non-erosive, structurally stable and must not induce any flooding or safety hazard

3.2.5 Structures must be inspected regularly or after every heavy storm event for accumulation of debris, blockage, erosion of abutments and overflow areas - debris must be removed and damages must be repaired and reinforced immediately.

Significant maintenance has been undertaken to ensure the functionality of the river diversion. Debris must be cleared after significant rainfall events Stormwater management at the pipeline crossing is sufficient and compliant. The dirty water trench is at risk of joining into

the river diversion during high rainfall events and attention is being given to rectifying this.

3.2.6 The construction camp, plant and material stockpiles must be located outside the extent of the watercourse(s) and must be recovered and removed one (1) month after construction has been completed.

Noted. No construction is currently undertaken

3.2.7 During construction erosion berms should be installed to prevent gully formation, according to the slope. Noted. No construction is currently undertaken

3.2.8 All areas affected by construction should be rehabilitated upon completion of the construction phase of the activity. Areas should be reseeded with indigenous vegetation species as required, and the use of seed-nets is recommended to prevent erosion.

Rehabilitated areas have been appropriately reseeded and have grown well where they have been allowed to do so. There are places where discard has been dumped on rehabilitated areas. A clear future mine plan must be drawn up to ensure that rehabilitation is effective. Attention must be given to the storm water management around these areas as they were originally designed to be clean water areas.

3.2.9 During the construction phase no vehicles shall be allowed to indiscriminately drive through any wetland areas. Noted. No construction is undertaken

3.2.10 No construction is allowed within the 1:100 year floodline and/or delineated riparian habitat, whichever is the greatest, or within 500m radius from the boundary of any wetland unless authorised in this licence.

Noted. No construction is undertaken

3.3 Water Quality

Noted and implemented 3.3.1

The Licensee shall sample the surface water quality weekly (during construction) and monthly (during operation) for the mentioned variables (Table 3) at the monitoring points both upstream and downstream of the activities and report to the Regional Head within 30 days after the results of each sampling event is received.

Table 3: Water quality parameters not to be exceeded The faecal coliform variable was found to

be higher than the quality objective parameters. The issue of clean and dirty water mixing has been identified and the future mine plan will help to create an effective stormwater management plan to reduce this. The parameters for faecal coliforms are very low and may require amendment. These high counts are not due to mining activities, but rather the considerable amount of rural/informal dwellings in the area.

Chemical parameters Unit Quality objectives

pH 4-5 > 9.5-10

Total Dissolved solids Mg/l 0-450

Electrical conductivity mS/m 150-300

Calcium as Ca mg/l 150-300

Magnesium as Mg mg/l 70-100

Sodium as Na mg/l 200-400

Chloride as Cl mg/l 200-600

Sulphate as SO4 mg/l 400-600

Nitrates as NO-N mg/l 10-20

Fluoride as F mg/l 1.0

Faecal coli forms Counts/100ml 1-10

3.3.2 The variables may be amended on the discretion of the Regional Head. Only an accredited (SANS 17025) laboratory to be used for analysis.

Aquatico Scientific (Pty) is an accredited (SANS 17025) laboratory

3.3.3 Activities that lead to elevated levels of turbidity of any watercourse(s) must be prevented, reduced, or otherwise remediated. Water Qualities are in compliance upstream

Activities must be scheduled to take place during dry seasons when flows are lowest and reasonably possible. If this is not possible and if management measures have not been provided the Licensee must submit to the Regional Head for written approval before these activities commence. Natural in stream hydrology is to be used to determine which months the low flow months.

and downstream of the operations.

3.3.4 The licensee must ensure that the quality of the water to downstream water users does not decrease because of the water use activities listed under condition 1.1 Appendix III.

Water Qualities are in compliance upstream and downstream of the operations.

3.3.5 A qualified person must be appointed to assess the quality of water both upstream and downstream of the activities prior to commencement of construction.

Aquatico Scientific (Pty) Ltd is the appointed contractor conducting the monitoring. Aquatico Scientific (Pty) is an accredited (SANS 17025) laboratory

3.3.6 Pollution of and disposal/spillage of any material into the watercourse must be prevented, reduced, or otherwise remediated through proper operation, maintenance and effective protective measures.

Vehicles operated on designated areas. Construction according to an approved plan to prevent pollution

3.3.7 Vehicles and other machinery must be serviced well above the 1:100 year flood line or delineated riparian habitat, whichever is the greatest. Oils and other potential pollutants must be disposed of at an appropriate licensed site, with the necessary agreement from the owner of such a site.

Vehicles and machinery are being appropriately serviced. The new mine management has been made aware that waste disposal needs improvement and has committed to do so.

3.3.8 Any hazardous substances must be handled according to the relevant legislation relating to transport, storage and use of the substance

General and hazardous waste management must be given attention. The issues identified are the hole in the bund of the fuel storage area and the oil barrel storage area. The handling of these used oil containers and the hole in the fuel bund have previously been identified as issues and have not been rectified.

3.3.9 All reagent storage tanks and reaction units must be supplied with a bunded area built to the capacity of the facility and provided with sumps and pumps to return the spilled material back into the system. The system must be maintained in a state of good repair and standby pumps must be provided.

The workshop area does not have an oil trap. The workshop area is roofed and has a concrete floor. The workshop area has a bunded, roofed area to store reagents. The fuel storage area is located at the processing plant and is bunded. However it has a hole in it, compromising its integrity.

3.3.10 The Licensee has to indicate to the Regional Head within sixty (60) days after issuance of this licence, the strategic placement of bio-swale, bio-filters, silt, litter and hydrocarbon (oil) traps to minimise the risk of pollutants entering the natural drainage system of the area.

No proof of such documentation could be provided.

3.4 Flow

Could not determine if there is a flood line report available. There are only wetland assessment reports. Flood lines are not indicated on maps

3.4.1 The Licensee must determine flood lines (1:50 and 1:100 year) prior to construction to ensure risks are adequately managed. Flood lines must be clearly indicated on the site plan(s) and drawings along with all wetland boundaries.

3.4.2 The activities must be conducted in a manner that does not negatively affect catchment yield, hydrology and hydraulics unless authorised by this licence. The Licensee must ensure that the overall magnitude and frequency of flow in the watercourse(s) does not

The mine has conducted significant maintenance on the river diversion which

decrease, other than for natural evaporative losses and authorised attenuation volumes. has ensured its functionality. Stormwater management and the separation of clean and dirty water require attention.

3.4.3 Appropriate design and mitigation measures must be developed to minimise impacts on the natural flow regime of the watercourse i.e. through placement of structures/supports and to minimise turbulent flow in the watercourse.

A new PCD for the opencast area has been designed by a qualified engineer to reduce the probability of clean and dirty water mixing. The banks of the river diversion have been supported through the placement of oversize burden to act as energy dissipating structures that will reduce the erosive capabilities of the water in the river diversion. The mine will be placing overburden between the pit and the oxbow area to prevent flooding of the pit.

3.4.4 Structures must be designed in a way to prevent the damming of stream/river water and where practically possible not impact on the flow of the water, during the construction and operational phases of all activities.

Damming of water occurs around the plant area due to poor storm water management practises. New mine management is aware of this and intend to create a future mine plan which will allow for an effective storm water management plan to be drawn up.

3.4.5 The development may not impede natural drainage lines unless authorised by this licence No activities other than authorised impede natural drainage lines

3.4.6 The diversion structures may not restrict river flows by reducing the overall river width or obstructing river flow unless authorised by this licence

Licence approves river diversion

3.4.8 Where flow in watercourse is permanent, the trench must be staged across part of the channel to maintain flows. Flows must not be stopped

This condition refers to the pipeline crossing between the underground mine area and the processing plant. The river diversion is a non-perennial stream and the pipeline is fixed to a bridge therefore this licence condition should be removed

3.5 Riparian and In-stream Habitat (Vegetation and Morphology)

Noted 3.5.1

Activities (including spill clean-up) must start up-stream and proceed into a down-stream direction, so that the recovery processes can start immediately, without further disturbance from upstream works.

3.5.2 Operation and storage of equipment must not take place within the 1:100 year flood line or delineated riparian habitat, whichever is the greatest unless authorised in this licence.

Noted – equipment is stored outside the 1:100 year floodline

3.5.3 Activities must not occur in sensitive riffle habitats. No sensitive riffle habitats were identified

3.5.4 Indigenous riparian vegetation, including dead trees, outside the limits of disturbance indicated in the site plans must not be removed from the area

Noted

3.5.5 Alien and invader vegetation must not be allowed to further colonise the area, and all new alien vegetation recruitment must be sustainably eradicated or controlled.

Maintenance of the river diversion has allowed for vegetation composition to be maintained and/or improved.

3.5.6 Existing vegetation composition must be maintained or improved by maintaining the natural variability in flow fluctuations. Rehabilitated areas shall have vegetation basal cover of at least 15% at all times.

3.5.7 Recruitment and maintaining of a range of size classes of dominant riparian species in perennial channels must be stimulated.

3.5.8 Encroachment of additional exotic species and terrestrial species in riparian zones must be discouraged.

3.5.9 Accumulation of woody debris on terraces by periodic flooding must be discouraged.

Maintenance of the river diversion removes accumulated woody debris. Clean and dirty water trenches need to be cleared of debris and the channels need to be properly defined.

3.5.10 Existing flood terraces and deposition of sediments on these terraces to ensure optimum growth, spread and recruitment of these species must be maintained.

River diversion is a non-perennial stream. Post maintenance the area shall be rehabilitated.

3.5.11 All reasonable steps must be taken to minimise noise and mechanical vibrations in the vicinity of the watercourses. Noted

3.5.12 Soils that have become compacted through the water use activities must be loosened to an appropriate depth to allow seed germination.

Will form part of the rehabilitation plan

3.5.13 Slope/bank stabilisation measures must be implemented with a 1:3 ratio or flatter and vegetated with indigenous vegetation immediately after the shaping.

The maintenance of the river diversion ensures compliance with this condition. The numerous trenches around the mine do not meet these requirements and must be given attention.

3.5.15 Stockpiling of removed soil and sand must be stored outside of the 1:100 flood line or delineated riparian habitat, whichever is the greatest unless authorised by this licence, to prevent being washed into the river and must be covered to prevent wind and rain erosion.

Soil stockpiles are encroaching towards the river diversion and the oxbow. Future mine plan to address this.

3.5.16 The indiscriminate use of machinery within the in-stream and riparian habitat will lead to compaction of soils and destruction vegetation and must therefore be strictly controlled

Maintenance of the river diversion is conducted in accordance with an approved EMP.

3.5.17 The overall macro-channel structures and mosaic of cobbles and gravels must be maintained by ensuring a balance (equilibrium) between sediment deposition and sediment conveyance maintained. A natural flooding and sedimentation regime must thus be ensured as far as reasonably possible.

The river diversion has undergone significant maintenance but the storm clean and dirty water channels/trenches require attention.

3.5.18 As much indigenous vegetation growth as possible should be promoted within the proposed development area in order to protect soil and to reduce the percentage of the surface area which is paved.

Noted. The future mine plan will take this into account.

3.5.19 Run-off from paved surfaces should be slowed down by the strategic placement of berms. No paved surfaces

3.5.20 Adequate measures must be implemented to prevent in stream siltation during the construction phase Maintenance is undertaken at the river diversion. Stormwater trenches/channels require maintenance.

3.5.21 Unless authorised by this licence, access roads must not encroach into the extent of the watercourse(s). Designated access roads are used

3.6 Biota

The river diversion is non-perennial and therefore there is no aquatic biota present. 3.6.1 The Licensee must take all reasonable steps to allow movement of aquatic species, including migratory species.

3.6.2 All reasonable steps must be taken not to disturb the breeding, nesting and/or feeding habitats and natural movement patterns of aquatic biota.

Pipeline on existing bridge crossing – no impact

3.6.3 The current level of diversity of biotopes and communities of animals, plants and microorganisms must be maintained.

4 Rehabilitation and Management

4.1

The Licensee must embark on a systematic long-term rehabilitation programme to restore the watercourse(s) diverted from the mining area to environmentally acceptable and sustainable condition after completion of the activities, which must include, but not limited to the rehabilitation of disturbed and degraded riparian areas to restore and upgrade the riparian habitat integrity to sustain a bio-diverse riparian ecosystem.

The river diversion is a permanent post closure diversion to prevent water from running over the rehabilitated opencast mine area causing erosion of the vegetated areas and increase the recharge to the aquifer.

4.2 All disturbed areas must be re-vegetated with an indigenous seed mix in consultation with an indigenous plant expert, ensuring that during rehabilitation only indigenous shrubs, trees and grasses are used in restoring the biodiversity.

The Rehabilitation Implementation Strategy Plan (RSIP) is currently being implemented and is updated if and when required. Existing rehabilitated areas have been used as a slurry disposal site. This has impacted on the existing placement of topsoil, prevents vegetation growth and formed erosion gullies.

4.3 An active campaign for controlling invasive species must be implemented within disturbed zones to ensure that it does not become a conduit for the propagation and spread of invasive exotic plants.

No invasive species control is in effect at current. Invasive species are posing a risk on disturbed areas.

4.4 Rehabilitation must be concurrent with construction. Noted – no construction currently underway

4.5 Topsoil must be stripped and redistributed Noted

4.6 Compacted and disturbed areas must be shaped to natural forms and to follow the original contour. In general cut and fill slopes and other disturbed areas must not exceed 1:3 ratio, it must be protected, vegetated, ripped and scarified parallel with the contour.

River diversion maintenance ensures compliance with this condition. Stormwater channels/trenches require attention to comply with this condition.

4.7 The Regional Head must sign a release form indicating that rehabilitation was done satisfactory according to specifications as per this license.

Final rehabilitation has not commenced

4.8 Rehabilitation structures must be inspected regularly for the accumulation of debris, blockages instabilities and erosion with concomitant remedial and maintenance actions.

Final rehabilitation has not commenced. Management measures must be put in place as to protect topsoil stockpiles from erosion. Areas that have been rehabilitated must be protected, future mine plan to ensure this condition is complied with.

4.9 A comprehensive and appropriate rehabilitation and management programme to restore the watercourse(s) to environmentally acceptable and sustainable condition after construction must be developed and submitted to the Regional Head for written approval within one (1) month from the date of issuance of this licence.

Maintenance of the river diversion currently ensures compliance with this condition.

4.10 The original contours must be established over the pipeline or bridge or road. After the backfill has subsided, the contour must follow the surrounding contours to stop irregular flows or blockage of biotic movement.

The pipeline is tied to the bridge. Where the pipeline is buried, the soils have been sloped and vegetated as to combat

erosion. This condition does not seem to be applicable to the approval granted w.r.t the pipeline and should be amended to be site specific.

4.11 A wetland Management and Rehabilitation Plan must be compiled by a wetland specialist when wetlands are affected and submitted to the Regional Head for written approval

The Wetland Management and Rehabilitation Plan formed part of the original licence documentation submitted to DWS. The approval of the licence assumes the approval of this document.

4.12 Wetland and stream crossing(s) must be visited by a wetland specialist prior to construction to determine baseline conditions. This shall be repeated during and after rehabilitation measures have been implemented to assess the success of rehabilitation and erosion control measures.

The wetland report and rehabilitation was submitted with the licence application and that the licence is the approval by the regional head. Wetland report (Wet-earth Geovicon Komati River – Madadeni Wetland Assessment 2011) done prior to construction

5 Monitoring and Reporting

5.1 The Regional Head must be notified in writing within one week prior to commencement of the licenced activities and again upon completion of the activities.

Done

5.2

A comprehensive and appropriate environmental assessment and monitoring programme (including bio-monitoring) to determine the impact, change, deterioration and improvement of the aquatic system associated with the activities listed under condition 1.1 of Appendix III as well as compliance to these water use conditions must be developed and submitted to the Regional Head for written approval before commencement and must subsequently be implemented as directed.

Monitoring plan was submitted and monthly reports are submitted to IUCMA.

5.3 Six(6) monthly monitoring reports must be submitted to the Regional Head until otherwise agreed in writing with the Regional Head Monitoring plan was submitted and monthly reports are submitted to IUCMA.

5.4 A qualified and responsible scientist must be retained by the Licensee who must give effect to the various licence conditions and to ensure compliance thereof pertaining to all activities of impeding and/or diverting flow of watercourses as well as alterations to watercourses on the properties as set out in condition 1.1 Appendix III

Aquatico Scientific (Pty) Ltd appointed as consultants for monitoring.

5.5 The Licensee must conduct an internal audit annually on compliance with the conditions of this licence. A report on the audit must be submitted to the Regional Head within one month of the finalisation of the audit. A qualified independent auditor must undertake this audit.

This condition reads the same as condition 10 of appendix I and should be removed

5.6 The audit report must include but are not limited to:

5.6.1 Reporting in respect of the monitoring programme referred to in condition 5.2;

5.6.2 A record of implementation of all mitigation measures including a record of corrective actions; and

5.6.3 Compensation measures for damage where mitigation measures have failed to adequately protect the in-stream and riparian habitat or any other characteristics of the watercourses.

5.7 The Licensee must apply in writing to the Regional Head: for alternative reporting arrangements for which written approval must be provided.

Original reporting arrangements adhered to.

5.8 An Environmental Management/Monitoring Committee (EMC) must be established consisting of, but not limited to, representatives of the Licensee, the Responsible Person(s) for ensuring compliance with this licence conditions, the Department of Water Affairs, the

Nkomati Mine is a member of the Nkomati Catchment Management Agency.

relevant Department of Environmental Affairs, the Department of Minerals and Resources, and other relevant stakeholders from the affected community. The EMC must be established by the Licensee.

Nkomati Mine has established the Nkomati Mining Forum

5.9 The EMC must in addition monitor compliance with the conditions of the Environmental Management Programme Report, for the duration of its establishment comply with the conditions of this water use licence.

A performance assessment of the EMP has been compiled.

5.10 A wetland specialist must be appointed to monitor the compliance to the wetland management and rehabilitation plan and conditions in this licence pertaining to impacts on wetlands and provide specialist advice for corrective actions and compile audit reports which must be submitted to the Regional Head.

Construction of the newly proposed purposefully designed river diversion and PCD near the oxbow has not yet commenced. The maintenance of the river diversion has proved to be sufficient to date.

6 Other Water Users

6.1 The Licensee must prevent adverse effect on other water users. All complaints must be investigated by a suitable qualified person and if investigations prove that the Licensee has impaired the rights of other water users, the Licensee must initiate suitable compensative measures.

Upstream and downstream monitoring will detect changes in the Komati River

7 Pollution Prevention, Incidents and Malfunctions

7.1 Pollution incidents shall be dealt with in accordance with the Act.

Oil spills have been greatly reduced due to the completed construction of a bunded area with a sump to store used oil containers, and the current construction of an additional bunded area. These bunded areas have not been correctly managed and mine management is aware of this issue and has committed to improvement.

7.2 Any incident that may cause pollution of any water resource shall immediately be reported to the Regional Head Noted

7.3 If surface and/or groundwater pollution has occurred or may possibly occur, the Licensee must conduct, and/or appoint specialists to conduct the necessary investigations and implement additional monitoring, pollution prevention and remediation measures to the satisfaction of the Regional Head.

Waste streams are not appropriately segregated. General and hazardous waste are currently mixed. Clean and dirty water separation requires urgent attention

7.4 The Licensee shall keep all records relating to the compliance or non-compliance with the conditions of this license in good order. Such records shall be made available to the Regional Head within 14 (fourteen) days of receipt of a written request by the Department for such records

Noted. Audit Report should be submitted to the DWS upon completion.

7.5 The Licensee shall keep an incident report and complaints register, which must be made available to any external auditor and the Department.

The mine has a complaints register which allows for logging all complaints and action plans taken.

8 Budgetary Provisions

8.1 The Licensee must ensure that there is a budget sufficient to complete and maintain the water use and for successful implementation of the rehabilitation programme as set out in this licence.

Noted

8.2 The Regional Head may at any stage of the process request proof of budgetary provisions for the rehabilitation and closure of project. Noted

Appendix IV – Section 21(g) of the Act: Disposing of waste in a manner which may detrimentally impact on a water resource

1 Storage of water containing waste

1.1

The Licensee is authorised to dispose a maximum quantity of waste or waste water into the waste management facility as described in table 4 below.

Noted Table 4: Volumes of waste water to be disposed

Facility and description Property Volume Coordinates

Disposing of dirty water found from underground into a return water dam

Un-surveyed state land owned by Matasamo tribal authority

55 760 m3/a

S 25º46’29.80” E 31º48’05.34”

The co-ordinates indicate that this is the PCD (two compartments) located at the processing plant. Water is currently being pumped from the underground to the old void north of the Nkomati River. The void has not been licenced to store water from the underground. The void must be licensed for the storage of water pumped from underground.

Disposing of dirty water into a pollution control dam (south dam)


55 470 m3/a

S 25º46’26.76” E 31º48’03.77”

The co-ordinates indicate that this is a 2

nd

PCD located at the processing plant. This facility has not been constructed.

Discard dumps


135 920.88 m3/a

S 25º46’44.04” E 31º48’07.54”

There is a discard heap at the processing plant. Discard from the processing plant is sold as product. Carbonaceous material as part of the overburden is placed back into the open pit areas as part of the roll-over method of mining as to ensure continuous rehabilitation. The old discard dumps have not been sufficiently rehabilitated.

Disposal of sewage into septic tanks and french drain


216 m3/a

Conservancy tanks have been installed for toilets only. These are cleaned via a Honey Sucker. French drains are used for change houses.

Disposal of dirty water into a pollution control dam (north dam)


37 670 m3/a

S 25º45’13.54” E 31º48’12.74”

The co-ordinates indicate the PCD north dam is situated at the underground mine area. There is no formal facility at the underground. Water from the waste rock dump areas are currently running into trenches from where it evaporates.

Coal Stockpiling


360 000 tons S 25º46’36.20” E 31º48’00.99”

Coal stockpiling not exceeding the authorised tons and co-ordinates are correct

Dust suppression Wildebeest 495 JU, 36 775 m3/a Nkomati Mine was unable to provide the

Rusplek 495 JU and Sweethome 496 JU Un-surveyed state land owned by Matasamo tribal authority

exact volume of water used for dust suppression. The volume indicated on the licence seems to be inadequate as it calculates to 100 m

3/day.

This may require amendment.

Stockpiling of Run of mine and product of the Madadeni Stockpile area


160 000 m3/a

S 25º49’47.6” E 31º47’47.6”

Co-ordinates on the licence indicate that the run of mine and product of Madadeni Stockpile is located in a clean water run-off area.

Disposal of dry slurry into a dry slurry stockpiling area


28 800 m3/a

S25º46’31.32” E 31º48’04.88”

The slurry is stockpiled and sold. This condition incorrectly states that the slurry is disposed and should be amended. The current slurry management facilities are inadequate and proper dewatering management practices are required. Nkomati Mine has appointed a design engineer as to investigate the options available and design these for approval by DWS prior to implementation.

Disposal of slurry into slurry settling dam


25 000 m3/a

S 25º46’32.21” E 31º48’07.09”

Co-ordinates to be amended to indicate the correct area for the slurry settling dams where currently located on-site. Nkomati mine has appointed a civil engineer for the design of an additional slurry settling facility to better manage the water on site.

Disposal of dirty water into the discard dumps evaporation dam

37 670 m3/a

This facility does not exist as no discard dumps are on-site.

Backfilling of Madadeni opencast pit during mine closure


135 920.88 m3/a

Activity will only commence once the Madadeni area has been mined.

Backfilling of old void pit 1


135 920.88 m3/a

Discard material is currently being backfilled of into the old voids.

Backfilling of old void pit2 Un-surveyed state land owned by

135 920.88 m3/a

Discard material is currently being disposed of into the old voids.

Matasamo tribal authority

The following water use is taking place within the 1:100 year floodline, exemption in terms of regulation 4 of GN704 of 04 June 1999 Disposal of dirty water into Madadeni pollutions control dam Unsurveyed state land owned by Matasamo tribal authority 18 615 m

3/a

S 25º49’58.0” E 31º48’04.3”

Noted.

1.2 The quantity of water containing waste authorised to be disposed of in terms of this licence may only be exceeded with authorisation in terms of the Act.

The mine is currently developing a materials and water balance as to determine the correct volumes to be authorised. Future man plan to influence how and where water is disposed of.

2 Construction, Operation and Maintenance

2.1 All facilities constructed to manage clean and dirty stormwater, seepage and or process water shall be constructed as per the proposed designs reflected in the reports listed in clause of the licence.

The Conceptual Stormwater Management Plan is outdated. Future mine plan to shape an updated storm water management plan.

2.2 The process dam systems must be operated under appropriate supervision and maintained in such a manner as to ensure that:

No erosion was detected at any of the PCDs. The ponds are lined with HDPE Liner and there is evidence of the liner tearing slowly. This will need to be repaired/replaced..

2.2.1 Wave action created by wind does not erode the inner sides of the pond walls;

2.2.2 A minimum freeboard of 0.8 meters be maintained for the mine residue facility return water dam above the expected maximum water level which is based on the average monthly rainfall figure for the catchment area concerned, plus the maximum frequency of once in every 50 years, less the gross mean evaporation for the; and

The PCD (two compartments) at the processing plant has been constructed according to an approved civil design and a freeboard of 0.8m is maintained. The PCD at the opencast area has not been constructed according to an approved civil design and therefore does not comply with this condition. A new PCD has been designed for the opencast area to address this. A concurrent rehabilitation and stormwater management plan for the life of Madadeni will be shaped by the future mine plan and implemented upon completion.

2.2.3 If, in the opinion of the Regional Head, the Pollution Control Dams fail to meet the requirements of this licence or otherwise constitutes a water pollution hazard, the Licensee must take such appropriate steps as may be deemed necessary by the Regional

Noted

Head.

2.3 Contour walls or furrows must be provided around the process dam system to prevent stormwater ingress or erosion of the evaporation pond walls and any wastewater from entering any river or stream


2.4 The construction, operation and maintenance of all dam facilities classified as a dam with a safety risk and Pollution Control Dams must be carried out under the supervision of a Professional Civil Engineer, registered under the Engineering Profession of South Africa Act, 1990 (Act 114 of 1990).

None of the dams at Nkomati are classified as a dam with a safety risk

2.5 The Operating Manual of the dam facilities shall include a water management plan that describes capacity and operating methods for the components of the water management system such as the minimum freeboard.

Nkomati Mine is in the process of developing an on-site water balance with correct capacities. Current facilities do not have an Operating manual but is managed in accordance to the requirements of GN704.

2.8 The Licensee shall implement the following erosion protection measures:

Invasive species are colonising on all disturbed areas and should be eradicated as soon as possible. Already rehabilitated areas have been compromised by disposal of slurry. These areas also show signs of soil erosion and gully formation.

2.8.1 The slopes of the Pollution Control Dams and berms shall be vegetated as soon as practically possible with appropriate seed mix.

2.8.2 All disturbed areas shall be vegetated as soon as practically possible with appropriate vegetation. Areas that fail to establish vegetation cover must be re-seeded immediately.

2.8.3 Where disturbed areas cannot be vegetated during the life operations of the dam, erosion control measures shall be implemented on all slopes exceeding 2% and engineered control measures on all slopes exceeding 15%.

2.8.4 Alien vegetation must not be allowed to colonise the area and all new alien vegetation recruitment must be eradicated or controlled, using standard methods approved by the Department.

2.8.5 Loose sack gabions (biodegradable sacks filled with soil and Cynodon dactylon seed) shall be placed within and/or around eroded areas.

2.8.6 The erosion zone shall be backfilled and seeded with appropriate seed mix, which will predominantly consist of creeping grasses.

2.9 The licensee must provide a detailed stormwater management plan for PCD’s. The stormwater management plant shall include details of the following:

Nkomati Mine is in the process of implementing a stormwater management and rehabilitation plan to reduce the dirty run-off area and comply with best practise.

2.9.1 Separation of clean and dirty water runoff: and

2.9.2 Surface water control measures

2.10 Groundwater monitoring programme shall include water level monitoring, rainfall records, tailings deposition data, and Aquatico has been appointed to conduct

hydrochemistry. groundwater monitoring on a quarterly basis. The condition should be amended to take out tailings deposition data as this is not applicable to Nkomati Mine.

2.10.1 The hydrochemistry must include: pH, electrical conductivity, total dissolved solids, calcium, magnesium, potassium, silica, chloride, total alkalinity, sulphate, nitrate, fluoride, iron, manganese, copper, and zinc.

Noted

2.11 The operating manual of the mine residue facility must include a water management plan that describes capacity and operating methods for the components of the water management system which will include the minimum freeboard, the closest acceptable distance of pool from perimeter and the decant arrangements.

This condition should be amended as to be more applicable to the mining operations. There are no mine residue facilities on site. Slurry is managed at the slurry dewatering sumps and stockpiled to be sold.

2.13

The Licensee shall establish a Pollution Control Dams management system appropriate for the size, complexity and safety classification of the residue disposal facility. The management system must include a policy, setting of objectives and targets, an organisational structure, the definition of duties and responsibilities, the setting of procedures and methods, training, performance monitoring, reporting and response mechanism, emergency preparedness plans, management review procedures and auditing of the tailings.

Nkomati Mine is in the process of developing a future mine plan which will influence a stormwater management and rehabilitation plan to reduce the dirty run-off area and comply with best practise.

2.14

The licensee must manage and operate the facility in accordance with the design plans and specifications. Notwithstanding these specifications, the operator of the facility shall advice the professional person on any circumstances or aspect of the facility that, according to his operating experience, might either endanger the integrity of the disposal facility of present a risk to the public or the environment.


3 Monitoring

3.2 Surface Water Quality

Monitoring conducted according to this WUL condition

3.2.1 The licensee must submit within one month of the date of the issuance of this licence, a surface water quality monitoring programme, with the GPS co-ordinates and the criteria used in the selection of the water monitoring points.

3.2.2

The following variables (constituents) must be included in the surface monitoring programme:

Table 5: Monitoring parameters to be analysed

pH

Electrical Conductivity (EC) mS/m

Total Dissolved Solids (TDS) mg/l

Suspended Solids (SS) mg/l

Total Alkalinity ( mg/l

Total Hardness mg/l

Nitrates (NO3) mg/l

Chloride (Cl) mg/l

Fluoride (F) mg/l

Iron (Fe) mg/l

Zinc (Zn) mg/l

Manganese (Mn) mg/l

Aluminium (Al) mg/l

Sodium (Na) mg/l

Magnesium (Mg) mg/l

Calcium (Ca) mg/l

Potassium (K) mg/l

Sulphate (SO4) mg/l

3.2.4 The location of additional monitoring points, which may form from time to time be specified by the Regional Head, shall be communicated in writing to the Licensee and this communication shall be regarded as part of the licence.

Noted – no new points communicated

3.3 Groundwater Quality

Noted and submitted

The Licensee must within one month of the date of this licence submit a ground water quality monitoring programme which must provide the detailed criteria followed in the establishment of the groundwater monitoring point as described below:

Table 6: Groundwater monitoring points

Location Description Longitude Latitude

Washing plant GCS1 -2850824 80325.04

Underground working GCS2 -2850245 80304.49

Underground working GCS3 -2852236 80764.88

Opencast mining GCS4 -2858059 80823.56



Washing plant GCS7 -2858620 80485.19

3.3.2 Samples from the relevant boreholes of different sites, where the groundwater in the boreholes are at expected higher hydraulic pressure levels than the hydraulic pressure levels in the groundwater under the sites, shall be considered as background monitoring.

Noted

3.3.3 Monitoring boreholes must be clearly marked and numbered, and must be equipped with lockable caps. The department deserves the right to sample monitoring boreholes at any time and to analyse these samples, or to have samples taken analysed.

Noted

3.3.4 The licensee must maintain the groundwater quality monitoring network to the satisfaction of the Regional Head, so that unobstructed sampling, as required in terms of this licence, can be undertaken.

Noted

3.3.5 The groundwater monitoring programme must include water level monitoring, rainfall records, tailings deposition data, and hydrochemistry.

The condition should be amended to take out tailings deposition data as this is not applicable to Nkomati Mine.

3.3.6 Groundwater monitoring points must be selected to measure the following:

Opencast and underground areas monitored 3.3.6.1 Groundwater impacts (quality and levels) associated with both opencast and underground mining activities;

3.3.6.2 Inter-mine flow (quality and levels); There is no inter mine flow

3.3.6.3 Quality and water levels of the participating mines underground mine workings Underground workings monitored

3.3.7 The licensee must monitor the impact of activities along geological structures that may act as preferential pathways for contaminant transport.

Compliant

3.3.8 The licensee must monitor direct impacts associated with the disposal of waste Direct impacts monitored

3.3.9 The licensee must monitor the impact of the activities on downstream groundwater users at the monitoring points and; Downstream points monitored

3.3.10 The licensee must provide a list of all groundwater monitoring points within the Mine’s property. The list shall include the following:

The water monitoring reports received from Aquatico contains this information. The borehole at the underground requires registration in order to abstract water.

3.3.10.1 Borehole reference

3.3.10.2 Description of the area where they are situated (location)

3.3.10.3 Coordinates

3.3.10.4 Monitoring frequency and

3.3.10.5 Variables analysed.

3.3.11 The frequency of sampling must not be changed prior to notification and written approval by the Regional Head Frequency has not changes

3.3.12 The licensee shall use acknowledged methods for borehole sampling and the date, time, sampler and borehole number must be indicated for each sample.

Information captured in the quarterly groundwater monitoring report by Aquatico.

3.3.13 The licensee shall make provision for the sampling of any additional monitoring requirements that might be required form time to time as specified by the Regional Head.

Noted

3.3.14 The proposed monitoring borehole network, potential scavenger boreholes must be identified or drill a new one along the boundary between the Komati River and Plant Area.

Boreholes between the plant and Komati River are monitored.

4.4 Investigative Monitoring

Noted

If, in the opinion of the Regional Head, water pollution may be or is occurring, or a water quality variable at any monitoring point shows an increasing trend, the Licensee shall initiate an investigation into the cause of the problem or suspected problem.

4.5 Bio-monitoring

4.5.1 Bio-monitoring shall be performed within the surface water resource to determine ecological integrity of the Noupoort Spruit on an ongoing basis.

Bio-monitoring is undertaken twice a year by Aquatico. The licence condition should be amended as to read “Komati River” instead of Noupoort Spruit

4.5.2 The sampling points shall be determined by an aquatic specialist

4.5.3 Ecological measures to be used for the biological monitoring programme must be as follows:

4.5.3.1 Aquatic macro-invertebrates must be sampled using the latest SASS (South African Scoring System) method;

4.5.3.2 Habitat Integrity must be assessed using the rapid method described by the Department of Water Affairs and Forestry (1999);

4.5.3.3 Fish Assemblages Integrity (FAII);

4.5.3.4 Riparian and Aquatic Vegetation Assessment; and

4.5.3.5 Whole Effluent Toxicity (WET) Tests.

4.5.4 Any variable, frequency of monitoring or additional monitoring points as may be required from time to time by the Regional Head, shall be adhered to.

5 Reporting

5.1 The licensee must update the water balance annually and calculate the loads of waste emanating from the activities. The licensee must determine the contribution of their activities to the mass balance for water resource and must furthermore co-operate with other water users in the catchment to determine the mass balance for water resource reserve compliance point.

The future mine plan will influence when and how water is used around the site. This will be used to finalise the water balance..

5.2 The licensee must submit the result of analysis for the monitoring requirements to the Regional Head on a quarterly basis under reference number 27/2/2/X13J/049

The monitoring reports are submitted to IUCMA by the mine directly.

5.3 The licensee must submit the nature and the quality of the waste disposed into the following dams and the water to be used for dust suppression on bi-annual basis

The nature of the water disposed in these facilities is determined through the toxicity

5.3.1 Madadeni pollutions control dam testing as undertaken by Aquatico. The monitoring reports are submitted to DWS.

5.3.2 Pollution control dam (South Dam) This dam does not exist

5.3.3 Pollution control dam (North Dam) This dam does not exist

5.3.4 Return water dam at the processing plant

The nature of the water disposed in these facilities is determined through the toxicity testing as undertaken by Aquatico. The monitoring reports are submitted to DWS.

6 Stormwater management

6.1 All runoff water (stormwater) arising as a result of precipitation:

The issue of stormwater management and clean and dirty water separation have been identified as areas of major concern and the new mine management is aware of this. The need for a future mine plan which will influence effective stormwater management has been stressed as a priority.

6.1.1 On land adjacent to the waste disposal sites; and

6.1.2 On the mine residue facility, must be prevented from coming into contact with any substance, whether such substance is a solid, liquid, vapour or gas, or combination thereof, which is produced, stored dumped or spilled on the premises, including leachate.

6.2 All stormwater must be diverted and drained around the Pollution Control Dams and from the working face of the Pollution Control Dams, by means of works constructed by the licensee.

6.3 Runoff may not be discharged to a watercourse and /or the environment unless it complies with the quality requirements as may from time to time be determined by the Regional Head, but must be diverted to and contained in works constructed by the Licensee.

No discharge of water is undertaken

6.4 Runoff water which comply to the quality requirements as may from time to time be determined by the Regional Head, will be regarded as uncontaminated runoff water and must be diverted away from the waste disposal sites to the environment and discharged into a watercourse at a point downstream of the waste disposal sites after verification of compliance by the Regional Head.

The issue of stormwater management and clean and dirty water separation have been identified as areas of major concern and the new mine management is aware of this. The need for a future mine plan which will influence effective stormwater management has been stressed as a priority.

6.5 Runoff water which does not comply with the quality requirements as may from time to time be determined by the Regional Head, may not be discharged to a watercourse or the environment, but must be regarded as contaminated runoff and must be collected and contained in facilities constructed from where it must be dealt with accordingly.

6.6 In the event that runoff water becomes contaminated with seepage or as a result of the operational activities on the premises of the licensee to the extent of not complying with the water quality requirements as may from time to time be determined by the Regional Head

6.6.1 The information regarding the quality of the water must be supplied to the Regional Head; and

6.6.2 This waste must be contained on the PCD sites in facilities constructed for this purpose, until the Regional Head has informed the licensee otherwise.

6.7 All seepage produced by the pollution control dams, must be collected in subsoil and surface seepage interception drains and containment works

6.8 No seepage or contaminated runoff water may be discharged to a watercourse or environment

The dirty water trench at Madadeni has broken into the clean water trench and not into the Madadeni PCD. A new PCD design has been completed by an engineer with the intention of solving this problem. Significant maintenance has been undertaken on the river diversion to ensure its functionality.

7 Access control

7.1 The licensee must ensure effective access control on the mine residue facility to reasonably prevent entry of domestic animals, game and unauthorised persons while the solid waste disposal sites are operative and during the period of construction or closure.

The entire mine area is fenced off

7.2 Notices prohibiting unauthorised persons from entering the mine residue facility, as well as an internationally accepted sign indicating the risks involved in unauthorised entry must be displayed at suitable intervals along the boundary fence of the solid waste disposal site.

Notices are up against the fence

7.3 The licensee must take all reasonable steps to maintain service roads in a condition which ensures unimpeded access to the mine residue facility for vehicles involved in closure construction and/or transporting waste and must keep these roads free of waste.

Only authorised access routes can be used

7.4 The licensee must ensure that all entrance gates are manned during the hours of operation/closure construction and locked outside the hours of operational/closure construction.

All gates at the mine are manned and access controlled.

8 Contingencies

8.1 Accurate and up-to-date records shall be kept of all system malfunctions resulting in non-compliance with the requirements of this licence. The records shall be available for inspection by the Regional Head upon request. Such malfunctions must be tabulated under the following headings with a full explanation of all the contributory circumstances:

Ad hoc records are available on site and need to be formalised into a reporting system.

8.1.1 Operating errors

8.1.2 Mechanical failures (including design, installation or maintenance)

8.1.3 Environmental factors (e.g.flood)

8.1.4 Loss of supply services (e.g. power failure) and other causes

8.2 The licensee must, within 24 hours, notify the Regional Head of the occurrence or potential occurrence of any incident which has the potential to cause, or has caused water pollution, pollution of the environment, health risks or which is a contravention of the licence conditions.

Noted – no incidents /potential incidents occurred since the last audit and the mine had nothing to reported to DWS

8.3 The licensee must, within 14 days, or shorter period of time, as specified by the Regional Head, from the occurrence or detection of any incident referred above, submit an action plan, which must include a detailed time schedule, to the satisfaction of the Regional Head of measures taken to:

No incident has occurred 8.3.1 Correct the impacts resulting from the incident

8.3.2 Prevent the incident from causing any further impacts

8.3.3 Prevent a recurrence of a similar incident

9 Auditing

9.1 The licensee must conduct an annual internal audit on compliance with the conditions of this licence. A report on the audit shall be submitted to the Regional Director within one month of finalisation of the report, and shall be made available to an external auditor should the need arise

This condition is a repeat of condition 9 of Appendix I and should be removed or placed under the General Licence Conditions.

9.2 The licensee shall appoint an independent external auditor to conduct an annual audit on compliance with the conditions of this licence. The first audit must be conducted within 6 (six) months of the date this license was issued and a report on the audit shall be submitted to the Regional Director within one month of finalisation of the report.

This condition is a repeat of condition 10 of Appendix I and should be removed or placed under the General Licence Conditions.

10 Integrated Water and Waste Management

10.1 The Licensee must update an Integrated Water and Waste Management Plan (IWWMP), which must together with the Rehabilitation Strategy and Implementation Programme (RSIP), be submitted to the Regional Director for approval within one (1) year from the date of issuance of this licence.

IWWMP update was done in 2015 (Alta van Dyk Environmental Consultants cc – Annual Revision of the Integrated Water and Waste Management Plan and Rehabilitation Strategy and Action Programme – Nkomati

10.2 The IWWMP and RSIP shall thereafter be updated and submitted to the Regional Director for approval, annually.

Anthracite (Pty) Ltd) and 2016. A 2017 version is currently being compiled and will be submitted before the end of 2017.

10.3 The Licensee must, at least 180 days prior to the intended closure of any facility, or any portion thereof, notify the Regional Director of such intention and submit any final amendments to the IWWMP and RSIP as well as a final Closure Plan, for approval.

Noted.

10.4 The Licensee shall make full financial provision for all investigations, designs, construction, operation and maintenance for a water treatment plant should it become a requirement as a long-term water management strategy.

Noted.

11 General Conditions

11.1

Water samples must be taken form all the monitoring boreholes by using approved sampling techniques and adhering to recognised sampling procedures. Samples must be analysed for both organic as well as inorganic pollutants, as mining activity often lead to hydrocarbon spills in the form of diesel and oil. At least the following water quality parameters must be analysed for:

Monitoring conducted according to this licence condition. An appropriate database is kept by Aquatico Scientific (Pty) Ltd who conduct the monitoring.

Table 9: Water quality parameters

Chemical parameters Unit Quality objectives

pH 4-5 & > 9.5-10

Total Dissolved Solids mg/l 0-450

Electrical Conductivity mS/m 150-300

Calcium as Ca mg/l 150-300

Magnesium as Mg mg/l 70-100

Sodium as Na mg/l 200-400

Chloride as Cl mg/l 200-600

Sulphate as SO4 mg/l 400-600

Nitrates as NO-N mg/l 10-20

Fluoride as F mg/l 1.0

12 These must be recorded on a data sheet. It Is proposed that the data shall be entered into an appropriate computer database and reported to the Department of Water Affairs.

Appendix V – Section 21 (j) of the Act: Removing of water found underground

1

The licensee is authorised to remove a maximum quantity of water found underground as indicated in table 8 below

Table 8: water use activities

Water from the underground is pumped to an open void before used during process. The new mine management has realised the need to develop a future mine plan. This will determine exactly how water is moved around the mine and in what volumes this water is moved. This will assist in developing a water balance for the entire mine. Total annual dewatering volumes estimated from one month’s readings indicate that 263 904m

3/a is pumped from the

underground workings to void. Inflow into the underground is rainfall and

Section 21 (j)

Removing water found in underground working

S 25º45’16.3” E 31º48’34.4”

recharge dependent.

Section 21 (j)

Taking water from Madadeni Opencast pit for reuse in the processing plant

Unsurveyed state land owned by Mawewe Tribal Authority

3 6 50 m3/a

S 25º45’56.1” E 31º47’48.4

Water use has not commenced. Currently no water transferred from Madadeni to the processing plant. The water balance to confirm the amount of water that will be transferred to the processing plant in the future.

2

The licensee is authorised to dispose water found underground into pollution control dams as indicated in Table 9:

Table 9: dirty storage facility to be used

Water disposed into the Madadeni PCD – Co-ordinate of the PCD is correct. A new PCD has been designed by an engineer for the Madadeni Opencast area.

Facility X Coordinate Y Coordinate

Madadeni Pollution Control Dam S 25º49’58.0” E 31º48’04.3”

Pollution control dam (north dam) S 25º46’57.8” E 31º48’27.0”

The co-ordinates given in the WUL indicate that the facility is located at the old void south of the processing plant. Section 21(g) of this licence also refers to the Pollution Control Dam (north dam) which is situated at the underground workings. It is assumed that this condition also refers to the facility at the underground workings. This facility does not exist and water from underground is pumped to an old void north of the Komati River before being pumped to the Processing Plant PCD.

3 The quantity of the water authorised to be removed and disposed of into the Pollution Control Dams in terms of the this licence may not be exceeded without prior authorisation by the Regional Head

Amendment required as PCD (north dam) authorised by this licence has not been constructed. Flow metering requirement.

4

The quality of the water disposed of into the Pollution Control Dams must not exceed the quality as specified in the Table 10 below:

Chemical Parameters Unit Quality Objectives

pH 4-5 & > 9.5-10

Electrical conductivity mS/m 70 – 150

Calcium as Ca mg/l 80 - 150

Magnesium as Mg mg/l 70 - 100

Sodium as Na mg/l 100 - 200

Chloride as Cl mg/l 100 - 200

Sulphate as SO4 mg/l 200 - 400

Nitrates as NO-N mg/l 06 - 10

Fluoride as F mg/l 0.7 – 1.0

Electrical conductivity, Calcium, Magnesium, Sulphate and Flouride all fell below the prescribed parameters. The issue of stormwater management and clean and dirty water separation have been identified as areas of major concern and the new mine management is aware of this. The need for a future mine plan which will influence effective stormwater management has been stressed as a priority. This will have impacts on the water qualities.

5 The licensee must provide any water user whose water supply is impacted by the water use with

2017 Water Use Licence Internal Audit...2019/05/05 · An internal audit was done on the Water Use...

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