Criteria for the evaluation of EMP as an environmental ...

ii

CRITERIA FOR THE EVALUATION OF EMP AS AN ENVIRONMENTAL

IMPACT MANAGEMENT TOOL: A CASE STUDY

by

ANDRIES JOHANNES VAN DE WALT

SHORT-DISSERTATION

submitted in partial fulfillment

of the requirements for the degree

STE - OF ARTS

in

GEOGRAPHY AND ENVIRONMENTAL MANAGE ENT

in the

FACULTY OF ARTS

at the

RAND AFRIKAANS UNIVERSITY

STUDY LEADER: PROF PAJ VAN RENSBURG

NO EMBER 1996

CRITERIA FOR THE EVALUATI F EMP AS AN ENVIRONMENT L IMPACT MANAGEMENT TOE Lz

A CASE STUDY

A.J. valn der 1/ s3M

iii

CONTENTS

List of figures

Ust of talbEsa

Abstact

Opsomming

Chapter 1 — Introduction

1.2 Aim of the study 2

1.3 otivation for the study 3

1.4 Method of the study 5

Chapter 2 — Theoretical Background to the Environmental

Management Program 7

2.1 Introduction 7

2.2 Definition and Nature of EMP 7

2.3 The E M P process 9

2.3.1 Identify Environmental Management requirements 10

2.3.2 Management goals 10

2.3.3 Project actions 11

2.4 The place of EMP in Integrated Environmental Management 14

2.4.1 The IEM procedure for new activities 17

2.5 Conclusion 21

iv

Chapter 3 ® Evaluation criteria for EMP as derived from

a theoretical background 22

3.1 Introduction 22

3.2 The formulation of evaluation criteria for EMP 23

3.2.1 Characteristics and requirements of E P 23

3.2.2 Formulation of a set of criteria for the evaluation of E P 29

3.2.3 questionn =lire for the evaluation of an RAP

31

3.2.4 Interpretation of the questionnaire

35

3.2.5 Chart for interpreting the questionnaire

41

3.3 Conclusion

45

Chapter 4 — Evaluation of the case study

47

4.1 Introduction 47

4.2 Evaluation of the case study 49

4.2.1 Evaluation report for the case study 49

4.2.2 Evaluation of the case study by questionnaire 59

4.3 Conclusion 61

Chapter 5 ® Interpretation and presentation of

the results of the evaluation 62

5.1 Introduction 62

5.2 Results of the evaluation by questionnaire 62

5.3 Visual presentation of the results of the evaluation questionnaire 65

5.4 Identification of the issues and major areas of concern 67

5.5 Recommendations and conclusions in respect of the case study 69

5.5.1 Co-ordination between this E P and other environmental

and management tools 70

5.5.2 Ongoing monitoring of the impacts on the environment

and the appropriate report-back procedures 71

5.5.3 Reviewing of the EMP 72

5.5.4 Training of personnel 72

5.5.5 Environmental policy and standards of the organization 73

5.5.6 Specific goals and objectives for the management of the

environmental impacts

74

5.5.7 Designation of responsibility

75

5.6 Conclusions on the case study

76

Chapter 6 — Conclusion

78

eferences

Appendix A

84

bl

LIST OF FIGURES

Figure 1: Progression off a study

Figure 2: Using r g a EMS proc es as framework for ENP

Fo tare 3: BEM prfOC dame ff®r sw activities

Fig re 4: Results for Section' A

Figu 5: exults for Section

Fl tor 6: -- ercenta e vd es for the di rent focus ram

Fagan, 7: The evaluation pr .,o es s pil in this Mu y

Figure = esul > f r Sect n

Figure 9: sults f r Sec on 0

Figure 10: Percentage values for the ifWerent focus area

Figur 11: Pr salon of t he study

6

94

65

66

67

80

vi i

LIST OF TABLES

T blle 1: ht factor vallues fce,r Section A

Table 2: Weight factor val es f r Secti 013 io

Tablle 3: Colour c odes for foc s areas

Table 4: Chart for interpret! g th ESP quest n ire

Table 5: Summary o the qualitative evaluation

7a le 6: Chart fo: Er late r.rrttgg the EllinP uestionnaire

41

83

viii

ABSTRACT

The Environmental Management Program (EMP) is a tool that is frequently used

in the management of environmental impacts associated with economic

activities. It exerts great influence in many environmental decisions affecting

most of the economic sectors in South Africa. This can be ascribed to the fact

that EMP is often the only tool used for the management of the environmental

impacts inherent to these activities. It is therefore of great importance that this

tool should be effective in all respects. An effective EMP can contribute greatly to

the practice of environmental impact management in that it will enhance the

exploitation of natural resources in a sustainable manner, thus stimulating

economic activity.

It is incontrovertible that no tool will be and remain effective if it can not be

evaluated in accordance with accepted scientific norms. Such a process of

evaluation should improve the adaptability of EMP to the manifold requirements

of the changing and dynamic environment to Which it applies, in a way that will be

uncomplicated in its application. Lastly, the quality of any environmental

management tool should be evaluated in order to protect the credibility of the tool

by ensuring that it is always applied effectively.

One of the major problems currently encountered with EMP is that there exist

virtually no generally accepted measures aimed at evaluating the quality and

effectiveness of this tool. This study therefore attempts to fill this gap by

formulating a set of criteria that can be used for the evaluation of EMP.

The set of evaluation criteria developed in this study was derived from a literature

study regarding the definition, concept, structure and nature of EMP. This

discussion lead to a list of characteristics and requirements regarding EMP. This

list of characteristics and requirements were then clustered into areas with

commonality and were subsequently used to devise and structure the set of

ix

criteria. The evaluation criteria thus arrived at, were then employed in the

formulation of a simple questionnaire that can be used generally to evaluate

EiV1P.

The process for the evaluation of E P formulated in this study is illustrated by

applying it to a specific case study. A relatively small refractory and ceramic clay

quarry was chosen for this purpose. It was selected because EMP plays such an

important role in the management of the environmental impacts in the mining

sector. It is the belief of the author that the recommendations and conclusions

flowing from this application of the proposed evaluation process might be useful

to improve this specific EMP, as well EMP in the mining sector in general.

It is furthermore believed that the proposed evaluation process and the

demonstration thereof in this study will lead to a better perspective on the

practice of EMP as an effective nvironmental impact management tool.

OPSOMMING

Die omgewingsbestuursprogram (OBP) is 'n instrument wet dikwels gebruik word

in die bestuur van omgevifingsimpakte, wet 'n direkte gevoig is van bykans elke

ekonomiese aktiwiteit. Dit maak hierdie instrument rigtinggewend in verskeie

omgewingsverwante besluite en sodoende oefen dit 'n info -=d uit in die meeste

van die ekonomiese sektore. Hierdie noemenswaardige invloed ken toegeskryf

word aan die fait dat 013P dikwels as enigste instrument in die bestuur van

omgewimgsimpakte gebruik word. Om hierdie rede is dit van besondere belang

dat OBP in ells opsigte effektief most funksioneer. 'n Effektiewe P ken 'n

groot bydrae !ewer tot impakbestuur as omgewingsbestuurspraktyk, deurdat dit

die volhoubaarheid van die wyse waarop natuurlike hulpbronne aangewend

word, ken verhoog en sodoende ekonomiese aktiwiteit stimuleer.

it is onweerlegbaar dat pen instrument effektief sal wees of bly, indian dit nie

voortdurend geevalueer ken word volgens aanvaarde wetenskaplike norms nie.

Sodanige evalueringsproses behoort die aanpasbaarheid van 0 P by die

menigvuldige vereistes van die dinamiese omgewing waarop dit van toepassing

is, te verhoog. Dit is verder ook belangrik dat hierdie proses aenvoudig sal wees

om toe te pas. In die laaste plek is dit belangrik om die kwaliteit van enige

omgewingsbestuursinstrument te evalueer, t n einde te varseker dat die

geloofwaardigheid van die instrument beskerm word deurdat dit altyd effektief

toegepas word.

Een van die grootste probleme wet tans met OBP in Suid Afrika ondervind word,

is dat dear gean algemeen aanvaarde maatstawwe bestaan wet gebruik ken

word om hierdie instrument te evalueer nie. Met hierdie studie word gepoog om

die gaping wet in die lig hiervan geIdentifiseer is, te vervul deur die formulering

van 'n stet kriteria wet gebruik ken word om OBP te evalueer.

xi

Die stel evalueringskriteria wet in hierdie studie ontwikkel is, is onttrek uit 'n

lieratuurstudie wet ondersoek ingestel het na die definisie, konsep, struktuur en

acrd van OBP. Die literatuurstudie het gelei tot die opts! van 'n lys waarin at die

belangrike karaktereienskappe en vereistes van 01- P verteenwoordig is. Hierdie

lys is as 'n volgende step georden sodat at die karaktereienskappe en vereistes

gegroepeer is in groepe met gemeenskaplikheid, oftewel fokusareas. Die

aangepaste lys is v rvolgens gebruik vir die formulering van 'n stel kriteria wet

gebruik ken word vir die evaluering van OBP. Die sodanig geformuleerde kriteria

is in 'n vardere step aangswend om 'n eenvoudige vraetys op to stel wet

algemeen vir die evaluering van OBP gebruik ken word.

Die proses van evaluering wet in die loop van hierdie studie geformuleer is, is

vervolgens geIllustreer deur die toepassing daarvan op 'n spesifieke

gevallestudie. 'n P elatief klein vuurvaste en keramiek-klei oopgroef-myn is gekies

as gevallestudie. Die spesifieke gavel is geselekteer op grond daarvan dat OBP

so ln besonder belangrike plek in die bestuur van omgewingsimpakte binne die

mynbou sektor inneem. Die outeur is van mening dat die voorstelle en

gevolgtrekkings wet uit die evaluering van hierdie gevallestudie voortgespruit het,

bruikbaar mag wees vir die verbetering van hierdie spesifieke OBP, maar ook

van OBP in di = mynbousektor as geheel.

Dit is verder die vertroue dat die voorgest•Ide evalueringsproses asook die

demonstrasie daarvan deur hierdie studie, sal lei tot 'n hater perspektief met

betrekking tot OBP as 'n effektiewa omgewingsimpak bestuursinstrument.

1

CHAPTER 1 - INTRODUCTION

Managing the environment in a sustainable manner has become increasingly

important over the past decade. This is the case in all the different sectors of

economies worldwide. Greater emphasis is placed on the specific activities that

make up our economies and the impact they have on the environment. This has

lead to the current situation, where environmental management plays a vital role

in the management of the activities in all the different sectors of the economy.

Such is also the case in South Africa where a higher degree of environmental

awareness has lead to policies and legislation that work towards the

sustainability of all activities within our economy.

Environmental management uses a variety of tools to achieve its specific goals

and objectives, which all strive towards greater sustainability of all human

activities (Fuggle & Rabie, 1996). This study will focus on one such tool, namely

the environmental management program.

The Environmental Management Program (Hereafter: E P) is a tool that is

frequently used in the management of environmental impacts associated with

economic activities. This tool holds great power in many of the economic sectors

in South Africa, since it is often the only tool used for the management of the

environmental impacts (Van Zyl, 1997). It is therefore of great importance that

this tool should be effective in all respects. A very relevant question is therefore

to ask whether this tool is applied effectively and whether it succeeds in its

objectives of advancing sustainability within each specific context.

This study will attempt to provide a guideline to answering this question by

formulating a set of criteria that can be used to evaluate an EMP and thereby

determine the successfulness of each evaluated case.

2

This set of criteria will then be used to evaluate a specific case study. The aim of

this evaluation is to illustrate the process of evaluation formulated by this study,

but also to ascertain the overall effectiveness and successfulness of the case

study EMP. As this E P was compiled according to a specific guideline

document, this evaluation will also make it possible to form an opinion of the

standard of this document.

1.2 Aim of the study

The aim of this study is to formulate a set of criteria for the evaluation of an EMP.

The criteria will be formulated in a way that will make it applicable to EMP in

general. The evaluation criteria will thus have to be of general nature so that it

will not only be applicable to a certain type of EMP or to a certain economic

sector. For that reason the set of criteria will be formulated according to the

findings of an intensive literature study, which will look into the characteristics

and requirements that are set for EMP. This study will make use of the most

recent and prominent sources available in a published form.

As mentioned in the previous paragraph the set of criteria that will be formulated

will also be used to evaluate a specific case study. This case study includes an

E P of a relatively small opencast mine in the Mpumalanga province. The mine

is a refractory and fire clay quarry situated approximately 17km north of

Bronkhorstspruit and 31 km north-east of Cullinan, at 28°45'00" longitude and

25°30'00" latitude on the remainder of the farm Blesbokfontein 459 JR. The clay

quarry belongs to an international company with its headquarters in France.

3

103 Motivation for the study

EMP is currently a widely used environmental impact management tool in South

Africa (Joughin et al., 1997). It does however seem that there may be some

shortcomings that influence the effectiveness of the results obtained by this tool.

One of the major problems experienced with E P is that there exist virtually no

measures aimed at controlling the quality and effectiveness of this tool. This

tends to lead to the situation where the term EMP is used for a variety of reports

that deal with environmental issues. It does however not necessarily mean that

they deal with these issues in the way an EMP is supposed to do. This can be

seen as a shortcoming in the literature as well as in the environmental practice

as applied on a day-to-day basis.

This shortcoming served as motivation for this study. It is the opinion of the

author that EMP is in reality a very powerful environmental impact management

tool that can serve the project management of any project well in pursuing their

overall environmental aims and objectives. This does however mean that the

EMP would have to be effective and successful in its handling of the relevant

environmental issues of the project. It is however a fact that no tool will be and

remain effective if it is not controlled and monitored in some way, since it is

applicable to a changing and dynamic environment.

It is furthermore important that the quality of any environmental management tool

be controlled in order to protect the credibility of the tool by ensuring that it is

always applied effectively.

The above mentioned reasons motivated the author to attempt with this study to

formulate a set of criteria and a procedure that can be used for the evaluation of

an EMP. This study therefore represents an attempt to fill the gap in the

literature, as well as in the environmental practice as described in this paragraph.

4

The criteria and procedure for evaluation that will be formulated in this study

might provide a useful tool in the environmental practice that could be used by

anyone who wishes to gain the benefit flowing from evaluating a certain E P. It

might prove to be useful to a variety of people, Whether it be an environmental

practitioner evaluating an EMP, or just a person concerned with the project that

wants to judge the quality of their EMP.

It is the wish of the author that this study will lead to a better perspective on this

subject, from which all people concerned with EMP as an environmental

management tool will benefit.

The case study that was chosen is concerned with a small clay quarry as

described in the previous paragraph. This specific case was chosen because

E P plays such a great role in the management of the environment in the mining

sector. The intensity of the impacts that the mining sector has on the

environment has made the role of environmental management even more

important and thereby placed even greater emphasis on EMP as an impact

management tool.

It can therefore be understood that EMP, as applied in the mining sector will have

received a lot of criticism over the past few years. Some of those criticisms are

well substantiated while others seem to be very biased -,nd subjective (Van Zyl,

1997; Boonzaaier & Van der Walt, 1997).

It is however the opinion of the author that EMP in the mining sector is not

functioning as well as it should. For this reason, this specific case study was

chosen. This study will provide a chance to evaluate the EMP of a mine and

thereby form an opinion of the way the tool is functioning in this specific case.

EMP in the mining sector in South Africa is structured in accordance with a

specific guideline document, namely the Aide Memoire (Department of Mineral

and Energy Affairs. 1992. Aide Memoire — For the preparation of Environmental

5

Management Programme Reports for Prospecting and Mining. RSA). This

document determines the way in which all EMPs in the mining sector are

structured and presented, as well as the quality of the information it contains

since it determines what information will be included in the E".'P document. This

document determines the quality and thus the usability of the E Ps. The

evaluation of the case study will therefore also serve to evaluate the Aide

Memoire as a guideline document used for the compilation of EMf-s in the mining

sector.

IA Method of the study

The progression of this study is illustrated by Figure 1

As mentioned earlier, the aim of this study is to formulate a set of criteria for the

evaluation of an EMP. This set of criteria will be derived from the literature. For

this reason, the study will firstly include an in-depth literature study of the concept

of EMP. This will include a definition of the term and a discussion of how this tool

is viewed by different sources in the literature.

From this discussion, a list of characteristics and requirements regarding EMP

will be derived. These will then be used to formulate the set of evaluation criteria.

The evaluation criteria will eventually be used as framework for the evaluation

questionnaire that will be formulated.

The questionnaire will form part of the procedure that will be illustrated with the

evaluation of the case study. This procedure is illustrated in Figure 7

Chapter 1

Chapter 2

Formulation of evaluation criteria

Chapter 3

Formulation of evaluation

questionnaire

Interpretation of questionnaire .

Chapters 4 & 5

Chapter 6 Conclusion of the study

6

Figure 1: Progression of the study

7

CHAPTER 2 - THEORETICAL BACKGROUND: AN BRIEF

LITERATURE OVERVIEW

2.1 'Introduction

This chapter will provide some theoretical background to EMP. The information

contained in this chapter is of a general nature in the sense that it does not

specifically focus on mining, but is applicable to the larger picture of

environmental management. The reason for this is to get a broad background,

which will make it possible to consider the case study in context.

The focus will therefore be on the definition and nature of E P, as well as the

way it functions and its place within the broader context of environmental

management.

The purpose of this chapter is to give a short theoretical background of EMP

based on the literature, from which a list of criteria can be derived that will ensure

the effective evaluation of the case study.

2.2 Deffinftrion and nature of OW

Several definitions exist for the term E P. The majority of these however focus

on the aim and purpose of EMP, rather than on being a direct definition of the

term. EMP is therefore described by the function it fulfills. A few such definitions

are:

"The aim of an EMP is to describe how negative environmental impacts will be

managed and monitored, how positive impacts will be maximised and how

negative areas will be rehabilitated" (Preston, 1993) ...with regard to a specific

development project.

8

According to the Department of Environmental Affairs (1992c) "The purpose of a

Management Plan is to describe how negative environmental impacts will be

managed, rehabilitated or monitored and how positive impacts will be

maximised".

Lucas (1997) uses the definition found in Preston (1993) to describe E P. He

describes it with the following statement: "An E P is a document that should be

generated from the outcome of some form of environmental assessment. For a

proposed new development, this could be an Environmental impact Assessment

(EIA). In this case the EMP would be to mitigate or avoid predicted impacts. For

an existing operation, process or plant it could be from an Environmental Risk

Assessment, an Environmental Management System (EMS) audit, or a Life

Cycle Assessment (LCA). In the case of an existing operation, the E P would

set out specifications to either mitigate or eliminate those identified impacts as

occurring or the identified risk areas and operations. The aim would be to

achieve specified environmental performance goals and objectives. The E P is

there to set out actions to be taken and standards to be met in order to avoid,

control, reduce or remediate adverse environmental impacts so as to conform to

EIA findings and recommendations, Life-cycle Assessment evaluations,

legislation obligations, permit requirements, license conditions and an

organisations policies and standards".

With this quotation, Lucas (1997) touches on a few important characteristics of

EMP. The first is that it should b = based on the results of one or the other form of

Environmental Assessment. An E P can not function by itself. It forms part of

a chain of tools working together to ensure effective management of the

environment. The extent of this statement will be discussed in another section

that is to follow later in this chapter. At this stage it will be sufficieht to state that

an E P forms the next logical step after an Environmental Assessment has been

done. It is, in other words, the instrument that makes the results of the different

forms of assessment relevant by offering an action-orientated plan to follow up

9

on the assessment. Another important characteristic is that an EMP should

always work towards specific environmental aims and objectives. These aims

and objectives should also be derived from the results of the specific assessment

on which the EMP was based.

With the following Lucas (1997) points to further characteristics of EMP which are

determinative to the nature of this tool: "Each requirement or specification of the

EMP must be measurable or quantifiable. The EMP should have an objective,

goal or target, a responsible person, adequate resources and a time frame. To

implement the EMP, through the management thereof, it must be measurable. To

audit and ensure compliance, it must be against something quantifiable. The test

should then be to ensure that each requirement of the EMP could be quantified".

The specific nature of EMPs are well described by the following quote from the

Department of Environmental Affairs (1992c) guideline documents for Integrated

Environmental anagement: "For environmental damage to be minimised, firstly

mitigation measures need to be identified. Secondly, authorities should be able to

ensure they are being implemented and thirdly, their effectiveness should be

monitored. The various mitigating measures should be organized and

coordinated into a structured and well formulated plan which will guide the

construction, operation and decommissioning of the development".

In this paragraph, the term Environmental Management Program was defined

and the nature thereof described. The next section will focus on the EMP process

itself. It will describe the process for the development of an EMP and the way it is

to be structured.

2.3 The EMP process

A matter of particular importance that should be kept in mind when dealing with

EMP is that an EiViP is compiled to be an environmental management tool in the

hands of project and operational staff. It is a tool that should enable them to meet

10

their environmental responsibilities and targets, and is not for the benefit of the

environmental practitioner. Clearly then the EMP must be compiled and

implemented into the existing project or operational management systems,

structures, processes and terminology.

The general process for the development and integration of the EMP, as

described by Lucas (1997), is the following:

2.3.1 "Menttofy EnvOroramenta0 wag a = nt op.& mend

Identify the environmental elements or issues that need to be addressed,

managed or controlled. These issues would be determined through the

undertaking of some form of assessment. For new development projects it would

be an Environmental Impact Assessment (EIA). For an existing operation or plant

it could be from a Life-cycle Assessment (LCA), an Environmental Risk

Assessment (ERA) or an Audit. These issues could include:

Waste management

Water management

Air pollution

Dust

Noise

Aesthetics

Rehabilitation

Storm water control

Protection of fauna and flora

2.3.2 Management ode

After determining the environmental issues, these should then be translated into

specific management goals or objectives, e.g. water quality standards that should

be adhered to.

11

2.3.3 PgpfleCt Acto ne

Each of the goals and objectives that are required need to be actioned. It must

be established what action is required to achieve the set of goals and objectives.

The project actions can be one of the following:

Construction of a facility (eg. water treatment plant)

Development of specific operational procedures for the carrying out of certain

activities (eg. to preserve archeological sites)

Specific siting of plant or activities

Policy setting with respective authorities (not internal organizational policy)

Specialist studies may be required

Monitoring requirements

Liaison with the authorities in connection with information on the project

Contract conditions for specific requirements for the contractor to achieve or

adhere to

Permits, where specific permits may be required and thereafter adhered to."

Lucas (1997) claims that by following the above procedure, it can be ensured

that environmental management requirements are effectively integrated into the

project management actions and contracts as well as operational systems and

processes.

The International Standards Organization's ISO 14001 (1996) document focuses

on the development of Environmental t. anagement Systems (EMS). It states

that, in order to comply with their requirements regarding an E S: "The

organization shall establish and maintain (a) programme(s) for achieving its

objectives and targets.

It shall include:

designation of responsibility for achieving its objectives and targets at each

relevant function and level of the organization;

the means and the time-frame by which they are to be achieved.

12

Of a project relates to new developments and new or modified activities, products

or services, programme(s) shall be amended where relevant to ensure that

environmental management applies to such projects".

Although this specification does not stipulate what the specific structure of the

EMP should be or how it should function, it clearly highlights the essence of an

EMP from their point of view. On doing so it points to certain important

characteristics of a successful and effective EMP within the broader context of an

EMS.

The Department of Environmental Affairs (1992c) also points out that certain

information is of vital importance when structuring an E P: "An effective

Management plan will be a practical document which precisely sets out both the

goals and actions required in mitigation or optimization. It should include at least

the following information:

Specific goals of the anagement plan

Details of management actions

Party responsible for carrying out management recommendations

Timing and duration of management actions

Personnel, training and financial implications."

This document also stresses the importance of monitoring once an effective

management plan is in place: "Some impacts may need ongoing monitoring or

management and these requirements should be outlined, along with appropriate

report-back procedure.

Monitoring may include:

e A check that actions are in line with conditions of approval

13

A check that mitigation measures are being implemented during the

construction phase

A check on the efficacy of these measures

Emissions monitoring

Monitoring of selected environmental variables."

This specification clearly points out that monitoring forms an important part of the

EMP, since it is the only means by which to ensure that it stays relevant and that

it is functioning properly.

From the ISO 14001 document can be concluded that an EMP forms an integral

part of an EMS. Lucas (1997) explains the role of EMP in an EMS by the

following statement: "Achieving sound environmental performance requires that

the organization implement and maintain an Environmental Management

System (EMS). An EMS provides order and consistency for an organization to

address environmental concerns through the commitment to an overall

environmental policy, the identification of existing and potential environmental

impacts, the setting of objectives and targets, the allocation of resources and

responsibilities and the continual evaluation of practices, procedures and

processes. The development and implementation of environmental management

plans or programmes (EM Ps) is not only an integral part of the requirements of

the E S, it is also the management tool for achieving the aims and objectives of

an organization's environmental policy".

When EF<aP is viewed in this context, it can be concluded that the actual design

of an EMP must be integrated and be an ongoing and interactive process of

continual improvement, as is the case with an EMS.

The E P process can therefore be illustrated by using the model used by the

ISO 14000 (1996) guidelines to illustrate the EMS process:

14

Figure 2: Using the EMS process as framework for EMP

M NAGEMERT

REVIEW

TOP MANAGEMENT TO

REVIEW EMP FOR

IMPROVEMENT

COMMITMENT TO

EMP

SUPPORT FOR EMP

PLANNING

EVELOPMENT OF EMP

o ID ROOT C USES & IMPACTS

EMP TO COVER LEGAL STD'S

SET OBJECTIVES & TARGETS &

KPI'S

CHECKING EMP &

CORRECTIVE ACTION

MONITORING & MEASUREMENT

o CORRECTIVE 8) PREVENTIVE ACTION

o RECORDS

o AUDIT / ASSESSMENTS

SOURCE: (LUCAS, 1997:12)

IMPLEMENTATION OF EMP

STRUCTURES & RESPONSIBILITIES

TRAINING, AWARENESS &

COMPETENCE

°COMMUNICATION (REPORTING)

OPERATIONAL DOCUMENT

CONTROL

°EMERGENCY PREP; EDNESS

Figure 2 illustrates the E1.1P process with all the essential elements that should

be included, in order to ensure that the E P could be effective.

This paragraph has now described the EMP process and the different elements

of an EMP. The following paragraph describes the place of EMP within the larger

structure of Integrated Environmental Management.

2.4 The place of EMP in Integrated Environmental Management

During April 1998 the Department of Environmental Affairs and Tourism

published a discussion document, namely Discussion Document - A national

strategy for Integrated Environmental Management in South Africa (April 1998). It

forms part of a process by which a new national strategy for Integrated

Environmental Management in South Africa is being developed. The document is

15

a draft strategy that was published in order to give the public an opportunity to

comment on its contents. It is however safe to assume that this document

represents the direction in which IEM and therefore Environmental anagement

in South Africa will be moving in the future.

This paragraph is based on the draft document mentioned.

According to Department of Environmental Affairs and Tourism (1998), EMP

should be seen as a management instrument within the bigger context of

instruments for Environmental Impact anagement. This instrument is described

as follow.

An environmental management programme (E P) for a new or existing activity

is a detailed plan and programme for the implementation, by an activity initiator,

of the conditions contained in the conditions agreement. An EMP specifies how

the activity is to be carried out in order to remain within the requirements of those

conditions and how all environmental impacts are to be managed for the duration

of the activity's life-cycle. Approval of the EMP by the relevant executive

environmental authority is a prerequisite for commencement of a new activity or

continuation of an existing activity that has been subjected to the IEM process."

The EMP will lay the basis for all the environmental management actions

associated with an activity, including audits and management systems, and

provides a budgetary framework to make provision for their implementation. An

EMP will specify how the activity initiator's resources (financial, human,

equipment, etc.) are to be used to control and manage the activity's

environmental impacts.

The EMP provides the framework for the application of all other subsequent

environmental management instruments to an activity, once the EMP has been

compiled by the activity initiator and accepted by the environmental authority.

16

Together with a conditions agreement, an EMP will always have to be in place

before an activity may proceed. It is therefore not an optional element of IEM, but

a compulsory one.

The first statement in the description of EMP that arrests attention, is the very

prominent place that is given to E P within the IEM context. It is not only

described as an important management tool, but as the 'framework' for the

application of all the subsequent tools. It is described as the tool that specifies

the actions to be taken to comply with the conditions that are associated with a

certain activity. It can thus be concluded that a new policy will view E P as of

much more importance than it has been in the past.

Henceforth the place of EMP within the larger context of the Integrated

Environmental anaging process, as formulated in the previously mentioned

discussion document is addressed.

The process of lEn described in this document differs somewhat from the

process as described in the previous Guideline Documents (Department of

Environmental Affairs, 1992), which is currently, still in place.

The greatest difference lies in the fact that the discussion document suggests

four different processes for IE , depending on the kind of activity that is dealt

with. The motivation for the implementation of these different procedures is

described by the following:

"To date IEM relied on a single procedure. The limitations of this is that it fails to

adequately address the environmental impacts of land use zoning plans and

schemes and the impact of existing activities. By using more than one procedure

the special requirements of each type of activity can be met much more

effectively" (Department of Environmental Affairs and Tourism, 1998).

17

The different procedures that are suggested are designed to cater specifically for:

fl Land use zoning plans and schemes

New activities

Existing activities, and

Activiti es in terms of an OW-approved land use zoning plan or scheme.

Not all of these procedures are addressed, because the aim of this paragraph is

merely to describe the place of EMP in this process. A study of the different

procedures has shown that the role of EMP stays the same in all these

procedures. Therefore only one procedure, namely the procedure for new

activities, will be described in detail.

2A1 The OEM procedure f r new actOvitOss

This procedure will be set in motion with an ctivity listed under Section 21 of the

Environment Conservation Act, 1989 (Act 73 of 1989). This will not include

activities that fall within the ambit of a land use zoning plan or scheme.

The procedure is illustrated in Figure 3 and comprises the following steps:

step 1: ActOvky pro , (0 - 810

At a conceptual stage (before any decisions have been made) a proposal for the

activity being contemplated should be formulated in the form of a concise report.

All permit applications to the different permitting authorities and environmental

resource managers should be made at this stage.

Step 2: Au orOty mvIew in t rms of the provincial EINF

The relevant environmental authority will review the proposal in terms of the

relevant provincial Environmental Management Framework (EMF). It should be

r

a

a

a

Activity Proposal Ca 01 0 =7 0 10

END LE

0 0 0>

Authority

Step described in tent

Normal flow

Possible iteration

Possible additdon

0 0 [[:).• Negative decision

0 0 0

0 :4thor .

coeao •tierested*id'4061t .„, .-:11 ,

olicr grement

EMF Environmental Management Framework

EIA Environmental Impact Assessment

COM Cost Benefit Analysis ROD Record of Decision EMP Environmental Management

Draft EMP

Appeal

Activity initiator

Qidesr ndent consultant

18

FCC 3: EN proceduy for nGtR9 actfivMes (Department of Environmental Affairs and Tourism, 1998)

19

noticed that from the provincial E F it might immediately be apparent that the

activity is not permissible under any circumstance, in which case the next steps

will be unnecessary.

St p 3: Sc*ping

An independent consultant must do scoping. All government authorities with

permitting- or environmental resource management responsibilities relevant to

the activity, should be consulted during the scoping process. This is necessary in

order to determine their needs and information requirements for the issuing of

permits/authorizations, so that these needs can be addressed sufficiently in the

Environmental Impact Assessment, should an EIA be required.

Step 4: 1161401N

In this step, the scoping is reviewed by the relevant authority, interested and

affected parties that took part in the scoping process and relevant authorities

responsible for the management of one or more environmental resources. If the

scoping report contains sufficient information for a decision to be made, the

proposal may either be rejected or accepted. Should there be insufficient

information or should the potential environmental impacts identified in the

scoping report be significant, an environmental impact assessment of the

proposal will be requested.

Step 5: Envir mental Impact mess nt

An Environmental Impact Assessment (EIA) must be done by an independent

consultant — either the same one that did the scoping report or a different one.

The issues addressed in the EIA will be based on the issues identified in the

scoping report. The EIA may use existing information or require new information

to be obtained. In certain cases, the EIA may also include a Cost Benefit

Analysis (CBA) for public sector activities. No CBA will be required for private

sector activities. The EIA will generate an environmental impact report (EIR) that

will be submitted to the relevant authority. The completed EIR will be referred

20

back into the review process. A decision must then be taken based on the EIR.

Whatever the outcome of the decision, a record of decision (ROD) should be

kept by the authority and made publicly available.

Step 6: ComoMona agFeeMGM

If the activity is approved in terms of the review of the scoping report or the

environmental impact report, the conditions agreement sets the conditions in

terms of which the activity will be allowed to take place. The Authorization and

Permit Review Committee must integrate the conditions set by different

permitting and environmental resource management authorities in the conditions

agreement. The conditions are negotiated between the activity initiator and the

environmental authority. The aim of the conditions agreement is to internalize

externalities, so that the costs of the significant environmental impacts caused by

the project are borne by the initiator rather than the public.

Step 7: Envir*nmentag Management Prove) me

An EIVIP is either prepared by the activity initiator or with the assistance of an

independent consultant. The Er. P is a detailed plan and programme for the

activity initiator's implementation of the conditions contained in the conditions

agreement.

Step 6: OOP ReAew

The draft E. 1 13 is reviewed by the environmental authority and interested and

affected parties to determine whether it conforms to the negotiated conditions

agreement.

step 9: App roval E rA P

The environmental authority approves the EA. P once it is satisfied that the EafilP

conforms to the conditions agreement.

A study of the above process indicates that EMP plays a vital role in the OM

procedure, since the entire procedure flows into the ENIP and the approval

21

thereof by the relevant environmental authority. It can therefore be concluded

that EMP should be seen as a step within a wider procedure and that that role

gives relevance and meaning to this tool.

2.5 Comhalm

The aim of this chapter was to provide a theoretical background of the

Environmental Management Program that can be used to formulate a set of

criteria for the evaluation of this tool.

This chapter therefore consulted the most recent and prominent sources on the

subject in the context of the South African situation. Those sources were firstly

scrutinized for a definition of the term EMP. Secondly the specific nature of the

tool was described. Thirdly, a study was made of the E P process and the way

the tool functions. The final paragraph then analyzed the place of E P within the

framework of Integrated Environmental Management.

In the next chapter, this information will be used to formulate a set of criteria for

the evaluation of an EMP. Those criteria will then be translated into a

questionnaire and used to evaluate the previously mentioned case study.

22

CHAPTER 3 ® EVALUATION CRITERIA FOR EMP AS

DERIVED FROM A THEORETICAL BACKGROUND

3.1 Ontr d ction

In the previous chapter, a theoretical study of EMP was reported on. The aim

was to highlight characteristics and requirements regarding EMP.

This chapter will now focus on the specific characteristics and requirements as

found in the literature. After these characteristics and requirements have been

described, they will be formulated as criteria for evaluation and categorized under

a few headings or areas to be focused on when evaluating an EMP.

The last paragraph of this chapter describes a questionnaire that can be used for

the evaluation of an EMP. This questionnaire will be based on the evaluation

criteria as formulated in paragraph 3.2.2.

3.2 The formulation f evaluation trite a for EMP

3.2.1 - Characteristics and requirements of EMP

The following paragraph will describe the specific characteristics and

requirements of EMP as derived from the previous chapter. These characteristics

and requirements are described by making use of a list. Each issue is

substantiated by reference to its sources in the literature, as described in

Chapter 2.

23

The characteristics and requirements of EMP include:

Larcy er framework: The first and maybe one of the most important characteristics of EMP is that it

can never function as an isolated tool, but instead forms part of the larger

framework of environmental management. It should therefore not be seen as

an isolated tool that will satisfy all the needs of managing the environment.

The literature strongly emphasizes this characteristic, as is evident from the

numerous paragraphs in Chapter 2 that address this issue (Department of

Environmental Affairs and Tourism, 1998; ISO 14001, 1996; Lucas, 1997).

The literature shows that EMP forms part of the process of IEM as it

represents the step in which the whole process culminates. It also illustrates

EMP as an integral part of any EMS. The literature is in other words quite clear

on the fact that an EMP is only one of the tools of environmental management

and can not function as an entity on its own. It is however a very important tool

since it gives rel vance to many of the other tools (Lucas, 1997).

g3) Cr,;mmitm nt to MP

For any project or task an organization attempts, it is of vital importance that

the whole organization, especially the top management thereof, should be

committed to the task. Without this support from the management, the project

can seldom be successful. EMP is no different in this respect. Total support for

the E P, from both management and the rest of the team is necessary in

order to implement it successfully in the organization (Lucas, 1997).

o) Man gement *if negativ nd p skive a pacts

EMP should manage both the negative and positive impacts that the activities

of an organization have on the environment. The EMP should contain

specifications that describe how negative impacts will be minimized, either by

the implementation of mitigatory measures, or by avoiding the activities that

will have adverse environmental impacts. It should however also describe how

24

positive environmental impacts could be maximized (Lucas, 1997; Preston,

1993).

I G P zhoulld be based on mulles off other toolle

The next important characteristic is that the EMP document should be

formulated in terms of the results obtained from some other form of

environmental assessment ctepartment of Environmental Affairs and Tourism,

1998; Lucas, 1997). This fact again emphasizes that EMP can not function in

isolation. An EMP for a new development project is normally based on the

results of an Environmental Impact Assessment (E1A). For existing operations

it can be based on the results of an Environmental Risk Assessment, an EMS

audit, or a Life-Cycle Assessment (Lucas, 1997). Since ElikiiP takes the results

of the different forms of environmental assessments and transforms them into

action plans and objectives, it can be regarded as the management tool that

gives relevance to many of the other tools in environmental management.

EMP shoadd stipa.date X00 actOons to be taken

An EMP should clearly stipulate the specific actions to be taken in order to

manage the impacts of the project activities on the environment. This should

be done in a manner that will ensure that the negative impacts are minimized

and the positive impacts maximized (Department of Environmental Affairs,

1992c; Department of Environmental Affairs and Tourism, 1998; 18014001,

1992; Lucas, 1997). This information forms the core of the EMP and is

therefore of paramount importance.

ST) Statement off the enedronntenta0 pofificy and standards

The EMP should state the specific policies and standards of the organization

itself. It should state the environmental policy of the organization, as well as

the specific standards that the organization has set for itself (Lucas, 1997).

This is necessary to ensure that the organization is committed to the EMP and

the successful implementation thereof.

25

Saaaentent of goalie and obl'ectrive's

The aim of an EMP is to achieve specified environmental goals and objectives.

This means that specific goals and objectives for the management of the

environmental impacts, by means of mitigatory measures and rehabilitation,

should be stated dearly in the EMP document. The literature study indicated

this as a very important component of any EMP. Without specific goals and

objectives, the actions and measures proposed by the EMP can never be

effective, since it will not be measurable in any way. This in turn means that

there will be no way to ensure that it will be relevant and effective in the

management of the environmental impacts. With this in mind, it is imperative

that every EMP contains an objective as well as distinct targets and goals.

These targets and goals must all be derived from the assessment that the

EMP was based on (Department of Environmental ffairs, 1992c; Department

of Environmental Affairs and Tourism, 1998; ISO 14001, 1996; Lucas, 1997).

NesetoreablOOV and quant0f0aMOV off Onformadon

If the management of any project is to work towards specific goals and targets,

it can be concluded that all measures, standards, goals and objectives

proposed in an E P, should be measurable or quantifiable. This is necessary

to enable the responsible person or environmental authority to evaluate these

measures, standards, goals and objectives (Lucas, 1997).

I) Do warignaion of responaMllty

It is important that (a) person(s) responsible for the implementation of the

different actions as stipulated in the EMP must be designated. This does not

necessarily have to refer to one person, but it should clearly designate the

responsibility for achieving the stated objectives and targets at each relevant

function and level of the organization (ISO 14001, 1996; Lucas, 1997).

.1)) Tkne frame

The EMP should stipulate a specific time frame for the actions to be taken.

This again, is aimed at making the measures proposed in the EMP more

26

quantifiable. It makes it possible to determine whether the objectives and

targets of the EMP are adhered to (ISO 14001, 1996; Lucas, 1997). This time

frame should stipulate dates for actions to be taken and time related phases

for rehabilitation.

Aveneb000qy of resources

The EMP should also stipulate the means by which the objectives and targets

will be reached. This means that adequate resources should be available for

the actions to be taken. It is important that this information should be included

in the EMP document, in order to enable the responsible person and the

relevant environmental authority to evaluate the EMP (ISO 14001, 1996;

Lucas, 1997).

0) The daffereot phases of .ahe prcleca

The management plan should give guidance throughout the entire project.

Therefore it should address the construction, operational and the

decommissioning phases of the project (Department of Environmental Affairs,

1992c). It is important that the EMP distinguishes between the three phases of

a project since they entail different kinds of actions in different kinds of

situations.

m) Onaearsifth off .ahe

Another requirement emphasized by ISO 14001 (1996) and Lucas (1997) is

that an Er,1P should be fully integrated into the existing project or operational

management systems, structures, processes and terminology. This means

that the EMP must be integrated into the systems by which the other aspects

of the project are managed. It is clear then that the EMP should form part of

the overall management of the project. In order to do this, it is important that

the structure and processes of the EMP as well as the terminology used

should be familiar to the people that Will eventually implement and use the

EMP.

27

UnderzgaandabOney of Ole EMP

The above mentioned requirement leads to another important matter, namely

that an EMP is meant for the benefit of the project or operational staff of the

specific development. It is a tool that should enable them to meet their

responsibilities and targets, and is not for the benefit of the environmental

practitioner (Lucas, 1997). This should be kept in mind whenever an EMP is

compiled. An EMP should therefore be as elementary as possible, both in

structure and in terminology, as the project or operational staff of a project will

in many cases have very little knowledge about sound environmental

practices.

o) OdscrMiceaon of the amuse .Ro add'essed

Any EMP should specifically identify the environmental issues to be addressed

by the EMP. These issues should be derived from the environmental

assessment preceding the EMP and should include at least the following:

Waste management

Water management

Air pollution

Dust

Noise

Aesthetics

Rehabilitation

Storm water control

Protection of fauna and flora.

These are the issues that should be translated into specific management

goals and objectives as mentioned earlier (Lucas 1997).

53) Trakang off parsonnell

Another issue raised by the Department of Environmental Affairs (1992c) is

the matter of personnel training. The entire EMP would be rather inefficient if

28

no provision is made for the training of personnel. It is only through using well-

trained personnel that an EMP can be implemented effectively.

q)) CommunAcerion channeDs Of equal importance is the effective communication of all relevant information

between personnel concerned with the project. This means a two-way flow of

information between the different levels of the organization. The EMP should

therefore include a plan or actions that will provide for the necessary

communications required in order that the ERfJP can be implemented

effectively (Department of Environmental Affairs, 1992c).

[11 Non0.2oFfing The next important issue is that of monitoring. Some impacts may need

ongoing monitoring and management and these requirements should be

outlined in the EMP, along with appropriate report-back procedures

(Department of Environmental Affairs, 1992c). This will ensure that these

impacts will not be neglected once the EMP is in place.

a) nevOswOng of the ENP Another issue related to that of monitoring, is the review of the EMP by project

management. It has been stated that the E'.1, process should be an ongoing

process of continual improvement (ISO 14001, 1992; Lucas, 1997). It is

therefore important that the management of the project should review the EMP

on a regular basis, and effect amendments where necessary. This will ensure

that the EiViP stays relevant and up to date and that all new issues that may

arise will be included in the document and therefore in the management of the

project.

Pv©AzOon ffor egme[rgeneez The EMP should also make provision for emergencies, e.g. spilling of

environmentally hazardous chemicals. This issue goes hand in hand with the

earlier mentioned issues of training and communication, but the necessary

29

steps to be taken in an emergency situation should also be included in the

EMP document itself. This is necessary since the personnel on site in most

cases will have very little information about the effect of such an impact on the

environment. Nor will they know which actions are to be taken in an

emergency, should one arise (Lucas, 1997).

3.2.2 FormdleMoull oq oetZ Of crAerda qsar evakla'on off ean ENG ,

In this paragraph, the characteristics and requirements listed in the previous

paragraph will be transformed in order to represent a list of criteria for the

evaluation of an EMP. To make these criteria more easily understandable and

interpretable, they will be arranged under certain focus areas or areas with some

commonality. This step is necessary in order to provide some structure to the

criteria for evaluation.

A study of the above mentioned characteristics and requirements has shown th t

each is applicable to a certain aspect of the E".'P. The first group that was

identified concentrates on the process itself and its place within the context of

environmental and project management. The criteria associated with these

characteristics and requirements will be arranged under the heading of Process

and CoMea The second group is concerned with the nature of the EMP and

the information it contains. These will be placed under the heading: NEWT® of

Me ENG) and le finfonnallon Ut contafine. Another group entails specific

information that should be present in the EMP for it to be complete. They will be

put under the heading of: Omportanq OnforrrnaTdon reguked. There is however

one aspect that is always determinative to the success of the EMP. This aspect

entails the cononntiment manageTneffilg End personnell tc) ete IMP and to

environmental management in general. For any EMP to be successful, it is of

utmost importance that the project and operational staff will be fully committed to

the objectives and targets set out in the EMP. This will therefore form another

group in the evaluation criteria as formulated in this paragraph.

30

In this paragraph the characteristics and requirements, as described earlier in

this chapter, will be arranged under the headings named above, and then they

will be transformed into criteria for the evaluation of an E 'P:

1. Comllvdtment to the ENP

The management and all personnel of the organization should be fully committed

to and have complete knowledge of the purpose, goals, targets, objectives and

actions set out in the EMP

2, Promo mnd content

1) An EiViP should always be implemented together with other environmental

management tools and thus as part of a larger process of environmental

assessment and management.

An E P should be based on the results of an EIA for new projects and on the

results of an Environmental Risk Assessment, an EMS audit, or a Life-Cycle

Assessment in the case of an existing project.

An EMP should address the construction, operational and decommissioning

phases of the project.

An EMP should be fully integrated into the existing project or operational

management systems, structures, processes and terminology.

An EMP document should make provision for ongoing monitoring and

appropriate report-back procedures.

Project management should review the EMP on a regular basis.

30 Rldanve off the ENP and the Wornutllon COMMOW

1) An EMP should state the environmental policy of the organization, as well as

the specific standards that the organization has set for itself.

31

2) An E r.' P should manage both positive and negative impacts on the

environment.

3) An EMP should clearly state specific goals and objectives for the

management of the relevant environmental impacts.

6) All measures, standards, goals and objectives contained in an EMP should be

measurable and quantifiable on a specified measuring scale.

5) An EIViP should be as elementary as possible, in structure and in terminology.

11n .iformation Mauldin] lin the ENID

11) An EMP should specifically identify the environmental issues to be addressed

by the document.

An E , . , P should specify the different actions to be taken in order to manage

the relevant impacts on the environment.

An EMP should stipulate a specific time frame for the actions to be taken.

6) A person or persons responsible for the implementation of the different

actions as stipulated in the EMP must be designated.

5)) Information regarding the financial and other resources available to reach the

goals and objectives of the EMP should be included in the EMP document.

OD An EMP should make adequate provision for emergency situations that may

arise.

7) An EMP should make provision for the adequate training of personnel.

8) An E P should identify the appropriate communication channels to ensure

the adequate flow of information in the organization.

302.3 A quest6onna6re ?or the evahllat6on o? IMP

In this paragraph a questionnaire will be presented that can be used for

evaluating an EMP. This questionnaire is based on the evaluation criterion that

was formulated in paragraph 3.2.2.

32

The aim of this questionnaire is to simplify the process for evaluating an EMP.

This step is necessary since the people that have to make the decisions

regarding an E"P in an organization in many cases will not be formally schooled

environmental practitioners. For this reason, it is the aim of this questionnaire to

make it easier for them to form an accurate opinion about an EMP and thereby

promote sound decision-making in this regard.

Another benefit of this questionnaire is that it makes it possible to assign different

weight factor values to the different criteria that can be used to evaluate the

EMP. This makes it possible to distinguish between the different criteria in

accordance with their level of importance (Mouton & Marais, 1985).

The questionnaire also makes the criteria measurable and quantifiable, which will

ensure better and more objective analysis of the information (Goode & Hatt,

1979). It also simplifies and enhances the presentation of the information, and

thereby makes the whole process of evaluating an EMP more understandable to

people with little knowledge of the subject.

It is however important to note that this questionnaire taken on its own can not be

claimed to be satisfactory for the evaluation of an EMP. For a complete

evaluation, it is still necessary that an in-depth report must be compiled that

evaluates the EMP in detail.

This report will in fact precede the evaluation by questionnaire and will be of a

qualitative nature. Although the aim of the evaluation is to provide a quantitative

evaluation that is measurable and therefore understandable, this qualitative

report will provide the background and basis for the completion of the

questionnaire. The aim of that report is therefore to provide the information

necessary to complete the questionnaire so that it will reflect the true status of

the EMP to be evaluated quantitatively.

33

The questionnaire consists of two sections. The first section includes questions

and statements that should be evaluated on an ordinal scale that varies between

one and five (1-5). A "one" on this scale will indicate that this specific aspect of

the EMP is evaluated as totally insignificant or not present at all. A "two" will

indicate that the aspect in question is present but that there are major

shortcomings associated with this aspect. A "three" will typically mean that the

aspect is evaluated as average, while a "four" or a "five" will indicate that this

aspect is evaluated as above average, adequate and exceptionally good.

Different weights have been assigned to the different aspects. These weights are

based on the prominence given to the specific aspect in the literature, as well as

the influence that this quality will have on the rest of the EMP. As an example,

the aspect of ongoing monitoring carries much less weight than the aspect of

commitment of management and personnel to the EMP. That is why a weight of

three was assigned to the latter, as opposed to the weight of one assigned to the

first. These weights nevertheless do not affect the completion of the

questionnaire in any specific way, since it only becomes functional with the

revising of the questionnaire after it has been completed. The value that each

aspect will carry will be stated in a paragraph to follow.

The second section of the questionnaire consists of simple questions with a

positive or a negative answer, and therefore represents an evaluation on a

nominal scale. This means that they will simply be answered with a Yes or a No.

Similar to the previous section, different values have also been assigned to the

aspects addressed in this section, based on the importance of the specific aspect

for the complete EMP.

The following section of this paragraph presents this questionnaire

34

QUESTIOMMAORE FOR rIE EVALUATOOM OF z EIrP

Mark the applicable box with an 'X' 9. Commitment of management and personnel to the EMP

Knowledge of the aims, objectives, targets and actions set out in the EMP To what extent is is EMP linked up with other environmental assessment and management tools? How well is the EMP integrated into the existing project or operational crnanagement systems, structures, processes and terminology? Does the EMP make adequate provision for:

Ongoing monitoring? The appropriate report-back procedures?

5. Is the EMP reviewed on a regular basis?

7. How well does this EMP manage: Negative impacts on the environment?

Positive impacts on the environment? Measurability and quantifiability of the measures, standards, goals and objectives contained in the EMP Understandability of the structure and terminology of the EMP and the information it contains Does the EMP identify all the environmental issues that are to be addressed in the document? Does the EMP specify effective actions for the management of each identified environmental issue?

< 5 NA

Existing project: is this EMP based on

1. In the case of a: New project: Is this EMP based on the results of an EIA?

e results of an ERA, EMS

Mark the applicable box with an 'X' 0

Does the EMP make adequate provision for emergencies that may arise? Does the EMP make adequate provision for training of personnel?

Does the EMP identify appropriate communication ch nnels th t will ensure the adequate glow off information in the organization?

YES NO

audit or a Ufe-Cycle assessment? Does the EMP address the constructional, operational and the decommissioning phases of the project? Does the EMP state the environmental policy and standards of the organization? Does the EMP state specific goals and objectives for the management of the identified environmental impacts? Does the EMP stipulate a specific time frame for the actions to be taken?

5. Does the EMP include information regarding the financial and other resources that will be used to reach its objectives and targets?

7. Does the EMP designate (a) person(s) responsible for the implementation off the actions to be taken?

35

3.2.6 MtarpestWon of the quissUomaks

This paragraph will describe how the foregoing questionnaire should be

interpreted to ensure an effective evaluation of the EMP.

This questionnaire was based on the evaluation criteria presented in Paragraph

3.2.2. The criteria have been divided into two groups. The nature of the first

36

group determines that an evaluation of the quality of the specific aspect is

required, which should then be transformed to a grading on an ordinal scale,

which in turn will make it measurable and quantifiable. To achieve this it is

necessary that each aspect be discussed in a qualitative descriptive report

before Section A is completed. This report will therefore form the basis for the

completion of this section. The relevant questions appear in Swct6on A of the

questionnaire as presented in the previous paragraph.

Secnon A therefore includes questions and statements that should be evaluated

on an ordinal scale that varies between one and five, as described earlier.

The second group consists of questions with only a positive or a negative answer

(nominal scale) and forms Swam B of the questionnaire.

To interpret the questionnaire effectively, it is important to keep the following in

mind:

o The weight factor assigned to each of the questions in the questionnaire

differs according to the importance of the specific aspect within the context of

the complete EIVIP. The weight factor that was assigned to each question is

illustrated in Tables 1 and 2. When a certain aspect carries a weight of one

(11), it means that the total of the value assigned to it by the evaluator will be

the total given to the specific aspect. When a question however carries a

weight of more than Dm (>9 y , the value assigned to it by the evaluator must

be multiplied by the specific weight-factor that was assigned to this aspect.

Example:

Question 1 was assigned a weight factor of 1; and

Question 2 was assigned a weight factor of 2

37

8

@

1 44----to> 5

Question 1

Question 2 X

The value for Question 1 will be: 4 x 1 = 4; and

The value for Question 2 will be: 3 x 3 = 9

o For Section 3, a Yee answer would mean a value of five i511, while a No

answer would mean a value of zero (©). As for the weight factors assigned to

the different questions, it works in the same way as for Section A.

Exampile:

Quiwattionz I and 2 were assigned a weight factor of one OD, while

Questrions 3 and 4 were assigned a weight factor of two Q2).

®

YES No

Question 1 X

Question 2 X

Question 3 X

Question 4 X

The total values for these questions will then be:

Question 1: 5 x 1 = 5




o The questions in this questionnaire were taken out of their focus areas as

formulated in Paragraph 3.2.2. This step was necessary for the formulation of

38

the questionnaire itself. For effective evaluation of the EiViP, it is however

necessary to place the different aspects back into the focus areas where they

belong. For this reason the different focus areas of the evaluation criteria

were color coded in Tables 1 and 2. This color coding is illustrated by Table 3.

o Tables 1 and 2 illustrates the weight factor values that was assigned to each

of the questions:

Tab09 1: WUMgh2 gackg vahass for Section A

SC CTOOM A

Question nuirobeT: Weight factor:

1 X 3

X3 2

3 X3

4 X1

5 X1

6 X1

7 X1

8 X1

9 X1

10 K 2

11 K 2

12 X 1

13 X 1

14 A 1

39

Tae 2: WMght factor yahoos for Sectoon

SECTOON B

Question number: Iffletght factor:

1 X 2

2

3

X1

X1

4 X1

5 X 1

es X I

XI

Tables 1 and 2 illustrated the different weights that were assigned to the

aspects contained in the questionnaire.

The following paragraph describes the procedure followed with the assigning

of the different weights:

All of the aspects contained in the questionnaire are important and necessary

in any EMP and are therefore determinative of the successfulness and

effectiveness of the tool. A weight of 1 was for this reason assigned to each.

There are however some of these aspects that will have a much greater

influence on the quality of the EMP than some others will. Therefore, it is

understandable that these aspects should carry a greater weight. The aspects

that was identified as of greater importance than the others, together with the

weights that was assigned to them, are the following:

Commitment of management and personnel to the EMP - 3

Knowledge of the aims, objectives, targets and actions set out in the EMP

—3

Co-operation between this EMP and other environmental management

tools — 3

40

Identification of the issues to be addressed by the EMP — 2

Effectiveness of the actions specified for the management of the different

environmental impacts — 2

The issue concerned with the environmental assessment tool that the

EMP was based on — 2

The importance and prominence of these aspects have been described in detail

in Chapter 2 and the previous paragraphs of Chapter 3 and will therefore not be

described again in this paragraph. It is however, important to note that all of

these aspects will have an influence on the quality of the complete EMP,

because within these aspects are contained the essence of EMP as an impact

management tool. It is furthermore important to note that the weights that are

assigned to the different aspects will only have an influence on the results

obtained for the evaluation of the different focus areas. They will not influence the

results of the evaluation of the separate aspects since the values used as results

for this evaluation consist of the percentages of the maximum obtainable values.

It can be concluded that the aim and purpose of the different weights that were

assigned to the different aspects, is to adapt the weight of each aspect. This will

ensure that the image that is reflected by this evaluation would be realistic and

useable on a day-to-day basis.

Tab[le 3: Odour codes for focus areas

FOCUS AREA: COLOUR CODE:

Commitment

Process and Context

Nature of the EMP and the

information it contains

Information included in the

EMP

Question number Value assigned Weight factor (mmtlnuom value)

Totaa vaiue

t'k of 0111CI

value Focus area

SECTION A X 3 (15)

COMMITMENT X 3 (15) 2

SUBTOTAL FOR FOCUS AREA

(30)

41

This paragraph has illustrated all the factors that should be kept in mind when

interpreting the questionnaire. This will however not ensure that it is interpreted

correctly. Therefore, the next paragraph will present a chart that can be used to

interpret the questionnaire.

3.2.5 Chest for 5nterpretung the quesUonnare

This paragraph will focus on formulating a chart that can be used to interpret the

questionnaire for evaluating an EMP as presented in paragraph 3.2.3. This chart

will take all of the issues presented in the previous paragraph into account and

will therefore ensure that the questionnaire is interpreted correctly and effectively.

Table 4 illustrates this chart.

TEN® 4: Churt for linterpmating the ENG) quesUonnake

X 3 (15)

PROCESS AND

CONTEXT

4 X 1 (5)

5 • X 1 (5) =

X 1 (5) =

6 X 1 (5)


(35)

7 X 1 (5)

X 1 (5)

X 1 (5)

X 1 (5)


(20)

NATURE OF

EMP AND

INFORMATION

oRm AVER

REQUIRE @

IfIXIE EMI? s

0120) TOTAL FOR BECTON A

novoirail. Boa PCDCUSt ME&

42

Question number Vague assigned WMght f~a®

(maximum value)

Totai

Itfallue

% off max

vsOue Focus air

SECT O[ B

1 X 2 (10) - i PROCESS AND

CONTEXT 2 I I X 1 (5) =

SUBTOTAL FOR FOCUS AREA (15)

3

4


X 1 (5) =

=

NATURE OF

EMP AND

INFORMATION X 1 (5)

(10)

@ K il M e OR mAllaq

REQUIRED 015■9

1TGM MK) Q K 9 (5,p

V K Il 1M EB

§0:34CM11, POW POOL Ng AG rea 5)

TOTAL FOR SECT[10R9

F°0CUS A - E AS TOTAL % OF MAN MAN. TOTAL

Commitment to the EMP i 30

Process and context

Nature of the EMP and the information it contains

45

25

OnformEtbn PGCMITGII on Oho ENV giO

TOTAL 950

I

100%

Per

cen

tag

e o

f man

iunu

m v

sOu

e 90%

80%

70%

60%

50%

40%

30%

20%

10%

0%

43

Table 4 as illustrated above presents a chart that can be used to interpret the

questionnaire for evaluating an EMP. It is however useful to present these results

in an easier to understand, visually interpretable manner. Figures 4,5 & 6

illustrates how this can be managed by making use of bar graphs that use the

percentages of maximum obtainable values that were assigned to each aspect.

These values can be obtained from the chart used to interpret the questionnaire.

Figure 4 illustrates typical results for Section A, while Figure 5 illustrates results

for Section B of the questionnaire. The use of these bar graphs makes it possible

to visually identify the aspects that were assigned low values during the

completion of the questionnaire and that were therefore evaluated as inadequate

or not up to standard. The aspects that will need to be attended to when the EMP

is improved can therefore be identified at a glance in this way.

The function of Figure 6 on the other hand is to identify the focus area where the

most shortcomings of the evaluated EMP occur. 8n the example presented by

Figure 6 it can clearly be seen that the focus area of OnformagOon contened

.ahe ENP reveals the most serious shortcomings. This means that the weakest

point in this EMP is that it does not contain all the information needed for a

successful EMP.

Friguirs 4: Resu 'RD F ascUon A *.?.. 2,7"0-: _. , Jr

: I-

,. .-!

1 . ..,..

`Y.

.,..

,---:

.-:

41

.„-:4---

..:

2

3

4

5 6 7 8 9

10

11

12

13

14

Quezit6one

I

.-r, .,,, . .*.,s1

...—.,

s

..,

.•

100%

90%

80%

70%

60%

50%

40%

30%

20%

10%

0%

100

©

PER

CEN

T/A

GE 70

00

40 30 20 110

44

Fglups go Reau[lits foF SecUon 100%

100%

100%

100%

7 2

3 4

5

OanoUons

Fngus 6: PameMags egmhoso ffov .Chs dnffoveM Vocue eff8E0

4

'...: 4s-

1

N

, ...

1;4 - .

FOCUS AREAS

COMMITMENT

0 PROCESS AND CONTEXT NATURE OF ON 0 INFORMATION REQUIRED

45

These visual presentations of the results of the questionnaire makes the

evaluation process easily understandable to any person and therefore makes it

more useful in the day-to-day management of the project. It simply makes sense

to present all results in this manner in future for in doing so the evaluation

process will be made readily applicable in the practice of environmental

management.

3.3 Concilus6on

In this chapter a set of criteria for the evaluation of an Er 1P were formulated.

Firstly, all the different characteristics and requirements that were found in the

literature studied in Chapter 2, were identified and stated in the form of a list. The

purpose was to include all the information, characteristics and requirements that

are necessary for n E P to be successful. This list can therefore be seen as

complete in the sense that it contains all the elements of a successful and

effective E P.

The next step was to group these characteristics and requirement into specific

areas with commonality or the same focus. The object of this paragraph was to

give some structure to the information derived from Chapter 2. This makes it

easier to distinguish between the different functions and aims of the stated

characteristics and requirements.

At the same time these characteristics and requirements were transformed into a

set of criteria that can be used to evaluate an EMP.

Paragraph 3.2.4 then focused on compiling a questionnaire that can be used for

the evaluation of an EMP. The aim of this questionnaire is to make the evaluation

process as elementary, yet as measurable and quantifiable as possible. This is

imperative if any interested person should be able to use the criteria to evaluate

an EMP. Furthermore it focused on assigning weight values to the different

46

aspects of the evaluation criteria. This ensures that every aspect is handled

according to its importance within the EMP as a whole.

The set of criteria and the questionnaire now constitute the platform on which the

rest of the study will be based, as it will be used in the following chapters to

evaluate the case study.

47

CEn,PTIER. EVALUAT[10M OF TEE CAME STUDY

4.1 {introduction

In this chapter, the case study presented as Appendix A to this document will be

evaluated according to the evaluation criteria and the subsequent questionnaire

that were formulated in the previous chapters.

The aim of this chapter is therefore to evaluate the case study in such a way that

recommendations for the improvement of the EMP can be made after the EMP

has been evaluated.

The process of evaluation as applied in this study is illustrated by Figure 7.

Figure 7 illustrates the steps as described in this paragraph as well as the

corresponding chapter where each step can be found.

As mentioned earlier, the questionnaire can not be used on its own to evaluate

an EMP. It should be accompanied by a report that describes each of the issues

evaluated using the relevant criteria. Paragraph 4.2 therefore contains such a

report. This report will provide a qualitative evaluation of the EMP on which the

quantitative evaluation will be based.

Paragraph 4.3 contains the completed questionnaire as formulated in Chapter 3.

This questionnaire will be completed according to the information found in the

EMP document itself as well as the information presented in the evaluation report

of the previous paragraph.

The interpretation of the questionnaire and the results of the evaluation will be

presented in Chapter 5, together with the recommendations that will conclude the

evaluation process.

48

Mgalure 7: The swakoatrion process as appHod Chas

Mucly

Step 1: Descriptive evaluation

Chapter

Step 3: Interpretation of the quantitative evaluation

Step 4: Visual presentation of the results of the evaluation

Chapter 3

Step 5: Identification of the issues and major areas of concern

Step 6: Recommendations and conclusions

49

Eva0u0on oq the case study

4.02.1 Evaguatkm veport gar the case study

This paragraph entails an in-depth report on the evaluation of the case study

presented as Appendix A to this document.

Every criterion for evaluation as presented in Chapter 3 will be evaluated

separately in this paragraph. Every aspect will be evaluated by describing the

positive and negative issues associated with each. No numeric values will

however be assigned to any aspect, because this will be done in the next

paragraph after the questionnaire is completed. The aim of this paragraph is

therefore to describe the quality of each of the aspects in question, which will

provide a guideline when the questionnaire is completed in the next paragraph.

The discussed aspects are:

1. CaMmtment ENP

The management and an personne0 sholgOd be fanny coronOtted to and have

compOete lumenledge off the purpose, oblectOves, targets and actOons set out

On the ENP.

The management of the mining group that is being evaluated is very strongly

committed to the EMP. This statement can be substantiated by mentioning that

they put a lot of effort into trying to keep to the requirements in terms of

rehabilitation and mitigatory measures, as well as the time frame stipulated in the

EMPs of their different mines. They also put considerable effort into ensuring that

their EMPs are up to standard and in line with the latest trends in the

government's thinking as it appears from environmental litigation and policy. The

persons responsible for the EMP on management level in the organization also

50

possess extensive knowledge of all the information included in the EMP.

Therefore this aspect can be evaluated as positive.

This however only applies to the management of the organization. The ordinary

workers are in many cases not completely or at all familiar with the contents of

the EMP and can therefore not be committed to the aims, objectives, actions and

requirements set out in these documents.

20 Procsaa and conteKt

9) An ENI? sholoOd dways act together won other envOronmental

management Coda and thus as part off a Darfur process off any'konmenta0

assessment and ffinanagement.

This EMP does not effectively link up with environmental assessment and

management tools other than the EIA that it was based on. This means that the

E P functions largely in isolation and not as part of an EMS or as a step in the

IEM process. As illustrated in the literature, this implies that the EMP will never

be able to function properly, as an EMP is supposed to function as part of a

broader process and within a larger environmental management context and

structure. This aspect is a major shortcoming with this particular EMP and

apparently with EMP in the mining sector in general.

This aspect is therefore evaluated as negative.

2) An ENG) shoadd be based on the mune off an EA for new ptroOcts And

on the resabOts off an EnvOronments0 GlOsh Assessment, an ENS audit., or a

Rife-Cyde Assessment In the case off an =Ming pTO.teCt

The EMP in the case study is for a new project and is based on an EIA as

required by the literature. This EIA thus forms part of the EMP and provides the

structure for the rest of the EMP.

51

The Aide Memoire makes no provision for existing projects from this point of

view. According to it, the ENIPs for existing projects are also based on EIA

results and not on the results of other forms of environmental assessment, as is

actually required by the literature.

For this particular project, this aspect can however be evaluated as positive.

3) An ENP shoulld address the constructlion, operattionall and

decomnlsotionOng phases off the pro,ect.

This EMP addresses all three the phases of the project and is therefore adequate

in this sense. The constructional work needed for this project is however not very

extensive. Therefore, this phase is handled as part of the operational phase in

the EMP report.

The aspect is therefore evaluated as positive.

k) EMP shoadd be gugOy rintegrated Nnto the en6sOng project or

operratOona0 management systems, structures, processes and

termOno0ogy.

On a management level, this EMP is well integrated into the processes and

terminology of the project. The terminology used is the same as that used

generally in this type of mining and will therefore integrate well with the rest of the

project. The EMP forms part of the whole process implied by the project,

because it describes the different steps and phases of the project in detail.

The EMP is however not very well integrated into the existing management

systems and structures of the rest of the project, since no effort has been made

to implement such integration between the EMP and these systems.

52

For this reason, the first issue concerning this aspect is evaluated as positive,

while the second is evaluated as negative.

5) An ENG,' document shoulld mahe provtierion for ongoting woonOtorrOng and

the approprilate report-back prOCedlINGZ.,

This EiViP does mention certain aspects that will need ongoing monitoring but

does not specify the regularity of monitoring or the procedures to be followed.

Furthermore, it does not make any provision for report-back procedures on this

monitoring. This aspect makes the whole procedure of monitoring dysfunctional,

because no measures are specified that will ensure that the relevant information

is reported back to the appropriate people.

This aspect can therefore be evaluated as average, but far from adequate.

0) Pmdect management shouilld remiew the ENP on a regagar basis.

No actions or measures are specified in the E P that will ensure that it is

reviewed on a regular basis. This is a major shortcoming in the way that EiVi(P is

compiled in the mining sector, since the Aide Memoire does not specify any

requirements in this regard. From this can be concluded that EMP is seen by this

sector as a one-time only document that has to be submitted when a mine

applies for a mining license. This practice is contradictory to the requirement

found in the literature that an EMP should imply a process of continual

improvement and therefore needs to be reviewed on a regular basis.


30 Ham oV 'dm EN? and ne Wormeren contans

1) The ENG) shouilld state the envfironmenta0 paw of the organOmatrion,

wen as the speak standards that the organhatilon has set for OtssOf.

53

Neither this RAP, nor any other that is compiled according to the requirements of

the Aide Memoire will state the environmental policy or any specific

environmental standard of these organizations, since it is not required by this

guideline document. This can be seen to be yet another major shortcoming in

this EMP and by implication also any other E P that is compiled according to the

requirements of the above mentioned Aide Memoire.


An SNP shouild viol-J.80a the management of both pozitive and negative

impactz on the environment.

This EMP addresses the management of both the negative and the positive

impacts that the project will have on the environment. While adequate attention is

given to the management of the negative impacts, more attention should

however be paid to maximizing the positive impacts that can be expected from

this project.

This aspect is therefore evaluated as positive.

An) ENP stimid eleariy eats specific goes and agectivez for th

management of the relevant environmental) irrpeacta.

No specific goals or objectives for the management of the relevant environmental

impacts are stated in this document. This can again be seen as a shortcoming in

this specific document, but also in the Aide Memoire that was used to compile

this document, because it contains no measures to ensure that specific goals

and objectives are stated in an EMP document.


54

6) ADO nwasures, standards, goals and obb'ectives contained in an EN?

should by= measurable and quantifiable.

The measurability and quantifiability of the actions contained in this E"P differs

from one to the other. Some are adequately quantifiable and measurable, as is

the case with the monitoring of water samples. Others are less measurable and

quantifiable, as is the case with the rehabilitation of the soil after mining in a

specific area. This aspect is however heavily influenced by the fact that no

specific standards, goals or objectives are stated in this document, because it

implies that there will be very little to measure any action or measure against.

This aspect is therefore evaluated as average.

5) The structure and terminology off an ENG) should be as elementary and

understandable as possible.

The structure as well as the terminology used in this EhV P is very elementary and

therefore very understandable to any person. The same structure that is used for

the identification of the relevant impacts is used for the HA as well as for the

formulation of the different management actions and measures later on in the

document. The terminology used in the document will be familiar to any person

concerned with the project, since it is the same terminology that is generally used

in the mining sector. This makes the document logical and easily understandable

to any person that may have to use it.


6. OMR:merlon Mcfluded EWALD

I) An ENP should identify aDO the environmental issues to be addressed

tllwoughout the EDO.

55

This Ei\iiP effectively identifies all the issues that are to be addressed in this

document. Here the structure required by the Aide Mernoire plays a very positive

role, since it forces the person compiling the EMP to take all the different

environmental aspects that might be affected by the project into account.

This aspect is evaluated as positive.

An [MP ehou0d opecirk taw different actOcons to be taken on order to

manage the Mena'ed Ompactz on the envoronment.

The actions specified for the management of each of the identified environmental

issues in this document can be evaluated as effective and adequate. These

actions will ensure that each negative impact is minimized and that the positive

impacts are managed in a manner that will ensure that their results are utilized

for the benefit of the environment. The effectiveness of these actions is,

however, influenced by the measurability thereof and by the absence of specific

goals and standards in the document, which is supposed to provide a guideline

according to which these actions should be taken.

Although the actions are therefore not effective in all senses, this aspect can still

be evaluated as positive.

An IMP abodd atOpa.date a speeToc t6me fframe flop Qhe ac Pions to be

tam.

This EMP stipulates a specific time frame for the completion of the different

actions and is therefore adequate in this regard. It breaks the process into the

different phases with steps within each of these phases. This makes the EMP

document suitable for use in the day-to-day management of the project.


56

4) An ENP shou0d cllearOy dwoOgnate Qa) person(s) reepons6b0 for the fimMementatOon of the dOfferent actgone to be Wone

Although a responsible person is designated for some of the actions contained in

this document, it is in many of the cases not clear who the person responsible for

a specific action will be. This shortcoming again has its origin in the Aide

Memoire, since this document does not require that a responsible person must

be designated for each of the actions. This makes it very difficult to control the

actions, since it is not clear who the responsible person will be.

This aspect is evaluated as negative because it is not always clear who the

responsible person will be.

Z) An EN G, shougd make adequate proviMon qaff emergency eItuagons that may aril's&

This EMP does not make adequate provision for emergency situations that may

arise. It does state that provision will be made for some emergency situations,

e.g. spills of environmentally hazardous chemicals, but it does not specify the

actions that will be taken if and when such a situation should arise. No

emergency procedures are identified and only one or two possible situations are

indicated. This aspect did not receive adequate attention in this document.

This aspect is therefore evaluated as average but far from adequate.

1M Qn ENP ahouOd make proviisOon Tor the adequate trahOng of perzonneL,

This aspect is yet another major shortcoming in this document, since very little

provision is made for the training of personnel. The literature has illustrated that

intensive training of personnel is necessary for any EMP to function effectively,

since it is the only way to ensure that all personnel understand the aims,

objectives, actions and requirements contained in the EMP. This document does

57

state that personnel will be trained in the handling of potentially hazardous

chemicals. This measure is however far from adequate. It applies only to one

aspect of the EMP and will not necessarily mean that these personnel will know

why they have to take certain actions or do things in a specific manner.


7) An EMP ohcanfld [denary gut appyoproste commagantron dunnage Qo

ensure en adeques Row Onfounstion On 1the OUVEMEE200171

This EMP states that the mine manager will be responsible for providing the

relevant information to persons concerned with this project. This does represent

a communication channel in the organization, but is far from adequate to ensure

that all the correct and relevant information will reach the right people within but

also outside of the organization.

This aspect is therefore evaluated as average but inadequate.

This paragraph presented a descriptive evaluation of the case study. It pointed to

the positive aspects, as well as the shortcomings of the EMP that was evaluated.

All the information contained in this paragraph were derived from a study of the

EMP document, as well as from information obtained verbally from the

organization. This report assigned no numeric values to any of the aspects that

were evaluated, as all aspects were only evaluated as positive, negative or

average. Table 5 presents a summary of this evaluation by indicating the option

that was assigned to each of the aspects.

From the previous can be concluded that it was not the aim of this report to

provide a quantitative evaluation of the case study. Instead, it presented a

qualitative evaluation that can be used as a basis and reference when the

questionnaire is completed in the next paragraph.

58

Table 5: Summary of eh ® qualltatrive evalluelon

"+" = Positive; "-" = Negative; and "0" = Average 1. The management and all personnel should be fully committed to and have

complete knowledge of the purpose, objectives, targets and actions set out

in the EMP

+

An EMP should always act together with other environmental management

tools and thus as part of a larger process of environmental assessment and

management.

-

An EMP should be based on the results of an EIA for new projects and on the

results of an Environmental Risk Assessment, an EMS audit, or a Life-Cycle

Assessment in the case of an existing project

+

An EMP should address the construction, operational and decommissioning

phases of the project. +

An EMP should be fully integrated into the existing project or operational

management systems, structures, processes and terminology. 0

An EMP document should make provision for ongoing monitoring and the

appropriate report-back procedures. 0

Project management should review the EMP on a regular basis. -

1 . The EMP should state the environmental policy of the organization, as well

as the specific standards that the organization has set for itself.

. An EMP should address the management of both positive and negative

impacts on the environment.

. An EMP should clearly state specific goals and objectives for the

management of the relevant environmental impacts.

+

_

- 4-

0

0

+

All measures, standards, goals and objectives contained in an EMP should

be measurable and quantifiable.

The structure and terminology of an EMP should be as elementary and

understandable as possible.

. no MP *DOW identify EEO 4h2 glitelTORNOGiit4d WIlflgi@ 40 to acidegg@od

Nucoghogra 0® Ell?.

2. aR EN? @Nook] @GD@O439 40Ig digitgoa4 ea5aw flo to kaGR Oti CIKIW 40 memsd:ga

R:bt identified ttuipEige cm rhg gimtioRmgva,,

L Afji) ENGD @Otoo0c1 n46pdO& ei @3peeific 405D® WEICO@ 907 aca aetionn ID CX; tietAgit.,

Z. na IMP should @.0.6711w designer ND personM ift;@ponsit{13 ke 450

Iftplementation (INN@ different &@;4600i1@ 40 b2 4 .

@. AR ENGD @hogOd met® erUqu n6Ct fte GRergency CINEROCGO@ inER OM

674(40

to an ENG) Moo0c1 max; p7a96AcQ fice 'Mg adaqueRG 'VetRbag cR personWo .

T. &IR EMP @b:Dgi)cl identify 01)Dig appropriate @ORMIglika6C0i) @heligOgb Q) GQ@ARg

a@ Ed@;pElag VOOM a mocumeoce oat ag organization.

59

6.2.2 Evekllaidon of the c@se study by op,ilestronnare

This paragraph deals with the questionnaire as formulated in Chapter 3. Numeric

values will be assigned to each of the aspects contained in the questionnaire.

The values assigned to each of the aspects will be based on the information

obtained from the qualitative evaluation of the case study that was presented in

the previous paragraph. It is therefore the aim with this paragraph to present a

quantitative evaluation of the case study by means of the questionnaire.

QUESTIONNAME FOR THE EVALUATDON OF am ENP

Mark the applicable box with an 'X'

<1 > 5

Commitment of management and personnel to the EMP

X

Knowledge of the aims, objectives, targets and actions set out in the EMP

x

To what extent does this EMP act together with other environmental assessment and management tools?

X

How well is the EMP integrated into the existing project or operational marumgement systems, structures, processes and terminology?

x

Does the EMP make adequ te provision for: Ongoing monitoring?

X

The appropriate report-back procedures?

8. Is the OAP reviewed on a regular basis?

7. How well does this EMP manage: Negative impacts on the environment?

Positive impacts on the environment? Measurability and quantifiability of the measures, standards, goals and objectives contained in e EMP Understandability of the structure and terminol y of e EM and the information it contains Does the EMP identify all the environmental issues that are to be addressed by the document? Does the EL? specify effective acti ne for e [mane ernent of each idea ed environmental issue? Does the EMP make adequate provision for emergencies that may arise? Does the EMP make adequate provision for the training of personnel?

Does the EMP identify appropriate communication channels that will ensure have adequate flow off infformation in the organization?

X

X

X

x X

X

60

Mark the applicable box with an 'X'

© 0 YES NO

1. In the case of a: New project: Is this EMP based on the results of an EIA? Existing project: Is this EMP based on the results of an ERA, EMS audit or a Life-Cycle assessment? Does the EMP address the constructional, operational and the

X

decommissioning phases of the project? Does the EMP state the environmental policy and standards of the organization? Does the EMP state specific goals and objectives for the ma ageme

X

of the identified environmental impacts? Does the EMP stipulate a specific time frame for the actions to be wizen?

Does the EMP include information regarding the financial and opt er resources that will be used to reach its objectives and targets? Does the EMP designate (a) person(s) responsible for the

X

implementation of the actions tm be talken?

61

The aim of this paragraph was to complete the questionnaire for the evaluation of

the case study EiViP according to the report found in the previous paragraph and

to transform this qualitative report into quantitative terms. Therefore, numeric

values were assigned to each of the aspects in question. These values will make

it possible to present the results of the evaluation in a visually understandable

manner and to identify the major areas of concern in Chapter 5.

6.3 Condluallon

This chapter presented an evaluation of the case study according to the

evaluation criteria that were formulated in Chapter 3.

This evaluation consisted of two parts. Paragraph 4.2.1 entailed a descriptive

evaluation of the case study according to the different aspects contained in the

criteria for evaluation found in Chapter 3. The aim of this paragraph was to

present all the negative and positive issues associated with each aspect named

in the criteria, concerning the case study.

This descriptive report then formed the basis for the evaluation by means of the

questionnaire that followed in Paragraph 4.2.2. This paragraph presented a

quantitative evaluation of the case study, by means of the questionnaire

formulated in Chapter 3. For this evaluation, numeric values were assigned to

each of the aspects in question.

This chapter therefore presented the first two steps in the process of evaluation

as illustrated by Figure 7, found in the introduction to this chapter.

In the next chapter the results of the evaluation performed in this chapter will be

interpreted and presented in order to derive from this evaluation of the EIMP,

recommendations for the improvement thereof.

62

CHAPTER 5 ONTERPRETATOOM AHD PRESENTATOOM OF

T RESULTS OF THE EVALUATOOM

5.1 Ontoda.ild0on

This chapter presents an interpretation of the results of the evaluation performed

in the previous chapter according to the process presented in Chapter 3.

The first step interprets the results of the questionnaire by presenting these on

the Chart 4 as formulated in Chapter 3. The results of this interpretation will then

be restated in a visually understandable manner with the use of bar graphs in

Paragraph 5.3. In Paragraph 5.4 the aspects that need to be addressed in order

to improve this BAP, will be identified from the visual presentation derived from

the previous paragraph. This will then be used in Paragraph 5.5 to make some

recommendations towards the improvement of the case study EMP. This also

forms the final step in the evaluation process as presented in the previous

chapter and will therefore conclude the evaluation of the case study.

5.2 Reauft og the evekfiat0on Coy queatronnakre

This paragraph presents the results of the evaluation of the case study by the

questionnaire, as found in Chapter 4. It will therefore interpret the questionnaire

so that the major areas of concern within the evaluated IENIP can be identified. It

therefore firstly presents the chart for interpreting the questionnaire, as found in

Chapter 3. This chart will be completed with the values that were assigned to the

different aspects when the questionnaire was completed, as was shown in the

previous chapter.

Table 6 presents the completed chart for interpreting the questionnaire. The

values assigned to each aspect in the questionnaire are indicated on this chart.

63

Each of these values has been multiplied by the weight factor that was assigned

to it. The adapted value is then indicated in a separate column. This chart

furthermore shows the maximum possible values that can be assigned to any of

the aspects; the percentage of the maximum value obtained as well as the

subtotals obtained within the different focus areas. The last part of Table 6 will

indicate the totals and the percentages of the possible maximum obtained within

each of the focus areas.

Tab119 6: Marra for OntealpregOrng .ahe GNP queedonourire

weight factor (mmaimum value)

Total] vaDue

% of man vague

Focus area Question number VsDue assigned

SIECTOM A

2

4 X 3 (15) = 12 80

3 X 3 (15) = 9 60 COMMITMENT

SUBTOTAL FOR FOCUS AREA (30) 21 70

X 3 (15) 20 = 3 1 3

X 1 (5) 60 3 = 3 4

X 1 (5) = 3 60 PROCESS AND

CONTEXT 20

3

X 1 (5)

X 1 (5) = 1


6 20

= 1

X 1 (5) = 5 100

X 1 (5)

4 80

X 1 (5)

= 3 60

NATURE OF

EMP AND

INFORMATION

7

5

8

100 9 5 X 1 (5)


(20) 17 85

OC) .i1C1 boo

g

80

GO

n M

130

EVCOACWOON

REQUIRE POG6

VIE IMP

ga3110MIL, FOR FOCUI% ME & OS) Mog

TOTAL FOR SECTION A (120) 74 61.7

TOTAL FOR SECTKDN E (4C1 26 62.5

64

Question number Veflue assigned ,

Iffe6011 fmct° " (maximum value)

Tote

V800,03

% off maul

veue Focus area

S ECTll'ON1 ,

1 5 X 2 (10) = 10 100 PROCESS AND

, t CONTEXT 2 5 I X 1 (5) = 5 j 100


3 0 ,

, X 1 (5)

4 0 X 1 (5)

SUBTOTAL FOR FOCUS AREA (10)

= 0

= 0

0

0

0

NATURE OF

EMP AND

INFORMATION

g g K 9 00 a IJO® ORMATIOGg

REQUIRED ON K 11 00 e t10

MENCD4G2. Fa3 FOCU@ &RE& qm .i)c) mov

F CUS AREAS 1TOTAL % OF MA. MAX. T T L.

Commitment to the EMP 21 70 30

Process and context 25 56 45

Nature of the EMP and the information it 17 68

contains 25

Onformatoon croqukGcl ow thig EMP ad 72

ie) L TT 99 65.75 150

The aim of this paragraph was firstly to elaborate the values assigned to each

aspect in the questionnaire according to the weight factors that were assigned to

the different aspects, and secondly to place each aspect back into the focus

areas where they belong. It thus presented the results of the evaluation

questionnaire by indicating all the values, adapted values and percentages in

100%

Per

cen

tag

e o

m

axim

um

va

lue 90%

80%

70%

60%

50%

40%

30%

20%

10%

65

Table 6. This has now made it possible to present the results of the questionnaire

in a visually understandable manner in the following paragraph (5.3).

5.3 Viinamil prezentattion of the vesullts off the evahmtdon

questio'onnE5re

The aim of this paragraph is to present the results of the evaluation questionnaire

in a visually understandable manner. Therefore, the results indicated on Table 6

in the previous paragraph will be presented in the form of visually interpretable

graphs. This will make the results of the evaluation easily understandable to any

person that might be concerned with the project. These visual presentations will

also be used to identify the major areas of concern in Paragraph 5.3.

Figures 8 and 9 illustrate the values assigned to each question. It is not the direct

value that is displayed in these graphs, but rather the adapted value assigned to

each question as a percentage of the maximum obtainable value for the specific

issue.

FOgitave @: ResuRo Tor ascItIon

..

:..-.

I..:

,:,._

..7 .:,...7

V,.

`-&-"

I

..„.

a

....,, . .,,,..„.

,.. 1 2 3 4 a 6 7 8 9

10 11 12

13

14

QuisegOotme

0% 1

-

ts :.•7

.?...4

,...1

.agf, :.

, g

%-.7.'

,

..-':

s . ..

51s,

,-.--- fra".

.,'.- .-4-: :,

-- 7

100%

90%

80%

70%

E

60%

50% 01 Ed

9 40%

30%

20%

10%

0%

66

F5gmu'e 92, 380(LIMO gOP escgon 100%

100%

100%

100%

2

3 4

5

6

7

atnotion@

These figures illustrate the values assigned to the different questions, as a

percentage of the maximum obtainable value for each. These illustrations

therefore clearly identify the issues that received the lowest values in the

evaluation of the case study. Thos issues should receive attention when effort is

put into improving the EMP. Furthermore they influence the effectiveness and

successfulness of the EMP in its current form. Those issues of concern will be

identified in ragraph 5.4.

Figure 10 illustrates the total values obtained within each of the focus areas.

Those values are also expressed as a percentage of the maximum obtainable

value within the different focus areas. This illustration therefore makes it possible

to identify the focus area(s) that received the highest and the lowest values in the

evaluation of the case study. They will be used in the following paragraph to

identify the major area(s) of concern.

0

PER

CE

NTA

GE

100

90

80

70

60

50

40

30

20

10

67

Figure 10: Percentage values for the different focus areas

..,

■4-:::: f'd A Il MEI • ,.

FOCUS AREAS

COMMITMENT

o PROCESS AND CONTEXT NATURE OF EMP

0 INFORMATION REQUIRED

5.4 Identification of the issues and major areas of concern

The aim of this paragraph is to identify the major issues and areas of concern

within the evaluated case study. Those issues should be improved in order to

make the EMP more effective and successful.

The issues included in this paragraph will be identified from the illustrations of the

results of the questionnaire as presented in Paragraph 5.4. This paragraph will

only identify the different issues, as recommendations for the improvement of

those issues will be presented in Paragraph 5.5.

In order to standardize the identification of those issues, any question that

received a value less than 60 % of its maximum value, will be identified as an

issue of concern. Those issues are inadequately catered for currently and will

need improvement.

68

The issues of concern that were identified in Section A of the questionnaire

include the following:

CAF etOon 3 — This issue is concerned with the co-operation between this

specific E" '13 and other environmental assessment and management tools.

motion 6 — This issue is concerned with the monitoring of the impacts that

the project will have on the environment. The problem with this issue has

however specifically to do with the report-back procedures of this monitoring.

ti n 6 — This issue is concerned with the reviewing of the Er.$P by the

management of the project.

QuestO n 13 — This issue is concerned with the training of the project

personnel.

For Section B the issues of concern include:

stion 3 — This issue is concerned with the statement of the environmental

policy and standards of the organization in the BAP document.

tA est n 4 — This issue is concerned with the specific goals and objectives

for the management of the environmental impacts.

tl [rt 7 — This issue is concerned with the designation of a person(s)

responsible for thie implementation of the actions set out in the E P.

The above mentioned are the issues that have been found to be inadequate or

not up to standard in the evaluated case study. Those issues will receive

attention in paragraph 5.5 when recommendations are made for the improvement

of the E P.

When those issues are studied closely, it becomes apparent that quite a few of

them belong to the same focus area. This conclusion is substantiated by

Figure 10 from the previous paragraph. This illustration identified the focus area

of Process and Context as the one that received the lowest overall value. The

average values assigned to the issues within this focus area are lower than the

69

values for any of the other focus areas, by more than 10 %. It can therefore be

concluded that this focus area is the one that should receive specific attention in

the evaluated EMP in order to make it more successful and effective.

5.6 Recommendations and conclusions in respect of the case= study

This paragraph will present some recommendations for the improvement of the

EMP case study. These recommendations are based on the results of the

evaluation that was conducted in the previous chapter. It thus presents findings

based on the evaluation criteria that were formulated in Chapter 3 of this study.

The recommendations contained in this chapter form the last step in the

evaluation process as presented by this study. This evaluation process is

illustrated by Figure 7. The first step in this process was to evaluate the case

study in a descriptive manner. This formed the base for the quantitative

evaluation that followed. These two steps were presented in Chapter 4. The next

step was to interpret the results of this quantitative evaluation numerically. This

lead to the next step, which was to present these findings in a visually

understandable way, by making use of different graphs. These presentations

were then used to identify the issues and areas of concern within the studied

E 1 P. All of these steps have now made it possible to formulate

recommendations and draw conclusions concerning the evaluated E P, as will

be presented in this paragraph.

This last step in the evaluation process can be seen as particularly important to

the process as a whole, since it will give enhanced relevance to the process. This

statement can be substantiated by the fact that the whole process up to now will

not have changed the quality of the evaluated EMP in any way. This step will

however provide the opportunity to make the valuation process worthwhile by

presenting the information needed to improve the EMP.

70

The issues and major areas of concern identified through the evaluation of the

case study that was presented in Paragraph 5.4 will be used to provide structure

to the recommendations and conclusions.

The origin of the shortcomings with many of the issues that will be described in

this paragraph lies with the guideline document that was used to compile this

E P. The recommendations that will be made are therefore applicable to the

case study itself, but can also be seen as applicable to the Aide Memoire as a

general guideline document.

The issue under discussion in each case will be used as a heading, under which

the recommendations and conclusions related to such issue will be described:

5.5.1 C -operati

tw

n this EMP End o er environmentassesameng Loc.

(t.

nd managente o4 tools

The importance of effective co-operation between an E P and other

environmental assessment instruments has thoroughly been illustrated in

Chapters 2 and 3. It stated that no EMP can be fully effective when used in

isolation from other environmental management and assessment tools. It also

indicated that an EMP should always form part of the larger environmental

management framework.

As is the case with many EMPs in the mining sector, the case study E P does

not form part of such a larger framework. It functions largely on its own and in

isolation from the other environmental assessment and management tools. This

can be ascribed to the Aide Memoire as the guideline document that was used to

compile this E P.

It is therefore recommended that the process used in the mining sector for the

compilation of EMPs should be revised in terms of the aim, purpose and

71

functionality of an EMP. Figure 3 (Chapter 2) illustrated how an EMP should be

viewed in terms of the larger framework of Integrated Environmental

Management (IEM). It clearly shows that an EMP should be viewed as a step in a

process and not as a tool that functions in isolation, as is the case with this

specific E P.

5.5.2 Ongoing gm o,nlitoviing of the ea on the anutronment and the

approcoglate report-back 53vocaduras

The importance of this issue is also illustrated in Chapters 2 and 3. This EMP

does make provision for some impacts to be monitored during the life of the

project. The problem is however that it provides no specific guidelines and

procedures in this regard. No responsibility is assigned to a specific person, no

procedure for monitoring is stipulated and no report-back procedures are

specified. This unfortunately implies that the monitoring will not be efficient.

For the monitoring of this EGVIP to be efficient, it will be necessary to specify the

following aspects with every impact that is described in Section 6 of the EMP

document:

Does this impact need ongoing monitoring? If n

If IF a, describe the following:

Procedure to be followed with monitoring

Person(s) responsible for monitoring

Regularity of monitoring

Report-back procedures

It, substantiate your reason.

This information should be stated as briefly and effectively as possible. This will

ensure that provision is made for effective monitoring where applicable. By

illustrating the procedures and communication channels to be followed

graphically, unnecessarily lengthy discussions of these procedures and channels

can be avoided.

72

5.5.3 ReAswilng off .ihe EMP

Reviewing is yet another shortcoming in this EMP that is related to the process

followed or the context of the EMP. The literature has shown that the EMP

process should be a process of continual improvement. For this to be attainable,

it is necessary that the project management should review the EMP on a regular

basis.

It may be possible that the project management of this project will review this

EMP on a regular basis of their own accord, because they are committed to the

findings and requirements of the EMP. The document itself however contains no

measures or requirements to ensure that this will take place. Since the review of

the EMP is not made compulsory in any way, it is more likely that it will not take

place on a regular basis.

It is therefore recommended that measures and requirements should be included

that dearly stipulate the following aspects regarding the reviewing of the EMP

document:

Regularity of reviewing

Procedures to be followed, e.g. audit of the EMP document

Person(s) responsible for the reviewing process

Communication channels to be followed

6.6A Tr Ming of parsonn

This issue is strongly emphasized in the literature. No measures or requirements

contained in an EMP can be applied successfully if the personnel concerned with

the project are not trained properly in the aims, purpose, requirements and

measures of the EMP.

73

Unfortunately, this issue received very little and totally inadequate attention in the

EMP evaluated in this analysis. Although the issue of training is mentioned, no

measures or requirements are specified that will ensure that all personnel are

adequately trained in a way that will promote sound environmental practice at all

times.

For the improvement of this EMP, it is therefore recommended that a separate

section be included in the document that will pay specific attention to the training

of personnel. It is important that this section will include information on all of the

following aspects:

Training and education levels of personnel on all different levels

Practices that personnel need to be trained in

Responsibility for training, e.g. person from project management, consultant

etc.

Procedures that will be followed with training

Completion dates for the different stages of training

onitoring of the training of personnel

5.5.5 Environni Wag 1iccy nd standards ff th organOzatOon

The importance of this issue was discussed in Chapters 2 and 3 of this study. It

became clear that according to views found in the literature an EMP will not

contribute to specific goals and objectives, if no environmental policy or standard

is stated as the main aim of the document.

The fact that this EMP contains no statement of the environmental policy or

standards of the organization should therefore be regarded as a very serious

shortcoming in this document.

It is recommended that a section be included that will state the environmental

policy and standards of the organization. This section should be placed at the

74

beginning of the EMP document, since it describes the overall aim of the

document. It should be formulated so that it:

Is easily understandable;

Includes all the necessary information;

Contains an aim and vision that is obtainable within reasonable cost and

effort;

Will inspire people to work towards this aim.

A policy that satisfies the above-mentioned requirements will form a strong

platform on which the rest of the EMP can be based.

5.5.6 SpecIfic goals and o lectIves for the mans*

environmental I ;pac

meat of the

As illustrated in Chapters 2 and 3, this issue goes hand in hand with the previous

issue of environmental policy and standards. The specific goals and objectives

for the management of the different environmental impacts should be derived

from the environmental policy of the organization.

The evaluated EMP contains no statement of the goals and objectives of the

document.

It is therefore recommended that these goals and objectives be included in the

document so that it forms part of the section that states the environmental policy

of the organization. It should be formulated in a way that will make the aims and

objectives of the policy and standards measurable and quantifiable. This means

that it should be specific with respect to the aim and vision of the environmental

policy and standards of the organization. Goals and objectives that are

formulated in this way will ensure that the Er.1P can be evaluated according to

the degree to which it attains its aim and vision. It will enable the evaluator to

75

refer back to these goals and objectives in order to ascertain Whether they were

reached through the management of the different environmental impacts.

6.5.7 DesigneVon off respons6b500ty

This important issue clearly did not receive due attention in the evaluated EMP

document.

The literature discussed in Chapters 2 and 3 illustrated the importance of this

issue in the context of an effective EMP. It was there stated that an EMP can

only be successful if a person or persons are designated that will be responsible

for the execution of each action contained in the EMP.

This E P is not in all instances clear on who the person(s) responsible for each

action will be. This makes it impossible to assign responsibility for an action that

was neglected or that was ineffective to any person or persons.

It is therefore recommended that each action or group of actions should be

assigned to a specific person or persons. This will make the EMP more

quantifiable and auditable.

The recommendations as described in this paragraph include some important

information regarding the evaluated EMP. It highlights the issues that need to be

addressed in order to improve the effectiveness of the EMP. The aim of these

recommendations is to provide the information necessary to improve this E P to

an acceptable standard. The measures addressed by these recommendations

should therefore receive due attention when this E P is upgraded.

76

506 Conclusions on the case study

It is the aim of this paragraph to draw conclusions with respect to the evaluation

of the case study that was performed in Chapters 4 and 5 of this report.

When the evaluated EMP is viewed as a whole, it can be viewed as successful.

This statement can be substantiated by referring to the fact that the EMP

received an average of 65.7 % in the evaluation that was performed. Although

this is not an exceptionally high score, it nevertheless indicates that it addresses

most of the important issues associated with the project and with this kind of

document in general.

There are however a few major shortcomings in this EMP. It is those issues that

were identified and that received attention in this chapter. It can be concluded

that most of those issues form part of the focus area of Process and Context, as

identified in Chapter 3. This means that the most significant shortcomings of this

EMP occurred in the process that was used for the compilation of the EMP and in

how this E P is evaluated within the larger context of environmental

management. As this E P was compiled according to a specific guideline

document, it can only be evaluated in terms of it as a process by referring back to

this guideline document. If the EMP is deficient in its dimension of process, the

guideline used in its compilation was deficient in that respect.

The conclusion reached is therefore that the Aide itliemoire (the guideline

document used to compile the evaluated EMP and EMPs generally in the mining

sector) does not interpret this tool correctly as far as the characteristics and

requirements of the process involved in a environmental management program

are concerned. EMP is erroneously viewed as an isolated tool that can function

effectively on its own, instead of being a step in a process that forms the larger

framework of environmental management and assessment.

77

From all of the previous flows the recommendation that the process of EMP in

the mining sector be revised in terms of its aim, objectives, context where it

functions and information that should be included in these documents.

78

CHAPTER 6 CONCLUSION

The environmental management program is a powerful tool used in the practice

of environmental impact management. It has the ability to provide in a variety of

needs regarding environmental impact management. The tool can give relevance

to the environmental assessment tools used to ascertain the possible impacts

that a specific project will have on the environment. It can also be used as a tool

for the management of the environmental impacts associated with each kind of

project, seen from the economic perspective.

For any environmental management tool to be effective, it is essential that it be

structured in a way that will enable its users to achieve its aims and objectives.

The environmental management program is no exception to this rule. For this

tool to be effective in reaching its aims and objectives, it needs to be structured

so that it fits into its place within the larger framework of environmental

management. The process for the application of this tool should also be

functionally linked to the aims and objectives. It also needs to contain specific

information that should be of a specific nature (as described in Chapters 2 & 3).

The only way to ensure that all of these requirements are met is to evaluate the

tool on a regular basis.

In the relevant literature a number of documents can be found that contain a

variety of characteristics and requirements regarding the EMP as an impact

management tool. Those documents often serve as guidelines when an EMP is

compiled. The literature does however not provide the users of the tool with any

means for the evaluation of the EMP document. This can be seen as a

shortcoming in the literature that needs to be attended to, since it will inevitably

lead to a negative situation where EMP will no longer be effective and successful

in attaining its aims and objectives.

79

All of the matters mentioned above served as motivation for this study, which

was aimed at the formulation of a set of criteria that can be used for evaluating

an EMP according to its effectiveness as an impact management tool.

Figure 11 illustrates the progression of the study by presenting the different steps

that were taken together with the corresponding chapters where this information

can be found in this document.

The set of criteria that was formulated was based on an intensive study of the

information contained in the most recent and prominent sources in the literature

regarding E P. From this study, a number of characteristics and requirements

for a successful EMP were derived. These were then divided into areas of

commonality and were transformed into a set of criteria that evaluates an EMP

according to its effectiveness as an environmental impact management tool. The

innovative step that was taken to duster the aspects addressed in terms of the

criteria into areas with commonality proved its value by simplifying the process of

evaluation, thereby enhancing its practical applicability.

A set of criteria in the form of a list is however not easy to use and is therefore

not very accessible to a person with little knowledge of the subject in question.

For this reason, the criteria were transformed into a questionnaire that can be

used to evaluate the E P. This questionnaire was formulated in such a way that

the evaluation process would be as elementary as possible, thereby ensuring

that it will be usable in the day-to-day management of a specific project.

The evaluation process as formulated in this study was then used to evaluate the

case study presented as Appendix A to this document. The aim of the case study

evaluation was to illustrate the evaluation process as formulated in this report by

making use of a practical example. It furthermore made it possible to form an

opinion of the standard and effectiveness of the case study EMP, as well as of

E P in the mining sector in general.

80

Figure i i o Progression of the study

I Chapter 1

Chapter 2

/ Formulation of

evaluation criteria

Chapter 3

Formulation of evaluation

questionnaire

Conclusion of the study

/

Chapters 4 & 5

Chapter 6

81

The author trusts that he succeeded in formulating a set of criteria that can be

used for the evaluation ofViP as an impact management tool, through this

study. That set of criteria was made more practical by presenting it in the form of

an easily interpretable questionnaire that is also easy to use. The study

furthermore succeeded in presenting a process that can be followed with the

evaluation of an E P by demonstrating it by employing a case study.

The author trusts that this study will prove to represent a useful contribution to

the practice of environmental management and specifically to the management

of the environmental impacts that all economic activities have on the

environment. This study was aimed at attending to a shortcoming in the literature

that currently has a negative influence on the practice of environmental

management as applied in the day-to-day management of the associated

economic activities. It is suggested that this study has succeeded in its aim to

highlight that shortcoming and to give clear guidelines indicating how it could be

rectified. The final submission is that the use made of both qualitative and

quantitative analyses and the representation of th = results in both the prose and

visual formats, represents a further step towards improving the practice of

environmental impact management.

82

REFERENCES

BOONZAAIER, J.M. & VAN DER WALT, I.J. 9997: EMPs — a futile exercise?

Mining world — your window to mining. Jan.

INTERNATIONAL ORGANIZATION FOR STANDARDIZATION. 1996: ISO 14001: Environmental Management Systems — Specifications with guidance for

use.

DEPARTMENT OF ENVIRON ENTAL AFFAIRS. 1992c: The Integrated

Environmental Management Procedure. Vol. 3. Department of Environmental

Affairs, Pretoria.

DEPARTMENT OF ENVI f - ON ENTAL AFFAIRS AND TOURISM. 1998:

Discussion document — A national strategy for Integrated Environmental

Management. Department of Environmental Affairs and Tourism, F - retoria.

DEPA TMENT OF MINERALS AND ENERGY AFF S. 1992: Aide Memoire —

for the Preparation of Environmental Management Programme Reports for

prospecting and mining. Department of Minerals and Energy Affairs, Pretoria.

FUGGLE, R.F. & RABIE, M.A. 1996: Environmental Management in South

Africa. Juta, Cape Town.

GOODE, W.J. & HATT, P.K. 1979: Methods in social research. McGraw-Hill,

New York.

JOUGHIN, J.; SMITHEN, A. & POSIT, S. 1997: The environmental

management puzzle. Mining world — your window to mining. May. 28 — 30.

83

LUCAS, D. 1997: Development and integration of Environmental Management

Plans (EMPs). Rand Afrikaans University.

MOUTON, J. & MARAIS, H.C. 1985: Metodologie van die cseesteswetenskappe:

Basiese begrippe. Raad vir geesteswetenskaplike navorsing, Pretoria.

PRESTON, G. 1993: Integrated Environmental Management Will it Work?

Africa Environment and Wildlife. 1(1): 31 — 35.

VAN DER WALT, A.J. 1998: Environmental Management Report for

Blesbokfontein Remainder Clay Quarry.

VAN ZYL, W.J.S. 1997: EMPs — A quantum leap ahead. Mining world — your

window to mining. Feb. 32-34.

APPENDIX A

FOR

Ics3LEaROFOTE REA CLAY QUAY

lE

COMPILED BY

13 LUE SWALLOW SERVIICES

Blue Swallow Consultants CC trading as Blue Swallow Services

I EMP

Blesbokfontein Remainder Quarry

Bkos SuedEovi Senlices Environmental! Divizion

Compiled by:

Blue Swallow Originator:

AJ van der Walt.

EMP Blesbolcfontein Remainder Quarry

CONTENTS

EXECUTIVE SUMMARY

SECTION 1

SECTION 2

SECTION 3

SECTION 4

SECTION 5

SECTION 6

SECTION 7

SECTION 8

SECTION 9

A BRIEF PROJECT DESCRIPTION

DESCRIPTION OF THE MINING ENVIRONMENT

MOTIVATION FOR THE PROPOSED PROJECT

DETAILED PROPOSAL OF THE PROJECT

ENVIRONMENTAL IMPACT ASSESSMENT

ENVIRONMENTAL MANAGEMENT PROGRAMME

CONCLUSION

STATUTORY REQUIREMENTS

AMENDMENTS TO THE EMPR

SECTION 10 REFERENCES AND SUPPORTING DOCUMENTATION

SECTION 11 CONFIDENTIAL MATERIAL

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Blue Swallow Originator. AJ van der Watt.

3 EMP


EXECUTIVE SUMMARY

Blesbokfontein Remainder Clay Quarry on the remainder of the farm

Blesbokfontein 459 JR will be a new refractory and ceramic clay quarry in

the Bronkhorstspruit District that will provide a good quality product to be

sold on the domestic market. It will also provide a number of new job

opportunities in this area. The mining will take place in an area that has

been disturbed severely by mining activities in the past. No attempt to

rehabilitate the remains that these mining activities have left in the area

has thus far been made. After completion of this project, the site under

discussion will however have been fully rehabilitated as grazing land,

which is also the current pre-mining land use. This rehabilitation will also

include the remains left from the previous activities.

The most significant adverse impact that this project will have on the

environment, is the permanent disturbance of the geology in the area. No

significant secondary impacts are however expected from this

disturbance. This impact is inevitable with any mining activity and no

steps exist within reasonable cost, to rehabilitate this impact. The overall

impact of the project can however be regarded as positive since the

project will show a net benefit after completion.

The management of the proposed quarry is committed to undertake an

environmentally acceptable business that will meet the fair requirements

of all affected parties. To ensure this, intensive guidance from the different

State Departments is however of particular importance.

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AJ van der Watt.

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EMP Blesbokfontein Remainder Quarry

SECTION ONE - Brief project description

1.1 Name, address of mine, mine owner and mine manager

Name: Blesbokfontein Remainder Clay Quarry

Address: Blesbokfontein Remainder Clay Quarry P 0 Box 1100 Bronkhorstspruit 1020

Telephone No.: (013) 932 1691

Fax No.: (013) 932 1691

Mine owner: (owner)

Mine manager: Mr. K Roos P 0 Box 1100 Bronkhorstspruit 1020

1.2 Name and address of the mineral rights holder

1.3 Name and address of the holder of mining authority

Name: #

Address:

# Requested to remain anonymous

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Blue Swallow AJ van der Watt.

5 EMP


1.4 Name and address of the owner of the land and title deed descriptions

The site is situated on the Remainder of the farm Blesbokfontein 459 JR — The land is owned by the Government of RSA per title deed T26529/85. (See Section 10)

1.5 Regional setting

1.5.1 Magisterial district and services counsel

The site is situated in the Kwamlangha magisterial district.

1.5.2 Location

The site is situated approximately 17 km north of Bronkhorstspruit and 31 km north-east of Cullinan, at 28°45'00" longitude and 25°30'00" latitude.

1.5.3 Surface infrastructure

The only infrastructure in the vicinity, of the site is a series of dirt roads -linking the local farms and mines with the nearby Ekangala, Cullinan and Bronkhorstspruit.

1.5.4 Presence of servitudes

No servitudes are present on this portion of the farm Blesbokfontein.

1.5.5 Land tenure and use of immediately adjacent land

There are a number of opencast mines situated on the nearby farms. All other surrounding farmland is used for cattle grazing.

1.5.6 Name of river catchment

The site is located in the Elands catchment area.

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1.6 Description of the mine and its actual operating parameters

1.6.1 Mineral deposit

Refractory and ceramic clay

1.6.2 Mine product

Refractory and ceramic clay

1.6.3 Estimated reserves

The estimated reserves are 180 000 metric tons over a target area of approximately 10 ha at a maximum depth of 15 (fifteen) metres. These reserves will last for 10 (ten) years.

1.6.4 Mining method

The mining method is shallow opencast mining. Topsoil will be removed by bowl scraper and stored separately. Overburden and clay will be removed from the quarry by excavator and dumper truck and transported to the stockpile area where they will be stored separately. The mine will be shallow enough to mine without benching.

1.6.5 Planned production rate

The production rate will be approximately 18 000 metric tons per year.

1.6.6 Planned life of mine

It is estimated that the mine will be in production for the next 10 (ten) years at the planned production rate.

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SECTION TWO - Description of the existing mining environment

2.1 Geology

2.1.1 Geology

The geology in the study area comprises of 2-3 metres of grit and coarse sandstone underlain by 2-3 metres of red to yellow clay and sandstone, followed by approximately 4 (four) metres of ceramic clay. Below the ceramic clay semi-flint clay occurs that generally grades downward into sandy flint clay and eventually into sandstone and grit.

2.1.2 Presence of dykes, sills and faults

No known dykes, sills or faults are present on or extend beyond the property boundary.

2.2 Climate

2.2.1 Regional climate

The area has a typical Highveld climate with hot summers and cold winters. Frost frequently occurs during winter times. Most rainfall occurs in the summer, during the months November to March, in the form of thunderstorms. Some extreme weather conditions occur.

2.2.2 Mean monthly and annual rainfall

The rainfall is summarised in Table 1. The rainfall is due almost exclusively to showers or thunderstorms and occurs mainly in summer from November to March with the maximum falls occurring in January, 118.8 mm on average. The mean monthly rainfall in the area is 56.7 mm.

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2.2.3 Maximum rainfall intensities

No record exists of the maximum rainfall intensities in this area. Therefore, no information in this regard can be presented.

2.2.4 Mean monthly maximum and minimum temperatures

The mean monthly maximum and minimum temperatures are summarised in Table 1 The highest mean monthly maximum of 27.0 °C occurs during January, while the lowest mean monthly minimum of 0.7 °C occurs during June.

2.2.5 Wind direction and speed

On the whole winds are light except for short periods during thunderstorms.

2.2.6 Mean monthly evaporation

The mean monthly evaporation is 150.01 mm with the highest occurring in December (201.6 mm) and the lowest in June (85.7 mm).

2.2.7 Incidences of extreme weather

Hail and drought are the only forms of extreme weather that occurs in the area. The exact frequency for hail is unknown, but it occurs mainly in summer time, while severe drought occurs 12% of all years.

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Table 1 Rainfall Temperature Evaporation

mm Maximum Minimum Mm January 118.8 27.0 13.8 198.0 February 93.3 26.3 13.1 165.1 March 79.3 24.9 11.6 162.9 April 39.6 23.0 7.6 125.3 May 19.7 20.3 3.0 105.5 June 6.8 17.7 (0.7) 85.7 July 8.8 17.5 (0.8) 93.8 August 8.4 20.6 1.8 124.2 September 22.1 23.6 6.1 160.9 October 64.1 26.0 10.4 194.0 November 109.1 25.9 11.9 183.1 December 110.2 _ 26.8 13.2 201.6

Total 680.2 I 1800.1 Mean 66.68 23.3 7.68 180.01

2.3 Topography

The site itself is situated on a relatively flat area. There are four dumps and two quarries present on the site from previous mining activities. There are also a great number of mine-dumps from previous mining activities, surrounding the site.

(See Figure 1 - Structure pi

The site is situated on an average elevation of 1 475 metres above sea level. The highest point on the site is the northern corner (1481.5 m), while the lowest point is the south-eastern corner (1472.5 m).

2.4 Soil

P.N. Olivier of Doornkraal Nursery (see Section 10) derived the soil information in this document from the attached survey

In general, the soil of the farm Blesbokfontein is that of the Hutton, Clauvelly, Longlands, Weistleigh, Glencoe, Glenrosa and Mispah Forms.

The occurrence of high rainfall during the summer months causes run off and erosion of the topsoil. The area has a general erosion index of 5 (WRC Report No. 298/1.1/94).

See Section 10 - Appendix 4 for the results of the detailed soil analysis.

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2.5 Pre-mining land capability

The land to be disturbed can currently be classified as grazing land. No information about the initial pre-mining land capability is available because opencast mining has been practised on the land surrounding the site, for more than 30 years.

2.6 Land use

2.6.1 Pre-mining land use

The land is currently used for grazing. As stated in the previous paragraph, no information about the pre-mining land-use is available.

2.6.2 Historical agricultural production

No data is available to draw any workable conclusion as to the pre-mining agricultural productivity of the mining area. The land is currently being used as grazing and has a carrying capacity of approximately 6-8 large head of cattle per hectare.

2.6.3 Evidence of misuse

Major signs of misuse associated with the previous mining activities that took place near to the land under discussion, is apparent. On the site itself, there are four different mine dumps of varying sizes, as well as two old quarries. All of these are however included in the plan for rehabilitation of the site and will therefore not be present after mining on the site has ceased.

2.6.4 Existing structures

No structures currently exist on the site.

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2.7 Natural vegetation/plant life

2.7.1 Dominant species

P.H. Olivier of Doornkraal did a survey of the plant species found on the farm Blesbokfontein. All the information about the plant species on the remainder of the farm was derived from this report.

The veld type in the vicinity can be described as Sourish Mixed Bushveld. It is generally a rather open savana with Acacia caffra the dominant tree, in a fairly dense grassveld dominated by Cymbopogon plurinodis, Themeda triandra, Elionurus muticus and Hyparrhenia ssp.

Here follows a list of the principal tree, shrub and grass species in the area, as compiled by Olivier:

Principle trees and shrubs:

Acacia caffra Acacia karoo Acacia robusta subsp. Robusta Acacia tortilis subsp. Heteraccantha Rhus gueinzii Grewia spp. Peltophorum africanum Acacia gerrardii var. gerrardii Pappea capensis Dichrostachys cinerea subsp. Africana Dombeya rotundifolia Combretum zeyheri Sclerocarya birrea subsp. Caffra Ziziphus mucronata Burkea africana

The dominant grass species are: Cymbopogon plurinodis Themeda triandra Elionurus muticus Heteropogon contortus Aristida canescens Eragrostis superba Brachiaria nigropedata Anthephora pubecens

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Aristida stipitata subsp. Gracicliflora Panicum maximum

2.7.2 Endangered or rare species

No evidence was found of any endangered or rare species occurring within the boundaries of the mining site.

2.7.3 Invader or exotic species

No evidence was found of any invader or exotic species occurring within the boundaries of the mining site.

2.8 Animal life

2.8.1 Commonly occurring species

Jackal, duiker, and warthog have occasionally been observed near the mine. A wide variety of bird species, including some water birds eg. The Little Egret and Spurwinged Goose, where spotted in the area.

2.8.2 Endangered or rare species

No endangered or rare species have been observed near the area to be mined.

2.9 Surface water

2.9.1 Surface water quantity

2.9.1.1 The affected water course

No rivers, streams or dams occurred on the mine site prior to mining activities. Currently a quarry exists that is roughly 7- 8 m deep and has a surface area of no more than one hectare. The quarry contains only rainwater. All the effects on the normal water flow are local to the site and have no effect on the surrounding sub-catchment. The sub-catchment is significantly larger in area than the mining area itself.

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Blesbolcfontein Remainder Quarry

2.9.1.2 Mean annual run-off

The annual run-off from the mine area is unknown. The mean annuai run-off in the drainage basin where the site is situated is between 20 and 50 mm (WRC Report No. 298/1.1/94).

2.9.1.3 Normal dry weather flow

There is no dry weather flow of water within the area in which the mine will be situated.

2.9.1.4 Flood peaks

Flood peaks and volumes for recurrence intervals of 1:20, 1:50 and 1:100 year - regional max flood is unknown. Such information is however not of importance to the mine because of the site's elevation and the relative flatness of the area. There is no significant inflow of water onto the site during rainy periods.

2.9.1.5 River diversions

NOT APPLICABLE - no diversions will occur.

2.9.2 Soxlace water quality

The only surface water in the vicinity of the site, is rainwater that is collected in the quarry. See Table 2 for results of tests done on the water in the quarry.

Table 2 Results of water analysis Results: me/1 I dpm nj__IL3/11y___

Flouride(1. 5) 0.00 0.00 Sodium(400) 0.06 1.40 Nitrate(4.0) 0.00 0.00 Potassium(400) 0.04 1.4 Nitron(44.0) 0.00 0.26 Calcium(200) 0.11 2.10 Chloride(250) 0.03 1.19 Magnesium(100) 0.06 0.77 Sulfate(500) 0.06 2.92 Boron(1.5) 0.00 0.00 Phosphate 0.00 0.00 Carbonate 0.00 0.00 Bicarbonate 0.10 6.10

Subtotal: 0.19 I 10.47 Subtotal: 1 0.27 5.65

TOTAL:

16.10

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Human Animal Irrigation

#1111#11 Suitable

Advisory:

Not Suitable

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Min(*)

3.10* TOTAL DISSOLVED MATERIAL:

13.00

To Carbonate 0.00 0 Time Hardening 0.10 5 To Bicarbonate 0.00 0 Perm Hardening 0.07 , 4 Alkalinity 0.10 5

a Correction for any volatile elements, HCO3/2 or.. HCI+HNO3+HF+.. ( ) Advised maximum value for Humans in dpm

pH (>9.5 and <8.6) pHS NAV Electrical conducting ability

5.11 10.35 0.53 9.2 ms/m at 25 degrees Celsius

Class 1 Irrigation water

NB Analysis was not done for microbiological patogenes, organic compounds or pest control substances

2.9.3 Drainage density

The drainage density over the area is unknown, but all other facts indicate that it is very low.

2.9.4 Surface water use

NOT APPLICABLE — no watercourse is affected.

2.9.5 Water authority

The Department of Water Affairs - Centurion.

2.9.6 Wetlands

NOT APPLICABLE - no wetlands occur in the vicinity of the site to be mined.

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Originator: AJ van der Walt.

15 EMP


2.10 Ground-water

2.10.1 Depth of water table

The water table is approximately 10 (ten) metres below the surface. The quarry is 7-8 meters deep and contains only rainwater.

2.10.2 Boreholes

No borehole exists on the site.

2.10.3 Ground-water quality

As stated in the previous paragraph, no borehole exists in the direct vicinity of the mining site. That is why no information regarding the ground-water quality is currently available.

2.10.4 Ground-water use

No ground water is currently being used on the site under discussion.

2.10.5 Ground-water zone

Due to the low transmissibility of the country rocks, the affected ground water compartment will be restricted to that being dewatered for mining purposes at any one time. The mine will not have a noticeable impact on the groundwater zone.

2.10.6 River diversion

NOT APPLICABLE - no rivers will be diverted.

2.11 Air quality

Apart from this mine, as well as the other mines nearby, there will be no identifiable sources of air pollution within the vicinity of the mine. The main source of pollution will be vehicle generated dust.

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The main sources of vehicle generated pollution will be:

Ore loading (vehicle emission and dust) Hauling (vehicle emission and dust) Other traffic (vehicle emission and dust)

Hauling of the mining product will be done by heavy vehicles. The use of dirt roads during the winter months will be a source of dust pollution, but due to the infrequency and low volume of traffic, pollution levels will be limited.

Dust particle pollution can also be caused by abnormally strong winds. Fortunately these winds are normally associated with thunderstorms.

Air pollution due to fires does not normally occur, but may cause temporary pollution in case of serious fire.

2.12 Noise

Vehicles active on the mining site will be the most important sources of noise pollution.

Apart from the mines located in the area, it can be seen as a typical peaceful farming region. Mining activities consist of excavation and dumping by means of large earthmoving equipment. Neighbouring farmers should not be affected by this noise as work takes place during normal daytime hours only and the necessary technology will be used to minimise noise pollution.

Trucks moving on the main dirt road are a normal occurrence and therefore no significant additional impact in this regard will be experienced.

2.13 Sites of archaeological and cultural importance

NOT APPLICABLE — no sites of archaeological or cultural importance occur in the direct vicinity of the site under discussion.

2.14 Sensitive landscapes

No sensitive landscapes that are under -statutory protection are found in the area to be mined. The normal landscape is not regarded as sensitive in any way since it can be rehabilitated and will not give rise to any significant environmental risks under normal circumstances.

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2.15 Visual aspects

The overburden dumps, topsoil dumps and the quarries from the previous mining activities are currently responsible for a great degree of aesthetic pollution on the land surrounding the site, since no rehabilitation has been done to minimize this effect. The site is however situated far from the nearest tarred road. Furthermore, the surrounding region is not seen as a tourism area. The current aesthetic pollution therefore poses no threat to the tourism potential of the area. Settlements in the area are widely dispersed and the population is thinly distributed.

The stockpile and spoil pile areas that will be generated during mining activities will be similar in colour to its surrounds. The size of these piled areas will be kept to a minimum during mining operations since backfilling and rehabilitation will take place as part of the mining operations. During periods of temporary closure, the majority of disturbed areas will have been rehabilitated.

Visual pollution due to atmospheric dust does not take place at present.

2.16 Regional socio-economic structure

2.16.1 Population density, growth and location

The site is situated in the rural area approximately 35 km north of Bronkhorstspruit. The biggest nearby population concentration is in Bronkhorstspruit (38 940 in 1995).

The population density in the immediate vicinity of the mining site is very low (on par with national figures for agricultural rural communities).

The population growth rate in the region is rather low although the birth rate is high (most people migrate to larger developmental nodes if they are not employed locally or if they are dependent on a person who is locally employed).

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2.16.2 Major economic activities

The development nodes of the region act as service centres to the farmers within their spheres of influence. Limited governmental services are also provided within these nodes.

The Bronkhorstspruit, Cullinan, Heidelberg region can be seen as an important agricultural area, specifically for the cultivation of sunflower, cotton, nuts and sorghum. None of these activities however occurs within the direct vicinity of the mine.

The economy of Bronkhorstspruit itself is primarily dependent on income from the following sectors, in this specific order: Agriculture, Manufacturing and Mining.

2.16.3 Unemployment

The unemployment level within this area is very low compared to national figures. This is due to the rural nature of the area and the comparative closeness of larger developmental nodes that act as urbanisation magnets. The majority of the population is employed by the agricultural or agricultural services sectors, manufacturing and lesser so, by mining.

2.16.4 Housing

The nearby Ekangala and other townships provide for housing in the area. The population is concentrated around farmsteads except in Bronkhorstspruit, Cullinan and Ekangala, which are urban areas.

2.16.5 Social infrastructure

The most comprehensive infrastructure in the vicinity of the mine is concentrated in Bronkhorstspruit. The town has the following service facilities:

Schools Clinic Recreational facilities

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Shops Police station Banks Pharmacies Vehicle service stations

The town has shown a growth rate over the past few years of 21.8 %. Approximately 44 heavy and 310 light industries are currently accommodated within the boundaries of the magisterial district of Bronkhorstspruit.

2.16.6 Water supply

No water will be used as part of the mining process. Since there is no borehole on the site, and the water in the quarry is not suitable for human use (See Paragraph 2.9.2), potable water will have to be brought in from elsewhere.

The water in the quarry can however be used for dust control, since it will do no harm to plant or animal life.

2.16.7 Power supply

NOT APPLICABLE — the mine is not connected to ESKOM's national grid.

2.17 Interested and affected parties

Interested parties: (owner) The Department of Minerals and Energy The Department of Water Affairs and Forestry The Department of Agriculture The Department of Environmental Affairs

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SECTION THREE - Motivation for the proposed project

3.1 Benefits of the project

3.1.1 Product Market:

The product will be sold on the domestic market.

3.1.2 Investment:

It is estimated that some R 16 000 will be spend to bring the project into full production.

3.1.3 Running Costs:

The total annual expenditure at full production is estimated to be in the region of no less than R 270 000.

3.1.4 Workforce Necessary:

It is estimated that around 10 people will be employed at full production.

3.1.5 Multiplication Effect:

The product will be for the domestic market. Market related data is not known at this stage and the multiplication cannot be determined significantly because of the varying market.

3.2 Project Alternatives

3.2.1 Mining Method:

Shallow opencast mining with concurrent rehabilitation is the only method possible for this type of project at reasonable cost.

3.2.2 Mineral Processing:

NOT APPLICABLE since the product will be processed elsewhere.

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3.2.3 Transport, Power and Water Supply Routes:-

The mine will use the existing network of dirt roads to haul the product and supply water to the site (See Locality Plan — Figure 3).

3.2.4 Water Supply:

Potable water will be brought in by tanker truck. No water will be used in the process of mining or screening. The only other water that will be used, will be the water from the quarry that will be used for dust control on the access roads.

3.2.5 Mine Infrastructure Sites:

Little infrastructure is necessary for this project. The necessary infrastructure will be placed as close as possible to the boundaries or on sterile land in order to ensure the least possible impact on agricultural land. No workshops will be necessary.

3.2.6 Mine residue sites:

Mine residue will be piled as close as possible to the latest mining site in order to ensure the least possible sterilisation of agricultural land. Most of the residue will be placed back into the quarry areas that have been mined.

3.2.7 Domestic and Industrial Disposal sites:

Very little domestic or industrial waste will be generated in the mining area. All domestic and industrial waste will be contained in drums, removed from the site and sold to scrap-metal dealers, recycled or sent to the nearest municipal waste dump.

3.2.8 Housing Sites:

The workers on the mine will be accommodated in the surrounding townships. There is however also a hostel near the offices of the mining group that can accommodate the workers (See Locality Plan -Figure 3).

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3.2.9 Final Land Use:

Two possible options exist. The first is to use the quarry areas as a dam. This option will however prove to be very costly, as an extensive impact assessment as well as a lot of planning and consultation will be needed. Furthermore, it might present problems if any mining use is opted for in addition to grazing or cultivation.

The second option is to restore the land to grazing land. This will be possible for the whole site.

3.2.10 River Diversions:

NOT APPLICABLE as already stated.

3.2.11 The "No Project" Option:

After a comparison between economic gain and environmental loss have been made and considered, it was realised that the project has greater economic benefit and will have a small environmental impact, that can in any case be managed and minimised.

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Blesboldontein Remainder Quarry

SECTION FOUR - Detailed proposal of the project

4.1 Surface infrastructure

For further information on the subjects as mentioned below, please see the Structure Plan (Figure 1).

4.1.1 Roads, railways and power-lines

Roads required will be an exit ramp from the mine and access roads to the dumps. Currently a road exists that will link the mine to the other dirt roads in the region. This road will however have to be upgraded.

The mine is not connected to the power grid of ESKOM.

4.1.2 Solid waste management facilities

4.1.1.1 Industrial and domestic waste disposal sites

The mine will store all its industrial and domestic waste temporarily on the premises, from where it will either be sold to scrap metal dealers, recycled, or sent to the nearest municipal waste dump.

4.1.1.2 Mine residue disposal sites

All the overburden will be used to rehabilitate mined-out sections of the quarry. The material of the overburden dump will be used during the final phases of rehabilitation. Topsoil will be stored separately.

4.1.2 Water pollution management facilities

4.1.2.1 Sewerage plant

The domestic sewerage generated by the mine will be disposed of by means of pit latrines.

4.1.2.2 Pollution control dams

NOT APPLICABLE — no pollution control dams will be used by the mine.

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4.1.2.3 Polluted water treatment facilities

NOT APPLICABLE — no water treatment facilities will be used by the mine.

4.1.3 Potable water plant

No potable water is currently available on the site and will have to be brought in from elsewhere.

4.1.4 Process water supply system

NOT APPLICABLE — no water is used to process the product of the mine.

4.1.5 Mineral processing plant

NOT APPLICABLE — no mineral processing plant is present.

4.1.6 Workshops, administration and other buildings

NOT APPLICABLE — no workshops, administration and other buildings will be present.

4.1.7 Housing, recreation and other employee facilities

There will be no such facilities for workers other than the basic sanitary facilities.

4.1.8 Transport

The clay will be stockpiled on site and then trucked to the consumer. It is the responsibility of the workers that live off site to arrange for their own transport to and from work (See Locality plan - Figure 3).

4.1.9 Water balance diagram

No water balance diagram will be presented as the only water that will be used at the mine, is the water from the existing quarry. It will be sprayed on the roads as a measure of dust suppression.

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Potable water will be brought in from elsewhere and stored in a tank. The project will therefore have no effect on the water balance of the area.

4.1.10 Disturbances of watercourses

There are no streams or dams within the area. Thus it is unlikely that any of the infrastructure that are necessary for this project will cause any significant disturbance to the normal surface water flow within the mine area.

The quarry areas will not have an impact on the lower-lying parts of the area concerning the runoff volume. Excavated areas will merely hold rainwater that will be pumped out of the quarry areas and sprayed onto the roads as a dust-control measure, as well as onto the open grazing areas. It will be done in such a way that no erosion takes place.

Activities in the mining area will have very little impact on any stream in the region around the mine.

4.1.11 Storm water

The northern corner of the mine area is regarded as representing the highest elevation of the area (1481.5 m). From this point the surface slopes towards the south-eastern corner of the site (1472.5 m). Normal storm water flow will take place in the open areas to the south-east of the existing dumps and quarry.

Storm water will flow mainly into the quarry areas. This scenario will ensure that any surface water pollution due to natural sediments that are suspended in the water is contained within the quarry area.

Any infrastructure that has the potential of causing water pollution will be designed and constructed to be closed areas with no inflow of storm water or effluent release.

Vehicles causing any oil or petroleum spills will be repaired immediately and the necessary chemicals will be used to neutralise a spill of any kind immediately.

These above-mentioned procedures would ensure that no other physical storm water control facilities will be necessary.

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4.2 Construction phase

The following activities will occur prior to commencing with the physical mining of the clay body:

Fencing-off of dangerous areas and introduction of danger signs. Construction of additional roadways — if necessary or upgrade of existing roadways. Construction or upgrade of any other required infrastructure. Installation of dewatering pipelines. Installation and commissioning of dewatering pumps. Removal of vegetation and topsoil to expose the clay body to be mined.

4.3 Operational phase

4.3.1 Soil utilization guide

All the soil, including vegetation, will be removed to expose the clay body. It will be stored for rehabilitation.

Mined-out sections of the quarry will be actively rehabilitated while normal mining commences. Topsoil and overburden from new mining phases will be used to rehabilitate mined-out areas of the quarry. Any topsoil or overburden that is not utilised for immediate rehabilitation will be stockpiled for use during later rehabilitation phases.

4.3.2 Surface layout

For further detail, see the Structure Plan (Figure 1).

4.3.2.1 Access to workings

Access to the working area of the quarry will occur along a gravel road, which will connect the site with the local grid of roads. Access to the quarry can be gained by vehicle or on foot. The roadways are depicted on Locality Map and Structure Plan (Figures 1 and 3).

4.3.2.2 Structures that might be affected by blasting

No blasting will be done.

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4.3.2.3 Surface subsidence

NOT APPLICABLE - no subsidence is expected.

4.3.2.4 Structures and draining paths that might be affected by

subsidence

NOT APPLICABLE - no surface subsidence is expected.

4.3.2.5 The mining plan

See Structure Plan and Rehabilitation Plan (Figure 1 and Figure 2)

4.3.3 Mineral processing

No mineral processing will take place at the mining site.

4.3.4 Plant residue disposal

NOT APPLICABLE — no processing will be done and therefore no residue will be produced.

4.3.5 Transport

Ore is transported by heavy machinery from the quarry to the stockpile dump. The final product is transported to the client by road.

4.3.6 Proposed river diversion

NOT APPLICABLE — no river will be diverted

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AJ van der Walt.

28 EMP


SECTION FIVE — Environmental impact assessment


All those activities that may have an environmental impact will be discussed under the Section 5.2 Operational phase.


5.2.1 Geology

The impact on the geology of the area will be significant but not serious. The impact is immediate, long-term and permanent, but will have only limited impact on other associated environmental aspects. The impact is limited to the site.

The indirect impacts will however not exceed the natural carrying capacities of the area.

5.2.2 Topography

The topography of the area will be changed. The final mined area will probably be left with a sloped minor depression.

The impact is only significant in the sense that it will be a permanent and long-term impact that will occur in stages. It will have an indirect impact on the hydrology of the area, mainly to the surface water flow.. During operations the topography will be in a state of disturbance for short periods in areas where mining and dumping occurs.

The indirect impacts will not exceed the natural carrying capacities of the area.

5.2.3 Soil

No significant impact is expected on soil type or soil quality. If any, the impact will only be for the duration of the life of the mine. All topsoil removed from the quarry will be stockpiled and preserved for rehabilitating the area. The possible impact is limited to the mining site.

For this reason this impact can be regarded as immediate, insignificant and temporary.

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AJ van der Watt.

29


There will be minor indirect impacts on the vegetation of the area. The indirect impacts will however not exceed the natural carrying capacity of the area.

5.2.4 Land capability

The land capability of the area has already been severely influenced by previous mining activities. Since the land capability of the area has already been compromised, the proposed mining activities will not have any major effect on the land capability. Any impact in this regard that may occur will not be permanent, as the rehabilitated land will have the same capacity as the current agricultural land capacity. (it will be suitable for grazing). The impact will be limited to the mining site.

5.2.5 Land use

The land use will not change as it is currently used for grazing purposes. The impact that will occur will however be significant, as it will not allow any other possible land use to occur in the area again. The impact will be permanent and immediate in the mined-out areas and therefore gradual for the mine area as a whole.

5.2.6 Natural vegetation

Compared to the other land in the vicinity, the mining site is relatively sparsely vegetated. Its vegetation consists mostly out of grasses and low shrubs. The removal of vegetation from the site will therefore not have any significant impact.

Rehabilitation of the mined-out areas will in fact have a sianificant and permanent positive impact on the vegetation, as it is expected that more of the natural vegetation of the area will be present on the site after rehabilitation than can be found at present. In addition, no exotic species will be allowed for rehabilitation. The residual impact on the vegetation can therefore be expected to be permanent and positive.

5.2.7 Wild life

Due to mining activities, wild animals will prefer not to enter the area during working hours. The mining activities will have a temporary effect, especially on the smaller species of wild animals that occur in the area. The negative impact is therefore expected to be insignificant.

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AJ van der Watt.

30 EMP


5.2.8 Surface water

There will be no significant impact on the water quality. Any water pollution that might occur can be managed in a pro-active manner. Should any pollution occur it will be possible to manage the situation by implementing procedures and by using the necessary remedial measures during an incident.

In terms of the catchment yield, no significant impact is expected other than that of the change in watering periods in the area compared to normal flow occurrences.

Any negative impacts will be temporary and are expected to be insignificant. Any impacts that may occur will however not exceed the natural carrying capacity of the area.

5.2.8.1 Dewatering volumes and discharges

Dewatering of the existing quarry will have a positive impact, as this water will be used for dust control. This water is suitable for animal and plant use (See Section 2.9.2) and thus evidently not polluted. The impact of dewatering will therefore be immediate, short-term and positive.

5.2.8.2 Flooding

As stated in Section 2.9 floods very rarely occur in this area and no impact in this regard is expected.

5.2.8.3 River diversions

No river diversion occurs. Therefore no impact occurs.

5.2.9 Ground-water

The ground water table will be lowered locally due to dewatering of the area that is mined at the time. The impact will occur gradually and will be long-term. For these reasons the impact is regarded as significant but not serious. Indirect impacts will also occur.

5.2.10 Air quality

This impact can be regarded as insignificant and temporary. Some dust pollution will be generated by the mining activities due to vehicle movement associated with hauling of the product. Roads will constantly be dampened with water from the quarry to control dust pollution.

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31 EMP


The effect of pollution due to vehicle emission is regarded as insignificant and temporary. Very few vehicles will be used which will ensure that no significant pollution of this kind takes place.

Topsoil stockpiles will be grassed to control water and wind erosion as well as the subsequent dust pollution.

Any impacts that may occur will not exceed the natural carrying capacity of the area.

5.2.11 Noise

Vehicle generated noise pollution, due to the small number of vehicles used during mining, will have a temporary negative impact, but can really be regarded as insignificant.

5.2.12 Sites of cultural and archaeological interest

Since no such sites are present there can be no impact.

5.2.13 Sensitive landscape

Since no sensitive or protected landscapes occur there can be no impact.

5.2.14 Visual aspects

The whole site is obscured from the road by the dumps from previous mining activities. Thus, no mining activities will be visible from off-site.

The aesthetic value of the area as a whole has already, due to previous mining activities, severely been compromised. Therefore, any further mining activities in this area will not have any major impact on the aesthetic value of the region.

The residual impact can however be seen as significant, permanent and positive, since the mining site will be fully rehabilitated. This rehabilitation will also include the quarries and overburden dumps that are currently found on the site. After final rehabilitation, the mine will be visible only to the trained eye from off-site. There will be no sharp curves or edges, colour differences and no vegetation variance from that of the region.

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AJ van der Watt.

32


5.2.15 Regional socio-economic structure

The mine will provide work to approximately 10 workers. The impact is positive, long-term and significant if seen in the context of the region.

5.3 Decommissioning phase

The aspects of the mine that should be monitored after closure are:

The resoiled areas, to prevent or fix any erosion channels. The vegetation, to ensure success of the re-vegetation programme.

All other aspects of the EMP should have been accomplished by the time the mine applies for a closure certificate.

5.4 Residual impact after closure

No significant impact in this regard is expected since the mine infrastructure will be easily removable. No permanent structures will be constructed and all structures will be moveable.

The same general principles as for the operational phase will be applicable and therefore no significant impact in this regard should occur.

An application for final closure of the total area will be made after completion of the mining activities and rehabilitation.

Address after closure: (owner)

Compiled by:


AJ van der Watt.

33 EMP


SECTION SIX - Environmental Management Programme


The management of all the activities that take place during construction will be the same as those activities of the operational and closure phases.


6.2.1 Geology

The disturbance of the natural stratigraphy can never be repaired to its original state. No specific management steps will be taken since there are no measures possible for rehabilitating the damage to the geology without excessive cost.

The rehabilitation of the geology consists of the replacement of the high-grade clay with overburden. This will be done concurrently with normal production by backfilling the mined-out parts of the quarry. This approach will include a relatively large amount of the rehabilitation cost in the running cost of the mine, but will prevent double handling of material and thus be more cost-effective.

6.2.2 Topography

The impact on the topography will be minimised by the following measures:

Quarry areas will be refilled with overburden, compacted and covered with topsoil for final rehabilitation. There will be no cavities left after mining. There will also not be any areas left that have not been sloped and revegetated. This will ensure that no erosion will occur after closure.

6.2.3 Soil

Topsoil will be introduced to all areas disturbed by the mining activities, as well as the quarries that are currently found on the premises. Seeding and ripping will be done in all the disturbed areas to promote the prompt resettlement of natural vegetation. This will ensure that no erosion takes place. Soil capability will be monitored and fertilisation will take place should the need to do so occur. The disturbed areas will be sloped before

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AJ van der Walt.

34 EMP


the topsoil is replaced. Sloping will ensure an even distribution of topsoil and prevent any erosion.

The mine's personnel will ensure that no spillage of any effluent from vehicles or machines or tanks occur unnecessarily. The mine will keep the necessary chemicals on site and in stock to treat any spillage. The mining contractor will issue the mentioned chemicals to each vehicle and train his drivers in the use of the mentioned chemicals.

6.2.4 Land capability

Al the disturbed areas indicated on the Structure Plan (Figure 1) will be rehabilitated to grazing land (See the Rehabilitation Plan — Figure 2).

In order to ensure the best possible land capability after closure, the soil quality management and landscaping methods used will be carefully considered after each phase of the operation.

6.2.5 Land use

The same management principals as for soil and land capability will be applicable for land use. The current land use, which is grazing, will remain after closure

6.2.6 Natural vegetation

Disturbed areas where operations have been completed will be seeded and the water that is removed from the existing as well as new quarries will be sprayed onto these when such water is available and not in use for the control of dust pollution. Vegetation will be rehabilitated using only indigenous species.

To ensure that no veld fires occur, personnel and workers will not be allowed to make open fires in the area.

6.2.7 Wildlife

Since very little can be done to manage the wildlife of this area, it was decided to ensure only the least possible disturbance of the natural fauna of this area.

The mining contractor will ensure that no fauna occurring in the area is harmed or killed for whatever reason by his personnel or anyone visiting the site.

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AJ van der Walt.

35 EMP


6.2.8 Surface waiter

No harmful chemicals will be used during the normal production of the mine. If any harmful chemical should be identified or used, special care will be taken to manage the use thereof. The only surface water present on the site is the water contained in the present quarry and occasional rainwater runoff. The mine will take the necessary precautions to prevent any erosion.

Any effluent spillage that might occur will be the responsibility of the mine manager who will keep the necessary chemicals to treat any spillage of harmful effluent immediately.

Tests will be done every year to ensure that the water quality is not affected by the mining activities.

6.2.8.1 The water balance

NOT APPLICABLE — no water will be used in any of the production phases of the mine.

6.2.8.2 Storm-water

Disturbed areas will be rehabilitated to prevent erosion by storm-water.

6.2.8.3 Surface rehabilitation

No perennial water bodies occur within the mine's vicinity. Rehabilitation will focus on the prevention of possible storm-water generated erosion.

6.2.8.4 Legitimate requirements of other surface water users

NOT APPLICABLE — no perennial water body is in the area of the mine.

6.2.8.5 River diversion

NOT APPLICABLE — no river diversions will occur.

6.2.9 Ground water

Currently there is no source of ground water on the site and therefore there is no indication of the quality thereof. There are currently no plans for drilling a borehole in the future. Should the need for a borehole however arise, all the correct procedures will be followed and the water

Compiled by:

Blue Swallow

Originator:

AJ van der Watt.

36 EMP


will be tested on a regular basis to identify and prevent any possible contamination.

6.2.10 Air quality

Dust suppression on roads at the mine will be conducted and vehicles will adhere to appropriate speeding levels applicable both in the mining area and on the nearby dirt roads to be used.

6.2.11 Noise

Vehicles will operate during normal working hours only. Vehicles will be kept in good working condition and the appropriate silencers will be used to ensure that acceptable noise levels are maintained.

Noise levels will also be monitored should any complaints occur in this regard.

6.2.12 Sites of cultural or archaeological interest

NOT APPLICABLE — no sites of archaeological or cultural interest occur on site or in the direct vicinity of the proposed mine.

6.2.13 Sensitive landscapes

NOT APPLICABLE — no sensitive landscapes occur within the mining area.

6.2.14 Visual aspects

Slopes that remain after closure will not have any sharp curves or edges that may not blend in with the natural area. The reintroduction of vegetation will ensure that the least possible visual impact remains after closure. During mining operations the management of dust pollution will also minimise the visual impact. Good vehicle maintenance by the mining contractor will also be a requirement in order to ensure that emission visibility is minimised.

6.2.15 Regional socio-economic structure

No significant impact exists.

Compiled by:


AJ van der Watt.

37 EMP


6.2.16 Interested and affected parties

No significant impact is expected since the farm currently belongs to the government of R.S.A. The person responsible for the operation will however stay in touch with interested and affected parties that will have to be identified on a regular basis to ensure that any grievances that might occur are managed in a pro-active manner.

6.2.17 Submission of information

The person responsible for the operation will make the necessary information available to the interested and affected parties at their request and only with the approval of the (owner) management.

6.2.18 Maintenance

The rehabilitated areas will be monitored to ensure the successful establishment of vegetation. Remedial actions such as replanting or the repair of erosion channels will be taken as and when necessary.

The storm water controls will be monitored to ensure that no sediment bearing water enters the regional drainage pattern.

The rehabilitated areas will be monitored to ensure the successful establishment of vegetation.

6.3 Decommissioning phase and closure

6.3.1 Closure objectives

The mine aims to rehabilitate the environment during normal production. This will minimise the rehabilitation period and limit the funding needed after production has ceased.

The objective is to leave as little as possible evidence that mining ever occurred in the area.

Compiled by:


38 EMP


6.3.2 Infrastructure

The removal of infrastructure will take place after the cessation of production and will be discussed with the future landowner to establish whether it will be useful to him. The remaining infrastructure will then be removed from the site.

6.3.3 Mine residue deposits

6.3.3.1 Disposal facilities

All domestic disposal facilities will be rehabilitated to blend in with the natural environment. No other disposal facilities will be present on the mine.

6.3.3.2 Rainwater control

No seepage or pollution of rainwater is expected during production.

6.3.3.3 Long-term stability

The necessary precautions will be taken to prevent the formation of any unstable areas after rehabilitation.

6.3.3.4 Erosion and dust control

The affected areas will be rehabilitated and covered with indigenous vegetation, as previously described, to prevent any erosion and air pollution.

6.3.4 Dangerous excavations

No dangerous excavations will be left behind after rehabilitation is complete. The quarry will be backfilled to prevent any lengthy or costly rehabilitation procedures after cessation of production. The quarry will be rehabilitated to standards comparable with that of the surrounding environment.

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39


6.3.5 Final rehabilitation

All haul ramps and roads will be rehabilitated during the operational stage, as rehabilitation of the pit will take place concurrent with mining.

6.3.6 Information

The mine manager will supply information to all relevant parties at their request.

6.3.7 Maintenance

The establishment of vegetation and any erosion that might occur will be monitored during the decommissioning phase to determine any possible new problems that might require maintenance.

6.4 Proposed timetable, duration and sequence

6.4.2 Mining projects

6.4.2.1 Submission date of EMP

The EMP will be submitted during September 1998.

6.4.2.2 Construction period

The construction phase of the mine will take approximately 3 months.

6.4.2.3 Cessation date

The mine is scheduled to cease production on 30 September 2008.

6.4.2.4 Proposed rehabilitation programme

Mining with concurrent rehabilitation will take place in five different phases (See Rehabilitation Plan — Figure 2). Rehabilitation will however continue for some time after mining has ceased during a specific phase.

Compiled by:


AJ van der Watt.

40 EMP


The proposed completion dates for the different phases:

Phase 1 — 30 June 2001 Phase 2 — 30 September 2004 Phase 3 — 31 March 2006 Phase 4 — 31 March 2008 Phase 5 — 31 December 2009

6.4.2.5 Proposed date for closure

The proposed closure date is 30 June 2010

6.4.2.6 Proposed decommissioning programme

No final decommissioning programme has been accepted. A comprehensive decommissioning programme will be compiled as soon as the closure date is nearing. The mine is planning to start decommissioning once the resources have been depleted.

6.4.2.7 Proposed date for closure application

The mine will apply for a closure certificate after rehabilitation is completed. The proposed date for the closure application is 31 January 2010.

6.5 Financial provision

The company undertakes to provide a bank guarantee to the amount total of R 180 000,00 (one hundred and eighty thousand Rand) towards the final rehabilitation of the proposed mining area if the costing estimate is approved by the Department:

Compiled by:


41


Large quarry: Sloping of sidewalls by backfilling with overburden : 130 000 m @ R10,00 /m = R 130 000

Small excavations and dumps:

Backfilling of small excavations by overburden from dumps: 5 000 m @ R10,00 /m = R 50 000 (This includes topsoil spreading)

TOTAL R 180 000

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AJ van der Watt.

42


SECTION SEVEN — Conclusion

The net overall impact will not exceed the natural carrying capacity of the environment of the area. No residual impacts should occur that could cause damage to the environment after mining.

The overall success of the rehabilitation process will depend on the extent to and manner in which the mining activities are monitored for the total lifetime of the mine.

Compiled by:

Blue Swallow

Originator. AJ van der Watt.

43 EMP


SECTION EIGHT - Statutory requirements

None at this stage.

Compiled by:


44 EMP


SECTION NINE - Amendments to EMP

Compiled by:


AJ van der Walt.

45 EMP


SECTION TEN - References and supporting documentation

Compiled by:


AJ van der Walt.

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46 EMP


SECTION ELEVEN - Confidential material

None at this stage.

Compiled by:


AJ van der Watt.

Criteria for the evaluation of EMP as an environmental ...

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