GCS Discard Dump EMPR (2016)

Annex 2B

GCS Discard Dump EMPR

(2016)

GCS (Pty) Ltd. Reg No: 2004/000765/07 Est. 1987

Offices: Durban Johannesburg Lusaka Ostrava Pretoria Windhoek

Directors: AC Johnstone (Managing) PF Labuschagne AWC Marais S Pilane (HR) W Sherriff

(Financial)

Non-Executive Director: B Wilson-Jones

www.gcs-sa.biz

Kangra Coal (Proprietary) Limited

(Reg No. 2001/003104/07)

Unit 12b, 2nd Floor, 3 Melrose Boulevard, Melrose Arch

Melrose North 2196

Postnet Suite 379, Private Bag X1, Melrose Arch, 2076

P O Box 745, Piet Retief 2380

Telephone: +27 (0) 17 826 9700

Facsimile: +27 (0) 17 826 5284

Kangra Coal (Pty) Ltd.: Proposed Discard Dump at Maquasa East Mine

Environmental Impact Report and Environmental Management Programme

In terms of the Mineral and Petroleum Resources Development Act (Act No. 28 of 2002)

Report

Version – 1

26 January 2016

Kangra Coal (Pty) Ltd

GCS Project Number: 13-347

DMR Reference: MP 30/5/1/23/2/1/133 & 134 EM

Submitted on behalf of Kangra Coal (Pty) Ltd. by GCS Water & Environment (Pty) Ltd.

GCS Project Number: 13-347 4a Old Main Road, Judges Walk, Kloof, Kwazulu-Natal, 3610 PO Box

819, Gillitts, 3603 South Africa

Kangra Coal (Pty) Ltd Maquasa East Discard Dump

13-347 9 March 2016 Page ii

Kangra Coal (Pty) Ltd. Maquasa East Discard Dump Environmental Impact Report and Environmental Management Programme

In terms of the Mineral and Petroleum Resources Development Act (Act No. 28 of 2002)

Report Version – 1

26 January 2016

DOCUMENT ISSUE STATUS

Report Issue Final

GCS Reference Number 13-347

DMR Reference MP 30/5/1/23/2/1/133 MR

Title

Kangra Coal (Pty) Ltd Maquasa East Discard Dump: Final

Environmental Impact Report and Environmental Management

Programme

Name Signature Date

Author Renee Francis-Steele January 2016

Document Reviewer Renee Janse van Rensburg January 2016

Director Pieter Labuschagne January 2016

LEGAL NOTICE This report or any proportion thereof and any associated documentation remain the property of GCS until the mandator effects payment of all fees and disbursements due to GCS in terms of the GCS Conditions of Contract and Project Acceptance Form. Notwithstanding the aforesaid, any reproduction, duplication, copying, adaptation, editing, change, disclosure, publication, distribution, incorporation, modification, lending, transfer, sending, delivering, serving or broadcasting must be authorised in writing by GCS.


13-347 9 March 2016 Page iii

EXECUTIVE SUMMARY

Background

Kangra Coal (Pty) Ltd (Kangra) owns various operational and defunct coal mines in the

vicinity of Piet Retief in the Mpumalanga Province. An application to combine the approved

Environmental Management Programme (EMPr) for these operations was approved by the

Department of Mineral Resources (DMR) in August 2014. These operations comprise the

Maquasa East (mining completed), Maquasa West (current), Rooikop (historical) and

Nooitgesien (current) mining areas, situated approximately 40km west of the town of Piet

Retief.

All coal from the operational mining areas is transported via conveyors and trucks to the

coal washing plant located at Maquasa East, from where the produced coal discard is

dumped onto the current Discard Dump, also located within the Maquasa East surface area.

Input from the proposed future mine expansion at the proposed Savmore Colliery:

Kusipongo will produce additional discard material in the future which cannot be

accommodated within the existing Discard Dump footprint. To make provision for the

additional discard, a new Discard Dump, to the west of the Maquasa East mining area, is

proposed.

Motivation for the project

In order to facilitate the proposed expansion of Kangra’s mining area and the subsequent

extension of the life of mine (LoM) of these operations, a new Discard Dump is required to

accommodate the additional discard material which will be produced. An expansion of the

LoM will also facilitate the retention of jobs in the long term.

The option for the expansion of the existing Discard Dump was rejected because it was not

considered feasible. The available area would not provide sufficient capacity for the

additional discard disposal required for the extended LoM for the proposed expansions.

Summary of Proposed Development

The proposed new Discard Dump will be situated on Portion 0 (RE) the farm Rooikop 18 HT,

with a portion of the dump overlapping onto Portion 0 (RE) of the farm Maquasa 19HT. The

dump has been designed to cover an area of approximately 65ha, to accommodate

approximately 20 million tonnes of discard, comprising a volume of approximately 11

million m³ over a period of 20 years.


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The proposed new Discard Dump will be equipped with an underdrainage system, liner and

catchment paddocks, Pollution Control Dam (PCD) (two compartments HDPE lined),

stormwater management infrastructure such as trenches and berms, internal haul roads and

fencing/access control.

The proposed dump will be developed in three compartments/phases. Each compartment

will be concurrently rehabilitated to reduce the infiltration of rainwater and to reduce the

amount contaminated runoff, thereby reducing the required capacity of the PCD. The

proposed PCD capacity is 100 000m³, which will be able to accommodate the 1:50 year

storm event, provided that concurrent rehabilitation is undertaken and that a minimum of

200m³/day of water is pumped out of the PCD.

Waste Classification

An assessment of Mineralogy and Total Chemical Composition of a sample of discard found

that the sample consists mostly of Gypsum and Quartz. The acid-base accounting (ABA) and

net acid generation (NAG) analyses revealed that the discard material has a significant

potential to generate acid mine drainage (AMD)/seepage.

Based on the comparison of the leachable concentrations (LC) and total concentrations (TC)

of the discard material to the threshold limits specified in Section 6 of the Norms and

Standards, the discard is classified as Type 3 Waste. This waste may only be disposed of at

a landfill with a Class C liner.

Environmental Authorisation Applications

The following environmental authorisations are being applied for:

• Mineral Resource Development Act, 2002 (Act No. 28 of 2002) (MPRDA): An

addendum to the approved EMPr is required for the proposed Discard Dump. This

application constitutes an amendment to the Consolidated EMPr (approved in

August 2014);

• National Environmental Management Act, 1998 (Act No. 107 of 1998) (NEMA): The

development of the proposed Discard Dump triggers activities listed in terms of the

NEMA. An environmental authorisation is required, this includes a Scoping and

Environmental Impact Assessment (EIA) process; and

• National Water Act, 1998 (Act No. 36 of 1998) (NWA): The construction and

operation of the proposed Discard Dump and PCD require an Integrated Water Use

Licence (IWUL). Furthermore, an exemption from Regulation 4 (a) of Government

Notice 704, published in Government Gazette vol. 408, No. 20119 on 4 June 1999

(GN704) is required due to the proposed Discard Dump being located within 100m of


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a surface water resource. These exemptions must be issued as a condition of the

IWUL.

• A Waste Management Licence (WML) is also required in terms of the National

Environmental Management: Waste Act, 2008 (Act No. 59 of 2008) (NEMWA), as per

Government Notice Regulation 633 (GNR633), which was published in Government

Gazette No. 39020 on 25 July 2015. A full scoping and EIA process is also required,

which must be undertaken in terms of the NEMA Regulations. The WML application

does not form part of the scope of the current process being undertaken, therefore,

it is recommended that the DMR be consulted in order to determine the process to

be followed in respect of the NEMWA requirements.

Public Consultation

The Public Participation Process (PPP) has been undertaken for the three application

processes and complied with the NEMA regulations PPP, which is more comprehensive than

the MPRDA and NWA public consultation requirements. The PPP included the placement of

advertisements (English and Zulu) in the Excelsior News; the placement of site notices; the

distribution of Background Information Documents (BIDs); sms notifications; a Scoping Phase

and an EIA Phase public meeting; the public review of the draft and final Environmental

Scoping Reports (ESR); and the public review of the Draft Environmental Impact Report

(EIR)/Environmental Management Programme (EMPr). The main issues raised include:

• Environmental:

o The proposed dump lies within one of South Africa’s registered Important

Bird and Biodiversity Areas (IBAs) – IBA SA020 Grasslands (an Avifaunal

Assessment has subsequently been undertaken).

o What measures will be implemented to prevent impacts on air quality,

groundwater and surface water resources, including the Heyshope Dam.

o Are there downstream surface water users?

o The impacts of Kangra’s operations on the environment such as the

dewatering of wetlands (this is not part of the scope of the application as

was dealt with as part of the Consolidation and Amendment application).

o The project may have a secondary impact on farmer support programs run

by the Mpumalanga Department of Agriculture, Rural Development, Land

and Environmental Affairs (MDARDLEA) in the area, such as Masibuyele

Emasimini, Masibuyele Esibayeni, etc.

o The erosion identified at other parts of the mine site raises questions about

Kangra’s ability to manage stormwater within the remaining mining area

and the proposed site.


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o The soils study should focus on returning the land to its current land

capability and not its current land use.

o Liners sometimes fail and surface water may also be impacted on. Kangra

must commit to implementing the required mitigation and monitoring

measures.

o Spontaneous combustion of coal causes air pollution and may affect

livestock. Kangra must ensure that this is controlled.

• Community/Social/Socio-economic:

o How will the Iswepe and Driefontein communities benefit in terms of job

opportunities, assistance in small business development, opportunities for

local businesses and youth to subcontract and community projects.

o Security measures to protect community members, e.g. children who may

play in the area.

o What is Kangra’s budget for social investment for the community?

o A huge investment was made by the MDARDLEA in the

Donkerhoek/Driefontein area with regards to animal and crop farming as

well as infrastructure. The proposed development must be managed to

prevent impacts on these projects.

o The number of locals employed by the mine should increase where possible.

Whenever there are opportunities, the employment of local people must be

prioritised.

o When new areas are developed, fencing is often erected, access routes are

changed and security guards are deployed. Kangra must consult with the

community before making these changes and provide alternative access

routes as this affects the movement and everyday lives of the community.

o The studies and the paper exercise takes time, but the impact on the

farmers in the community is direct and immediate.

• Public Participation Process:

o The scheduling of the public meeting was inconvenient because it was in

the late afternoon when people had difficulty finding transport and it was

during the week (this was in contradiction with previous discussions with

the community where meetings on weekends were highlighted as

inconvenient. The Community Liaison Officer has been tasked with

scheduling a meeting with the community).

o An authority meeting and site visit was requested by the MDARDLEA official

(Natural Resource Investigation Unit) (this meeting is to be facilitated by

the applicant).


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o It would be helpful for authorities to attend public meetings to advise

community members in respect of the issues being discussed.

• Authorisation:

o Proof of rezoning in terms of the Spatial Planning and Land Use

Management, 2013 (Act No. 16 of 2013) (SPLUMA) was requested.

Environmental Baseline Conditions

Climate

The study area lies at an average altitude of approximately 1430 m. It is located in the

South African Highveld sub-humid climatic zone, which is a warm, mild summer rainfall

region. It is characterised by warm, wet summers and cool, dry winters.

The average annual rainfall for the area is in the order of 772 mm and the annual average

evaporation is 1 400 mm.

Geology

The proposed Discard Dump is located in the Ermelo Coalfield. The surface geology in the

study area is characterised by the development of a variable thickness of unconsolidated

overburden consisting of both transported and in-situ weathering material.

The Karoo Supergroup succession in the Ermelo Coalfield consists of the Dwyka Group

diamictites, which occur unconformably above a pre-Karoo basement which is overlain by

the coal bearing Vryheid Formation (Ecca Group); the basal Pietermaritzburg formation of

the Ecca Group not being present. The Vryheid Formation strata consist of five (5) coal

seams, namely A (at the base) – E Seams; of which all five (5) seams are hosted by the

Ermelo Coalfield coal seams.

Although no regional structural features are located within the proximity of and/or

traversing the study area, site-specific geophysical data indicates a number of inferred

structural features (interpreted as dolerite dykes) to traverse the study area.

Impacts and mitigation

No impacts on the geology are anticipated.

Topography

The proposed Discard Dump site is topographically flat with a slight slope in a westerly

direction (i.e. towards the Egude River) at 4.9%.


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It is anticipated that the construction activities, as well as the development of the

proposed Discard Dump over its life span will have an impact on the topography of the site.

Although the construction phase impacts can be mitigated through careful planning,

reducing the extent of the construction footprint, putting in erosion control measures and a

concerted rehabilitation effort, the Discard Dump will be a permanent structure that can

only be managed through careful shaping capping and vegetating of the dump.

Soils, Land Use and Land Capability

The study area comprises Pinedene (43.53ha), Clovelly (40.79ha), Glencoe (17.06ha) soil

forms, as well as Anthrosol (4.62ha) (soils largely affected by human activity).

The study area comprises land that is under rehabilitation (4.62ha) and Grassland (Themeda

triandra, also known as Redgrass) which is currently used for cattle grazing and has

scattered patches of bare soil.

Three land capability classes were identified within the study area, based on the soil types,

i.e. Intensive Agriculture (84.22ha), Moderate Agriculture (17.06ha) and Undefined Use

(4.62ha, land under rehabilitation).


The potential soil erosion, soil compaction and soil contamination due to the construction

activities, are rated as Low to Medium significance. The change in land use and land

capability (loss of agricultural potential) due to the development of the Discard Dump are

permanent impacts, and have received a High significance rating. In the event that

pollution from the footprint reaches the surrounding soils, this will result in soil

contamination and a change in the land capability. The proposed development will also

have a cumulative impact on the soil and land capability within the MRA by further altering

the pockets of undeveloped land. These impacts can be mitigated through proper planning,

the implementation of stormwater management and erosion control structures; training of

staff, etc.

There is also the potential for further erosion and compaction of areas surrounding the

dump during the operational phase, as well as the salinization and acidification of the soils

underlying and immediately surrounding the facility. These impacts can be mitigated


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through the construction of the liner system in accordance with the approved design, the

monitoring and management of rehabilitation areas and proper spill management.

Soil erosion and compaction are likely to occur during the decommissioning phase, however

these impacts will be short-term and with a focussed rehabilitation effort. The soil

conditions are expected to improve after decommissioning of the facility.

Terrestrial Ecology

The study area is covered entirely by the Eastern Highveld Grassland, which is an

‘Endangered’ vegetation type which warrants a medium-high environmental sensitivity

rating.

The study area comprises Degraded and Transformed Habitat (irreversible change in the

vegetation due to anthropogenic effects), and Grassland Habitat. The Degraded and

Transformed habitat is comprised of exotic tree stands (of no ecological importance);

excavations (low ecological status and sensitivity); and roads and Infrastructure (no natural

vegetation remaining). The faunal sensitivity of this habitat is low.

The Grassland Habitat has been ascribed a Medium/Low floristic sensitivity, i.e. the natural

habitat has been transformed, but a measure of the original vegetation remains albeit

dominated by secondary climax species. The faunal sensitivity of this habitat is medium.

None of the eight (8) Red Data Listed flora species or the 10 Red Data Listed faunal species

expected to occur within the relevant Quarter Degree Grid (QDS), were recorded in the

study area. However, the possibility that Red Data species might be present within the

study area cannot be excluded at this stage.


Construction activities may result in the loss of species of conservation importance, and the

fragmentation of habitat. Fauna may be affected through loss of habitat and displacement,

and potential harm from vehicles and workers. These impacts are of Low to Medium

significance and can be mitigated through maintaining as much land cover as possible,

demarcating the construction area, salvaging all plants of conservation importance, a

focussed rehabilitation effort and training and supervision of staff.

During operation, flora and fauna may potentially be impacted on through the spread of

impacts from the dump, as well as direct physical harm to fauna. The implementation of

recommended measures which aim to contain contamination, as well as an alien vegetation


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management plan will likely mitigate these impacts. Staff training and awareness is also

required to avoid unnecessary human-animal conflict.

The decommissioning activities are likely to cause disturbances, however this will be short

term and can be readily mitigated. Any land disturbed or exposed during decommissioning

must be rehabilitated, and monitoring of these areas must take place to avoid the

establishment of alien plants. With a carefully planned and implemented rehabilitation

program and proper control of alien plants, the overall conditions of footprint area is

expected to improve over time.

Avifauna

The proposed dump lies within one of South Africa’s registered Important Bird and

Biodiversity Areas (IBAs) – IBA SA020 Grasslands, which comprised 1 050 000ha, centred on

the towns of Volksrust and Wakkerstroom. This area was previously proposed, but has not

since been declared, a Biosphere Reserve.

The avifaunal sensitivity ratings (habitat availability, likelihood of encountering avifauna,

etc.) for the study area are Medium-Low for the Degraded Habitat and Medium-High for the

Natural Grassland, while the wetland outside of the study area is considered to have a high

sensitivity.

There are 30 Endemic and 7 Near Endemic resident species occupying the relevant QDS.

The residents have 20 listed species, these being 11 Near Threatened, and 9 Vulnerable,

however one species is listed as Critically Endangered in South Africa.


The loss of habitat has the potential to impact on breeding and feeding behaviour. This

impact cannot be avoided within the Discard Dump footprint, however management of

disturbed areas outside the footprint is required to reduce the effects of habitat

fragmentation and the loss of potential nesting and feeding sites.

Avifauna may potentially be impacted on through the spread of impacts and subsequent

deterioration of suitable habitat outside the footprint during operation. This must be

controlled through the implementation of a liner, stormwater management structures, dust

suppression and concurrent rehabilitation. An alien vegetation management plan will assist

in maintaining the integrity of the habitat outside of the footprint over the life of the

facility.


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Decommissioning activities may potentially disturb the avifaunal habitat surrounding the

dump. Furthermore, this habitat can be degraded in the long term should alien vegetation

establish within the disturbed areas. With a carefully planned and implemented

rehabilitation program and proper control of alien plants, the overall conditions within and

around the development footprint is expected to improve following decommissioning.

Wetlands and Aquatic Environment

A Channelled Valley Bottom Wetland unit was identified to the west of the proposed

Discard Dump site. The Wetland Index of Habitat Integrity (Wetland-IHI) assessment shows

that this wetland unit has been seriously modified. The Present Ecological Status (PES) of

the wetland is Category E (seriously modified) and the Ecological Importance and Sensitivity

(EIS) is Category D (the wetland unit is not important or sensitive and does not play a

significant role in the moderation of water quality and quantity). The wetland received a

low rating for indirect services (some form of erosion control is provided by the wetland)

and very low rating for direct services.

The Egude River is a perennial watercourse to the west of the proposed development which

is the receiving watercourse. The in-situ water quality (2014) indicated that the water

upstream and downstream of the study area is of good quality, with no evidence of mining

impacts at the time. The instream habitat upstream and downstream of the site is

described as Class C (adequate/fair, moderately modified). The aquatic invertebrate

assessment score (SASS5) upstream of the site was Class E/F (seriously impaired), and

downstream was Class B (very good). The improved/higher score downstream could suggest

that the site’s impacts are contained within the sampled areas or alternatively these

impacts are diluted or removed through wetland floodplain services.


The impacts on the wetland and aquatic ecology unit are ranked as medium significance.

During construction, the wetland soils may be contaminated, the wetland and stream

habitat may be degraded through siltation, potential increased toxicity, an increase in

electrical conductivity (EC) and total dissolved solids (TDS). The degradation may result in a

loss of wetland habitat and subsequent loss in faunal diversity. Mitigation measures include

stormwater management, energy dissipaters to reduce the velocity of stormwater, silt nets,

dust suppression measures and rehabilitation of disturbed areas.

During operation the wetland and stream may be further degraded by the potential spread

of impacts from the dump, i.e. through runoff containing contaminants or silt, dust from

the dump and increased velocity of runoff (leading to the scouring of the stream channel).


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The impacts can be minimised through the maintenance of stormwater management and

silt nets, the monitoring of rehabilitated areas and concurrent rehabilitation of the dump.

The decommissioning phase activities have the potential to create impacts similar in nature

to the construction phase impacts. Careful planning, rehabilitation and monitoring are

required to reduce these impacts. Furthermore, the control of alien plants is required to

prevent long term degradation of the wetland habitat.

Although the wetland ecosystem is already impacted, further contamination during the life

of the facility will also further degrade the wetland ecosystem. A rehabilitation program

must also be developed for the wetland.

Surface Water

The study area is located within the W51B quaternary catchment of the Usutu to Mhalatuze

Water Management Area (WMA). This quaternary catchment is the second catchment of the

Assegai River and the majority of runoff from the study area will eventually drain into this

river. Surface water flows in a north-easterly direction across the site, towards the Egude

River (more than 100m to the west of the proposed dump), which eventually flows into at a

point to the north-east of the study area.

Monitoring results for a point upstream of the proposed site indicates that the water quality

is generally good, falling within SANS 241:2006 drinking water standards.

The majority of surface water abstracted within the catchment is used for commercial

forestry and irrigated agriculture, with domestic use making up a significant portion of the

water abstracted. Water for mining and urban industrial uses makes up a small proportion

of the water use in the catchment.

Based on calculations, the proposed development is expected to cause a stream flow

reduction of not more than 0.7%.


The quality of the nearby Egude River may be impacted during construction due to runoff

containing silt and contaminants and dust from the cleared areas. The runoff

characteristics are expected to be impacted due to the reduction of runoff (due to dirty

water containment) and the increase of runoff velocity. The impacts are rated as medium

to high, but can be mitigated through the reduction of the footprint area, implementation


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of stormwater management structures, erosion control measures and the dissipation of the

energy of runoff.

During the operation, the surface water resource may be contaminated due to runoff from

the dump, overflow from the PCD or runoff from site where spillages have occurred. The

capturing of runoff from the “dirty catchment” will also reduce the volume of flow to the

stream. The maintenance of stormwater and erosion control structures, as well as timeous

intervention to contain and capture any potential pollution is required. Furthermore,

concurrent rehabilitation will reduce the amount of contaminated water created.

The decommissioning phase activities have the potential to create impacts similar in nature

to the construction phase impacts. Careful planning, rehabilitation and monitoring are

required to reduce this impacts.

Groundwater

Based on the aquifer characteristics (e.g. weathering depth, groundwater strike and static

water levels), the hydrogeological system within the study area can be categorised into two

aquifers: a shallow weathered rock/material aquifer and a deeper fractured rock aquifer,

hosted within the Vryheid Formation sediments.

Groundwater levels across the greater study area, range from artesian to ~64m below

ground level (mbgl), with an average water level of ~9.2mbgl. The regional groundwater

flow is from west to east, however, on a local scale the groundwater flow is likely to be

significantly more complex due to geological and structural controls (i.e. groundwater

barriers and/or discrete conduits to flow).

No hydrocensus boreholes were identified within the proposed footprint area. Furthermore,

the greater study area is characteristic of low groundwater usage, with the key source for

water supply to surrounding communities and farmers in the area being surface water. No

groundwater receptors were identified in proximity of the proposed development area.

The prevailing groundwater quality is dominantly of sodium-bicarbonate type, however,

groundwater sourced from monitoring borehole MONBH3 is characteristic of calcium-

sulphate rich water, which is typically associated with water influenced by weathering of

naturally occurring sulphide minerals and/or stagnant water. This deviation in water quality

can most probably be attributed to the mining activities located up-gradient of the study

area.


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During the construction phase of the development, the impact on groundwater is expected

to be of Low significance. This will be limited to potential groundwater contamination due

to uncontrolled spillages and the reduction of groundwater quantity due to the reduction of

recharge from the compaction of the base of the facility and installation of the liner.

During the operational phase, minimal impact on the groundwater system is expected, due

to proposed design and phasing of the facility (i.e. the liner and underdrainage system,

paddocks and concurrent rehabilitation). Seepage from the PCD is not considered likely as

this facility will also be lined. Recharge of the aquifers will be low due to the liner system

and ground compaction. Monitoring is important to detect potential damage of the liners.

Also, pumping and reuse or treatment of water from the PCD is required to avoid an

emergency release during high rainfall conditions, as this would cause contaminated

seepage to migrate from site (both vertically and laterally).

The reduction of recharge due to the use of liners below the Discard Dump and PCD in

conjunction with mining activities is likely to reduce the amount of groundwater within the

resource. The lack of groundwater users in the area and the fact that the removal of water

from the mining areas is likely to end once mining ends, makes this impact of Medium

significance.

Air Quality

The proposed Discard Dump site is located within the north-eastern portion of the Highveld

Priority Area (HPA) declared in 2007 in terms of the National Environmental Management:

Air Quality Act, 2004 (Act No. 39 of 2004) (NEMAQA)

According to the HPA Air Quality Management Plan (AQMP), most of the HPA experiences

relatively good air quality, but there are nine extensive areas (hotspots) where ambient air

quality standards for SO2, NO2, PM10 and Ozone (O3) are exceeded. The Pixley ka Seme Local

Municipality (PSLM) is highlighted as a hotspot.

The greater study area is characterised by high stability levels, which inhibits the ability of

inversion layers to develop, particularly in the early hours of winter mornings. This

phenomenon may result in increasing ground level pollution concentrations.

The sensitive receptors identified in the vicinity of the study area include the Heyshope

Dam, Driefontein community and surrounding farms.


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Air quality effects during the life of the facility will be limited to the creation of dust due

to surface being exposed to the action of wind, as well as the movement of vehicles on site

and haul roads. These impacts, which are considered to be of Medium significance, are not

significant in the context of the development site location, i.e. within a MRA, adjacent to

existing mine operations. However, the location of the footprint area within the HPA means

that special care should be taken to reduce the creation of dust and to monitor these

potential impacts. Proper rehabilitation of disturbed areas, the concurrent rehabilitation of

the dump and dust suppression spraying of the haul roads are required to mitigate these

impacts.

Noise

Mining and mining related activities are the sources of noise in the vicinity of the study

area. The prevailing noise level recorded at gravel road (to the south of the site and

adjacent to a conveyor) is around 66.7dBA during the daytime and 70.0dBA during the

night-time.

The Driefontein residential area and the residents are already exposed to a certain extent

of higher noise levels than expected in a residential area.


Although noise is likely to be created during the life of the facility, these are not likely to

be above the ambient noise levels of the nearby mining operations. Therefore, the impact

on sensitive receptors is considered low. The impact, however, can be mitigated through

following a daily work schedule and the regular servicing of all vehicles and equipment.

Visual

The proposed Discard Dump site is located within an existing MRA. The site comprises

grassland which is used for cattle grazing. Mining facilities and infrastructure are clearly

visible from the centre of the site, i.e. haul roads, a conveyor rehabilitated area, etc. The

site is not clearly visible by the nearby Driefontein community, or from any major routes or

residential roads.

The study area presents a disturbed sense of place due to the existing mining activities and

infrastructure, and the previous disturbances (area under rehabilitation).



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Although the removal of vegetation and undertaking the construction as well as the

increasing size of the dump are likely to result in a major change to the aesthetics of the

landscape, this impact is considered of low significance due to the fact that the footprint is

located within an existing MRA and is not visible from any local or regional roads, or the

nearby community. The concurrent rehabilitation, including the shaping of the dump, must

be undertaken with the aim of blending the dump in with the surrounding landscape as far

as possible.

Dust creation is likely to cause poor visibility conditions, however this impact would be

limited in spatial extent and duration. This impacts can be mitigated through the proper

rehabilitation of disturbed areas, the concurrent rehabilitation of the dump and dust

suppression spraying of the haul roads are required to mitigate these impacts.

Socio-economic Environment

The study area is located within the north-eastern corner of the Pixley ka Seme Local

Municipality (PSLM), which forms part of the Gert Sibande District Municipality (GSDM) of

the Mpumalanga Province.

The community which is closest to the project area, is the Driefontein community. The

community, which is located approximately 2km to the west of the proposed development

site, is a densely populated settlement consisting largely of Reconstruction and

Development Property (RDP) style housing, or low cost housing. Approximately 365 of

Kangra’s employees are from Driefontein.

Driefontein has many dwellings without clean running water and sanitation facilities; and a

number of roads are in poor condition which pose a risk to the safety of pedestrians and the

health of the larger community by dust creation.


The proposed Discard Dump poses very few impacts to the socio-economics of the

immediate area surrounding the region. Temporary labour will be created during the

construction phase, however a very limited number of jobs would be created for a short

period. The nuisance created by dust and noise are considered to be of Low significance,

due to the current ambient conditions created by the existing mining operation and the

distance of the site from the community. The potential nuisance impacts can be mitigated

through the implementation of the recommended environmental management measures.


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Although no additional socio-economic impacts are likely to be created by the operation of

the dump, the additional disposal capacity created will accommodate for the proposed

expansions, and will maintain employment for the current mine workers in the long term.

Heritage and Archaeology

Heritage resources, which are quite common in region, include historical remains

associated with farmstead complexes. These consists of houses, associated outbuildings,

cattle enclosures; formal graveyards, and abandoned graveyards left by farm workers who

moved from farms to urban areas. No sites of high significance (e.g. graveyards) were

identified within the areas surveyed.


Although no impacts on any sites of heritage or archaeological value are anticipated, it is

always a possibility that the assessments may have missed heritage resources in the areas

surveyed. Heritage sites may occur in tall grass or in Blue Gum lots and others may lie

below the surface of the earth and may only be exposed once development commences.

In the event that any heritage resource of significance is identified within the footprint, all

development activities must cease. The South African Heritage Resources Authority (SAHRA)

should be notified immediately, and an accredited archaeologist consulted to determine

appropriate mitigation measures for the discovered finds. This may include obtaining the

necessary authorisation (permits) from SAHRA to conduct the mitigation measures.

Main Issues and Recommendations

The main gaps identified area:

• Surface Water Quality: No baseline surface water data exists for any points

downstream of the proposed site. Downstream monitoring points must be included

in the monitoring programme to establish the baseline conditions of the affected

reach of the Egude River (pre-construction) and to measure potential impacts.

• Groundwater: It is recommended that a numerical model is constructed, during the

operational phase of the proposed Discard Dump. This model should be updated

using the groundwater monitoring data collected to assist in closure planning

objectives and management plans.

• Aquatic environment: There is currently no biomonitoring programme in place

within the vicinity of the proposed Discard Dump. It is recommended that a

programme is established prior to construction in order to establish the baseline

conditions of the affected watercourse.


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• Wetlands: A Wetland Rehabilitation Plan would be required as part of the IWULA

process, as per the DWS requirements. It is recommended that such a plan is

compiled for sign-off by the DWS.

• Authorisations:

o A Waste Management Licence (WML) is required in terms of the National

Environmental Management: Waste Act, 2008 (Act No. 59 of 2008)

(NEM:WA) before the development of the Discard Dump may commence. A

Scoping and EIA process is required, which must be undertaken in

accordance with the NEMA EIA Regulations (2014 Regulations) in order to

apply for this authorisation from the regional DMR.

It is recommended that the DMR is consulted with regarding the NEM:WA

application, taking cognisance of the current EIA process in terms of the

NEMA Regulations.

o The properties on which the proposed Discard Dump will be located may

require rezoning. It is recommended that Kangra liaise with the local

municipality prior to construction to determine whether rezoning would be

required.

EAP recommendation

No fatal flaws have been identified during the EIA process. There is however, the potential

for impacts on the environment, particularly of a cumulative nature, due to the proximity

of the development site to the existing mining activities. The proposed Discard Dump is

necessary to accommodate for the proposed expansion and continuation of Kangra’s mining

activities, which will preserve jobs over the long term and benefit the economy of the

region and the country. It is recommended that the development is authorised, provided

that the mitigation and management measures recommended in this report and in the IWUL

(should this granted) are enforced and monitored. Furthermore, the WML required must

also be applied for and obtained prior to the development proceeding.


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LIST OF ACRONYMS

BID Background Information Document

EMP Environmental Management Plan

EMPr Environmental Management Programme

ESR Environmental Scoping Report

DMR Department of Mineral and Resources

DWA Department of Water Affairs (changed to DWS)

DWS Department of Water and Sanitation (formerly DWA)

DEA Department of Environmental Affairs

EAP Environmental Assessment Practitioner

EC Electrical Conductivity

EIA Environmental Impact Assessment

EIS Ecological Importance and Sensitivity

ELWU Existing Lawful Water Use

GA General Authorisation

GSDM Gert Sibande District Municipality

GNR Government Notice Regulation

I&AP Interested and Affected Parties

IBA Important Bird and Biodiversity Areas

IHAS Invertebrate Habitat Assessment System

IUCN International Union for the Conservation of Nature

IWULA Integrated Water Use License Application

IWUL Integrated Water Use License

IWWMP Integrated Waste Water Management Plan

LOM Life of Mine

MAE Mean Annual Evaporation

mamsl Metres above mean sea level

MAR Mean Annual Runoff

mbgl Metres below ground level

MDARDLEA Mpumalanga Department of Rural Development, Land and Environmental Affairs

MPRDA Minerals and Petroleum Resource Development Act, 2002 (Act No. 28 of 2002)

MRA Mining Right Area

Mtpa Million tons per annum

NEM:WA National Environmental Management: Waste Act, 2008 (Act No. 59 of 2008)


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

NWA National Water Act, 1998 (Act No. 36 of 1998)

PES Present Ecological Status

PPP Public Participation Process

PCD Pollution Control Dam

PES Present Ecological Status

PSLM Pixley ka Seme Local Municipality

ROD Record of Decision

RoM Run of Mine

SANS South African National Standards

SASS South African Scoring System

SAWS South African Weather Service

SAWQG South African Water Quality Guidelines

SWMP Storm Water Management Plan

TDS Total Dissolved Solids


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CONTENTS PAGE

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

1.1 BACKGROUND AND HISTORY ............................................................................................................ 1 1.2 DESCRIPTION OF LAND .................................................................................................................... 4 1.3 NEED AND DESIRABILITY OF THE PROJECT ........................................................................................... 4 1.4 THE APPLICANT ............................................................................................................................. 6 1.5 ENVIRONMENTAL ASSESSMENT PRACTITIONER .................................................................................... 6 1.6 LEGISLATIVE CONTEXT .................................................................................................................... 7

1.6.1 Constitution of South Africa .............................................................................................. 7 1.6.2 Mineral and Petroleum Resources Development Act ....................................................... 7 1.6.3 National Environmental Management Act ....................................................................... 8 1.6.4 National Water Act ......................................................................................................... 10 1.6.5 GN704 ............................................................................................................................. 11 1.6.6 National Environmental Management: Air Quality Act .................................................. 11 1.6.7 National Environmental Management: Waste Act ......................................................... 12 1.6.8 Spatial Planning and Land Use Management Act........................................................... 14 1.6.9 Other Legislation ............................................................................................................. 15

1.7 ENVIRONMENTAL PROCESS ............................................................................................................ 15 1.7.1 Application phase ........................................................................................................... 16 1.7.2 Scoping and PPP initiation .............................................................................................. 17 1.7.3 EIA Phase and Public Feedback ....................................................................................... 17

1.8 REPORT STRUCTURE ..................................................................................................................... 18

2 PROJECT DESCRIPTION ............................................................................................................. 20

2.1 PROJECT BACKGROUND (CURRENT AND FUTURE MINING) ..................................................................... 20 2.1.1 Maquasa East (underground and opencast) and West (underground) .......................... 20 2.1.2 Nooitgesien Mining Area ................................................................................................ 21 2.1.3 Rooikop ........................................................................................................................... 21 2.1.4 Kusipongo ....................................................................................................................... 21 2.1.5 Projected coal tonnages ................................................................................................. 21

2.2 DESCRIPTION THE DISCARD MATERIAL ............................................................................................. 22 2.2.1 Hydrogeochemical Characterisation of the Discard ....................................................... 22 2.2.2 Waste Classification ........................................................................................................ 24

2.3 DESCRIPTION THE PROPOSED DEVELOPMENT ..................................................................................... 25 2.3.1 General Layout ................................................................................................................ 25 2.3.2 Dimensions and life of the facility ................................................................................... 27 2.3.3 Construction/Disposal Method ....................................................................................... 27 2.3.4 Groundwater/Seepage management ............................................................................. 29 2.3.5 Surface Water/Stormwater Management ...................................................................... 31 2.3.6 Safety Classification ........................................................................................................ 37 2.3.7 Access Control ................................................................................................................. 38

2.4 DISCARD DUMP REHABILITATION .................................................................................................... 38

3 PROJECT ALTERNATIVES ........................................................................................................... 40

3.1 ACTIVITY/PROJECT ....................................................................................................................... 40 3.1.1 Expansion of existing Maquasa East Discard Dump ....................................................... 40 3.1.2 Development of a New Discard Dump (Preferred Option) .............................................. 40

3.2 ALTERNATIVE LOCATIONS FOR NEW DISCARD DUMP .......................................................................... 42 3.3 DISPOSAL ALTERNATIVES ............................................................................................................... 46

3.3.1 Integrated Discard “Dry” (Preferred Alternative) ........................................................... 46 3.3.2 Co-disposal “Wet and Dry” ............................................................................................. 46 3.3.3 Integrated Discard “Wet” ............................................................................................... 46 3.3.4 Separate Disposal ”Wet – Site 1 and Dry Site 2” ............................................................ 46

3.4 LAND USE ALTERNATIVES .............................................................................................................. 47


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3.4.1 Tourism ........................................................................................................................... 47 3.4.2 Residential ...................................................................................................................... 47 3.4.3 Grazing of Cultivated Land.............................................................................................. 47 3.4.4 Mining ............................................................................................................................. 47

3.5 NO GO ALTERNATIVE ................................................................................................................... 48

4 ENVIRONMENTAL BASELINE DESCRIPTION ............................................................................... 49

4.1 CLIMATE .................................................................................................................................... 49 4.1.1 Temperature ................................................................................................................... 49 4.1.2 Wind................................................................................................................................ 49 4.1.3 Rainfall ............................................................................................................................ 49 4.1.4 Evaporation..................................................................................................................... 50

4.2 GEOLOGY ................................................................................................................................... 51 4.2.1 Regional Geology ............................................................................................................ 51 4.2.2 Local Geology .................................................................................................................. 52 4.2.3 Structural Geology .......................................................................................................... 54

4.3 TOPOGRAPHY ............................................................................................................................. 54 4.4 SOILS, LAND USE AND LAND CAPABILITY .......................................................................................... 56

4.4.1 Soil forms ........................................................................................................................ 56 4.4.2 Current Land Use ............................................................................................................ 59 4.4.3 Land Capability ............................................................................................................... 61

4.5 TERRESTRIAL ECOLOGY (FLORA AND FAUNA) ..................................................................................... 64 4.5.1 Vegetation Unit ............................................................................................................... 64 4.5.2 Declared Conservation Areas .......................................................................................... 67 4.5.3 Flora ................................................................................................................................ 67 4.5.4 Fauna .............................................................................................................................. 73 4.5.5 Avifauna .......................................................................................................................... 75

4.6 AQUATIC ECOLOGY ...................................................................................................................... 80 4.6.1 Sampling Sites ................................................................................................................. 80 4.6.2 Affected River Reaches ................................................................................................... 83 4.6.3 In-situ Water Quality ...................................................................................................... 84 4.6.4 Invertebrate Habitat Assessment ................................................................................... 85 4.6.5 Aquatic Invertebrate Assessment ................................................................................... 86

4.7 WETLANDS ................................................................................................................................. 89 4.7.1 Wetland Delineation ....................................................................................................... 91 4.7.2 Wetland Classification .................................................................................................... 93 4.7.3 Wetland Index of Habitat Integrity ................................................................................. 93 4.7.4 Wetland PES and EIS ....................................................................................................... 93 4.7.5 Wetland Eco-services ...................................................................................................... 94

4.8 SURFACE WATER ......................................................................................................................... 94 4.8.1 Catchment and Hydrology Description ........................................................................... 95 4.8.2 Mean Annual Runoff ....................................................................................................... 97 4.8.3 Flood Flows and Volumes ............................................................................................... 97 4.8.4 Floodlines ........................................................................................................................ 98 4.8.5 Surface Water Quality .................................................................................................... 98 4.8.6 Water Users within the Catchment ............................................................................... 100

4.9 GROUNDWATER ........................................................................................................................ 100 4.9.1 Aquifer description ........................................................................................................ 100 4.9.2 Drilling program ............................................................................................................ 102 4.9.3 Groundwater Strikes and Air-lift yield ........................................................................... 104 4.9.4 Groundwater Level and Direction ................................................................................. 104 4.9.5 Hydrocensus .................................................................................................................. 104 4.9.6 Natural Springs ............................................................................................................. 107 4.9.7 Groundwater Quality .................................................................................................... 107 4.9.8 Source-Pathway-Receptor Description ......................................................................... 112


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4.10 HERITAGE AND ARCHAEOLOGY ..................................................................................................... 113 4.10.1 Summary of findings ..................................................................................................... 115

4.11 NOISE...................................................................................................................................... 115 4.12 AIR QUALITY ............................................................................................................................. 116

4.12.1 Regional Air Quality ...................................................................................................... 116 4.12.2 Local Air Quality ............................................................................................................ 116

4.13 SOCIO-ECONOMIC ENVIRONMENT ................................................................................................. 117 4.13.1 Demographic Profile ..................................................................................................... 118 4.13.2 Economic Profile ........................................................................................................... 118 4.13.3 Neighbouring community ............................................................................................. 119

5 PUBLIC PARTICIPATION .......................................................................................................... 120

5.1 IDENTIFICATION OF INTERESTED AND AFFECTED PARTIES (I&APS) ....................................................... 120 5.2 NOTIFICATION OF I&APS ............................................................................................................ 121

5.2.1 Background Information Document ............................................................................. 121 5.2.2 Site Notices ................................................................................................................... 121 5.2.3 Newspaper Advertisement ........................................................................................... 122 5.2.4 Sms notification ............................................................................................................ 122

5.3 CONSULTATION WITH THE AUTHORITIES ......................................................................................... 122 5.4 CONSULTATION WITH I&APS ....................................................................................................... 123

5.4.1 Public review of documents .......................................................................................... 123 5.4.2 Scoping Phase Public Meeting & Distribution of Minutes ............................................. 123 5.4.3 Public Feedback (EIA Phase) Meeting ........................................................................... 124

5.5 STAKEHOLDER DATABASE ............................................................................................................ 124 5.6 COMMENTS AND RESPONSE SUMMARY ......................................................................................... 124

6 REHABILITATION PLAN ........................................................................................................... 152

6.1 AIM OF THE REHABILITATION PLAN ............................................................................................... 152 6.2 CLOSURE OBJECTIVES ................................................................................................................. 152 6.3 POST-CONSTRUCTION REHABILITATION .......................................................................................... 153 6.4 POST-DECOMMISSIONING REHABILITATION ..................................................................................... 153

6.4.1 Phase 1 .......................................................................................................................... 153 6.4.2 Phase 2 .......................................................................................................................... 153

7 ASSESSMENT OF ENVIRONMENTAL IMPACTS ......................................................................... 157

7.1 ENVIRONMENTAL IMPACT ASSESSMENT METHODOLOGY ................................................................... 157 7.2 CONSTRUCTION PHASE IMPACTS ................................................................................................... 159

7.2.1 Construction Phase Activities ........................................................................................ 159 7.2.2 Description of potential impacts ................................................................................... 160 7.2.3 Assessment of Potential Impacts .................................................................................. 164

7.3 OPERATIONAL PHASE IMPACTS ..................................................................................................... 174 7.3.1 Operational Phase Activities ......................................................................................... 174 7.3.2 Description of potential impacts ................................................................................... 174 7.3.3 Assessment of Operational Phase Impacts ................................................................... 178

7.4 DECOMMISSIONING AND CLOSURE PHASE IMPACTS ......................................................................... 185 7.4.1 Decommissioning and Closure Phase Activities ............................................................ 185 7.4.2 Description of impacts .................................................................................................. 185 7.4.3 Assessment of Decommissioning Phase Impacts .......................................................... 188

7.5 CUMULATIVE IMPACT ASSESSMENT ............................................................................................... 197 7.5.1 Description of Impacts .................................................................................................. 197 7.5.2 Assessment of Impacts ................................................................................................. 199

8 ENVIRONMENTAL MANAGEMENT PROGRAMME ................................................................... 205

8.1 RESPONSIBILITIES ....................................................................................................................... 205 8.1.1 Project Manager ........................................................................................................... 205 8.1.2 Environmental Control Officer ...................................................................................... 205


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8.1.3 Contractor ..................................................................................................................... 206 8.1.4 Environmental Manager/Officer................................................................................... 206 8.1.5 Consulting/Project Engineer ......................................................................................... 206 8.1.6 Plant Engineer ............................................................................................................... 206

8.2 ENVIRONMENTAL MANAGEMENT: CONSTRUCTION PHASE ................................................................. 207 8.2.1 Action Plan .................................................................................................................... 207 8.2.2 Reporting and General Requirements........................................................................... 217 8.2.3 Soil Management Plan .................................................................................................. 218

8.3 ENVIRONMENTAL MANAGEMENT: OPERATIONAL PHASE ................................................................... 219 8.3.1 Action Plan .................................................................................................................... 219 8.3.2 Reporting and General Requirements........................................................................... 227

8.4 ENVIRONMENTAL MANAGEMENT ACTION PLAN: DECOMMISSIONING AND CLOSURE PHASE .................... 228 8.4.1 Action Plan .................................................................................................................... 228 8.4.2 Reporting and General Requirements........................................................................... 240

9 MONITORING AND AUDITING ................................................................................................ 242

9.1 SURFACE WATER MONITORING .................................................................................................... 242 9.2 GROUNDWATER MONITORING ..................................................................................................... 245 9.3 AQUATIC BIOMONITORING .......................................................................................................... 248 9.4 AIR QUALITY MONITORING ......................................................................................................... 251 9.5 REHABILITATION PROGRESS .......................................................................................................... 251 9.6 REPORTING .............................................................................................................................. 251 9.7 ENVIRONMENTAL PERFORMANCE AUDITS....................................................................................... 252

10 ENVIRONMENTAL AWARENESS AND EMERGENCY RESPONSE PLAN....................................... 253

11 FINANCIAL PROVISION ........................................................................................................... 254

12 INFORMATION GAPS AND RECOMMENDATIONS ................................................................... 256

12.1 SURFACE WATER ....................................................................................................................... 256 12.1.1 Water Quality ............................................................................................................... 256 12.1.2 Floodlines ...................................................................................................................... 256

12.2 GROUNDWATER ........................................................................................................................ 257 12.3 AVIFAUNA ................................................................................................................................ 257 12.4 AQUATIC ENVIRONMENT ............................................................................................................. 257 12.5 WETLANDS ............................................................................................................................... 257 12.6 FURTHER AUTHORISATIONS REQUIRED........................................................................................... 258

12.6.1 Waste Management Licence ........................................................................................ 258 12.6.2 Rezoning ....................................................................................................................... 258

13 CONCLUSION AND IMPACT STATEMENT ................................................................................ 259

14 REFERENCES ........................................................................................................................... 265

LIST OF FIGURES

Figure 1.1 Locality of Kangra Mining Operations near Piet Retief ..................................................... 3 Figure 1.2 Property Details ................................................................................................................ 5 Figure 1.3 Environmental Process Flow Diagram ............................................................................ 16 Figure 2.1 Discard Dump Layout (Geotail, 2014) ............................................................................. 26 Figure 2.2 Proposed Liner for the Discard Dump (Source: Geotail, 2014)....................................... 30 Figure 2.3 Proposed Liner for the PCD (Source: Geotail, 2014) ....................................................... 31 Figure 2.4 Proposed Liner for the PCD (Source: Geotail, 2014) ....................................................... 33 Figure 2.5 Discard Dump Process Flow Diagram ............................................................................. 34 Figure 2.6 Discard Dump Water Balance ......................................................................................... 35 Figure 2.7 Proposed Cover for the PCD (Source: Geotail, 2014) ..................................................... 39


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Figure 3.1 Existing Discard Dump .................................................................................................... 41 Figure 3.2 Potential Discard Dump Locations .................................................................................. 44 Figure 4.1 Geological Map of the Study Area .................................................................................. 53 Figure 4.2 Topographical Map of the Study Area ............................................................................ 55 Figure 4.3 Soil forms within the Study Area .................................................................................... 57 Figure 4.4 Current Land Use of the Study Area ............................................................................... 60 Figure 4.5 Land Capability of the Study Area................................................................................... 63 Figure 4.6 Vegetation Units within the Study Area ......................................................................... 66 Figure 4.7 Macro-habitats within the Study Area ........................................................................... 70 Figure 4.8 Aquatic Sampling Points ................................................................................................. 82 Figure 4.9 NFEPA Wetlands around the study area......................................................................... 90 Figure 4.10 NFEPA Wetlands around the study area ..................................................................... 92 Figure 4.11 Channelled valley Bottom Wetland ............................................................................ 93 Figure 4.12 Discard Dump: Watercourse 100m Buffer Map ......................................................... 96 Figure 4.13 Location of groundwater monitoring boreholes ...................................................... 103 Figure 4.14 Location of hydrocensus boreholes .......................................................................... 106 Figure 4.15 Location of the Power Station project area (GCS, 2008) .......................................... 114 Figure 6.1 Phase 1 of Rehabilitation .............................................................................................. 155 Figure 6.2 Phase 2 of Rehabilitation .............................................................................................. 156 Figure 9.1 Proposed Surface Water Monitoring Points ................................................................. 244 Figure 9.2 Proposed Groundwater Monitoring Locations ............................................................. 247 Figure 9.3 Proposed Biomonitoring Sites ...................................................................................... 250

LIST OF TABLES

Table 1.1 Property Details ................................................................................................................ 4 Table 1.2 Applicant’s Details ............................................................................................................ 6 Table 1.3 EAP’s Details ..................................................................................................................... 6 Table 1.4 NEMA Listed Activities triggered by the proposed Discard Dump ................................... 9 Table 1.5 Summary of Environmental Authorisations Required .................................................... 15 Table 2.1 Dimensions and Capacity of the proposed Discard Dump ............................................. 27 Table 2.2 Stormwater Channel Dimensions ................................................................................... 31 Table 2.3 PCD Design Specifications ............................................................................................... 37 Table 2.4 Discard Dump Safety Classification................................................................................. 38 Table 3.1 Fatal Flaw Assessment of Potential Sites (Hatch 2011) .................................................. 42 Table 3.2 Assessment of Alternative Sites...................................................................................... 45 Table 4.1 Summary of rainfall data (Ilanda, June 2014) ................................................................. 50 Table 4.2 Summary of monthly evaporation data (Ilanda, June 2014) .......................................... 51 Table 4.3 Land Capability Classes- Description and Suitability ....................................................... 61 Table 4.4 Plant families recorded (March 2014 survey) ................................................................. 68 Table 4.5 Estimate of Floristic Sensitivity of the Study Area .......................................................... 71 Table 4.6 Red Data Flora Species known to occur in QDS2730AB ................................................. 72 Table 4.7 Estimate of Faunal Habitat Sensitivity of the Study Area ............................................... 74 Table 4.8 Red Data Fauna Species known to occur in QDS2730AB ................................................ 74 Table 4.9 Animal Species recorded in the Study Area .................................................................... 75 Table 4.10 Avifaunal Habitat Sensitivity of the study area............................................................... 78 Table 4.11 Aquatic Sampling Sites .................................................................................................... 81 Table 4.12 In situ water quality at the Aquatic Sampling sites (4-6 March 2015) ............................ 84 Table 4.13 IHAS results for the Aquatic Sampling sites (4-6 March 2015) ....................................... 85 Table 4.14 Ecological Classes Assigned to the SASS5 and ASPT Scores ............................................ 87 Table 4.15 SASS results for the Aquatic Sampling sites (4-6 March 2015) ....................................... 87 Table 4.16 Wetland IHI Assessment Results .................................................................................... 93


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Table 4.17 PES of the Wetland Unit ................................................................................................. 94 Table 4.18 EIS of the Wetland Unit .................................................................................................. 94 Table 4.19 Wetland Ecosystem Services .......................................................................................... 94 Table 4.20 Summary of flood peak calculations ............................................................................... 98 Table 4.21 Surface water chemistry (July & September 2014) ........................................................ 99 Table 4.22 Surface water users within the quaternary catchment ................................................ 100 Table 4.23 Hydro-chemical Parameter Summary .......................................................................... 109 Table 4.24 Sensitive Air Quality Receptors (GCS, 2008) ................................................................. 117 Table 5.1 Venues for public review of reports ............................................................................. 123 Table 5.2 Issues and Response Summary ..................................................................................... 125 Table 7.1 Impact Significance Ratings .......................................................................................... 158 Table 7.2 Impacts & Mitigation Measures: Construction Phase .................................................. 165 Table 7.3 Impacts & Mitigation Measures: Operational Phase .................................................... 179 Table 7.4 Impacts & Mitigation Measures: Decommissioning Phase .......................................... 189 Table 7.5 Impacts & Mitigation Measures: Cumulative Impacts.................................................. 200 Table 8.1: Environmental Management Action Plan: Construction Phase ........................................... 208 Table 8.2: Recommended Soil Stripping Depths .................................................................................. 218 Table 8.3: Soil Stockpile Volumes ......................................................................................................... 219 Table 8.4: Environmental Management Action Plan: Operational Phase ............................................ 221 Table 8.5: Environmental Management Action Plan: Decommissioning and Closure Phase ............... 229 Table 9.1: Proposed Surface Water Monitoring Sites .......................................................................... 242 Table 9.2: Water Quality Parameters for Sample Analysis ................................................................... 243 Table 9.3: Proposed Groundwater Monitoring Points ......................................................................... 245 Table 9.4 Proposed Aquatic Biomonitoring Sites ......................................................................... 248 Table 11.1 Closure Cost Summary .................................................................................................. 254

LIST OF APPENDICES

APPENDIX A: A3 FIGURES ............................................................................................................... 266

APPENDIX B: PROOF OF PUBLIC PARTICIPATION ............................................................................ 266

APPENDIX C: SPECIALIST STUDY REPORTS ...................................................................................... 266

APPENDIX C-1: SOILS, LAND USE AND LAND CAPABILITY REPORT .................................................. 266

APPENDIX C-2: HYDROLOGICAL STUDY REPORT ............................................................................. 266

APPENDIX C-3: WETLAND AND AQUATIC ASSESSMENT REPORT .................................................... 266

APPENDIX C-4: ECOLOGICAL ASSESSMENT REPORT ....................................................................... 266

APPENDIX C-5: AVIFAUNAL ASSESSMENT REPORT ......................................................................... 266

APPENDIX C-6: HYDROGEOLOGICAL INVESTIGATION REPORT ........................................................ 266

APPENDIX C-7: GEOTECHNICAL ASSESSMENT REPORT ................................................................... 266

APPENDIX C-8: WATER MONITORING REPORTS ............................................................................. 266

APPENDIX D: DISCARD DUMP SITE SELECTION REPORT ................................................................. 266

APPENDIX E: DESIGN REPORT ........................................................................................................ 266

APPENDIX F: ENVIRONMENTAL AWARENESS AND EMERGENCY RESPONSE PLAN ......................... 266

APPENDIX G: FINANCIAL PROVISION.............................................................................................. 266


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1 INTRODUCTION

This Final Environmental Impact Report (EIR)/Environmental Management Programme

(EMPr) has been compiled in accordance with the Regulations published in terms of the

National Environmental Management Act, 1998 (Act No. 107 of 1998) (NEMA). The

applicable regulations are discussed under Chapter 2 of this report.

1.1 Background and History

Kangra Coal (Pty) Ltd (Kangra) owns various operational and defunct coal mines in the

vicinity of Piet Retief in the Mpumalanga Province. Kangra holds approved Environmental

Management Programmes (EMPr) for their Maquasa East (mining has ceased), Maquasa West

(current), Rooikop (historical) and Nooitgesien (current) mining areas, situated

approximately 40km west of the town of Piet Retief (refer to Figure 1.1). The EMPrs for

each coal mine were combined into one EMPr during the application process undertaken by

GCS (Pty) Ltd (GCS) in terms of Section 102 of the MPRDA during 2013 (approval received

during August 2014).

Mining at Rooikop and Maquasa East has ceased. Mining currently takes place at Maquasa

West (farm Maquasa 19HT Portion 0 (Remaining Extent) (RE) and farm Rooikop 18HT Portion

0 (Remaining Extent) (RE)) (mining is close to completion), via underground. Opencast

mining is undertaken at Nooitgesien (Nooitgesien 381 IT, a Portion Mineral Area 1 of farm

Maquasa 19 HT and a Portion of Mineral Area 1 of Remainder (RE) of farm Rooikop 18KT).

All coal from the active mining areas is transported (via conveyors and trucks) to the coal

washing plant situated at the Maquasa East mining area.

Kangra intends to expand their operations in the area, pending the outcomes of the various

environmental application processes undertaken. The expansion includes the Kangra Group

(Pty) Ltd (Kangra Group) Savmore Colliery: Kusipongo (underground mining), which will

provide additional feed to the washing plant. The proposed Kusipongo adit (-27.016267°S,

30.285800°E) will be located approximately 10km to the west of the Maquasa East mining

area, with a conveyor planned between the adit and the Maquasa East coal washing plant.

The proposed expansion will increase the life of the current operations and will require a

larger capacity of coal discard area than current existing Discard Dump located within

Maquasa East mining area. As a result a new discard dump is required. Kangra proposes to


13-347 9 March 2016 Page 2

construct this discard to the west of the Maquasa East mining area, within an area

previously earmarked for the Kangra Power Station.

The proposed 65 hectare (Ha) Discard Dump will be designed to accommodate

approximately 20 million tonnes of discard, comprising a volume of approximately 11

million m³ over a period of 15 years. The Maquasa East discard dump will be situated on

Portion 0 (RE) of the farm Rooikop 18 HT, with a portion of the dump overlapping onto

Portion 0 (RE) of the farm Maquasa 19HT.

The Discard Dump complex will include the Discard Dump, Pollution Control Dam (PCD)

stormwater management infrastructure such as trenches and berms.


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Figure 1.1 Locality of Kangra Mining Operations near Piet Retief

[REFER TO A3 FIGURE UNDER APPENDIX A]


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1.2 Description of Land

The proposed Discard Dump will be located on Portion RE of the farm Rooikop 18 HT and

Portion RE of the farm Maquasa 19 HT, which is located immediately adjacent (west of) the

Maquasa East rehabilitated open cast pits, and to the east of the Maquasa West operation

(refer to Figure 1.1). This area forms part of the Maquasa East mining right area (MRA). The

proposed Discard Dump area is situated 40km west of the centre of the town of Piet Retief,

approximately 2km north-east of the Heyshope Dam and approximately 2km east of the

Driefontein Community in the Mpumalanga Province.

Furthermore, the Discard Dump is located within the jurisdiction of the Pixley ka Seme

Local Municipality (PSLM), which forms part of the Gert Sibande District Municipality

(GSDM). Part of the Maquasa East Mine, within which the Discard Dump site is located,

forms part of the Mkhondo Local Municipality, which also falls within the GSDM.

The property details are provided in Table 1.1 and the property portions are shown in

Figure 1.2.

Table 1.1 Property Details

PROPERTY DESCRIPTION EXTENT (HA) TITLE DEED NUMBER OWNER ON TITLE DEED

Rooikop 18HT, Portion 0 (Remaining Extent)

1278.2241 T78816/2004 Kangra Coal (Pty) Ltd

Maquasa 19 HT, Portion 0 (Remaining Extent)

1712.3421 T145840/2004 Kangra Coal (Pty) Ltd

The boundary of the proposed Discard Dump complex is shown in Figure 1.2. More detailed

information regarding the layout of the Discard Dump is provided in Chapter 3.

1.3 Need and Desirability of the project

Ms Susan Shabangu, the former Minister of Mineral Resources of South Africa, in an address

at the South African Coal Export Conference 2012, stated the vital and strategic role played

by coal in South Africa’s economy.

In order to facilitate the proposed expansions of Kangra’s mining areas and the subsequent

extension of the life of mine (LoM) of these operations, a new Discard Dump is required to

accommodate the additional discard that will be produced. An expansion of the LoM will

also facilitate the retention of jobs in the long term.


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Figure 1.2 Property Details



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1.4 The Applicant

The applicant is Kangra Coal (Pty) Ltd. (Kangra). The relevant contact details for the

applicant are provided in Table 1.2.

Table 1.2 Applicant’s Details

NAME OF APPLICANT Kangra Coal (Pty) Ltd

CONTACT PERSON(S) Millicent Mkhwanazi

CONTACT NUMBER +27 17 730 6309

FAX +27 17 826 5284

POSTAL ADDRESS Savmore Colliery – Maquasa East

P.O. Box 745

Piet Retief

2380

EMAIL [email protected]

1.5 Environmental Assessment Practitioner

GCS has been appointed by Kangra to undertake the environmental authorisation

application processes in terms of the MPRDA, NEMA and National Water Act, 1998 (Act No.

36 of 1998) (NWA). The relevant details of the GCS Environmental Assessment Practitioner

(EAP) are presented in Table 1.3.

Table 1.3 EAP’s Details

NAME OF EAP Renee Francis-Steele

YEARS OF PROFESSIONAL EXPERIENCE

8 years

PROFESSIONAL REGISTRATION Cert. Sci. Nat. (Registration No. 200224/13)

CONTACT NUMBER (031) 764 7130

FAX (031) 764 7140

POSTAL ADDRESS PO Box 819, Gillitts, 3603

EMAIL [email protected]

GCS is an independent environmental consulting firm and declares itself an independent

EAP, which has no vested interest in the outcomes of the applications.

Furthermore objectivity will not, under any circumstances, be compromised in the carrying

out of the environmental authorisation application processes. All the relevant specialist

investigations, project material, reports as well as the issues and response report resulting

from the public consultation process will be submitted to the competent authorities to

allow for informed decisions to be made.


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1.6 Legislative Context

The environmental legislation applicable to the Discard Dump project is discussed in this

chapter.

1.6.1 Constitution of South Africa

The Constitution of South Africa, 1996 (Act No. 108 of 1996) reigns supreme and the

advancement of human rights is one of the foundations of South Africa’s democracy.

Section 24(a) proclaims the right of everyone “to an environment that is not harmful to

their health or well-being”.

The constitutional environmental right elevates the importance of environmental

protection and conservation, and emphasises the significance that South Africans attach to

a sound and healthy environment. In addition, the environmental right applies horizontally

and this implies that any industry has to exercise a duty of care if liability, on the basis of

the constitutional environmental right, is to be avoided. The constitutional environmental

right is given effect to by means of detailed statutory provisions ranging from framework to

sectorial legislation which relate to mining.

1.6.2 Mineral and Petroleum Resources Development Act

The MPRDA provides that South Africa’s mineral and petroleum resources belong to the

nation and that the DMR is the custodian thereof. The MPRDA allows the DMR to promote

equitable access to these resources, as well as give effect to Section 24 of the South

African Constitution by ensuring the nation’s mineral and petroleum resources are

developed in an efficient and ecologically sustainable manner.

By virtue of Section 37(1) of the MPRDA, the NEMA principles apply to the mining sector and

therefore the mining industry must adopt a risk-averse and cautious approach; prevent

negative impacts or effects of their activities on the health and well-being of people and

the environment; and pay for all their pollution since they remain liable for the effects of

their policies, projects, programmes, products, processes, services or activities throughout

their life cycles.

Section 102 of the MPRDA provides that “A reconnaissance permission, prospecting right,

mining right, mining permit, retention permit, technical corporation permit,

reconnaissance permit, exploration right and production right work programme; mining

work programme, environmental management programme, and environmental management

plan may not be amended or varied (including the extension of the area covered by it or by


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the addition of minerals or a share or shares or seams, mineralized bodies, or strata, which

are not at the time subject thereof) without written consent of the Minister.”

Legal Requirement

The proposed development of the Discard Dump constitutes a change to the EMPr,

therefore an approval of the EMPr addendum is required from the DMR before the

development may commence. An EMPr amendment was submitted to the DMR in 2012 to

combine the EMPrs for the different Kangra operations in the Piet Retief area.

The current application process comprises an application for an addendum to the 2013

EMPR Consolidation and Amendment.

The EMPr Consolidation and Amendment document approved in August 2014, applied to

combine the mining rights and EMPrs for the Maquasa East, Maquasa West, Nooitgesien and

Rooikop mining areas. Mining Right No. (MP) 30/5/1/2/2/134MR and (MP)

30/5/1/2/2/2/209MR were consolidated into (MP) 30/5/1/2/2/133MR:

• (MP) 30/5/1/2/2/134MR: issued on Portion of the Remainder of the Farm

Nooitgesien 381 IT, Portion of Mineral Area No. 1 of the Farm Maquasa 19 HT and

Portion of the Mineral Area No. 1 on the Remaining Extent of the Farm Rooikop 18

HT, Magisterial District of Wakkerstrom (Maquasa West and Nooitegesien);

• (MP) 30/5/1/2/2/2/209MR: issued on Portions 1 and 2 of the Farm Kransbank 15 HT,

Magisterial District of Wakkerstrom (Maquasa West underground);

• (MP) 30/5/1/2/2/133MR: issued on Remaining Extent of the Farm Maquasa 19 HT,

Roodekraal 21 HR and Rooikop 18 HT, Magisterial District of Wakkerstrom (Maquasa

East and Rooikop).

1.6.3 National Environmental Management Act

Section 2 of the NEMA provides for a comprehensive array of principles which cumulatively

aim to create among others, corporate socially responsible behaviour by establishing legal

liability for environmental damage, as well as damage to human health and well-being.

Any decision taken in respect of the application for environmental authorisation should take

into account these principles which includes the Polluter Pays Principle, the Precautionary

Principle, the Preventative Principle and the Cradle-to-Grave Principle.

Apart from these principles, the NEMA also contains mechanisms, procedures and structures

to facilitate pollution prevention, minimisation and remediation. A duty of care is


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contained in Section 28, which encompasses the main liability provision which applies

retrospectively (includes historical pollution).

Section 24 of the NEMA provides that the Minister may list activities which may not

commence without prior authorisation from the competent authority. Furthermore the

potential consequences for or impacts on the environment of listed activities must be

considered, investigated, assessed and reported on to the competent authority before such

a decision is made.

Legal Requirement

The proposed construction of the Discard Dump and associated infrastructure trigger

activities listed (refer to Table 1.4) in terms of Section 24 of the NEMA.

A Scoping and EIA process is therefore required in order to apply for environmental

authorisation from the Mpumalanga Department of Agriculture Rural Development, Land

and Environmental Affairs (MDARDLEA).

The applicable activities, summarised in Table 1.4, are listed in Listing Notice 2

(Government Notice 545 (GN545) as amended by Government Notice 923, published in

Government Gazette No. 37085 on 29 November 2013. This Listing Notice has since been

repealed by Government Notice R 984, published in Government Gazette (GG) No. 38282 on

4 December 2014.

Furthermore, the regulations published in terms of the NEMA (2010 Regulations:

Government Notice 543 (GNR543), published in GG No. 33306 on 18 June 2010) where

repealed and replaced by Government Notice R 982 published in GG No. 38282 on 4

December 2014. However, due to the fact that the application for the Discard Dump was

submitted before 4 December 2014, the application process being followed to comply with

the 2010 regulations.

Table 1.4 NEMA Listed Activities triggered by the proposed Discard Dump

ACTIVITY LISTED ACTIVITY DESCRIPTION TRIGGERED BY


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ACTIVITY LISTED ACTIVITY DESCRIPTION TRIGGERED BY

GNR545

Activity 2

The construction of facilities or infrastructure for any process or activity which requires a permit or license in terms of national or provincial legislation governing the generation or release of emissions, pollution or effluent and which is not identified in Notice No. 544 of 2010 or included in the list of waste management activities published in terms of section 19 of the National Environmental Management: Waste Act, 2008 (Act No. 59 of 2008) in which case that Act will apply.

The construction and operation of the discard dump and pollution control dam requires a Water Use Licence for the water use listed in terms of Section 21 (g) (Disposing of waste in a manner which may detrimentally impact on a water resources), which must be issued by the DWS

GNR545

Activity 15

Physical alteration of undeveloped vacant or derelict land for residential retail, commercial, recreational, industrial or institutional use where the total area to be transformed is 20 hectares or more;

except where such physical alteration takes place for:

(i) linear development activities; or

(ii) agriculture or afforrestation where activity 16 in this Schedule will apply.

The proposed discard dump area is planned on undeveloped land and exceeds 20 hectares in extent.

GNR545

Activity 19

The construction of a dam, where the highest part of the dam wall, as measured from the outside toe of the wall to the highest part of the wall, is 5 metres or higher or where the high-water mark of the dam covers an area of 10 hectares or more.

The development of a pollution control dam.

1.6.4 National Water Act

One of the main and ever-continuing concerns in South Africa is the sustainability of water

management, and the costs associated with the prevention and remediation of pollution in

a country with an average rainfall far below international standards. The NWA is one of the

government’s answers to some of these challenges and functions as sectoral legislation

within the framework of NEMA.

Section 19 of the NWA mirrors the provision of Section 28 of NEMA and addresses the

prevention and remediation of the effects of pollution.

Section 21 of the NWA lists 11 consumptive and non-consumptive water uses. Section 22 of

the NWA provides that water may be used if it is permissible in terms of Schedule 1 of the

NWA, is an existing lawful water use defined under Section 32; is permissible under a

General Authorisation Notice published in terms of the Section 39, or if it is licensed in

terms of Section 40 of the NWA.

The following water uses are triggered by the proposed development:


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• Section 21(g) - Disposing of waste in a manner which may detrimentally impact on a

water resource.

• Section 21 (c): Impeding or diverting the flow of water in a water resource.

• Section 21 (i): Altering the bed, banks, course or characteristics of a watercourse.

Legal Requirement

A water use licence is required for the above listed water uses triggered by the construction

and operation of the Discard Dump and PCD.

An Integrated Water Use Licence Application Report (IWULA) and an accompanying

Integrated Water and Waste Management Plan (IWWMP) need to be submitted to the DWS

to apply for the WUL in respect of the proposed water uses.

1.6.5 GN704

Section 26 (1) of the NWA makes provision for the Minister of Water Affairs to make

regulations to control, monitor, modify or prohibit various practices related to water use.

Government Notice 704 was promulgated by the Minister on 4 June 1999 in Government

Gazette vol. 408, No. 20119 (GN704). The GN704 Regulations were published in terms of

Section 26 (1), (b), (g) and (i) of the NWA and pertain specifically to water uses for mining

and related activities.

Section 3 of the GN704 makes provision for exemption from the requirements of the GN 704

schedules. This exemption will only be granted if the mine can prove that they have

implemented measures according to the best practice guidelines and regulations that will

ensure the protection of the water resources at all times.

Legal Requirement

Exemption is required from Regulation 4 (a) of the GN704 due to the proposed Discard

Dump being located within 100m of a surface water resource. This application will be made

as part of the IWULA report to be submitted.

1.6.6 National Environmental Management: Air Quality Act

The purpose of the National Environmental Management Act, 2004 (Act No. 39 of 2004)

(NEMAQA) is to prevent air pollution, to enhance air quality and to ensure sustainable


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development. Section 8 of the Act provides for the setting of national air quality standards,

monitoring and management of air quality and emissions.

Section 32 deals with dust control measures and provides for the Minister to prescribe

measures for the control of dust in specified places or areas, either in general of by

specified machinery or in specified instances the steps to be taken to prevent nuisance or

other measures aimed at the control of dust.

Section 34 provides for measures to control noise. These measures may be promulgated

through regulations. As none have been promulgated, it appears that the noise control

measures promulgated in terms of the Environment Conservation Act, 1989 (Act No. 73 of

1989) (ECA) still apply.

Section 21 of the NEMAQA makes provision for the listing of activities which result in

atmospheric emissions, which must be licensed prior to commencement in accordance with

Section 22 of the NEMAQA.

Legal Requirement

No Atmospheric Emission Licence is required in terms of the NEMAQA.

The storage and handling of ore and coal not situated on the premises of a mine or works is

listed in Subcategory 5.1 of Government Notice No. 248, published in GG No. 33064 on 31

March 2010. The proposed Discard Dump falls within a mining right area, therefore this

listed activity is not triggered.

The proposed Discard Dump area is located within the Highveld Priority Area (HPA),

declared in terms of section 18 (1) of the NEMAQA, in Government Notice No. 1123, in

Government Gazette No. 30518, dated 23 November 2007.

A Priority Area Air Quality Management Plan (AQMP) for the HPA was developed in terms of

section 19 (3) of the NEMAQA, and published in Government Notice NO. 144, in Government

Gazette No. 35072, dated 2 March 2012.

1.6.7 National Environmental Management: Waste Act

The National Environmental Management: Waste Act, 2008 (Act No. 59 of 2008) (NEMWA)

fundamentally reformed the law regulating waste management, and for the first time

provides a coherent and integrated legislative framework addressing all the steps in the

waste management hierarchy (waste avoidance, reduction, re-use, recycle, which is the


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overall approach that informs waste recycling, recovery, treatment and safe-disposal as a

last resort). The NEMWA (Section 5 (2)) provides that the Act should be interpreted and

guided in accordance with the NEMA principles.

The objects of the NEMWA are to protect health, well-being and the environment by

providing reasonable measures for, inter alia, remediating land where contamination

presents, or may present, a significant risk of harm to health or the environment.

The NEMWA provides for a licensing regime specific to waste management activities. It

replaces the historical system of permits issued in terms of the repealed Section 20 of the

Environment Conservation Act, 1989 (Act No. 73 of 1989) (ECA). Category A activities

require a basic assessment process and Category B activities require a Scoping and EIA

process as prescribed in the NEMA regulations.

On 2 June 2014 the amendment to the NEMWA was published (effective on the date of

publication), providing that residue stockpiles, which includes discard dumps, were

included under Schedule 3 of the NEMWA as hazardous waste. This meant that the proposed

Discard Dump requires a Waste Management Licence (WML) in terms of the NEMWA.

Following the above mentioned amendment, Government Notice Regulation 633 (GNR633)

was published in Government Gazette No. 39020 on 25 July 2015, which amended the

Waste Management Activities List (published in Government Notice No. 921, of 29

November 2013 as amended by Government Notice No. R. 332 of 2 May 2014). This

amendment specifically lists the establishment or reclamation of residue deposits and

stockpiles as a waste management activity, which requires a WML.

Legal Requirement

A WML is required for the following Category B activity now listed under the Waste

Management Activities List:

(11) The establishment or reclamation of a residue stockpile or residue deposit resulting

from activities which require a mining right, exploration right or production right in terms

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

The competent is authority for the NEMWA application is the DMR.

The WML application is beyond the scope of this process. It is recommended that the DMR is

contacted regarding the required WML to determine if an additional application is

necessary of if the current process is sufficient for the granting of a WML.


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Government Notice Regulation No. 632, published in Government Notice 39020 on 24 July

2015 (GNR632) (“Regulations Regarding the Planning and of Residue Stockpiles and Residue

Deposits from a Prospecting, Mining, Exploration or Production Operation”) must be

adhered to in respect of the proposed Discard Dump.

Legal Requirement

The GNR632 provides that the planning, management and assessment of the residue

stockpile must be undertaken in accordance with the regulations set out therein. The

planning, i.e. design, waste characterisation, geotechnical study and groundwater

assessment was undertaken in accordance with the relevant regulations and DWS best

practices.

1.6.8 Spatial Planning and Land Use Management Act

The Spatial Planning and Land Use Management, 2013 (Act No. 16 of 2013) (SPLUMA), which

came into effect in 2015, provides a framework for local and provincial authorities in

respect of spatial planning and land use policies.

Section 24 of the SPLUMA provides that local municipalities must, within 5 years of

commencement of the Act, adopt and approve a single land use scheme for its entire area,

including areas not previously subject to a land use scheme.

Section 26 (3) of SPLUMA provides:

“Where no town planning or land use scheme applies to a piece of land, before a land use

scheme is approved in terms of this Act such land may be used only for the purposed listed

in Schedule 2 to this Act and for which such land was lawfully used or could lawfully have

been used immediately before the commencement of this Act.”

Schedule 2 lists land use for mining purposes as: “purposed normally or otherwise

reasonably associated with the use of land for mining.

Although the proposed Discard Dump will be located within an existing MRA, adjacent to

rehabilitated opencast pits, Kangra must ensure that the correct land use is allocated to

the properties in question by the local municipality in any land use scheme being prepared.

Kangra must also liaise with the local municipality regarding any rezoning permit which may

be required. The rezoning does not form part of the EIA process, so it will therefore this

issue will be addressed by Kangra during the planning phase of the development.


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Legal Requirement

The rezoning requirements must be determined in consultation with the local municipality.

Should it be determined that rezoning is necessary, this must be undertaken by Kangra prior

to any construction taking place.

1.6.9 Other Legislation

The legislation which has been reviewed during the compilation of this document includes:

• Hazardous Substance Act, 1973 (Act No. 15 of 1973)(HSA);

• The National Environmental Management: Biodiversity Act, 2004 (Act No. 10 of

2004) (NEM:BA);

• The National Heritage Resources Act, 1999 (Act No. 25 of 1999) (NHRA);

• The Conservation of Agricultural Resources Act, 1983 (Act No. 43 of 1983) (CARA);

• The Mine Health and Safety Act, 1996 (Act No. 29 of 1996) (MHSA); and

• The Occupational Health and Safety Act, 1993 (Act No. 85 of 1993) (OHSA).

1.7 Environmental Process

The three (3) environmental application processes currently underway in respect of the

proposed Discard Dump are summarised in Table 1.5. This section provides an overview of

the application process undertaken to date, as well as the remaining process. A detailed

description of the public participation process (PPP) is given under Chapter 5 of this report.

The application processes have been integrated as far as possible to also allow for an

integrated public participation process (PPP) (refer to Chapter 5 of this report) and for the

completion of all the necessary specialist studies.

The application process can be divided into four main phases (refer to Figure 1.3 and the

discussion which follows):

• Application phase;

• Scoping and PPP initiation;

• EIA Phase and public feedback and

• Final submission and CA feedback.

Table 1.5 Summary of Environmental Authorisations Required

LEGISLATION APPLICATION PROCESS

AUTHORISATION REQUIRED COMPETENT AUTHORITY (CA)


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LEGISLATION APPLICATION PROCESS

AUTHORISATION REQUIRED COMPETENT AUTHORITY (CA)

NEMA Scoping and EIA Positive Record of Decision

Mpumalanga Department of Agriculture Rural Development, Land and Environmental Affairs (MDARDLEA)

NWA IWULA Integrated Water Use Licence (IWUL)

Department of Water and Sanitation (DWS)

MPRDA Addendum to approved EMPr

Approval of addendum Department of Mineral Resources (DMR) Witbank

Figure 1.3 Environmental Process Flow Diagram

1.7.1 Application phase

An application form was submitted to the MDARDLEA on 25 February 2014 to initiate the

NEMA application process.

The application was accepted and a reference number (17/2/3 GS-240) issued on 5 March

2014. The applicant and EAP were instructed to continue with the application process.


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1.7.2 Scoping and PPP initiation

Once the NEMA application reference number was received the registered Interested and

Affected Parties (I&APs) and the public were notified of the application in writing via a

newspaper advertisement, site notices, Background information documents (BIDs) and text

messages (sms).

A draft Environmental scoping report (ESR) was compiled in accordance with the

requirements set out in the NEMA 2010 Regulations (GNR543) and the MPRDA Regulations

(GNR527, published in GG 26275, on 23 April 2004).

The Draft ESR was placed at public venues for public review during April/May 2014 (refer to

chapter 5) before submission to the DMR. After a second review period the Final ESR was

submitted to the MDARDLEA in November 2014.

In terms of the MPRDA, Ms Matshilele Ramhova of the DMR confirmed that the EIA process

could proceed (email dated 11 November 2014). In terms of the NEMA process, the final ESR

was accepted in a letter dated 21 January 2015. The MDARDLEA also requested that an

Avifaunal Assessment is undertaken for the proposed development area and submitted with

the EIR.

1.7.3 EIA Phase and Public Feedback

The EIA Phase will involve the following activities:

• Public review of the draft EIR/EMPr (30 calendar days);

• A public feedback meeting to discuss the outcomes of the various specialist studies

undertaken; and

• Compilation of the IWULA and IWWMP.

1.7.3.1 NEMA EIR/EMP

The application process set out in the NEMA regulations (GNR543) requires that an EIR and

EMP are compiled. This report has been compiled as a combined EIR and EMP report and

meets the requirements set out in the GNR543.

Furthermore, all specialist studies have been compiled by qualified environmental experts,

in accordance with the minimum requirements stipulated in the regulations.

1.7.3.2 MPRDA EMP Addendum

This report has been compiled as a combined EIR and EMP report and meets the

requirements set out in the MPRDA regulations.


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1.7.3.3 Integrated Water Use Licence Application

The IWULA Report will contain all the necessary information as required on the relevant

report checklist (as provided by the DWS). The IWWMP has been compiled in accordance

with the IWWMP Operational Guideline, 2010.

These reports will not be placed in the public domain for review and comment, as this is

not required in terms of the NWA.

1.7.3.4 Final Submission and Authority Feedback

After the comments are received during the public feedback meeting and the public review

period, they will be incorporated into the Final EIR/EMPr and IWULA and IWWMP Reports.

The following authority review periods are applicable:

• NEMA: The GNR543 makes provision for a minimum of 121 days for the MDARDLEA to

issue a decision (Acknowledgement of receipt- 14 days after submission;

Accept/reject EIR/EMP- 60 days after submission; Reach a decision (grant/refuse) -

45 days after submission; and issue the Record of Decision (ROD) - 2 days after

reaching decision);

• MPRDA: The MPRDA (section 39 (4) (a)) provides that a decision would be reached

within 120 days of the lodgement of an EMPr. Section 39 (5) further provides that

the Minister may request additional information, although no timeframes are

stipulated for a decision following the submission of additional information; and

• NWA: There are no legislated timeframes for the consideration of IWULAs. Most

applicants wait between 1 to 2 years to receive a decision from the DWS.

1.8 Report Structure

This report has been compiled to meet the requirements set out in the GNR543 in terms of

the NEMA and the GNR527 in terms of the MPRDA. As such, it contains the following

chapters:

• Chapter 1: Introduction - This includes the applicant and EAP details, an

assessment of the environmental legal requirements, as well as a brief description

of the environmental application process.

• Chapter 2: Project Description. This provides a brief overview of the current

operations and a description of the proposed development.

• Chapter 3: Project Alternatives. This provides a description of the alternative

disposal methods, options for discard disposal, disposal methods and land uses

considered.


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• Chapter 4: Environmental Baseline Description. This provides a current description

of the biophysical and socio-economic environment within and immediately

surrounding the proposed development area.

• Chapter 5: Public Participation. This chapter describes the process undertaken to

inform and consult with the public and registered Interested and Affected Parties

(I&APs). The proof of the consultation is attached under Appendix B.

• Chapter 6: Assessment of Environmental Impacts. This chapter includes the

identification and assessment of the potential environmental and socio-economic

impacts which may be caused by the proposed development. The significance of the

potential impacts is assessed without, then with proposed mitigation measures to

determine if the potential impacts can be appropriately avoided, mitigated or

managed.

• Chapter 7: Environmental Management Plan. This chapter comprises the

environmental management plan which includes specific environmental

management measures, timeframes within which each measure must be

undertaken, the persons to whom the tasks must be assigned as well as the

associated annual management costs.

• Chapter 8: Monitoring Programme. This chapter comprised the proposed

programme for monitoring the environmental impacts of the proposed development

as well as the efficacy of the proposed management measures.

• Chapter 9: Rehabilitation Plan. This chapter comprises the rehabilitation plan for

the closure of the discard dump.

• Chapter 10: Environmental Awareness and Emergency Response Plan. The plan is

attached as a separate report under Appendix E.

• Chapter 11: Financial Provision. This chapter comprises a summary of the

Financial Provision for closure. A full report which presents the methodology and

full assessment is attached under Appendix F.

• Chapter 12: Information Gaps and Recommendations. This chapter summarises all

information gaps and the significance of these information gaps.

• Chapter 13: Conclusion. This is a summary of the main findings and includes the

EAPs recommendations.


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2 PROJECT DESCRIPTION

2.1 Project background (current and future mining)

The information in this section has been extracted from the Section 102 Consolidation and

Amendment Report (GCS, April 2013), which was approved in August 2014.

The Maquasa East, Maquasa West, Rooikop and Nooitgesien mining areas are the closest

Kangra operations to the proposed Discard Dump operation. The proposed Kusipongo

underground mine will be located to the west of the proposed Discard Dump.

2.1.1 Maquasa East (underground and opencast) and West (underground)

The Maquasa West is an active underground and opencast operation (Nooitgesien), while

mining at Maquasa East recently ceased. All mining related surface infrastructure, which

includes the coal washing plant, is located at Maquasa East. All coal mined at the Maquasa

West and Nooitgesien areas is processed at this washing plant. In addition, there is a

screening plant at Maquasa West.

The following infrastructure are existing at Maquasa East:

• Conveyors and associated service roads (transporting mined coal to the Maquasa

East processing plant);

• Power lines and associated service roads;

• Access roads;

• Haul roads;

• Water Pipeline;

• Crushers (Maquasa East);

• Washing and screening plant (Maquasa East);

• Overburden and stockpile (i.e. topsoil, run of mine ore, product) dumps;

• Existing Discard dump (Maquasa East);

• Offices, workshops and ancillary buildings (Maquasa East and West);

• Diesel storage; and

• Borrow pits.

The following expansions were applied for in the 2012 Section EMPr:

• The addition of two (2) new opencast resource pits at Maquasa East (Pit A and D);

and


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• The expansion of four (4) opencast resource pits at Maquasa West (Pit A, B, C and

D).

The proposed Discard Dump area is located adjacent to the Maquasa East Pit D (refer to

Figure 1.1), which already been mined and backfilled.

2.1.2 Nooitgesien Mining Area

Kangra has expanded their mining operations by establishing six (6) new opencast pits (one

of which is situated near the Maquasa East mining area and the remainder at the

Nooitgesien mining area), as well as the addition of two (2) underground resource areas and

four (4) waste rock discard dumps.

2.1.3 Rooikop

Rooikop was mined coal using both opencast and underground mining methods. Mining has

ceased at this operation and the open voids are filled with water. Kangra Coal intends to

explore various options to make use of or treat the water.

2.1.4 Kusipongo

The proposed Savmore Colliery Kusipongo adit will be located approximately 10km to the

west of the Maquasa East operation, with a 10km overland conveyor linking the adit to the

coal washing plant.

2.1.5 Projected coal tonnages

According to the approved Consolidated EMPr, it is envisaged that the mining of the

Maquasa West and Nooitgesien expansion areas will produce 80 000 tons of coal per month

with an estimated life of mine (LoM) of 5 to 6 years

According to the EIA Report compiled by ERM Southern Africa (ERM) in respect of the

proposed Kusipongo mining area, it is envisaged that the operation will have a LoM of 10 to

20 years with the potential to generate a run of mine (ROM) production volume of

approximately 3.6 to 3.8Mtpa.

Kangra proposes to construct a new Discard Dump at the Maquasa East mining area, to

dispose of the additional discard which will be created due to Kangra’s’ proposed

underground mining expansion project.


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2.2 Description the Discard Material

2.2.1 Hydrogeochemical Characterisation of the Discard

A hydro-geochemical assessment was performed on a 52kg sample of discard provided by

Kangra. The assessment methodology, as well as the detailed results are presented in the

Hydrogeochemical Report compiled by Geostratum, attached under Appendix C of the

Hydrogeological Report (Appendix C-6).

The sample provided was crushed, split into two samples (ABK601 and ABK602), and milled

prior to testing.

2.2.1.1 Mineralogy and Total Chemical Composition

The results showed that Gypsum (CaSO42H2O) and Quartz (SiO2) (originating from calcic

rock) were the major minerals in the sample.

Kaolinite (Al2Si2O5 (OH) 4); Microcline (KAlSi3O8); and Muscovite (KAl2(Si3Al)O10(OHF)2)

occurred as minor minerals within the sample. Calcite (CaCO3) occurred as an accessory

mineral and is an important mineral in the neutralisation of acidity produced by pyrite

oxidation in acid-mine drainage (AMD) and frequently occurs in Karoo sedimentary rocks.

Plagioclase (NaAlSi3O8-CaAl2Si2O8) and Pyrite (FeS2) occurred in trace quantities.

2.2.1.2 Acid Rock Drainage Potential

The potential of geological material to oxidise and generate acidic drainage were

determined through acid-base accounting (ABA) and net acid generation (NAG) analyses,

respectively.

ABA is a set of analytical methods that measures acid generation potential through

independent determination of acid generating (AP) and neutralising (NP) content. These

tests provide an important first order assessment of potential drainage that could be

expected from the discard material.

NAG analysis, in combination with ABA tests, can be used to indicate the likelihood of acid

generation or stored acidity.

From the ABA and NAG test results, the following observations could be made:

• Pyrite was the only sulphide detected in the rock through means of X-ray

Diffraction (XRD). It was assumed that oxidation of pyrite will be the only

contributor to acidity;


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• Both samples showed high percentage Sulphur (%S), above 0.3%, of 0.55% and 1.49%

respectively;

• The neutralisation potential for the one sample is slightly higher than the acid

potential, while the other sample has a higher acid potential and is likely to

generate AMD; and

• During the NAG tests, only the second sample acidified. However, the part of the

discard with lower %S will not be able to neutralise all acidity generated by the

discard with the higher %S.

Overall, it could be concluded that the discard has a significant potential to generate

acid mine drainage/seepage.

2.2.1.3 Static Leach Tests

Discard material was subjected to the following leach tests in order to identify the

constituents that may leach out:

• Peroxide leaching test – reacted with 400 ml of 15 % hydrogen peroxide with a

rock/water ration of 1:100. This test simulates extreme conditions as all pyrite is

oxidised at once. Under field conditions, not all pyrite constituents will be oxidised

as some minerals are physically shielded by the rock matrix and oxidation will occur

over a long period of time.

• Reagent water leach test – 50g discard material reacted 1 000ml of reagent water

solution for 18 hours with water/rock ration of 1:20. The test was performed using

the extraction procedure for mono-filled waste according to Australian Standard

(AS) 4439.3.

• Toxicity Characteristic Leaching Procedure (TCLP) test – the test was performed

using the extraction procedure for mono-filled waste according to AS 4439.3.

The leachate composition does not reflect the leachate that may be expected from the

discard materials under field conditions. This is due to the fact that different leach rates

and water rock ratios are used in the leach tests and do not reflect conditions that is site-

specific.

The following observations were made from the leach testing:

• Peroxide leach test:

o The pH of the discard material is neutral to acidic, ranging between 3.26

and 6.92 (pH unit);


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o The leachate showed elevated dissolved concentrations of aluminium, iron,

manganese, nickel, lead and vanadium and to a lesser degree chromium;

and

o A positive correlation is present between the %S and the sulphate extracted

from the material.

• Reagent water leach test:

o The pH of the discard material is neutral, ranging between 6.49 and 6.55

(pH unit); and

o The leachate showed no elevated dissolved concentrations for metals or

trace elements.

• TCLP leach test:

o The pH of the discard material is acidic, ranging between 5.25 and 5.39 (pH

unit); and

o The leachate showed elevated dissolved concentrations of iron and

manganese and to a lesser degree aluminium and nickel.

2.2.2 Waste Classification

The NEMWA, Waste Classification and Management Regulations (Government Notice No.

634, published in Government Gazette No. 36784, dated 23 August 2013) require that all

waste generated by waste generators, subject to sub regulation (2) of the act, be classified

in accordance with SANS 10234 within one-hundred-and-eighty (180) days of generation.

Waste must be assessed in terms of the NEMWA National Norms and Standards for the

Assessment of Waste for Landfill Disposal (GN634). Waste is assessed for the purpose of

disposal to the landfill, by identifying the chemical substances present in the waste. This is

done by sampling and analysing the total concentrations (TC) and leachable concentrations

(LC) of the elements that have been identified in the waste and comparing that to the

threshold limits specified in Section 6 of the Norms and Standards.

The results of the TC and LC are summarised below (refer to the results in Table 6.7 and

Table 6.8 of the Hydrogeology Report, Appendix C-6):

• Barium, copper and lead results fall below the total concentration threshold (TCT0)

limits (<TCT0); and

• All chemicals falls below the total leachable concentration (LTC0) limits (<LTC0).

The discard material would be classified as Type 3 Waste based on the results of the TC and

LC analysis and the determination of waste types for landfill disposal Section 7(2) (d) that


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stipulates: “Wastes with all element or chemical substance leachable concentration levels

for metal ions and inorganic anions below or equal to the LCT0 limits are Type 3 Waste.”

2.3 Description the proposed development

A new Discard Dump is required, which will be located within the Maquasa East Mining Area

on Portion RE of the farm Rooikop 18 HT, with a small area of the dump on Portion RE of

the farm Maquasa 19 HT, in the vicinity of Piet Retief, Mpumalanga Province.

The Discard Dump will accommodate discard produced from the washing plant located at

Maquasa East, which currently wash and screens coal from the surrounding Kangra Mining

sections and will, in future, receive coal from the future expansion areas which are

discussed under section 2.1 of this report.

The Discard Dump has been designed by Geotail (Pty) Ltd and the description provided in

this section has been extracted from the Design Report (September 2014), which is

attached under Appendix E of this report. The recommendations made in the Geotechnical

Report (Appendix C-7) and in the draft Groundwater Assessment Report (refer to final

version under Appendix C-6) were incorporated into the Discard Dump design.

2.3.1 General Layout

The Discard Dump will be developed as a three-compartment side hill type storage facility

with a footprint of approximately 65ha. The three-compartment layout allows for a modular

implementation approach (Phases 1, 2 and 3) with the benefit of delaying capital

expenditure.

The following structures will be required:

• Lined Discard Dump (to be constructed in three different compartments/phases);

• Under-drainage system;

• Boundary fence;

• Internal haul roads

• Catchment Paddocks;

• Two compartment, HDPE lined Pollution Control Dam (PCD) (one compartment to

be operated as empty); and

• Stormwater management infrastructure, such as berms and trenches.

The layout of the proposed Discard Dump is presented in Figure 2.1. The location and

extent of the Discard Dump is provided in Figure 1.2 (refer to chapter 1 of this report).


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Figure 2.1 Discard Dump Layout (Geotail, 2014)



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2.3.2 Dimensions and life of the facility

The proposed Discard Dump was three-dimensionally modelled for an accurate

determination of the relationship between the height, area and capacity. The results of this

modelling, are the capacity and dimensions of the Discard Dump summarised in Table 2.1.

Table 2.1 Dimensions and Capacity of the proposed Discard Dump

DESCRIPTION TOTAL/UNIT PHASE 1 PHASE 2 PHASE 3

Life of facility 20 years 7.4 7.4 5.4

Extent of Discard Dump 65ha 23.5 21.9 19.3

Capacity of discard dump 20.2 million tonnes (Mt)

7.4 7.4 5.4

Airspace available 11.2 million m³ 4.1 4.1 3.0

Final vertical height of Discard Dump

m 34 33 32

Deposition rate 1 million tonnes per annum of coarse

material**

- - -

Final side slope area Ha 13.1 9.0 8.2

Final top surface area 38ha 9.5 13.9 14.6

2.3.3 Construction/Disposal Method

The coal discard will be transported from the Maquasa East coal washing plant to the new

Discard Dump by truck, where it will be placed and compacted mechanically. The discard

will be placed in horizontal layers (bottom-up) following an approved performance

compaction specification.

The design report recommends the following (to be verified by the Project Engineer prior to

construction):

• An access ramp will be required from where dumping can take place. Simultaneous

dumping from more than one platform should be considered in order to reduce the

advance rate of a platform and to prevent potential damage to the HDPE

geomembrane;

• The side slopes will be terraced and berm penstocks will be utilised to drain the

permanent benches;

• The final side slope geometry should include 10m wide benches at 10m vertical

intervals;

• The benches should be cross-graded at 1(v):10(h) and a 0.5m (minimum) high

perimeter bund wall should be constructed. Berm penstocks should be extended to


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the final height of the Discard Dump. The longitudinal slope of the benches should

be modified to achieve the required longitudinal fall to the berm penstocks;

• A perimeter bund wall should be implemented on the top surface. The top surface

of each lift should be constructed to a 1(v):100(h) gradient that falls away from the

perimeter bund wall in order to prevent overtopping at the side slopes (also an

operational safety measure);

• The soil cover (including vegetation) should be constructed to a final side slope

angle of 1(v):3(h), giving the Discard Dump an overall slope of 1(v):4(h). The soil

cover should be constructed to an agreed performance specification;

• Survey control should be implemented to indicate the required limits for soil cover

construction, as well as the required final as-built dimensions; and

• The compaction specification for the coal discard should be investigated further

and confirmed during the operation phase, by implementing the following

procedure:

o The Design Engineer should approve the compaction specification and lift

thickness before construction commences. The specification will be

influenced by the size of the construction equipment. If necessary, a test

fill program should be implemented prior to construction;

o Lift thickness should be measured;

o The density and moisture content of the compacted discard material should

be determined directly by conventional methods and indirectly by observing

settlement of the fill;

o Test pits should be excavated through the compacted layers to allow visual

observation of lift thickness, particle size distribution and distribution of

density;

o Inspection should form a critical part of the quality control plan. The

inspector should ensure that the field-testing program establishes the

methods required to achieve the required quality, then to ensure that the

quality is being maintained and quantify means of rejecting substandard

work;

o Records and data should be kept up to date (by means of photographs,

notes and visual observations); and

o The Design Engineer reserves the right to re-execute tests and to re-specify

the compaction requirements from time to time based on material

variability, compactor type, moisture content etc.

GCS Discard Dump EMPR (2016)

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