IMPORTANT NOTICE - Environmental consulting … · Web viewThe largest deposits of chromite in...

ENVIRONMENTAL IMPACT ASSESSMENT REPORTAnd

ENVIRONMENTAL MANAGEMENT PROGRAMME REPORT

SUBMITTED FOR ENVIRONMENTAL AUTHORIZATIONS IN TERMS OF THE NATIONAL

ENVIRONMENTAL MANAGEMENT ACT, 1998 AND THE NATIONAL ENVIRONMENTAL

MANAGEMENT WASTE ACT, 2008 IN RESPECT OF LISTED ACTIVITIES THAT HAVE

BEEN TRIGGERED BY APPLICATIONS IN TERMS OF THE MINERAL AND PETROLEUM

RESOURCES DEVELOPMENT ACT, 2002 (MPRDA) (AS AMENDED).

NAME OF APPLICANT: CRONIMET CHROME MINING SA (PTY) LTDTEL NO: 011 958 0544

FAX NO: 011 958 0467

POSTAL ADDRESS: P. O. Box 3319, Witkoppen, 2068

PHYSICAL ADDRESS: 220 Corner 3rd Street and Cedar Road, Building C, Willowwood Office Park,

Broadacres

DMR REFERENCE NUMBER: LP 30/5/1/3/2/1 (115) EM

1. IMPORTANT NOTICEIn terms of the Mineral and Petroleum Resources Development Act (Act 28 of 2002

as amended), the Minister must grant a prospecting or mining right if among others

the mining “will not result in unacceptable pollution, ecological degradation or

damage to the environment”.

Unless an Environmental Authorisation can be granted following the evaluation of an

Environmental Impact Assessment and an Environmental Management Programme

report in terms of the National Environmental Management Act (Act 107 of 1998)

(NEMA), it cannot be concluded that the said activities will not result in unacceptable

pollution, ecological degradation or damage to the environment.

In terms of section 16(3) (b) of the EIA Regulations, 2014, any report submitted as

part of an application must be prepared in a format that may be determined by the

Competent Authority and in terms of section 17 (1) (c) the competent Authority must

check whether the application has taken into account any minimum requirements

applicable or instructions or guidance provided by the competent authority to the

submission of applications.

It is therefore an instruction that the prescribed reports required in respect of

applications for an environmental authorisation for listed activities triggered by an

application for a right or a permit are submitted in the exact format of, and provide all

the information required in terms of, this template. Furthermore please be advised

that failure to submit the information required in the format provided in this template

will be regarded as a failure to meet the requirements of the Regulation and will lead

to the Environmental Authorisation being refused.

It is furthermore an instruction that the Environmental Assessment Practitioner

must process and interpret his/her research and analysis and use the findings thereof

to compile the information required herein. (Unprocessed supporting information may

be attached as appendices). The EAP must ensure that the information required is

placed correctly in the relevant sections of the Report, in the order, and under the

provided headings as set out below, and ensure that the report is not cluttered with

un-interpreted information and that it unambiguously represents the interpretation of

the applicant.

2. OBJECTIVE OF THE ENVIRONMENTAL IMPACT ASSESSMENT PROCESSThe objective of the environmental impact assessment process is to, through a consultative

process—

(a) determine the policy and legislative context within which the activity is located and

document how the proposed activity complies with and responds to the policy and

legislative context;

(b) describe the need and desirability of the proposed activity, including the need and

desirability of the activity in the context of the preferred location;

(c) identify the location of the development footprint within the preferred site based on an

impact and risk assessment process inclusive of cumulative impacts and a ranking

process of all the identified development footprint alternatives focusing on the

geographical, physical, biological, social, economic, heritage and cultural aspects of

the environment;

(d) determine the—-

(1) nature, significance, consequence, extent, duration and probability of the impacts

occurring to inform identified preferred alternatives; and

(ii) degree to which these impacts—

(aa)can be reversed;

(bb)may cause irreplaceable loss of resources, and

(cc) can be avoided, managed or mitigate

(e) identify the most ideal location for the activity within the preferred site based on the

lowest level of environmental sensitivity identified during the assessment;

(f) identify, assess, and rank the impacts the activity will impose on the preferred location

through the life of the activity;

(g) identify suitable measures to manage, avoid or mitigate identified impacts; and

(h) identify residual risks that need to be managed and monitored.

3. EXECUTIVE SUMMARY

Background Information

Cronimet Chrome Mining SA (Pty) Ltd, a diversified commodity group, contributing

significantly in the sustainable development of South Africa`s economy through mining, is a

holder of a Mining Right for its existing Thaba Cronimet Chrome Mine granted in terms of

section 23 of the Mineral and Petroleum Resources Development Act, 2002 (Act No. 28 of

2002) (MPRDA). The right involves exploitation of Cr and PGMs contained in the LG6

(including LG6A), LG4-high Cr to Fe ratio) (Lower Groups), MG2 and MG3 (Middle Groups)

of the Critical Zone in the Western Bushveld Igneous Complex using both opencast and

conventional underground mining method on portions of the farms Elandskuil 378 KQ,

Middellaagte 382 KQ, Moddergat 389 KQ, Roodedam 368 KQ, Schildpadness 385 KQ, and

Zwartkop 369 KQ, located within the Magisterial District of Thabazimbi, Limpopo Province.

Current mining activities at Thaba Cronimet Chrome Mine (Thaba Mine) include ML1 and

ML2 opencast pits, tailings storage facility (TSF), return water dams (RWDs), and Cr

processing plant located on the farms Middellaagte 382 KQ and Elandskuil 378 KQ, with

metallurgical chrome concentration as primary product at 40 000 tonnes per month (t/m).

The Thaba Mine plans to increase production through the expansion of the opencast mining

operations and underground mining areas. Expansion will cover an area of approximately

2129 hectares in extent and will include development of additional Cr and PGMs processing

plant on both the remaining extent of the farm Moddergat 389 KQ and portion 1 of the farm

Middellaagte 382 KQ. Thus, an amendment to the 2009 Environmental Impact Report (EIR)

has been submitted to both Limpopo Department of Economic Development and Tourism

(LEDET) and DMR Limpopo Region to meet the requirements of the National Environmental

Management Act, 1998 (Act No. 107 of 1998) (and Environmental Impact Assessment

Regulations, 2010) and Section 102 of the MPRDA.

The expansion of the opencast and underground mining operations require additional

support infrastructure to be constructed, which includes the expansion of an existing Tailings

Storage Facility (TSF) and development of new TSF as well as waste rock dump (WRD)

sites.

Sazi Environmental Consulting was appointed as an independent Environmental Practitioner

to undertake a full Environmental Impact Assessment process in accordance with the

requirements of the National Environmental Management: Waste Amendment Act, 2014 (Act

No. 26 of 2014) and the Mineral and Petroleum Resources Development Act, 2002 (Act 28 of

2002) together with the associated Environmental Impact Assessment Regulations, 2014

(GNR 984) for the proposed support infrastructure which require a Waste Management

Licence (WML) from the Department of Mineral Resources (DMR) before construction may

commence. According to the Waste Amendment Act, Act 26 of 2014, the Thaba Cronimet

TSF and WRDs are listed in Category A of Schedule 3 as hazardous waste. This activity

requires for the EIA Regulations, 2014, process to be followed.

The Draft Scoping Report including the Plan of Study for Environmental Impact Assessment,

dated December 2015, was made available for a 40 day public commenting period from the

11th of December 2015 to the 01st of February 2016. The Final Scoping Report including the

Plan of Study for Environmental Impact Assessment, dated February 2016, was made

available for a 21 day public commenting period from the 01st of February to the 22nd of

February 2016, and was accepted by the Department of Mineral Resources on 19 April

2016. The Draft Environmental Impact Assessment Report is being made available for a 40

day public commenting period from the 10th May 2016 to 07th June 2016. During this time

Interested and Affected Parties are requested to submit written comments to the

Environmental Assessment Practitioner in order for their comments and concerns to be

addressed in the Final Environmental Impact Assessment Report. This report, the Draft EIR

has been compiled in order to meet the requirements of NEMA. The Final Environmental

Impact Assessment Report, documents the findings of the Impact Assessment and will

adhere to GNR 982 of NEMA

Public Notice

All interested and affected parties (I & APs) are hereby notified that the draft Environmental

Impact Report (EIR) will be available for public comment from the 13th of May 2015 to the 13th

of June 2016. The draft EIR summarises key environmental issues identified to date and

recommended mitigation measures and will be available at the following places:

Public Place Locality Contact Person Telephone Number

Thabazimbi Local Municipality7 Rietbok Street T. Masilo 083 552 9341

Thabazimbi Public Library 4th Avenue Lerato Mokwena 014 777 1525

Northam Library 313 Tungsten Street Mariam Manyako 014 784 0128

PUBLIC MEETINGA public meeting will be held as follows:

Venue: Mawala Lodge, Brits Road, 0360

Date: 03 June 2016 Time: 12:00 pm

WHO SHOULD YOU CONTACT?Sazi Environmental Consulting is the independent Environmental Assessment Practitioner

(EAP) for the required Environment Impact Assessment and Public Participation (PP)

process for Thaba Mine. To register as an Interested and Affected Party (I&AP) and to obtain

details of the project, please submit your name, contact information and interest in the

project to:

Ms. Sandisiwe NdlaziSazi Environmental ConsultantB16 Lone Creek, Waterfall Park, Vorna Valley, 1684Tel: 011 312 2806 E-mail: [email protected] or [email protected]

Specialist Studies

The table below outlines the specialists which were appointed to undertake impact assessments

with regards to the proposed additional mining and processing activities and associated

infrastructure. The type of specialist appointed was done in consultation with the competent

authorities and where concerns were raised by IAPs which the EAP deemed necessary for

additional studies to be undertaken in order to determine the impacts. The full reports from all the

specialists are presented in Appendix 3.

Table 1-1: Specialists Appointed

Specialist Study Organization responsible for the study

Vibration Impact Assessment RC Kroch

Air Quality Specialist Derek Fletcher

Ecological Impact Assessment Exigo Sustainability

Geochemistry Specialist Study Enviro Resources Management

Groundwater JMA Consulting (Pty) Ltd

Archaeological Impact Assessment Heritage Contracts and Archaeological Consulting

Noise Study Francois le Roux Malherbe

Socio Economic Study Digby Wells

Soil, Land-use and Land Capability Terra Africa Consultants

Surface water Impact Assessment JR Croucamp

mailto:[email protected]


Tailings Water Quality Aquatico Scientific (Pty) Ltd

Visual Specialist Study Newton Landscape Architects cc

Wetland Delineation and Impact Assessment Mr Dieter Kassier

PART ASCOPE OF ASSESSMENT AND ENVIRONMENTAL IMPACT ASSESSMENT REPORT

4. Contact Person and correspondence address

a) Details of

i) Details of the EAP

Name of the Practitioner: Mrs. Nonkanyiso Zungu

Tel No.: +27 (0)11 312 7208

Fax No. : +27 (0)11 312 7208

E-mail address: [email protected]

1) Expertise of the EAP


(1) The qualifications of the EAP

(With evidence).

Masters in Environmental Management (University of Pretoria): 2011

Bachelor of Science Honours in Biological Sciences (University of KwaZulu-

Natal): 2005

Bachelor of Science in Biological Sciences (University of KwaZulu-

Natal): 2003

(2) Summary of the EAP’s past experience. (In carrying out the Environmental Impact Assessment Procedure)

Nonkanyiso Zungu is a Professional Natural Scientist (Pr.Sci.Nat) with 8 years’

experience in the environmental field. She has a Master’s Degree in Environmental

Management, and specializes on Water Resource Management. Nonkanyiso has

extensive experience in water resource management, waste management, and

obtaining environmental authorisations (air, water, waste) across sectors that include:

power generation, infrastructure (Construction), transportation (rail), waste disposal,

water purification & sewage works. The projects she has undertaken include:

Environmental Impact Assessments, Basic Assessments, Environmental Feasibility

Studies, Environmental scoping studies, Environmental legal compliance audits,

Waste management licences, Water use licences, and Baseline risk assessments.

b) Description of the property.

Farm Name: Portion 1 of the farm Elandskuil 378 KQ

Portion 1 of the farm Middellaagte 382 KQ

Portion 8 of the farm Roodedam 368 KQ

Remaining extent of the farm Moddergat 389 KQ

Portion 6 of the farm Zwartkop 369 KQ



Portion 21 of the farm Zwartkop

Application area (Ha) 136.392122 Ha

Magisterial district: Thabazimbi Magisterial District

Distance and direction from nearest town

The site is located approximately 18 km north of Northam and 30 km north-east from the town of Thabazimbi, in Limpopo Province

21 digit Surveyor General Code for each farm portion

T0KQ00000000038200001

T0KQ00000000038900000

T0KQ00000000037800001

T0KQ00000000036800008

T0KQ00000000036900006

T0KQ00000000036900012

T0KQ00000000036900018

T0KQ00000000036900021

T0KQ00000000036900026

c) Locality map

(Show nearest town, scale not smaller than 1:250000).

d) Description of the scope of the proposed overall activity.

Provide a plan drawn to a scale acceptable to the competent authority but not less than 1: 10 000 that shows the location, and area (hectares) of all the aforesaid main and listed activities, and infrastructure to be placed on site

i) Listed and specified activities

NAME OF ACTIVITY

(E.g. For prospecting - drill site, site camp, ablution facility, accommodation, equipment storage, sample storage, site office, access route etc…etc…etcE.g. for mining,- excavations, blasting, stockpiles, discard dumps or dams, Loading, hauling and transport, Water supply dams and boreholes, accommodation, offices, ablution, stores, workshops, processing plant, storm water control, berms, roads, pipelines, power lines, conveyors, etc…etc…etc.)

Aerial extent of the Activity

Ha or m²

LISTEDACTIVITY

(Mark with an X where applicable or affected).

APPLICABLE LISTING NOTICE

(GNR 544, GNR 545 or GNR 546)

WASTE MANAGEMENT AUTHORISATION

(Indicate whether an authorisation is required in terms of the Waste Management Act).

(Mark with an X)

Waste rock dump 1A 2.476 Ha footprint

4 (7 and 10)

GNR 921 X

Waste rock dump 1B 1.691 Ha footprint

4 (7 and 10)

GNR 921 X

Waste rock dump 2A 5.569 Ha footprint

4 (7 and 10)

GNR 921 X

Waste rock dump 2B 4.716 Ha footprint

4 (7 and 10)

GNR 921 X

Waste rock dump 2C 4.516 Ha footprint

4 (7 and 10)

GNR 921 X

Waste rock dump 3 4.190254 Ha footprint

4 (7 and 10)

GNR 921 X


4 (7 and 10)

GNR 921 X


4 (7 and 10)

GNR 921 X


4 (7 and 10)

GNR 921 X


4 (7 and 10)

GNR 921 X


4 (7 and 10)

GNR 921 X


4 (7 and 10)

GNR 921 X


4 (7 and 10)

GNR 921 X


4 (7 and 10)

GNR 921 X


4 (7 and 10)

GNR 921 X


4 (7 and 10)

GNR 921 X


4 (7 and 10)

GNR 921 X


4 (7 and 10)

GNR 921 X

Middellaagte tailings storage facility 1

60 Ha footprint

4 (7 and 10)

GNR 921 X

Moddergat Tailings storage facility

13.2 Ha footprint

4 (7 and 10)

GNR 921 X

ii) Description of the activities to be undertaken

(Describe Methodology or technology to be employed, including the type of commodity to be mined and for a linear activity, a description of the route of the activity)

Cronimet Chrome Mining SA (Pty) Ltd, a diversified commodity group, contributing

significantly in the sustainable development of South Africa`s economy through mining, is a

holder of a Mining Right for its existing Thaba Cronimet Chrome Mine granted in terms of

section 23 of the Mineral and Petroleum Resources Development Act, 2002 (Act No. 28 of

2002) (MPRDA). The right involves exploitation of Cr and PGMs contained in the LG6

(including LG6A), LG4-high Cr to Fe ratio) (Lower Groups), MG2 and MG3 (Middle Groups)

of the Critical Zone in the Western Bushveld Igneous Complex using both opencast and

conventional underground mining method on portions of the farms Elandskuil 378 KQ,

Middellaagte 382 KQ, Moddergat 389 KQ, Roodedam 368 KQ, Schildpadness 385 KQ, and

Zwartkop 369 KQ, located within the Magisterial District of Thabazimbi, Limpopo Province.

Current mining activities at Thaba Cronimet Chrome Mine (Thaba Mine) include ML1 and

ML2 opencast pits, tailings storage facility (TSF), return water dams (RWDs), and Cr

processing plant located on the farms Middellaagte 382 KQ and Elandskuil 378 KQ, with

metallurgical chrome concentration as primary product at 40 000 tonnes per month (t/m).

The Thaba Mine plans to increase production through the expansion of the opencast mining

operations and underground mining areas. Expansion will cover an area of approximately

2129 hectares in extent and will include development of additional Cr and PGMs processing

plant on both the remaining extent of the farm Moddergat 389 KQ and portion 1 of the farm

Middellaagte 382 KQ. This expansion requires additional support infrastructure to be

constructed, which includes an expansion of an existing tailings storage facility (TSF) and

development of new TSF as well as waste rock dump (WRD) sites.

Mining will involve pre-stripping of vegetation to clear the pit area, followed by the removal of

topsoil and waste rock material to expose the ore. Production for both the opencast and

underground mining operations is planned at 1 320 000 t/annum and 900 000 t/annum over a

27 years LoM. The underground mining areas have an estimated combined chromite ore

mineable reserves of approximately 25 509 132 tons, with an estimated saleable product at

19 131 849 tons.

The RoM will be processed to produce metallurgical concentrate, chemical concentrate, and

foundry sand. Final tailings from the processing will be pumped to a tailings thickener. The

overflow from the thickener will gravitate to a process tank whilst underflow will be pumped to

a TSF.

e) Policy and Legislative Context

APPLICABLE LEGISLATION AND GUIDELINES USED TO COMPILE THE REPORT

(A description of the policy and legislative context within which the development is proposed including an identification of all legislation, policies, plans, guidelines, spatial tools, municipal development planning frameworks and instruments that are applicable to this activity and are to be considered in the assessment process);

REFERENCE WHERE APPLIED

(i.e. Where in this document has it been explained how the development complies with and responds to the legislation and policy context)

HOW DOES THIS DEVELOPMENT COMPLY WITH AND RESPOND TO THE POLICY AND LEGISLATIVE CONTEXT(E.g In terms of the National Water Act:-Water Use Liscence has/has not been applied for).

National Environmental Management: Waste Act, 2008 (Act No. 59 of 2008): Government Notice 921 of Gazette No. 37083) (November 2013)

Regulation 4 of NEMWA, 2008 (Act No 59 of 2008): GN 921 of November 2013

Waste Management Licence Application has been lodged with the Department of Mineral Resources (DMR) Limpopo Regional Office

National Environmental Management Act, 1998 (Act No. 107 of 1998): Environmental Impact Regulation (2014)

Section 23 of the NEMA, 1998 (Act No. 107) of 1998): EIR (2014): Government Notice 982 of Gazette No.38282

Waste Management Licence has been applied and will follow the scoping and environmental impact process

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

Section 22 and 39 of the MPRDA, 2002 (Act No. 28 of 2002)

Thaba Cronimet Chrome Mine is the holder of the Mining Right for the current mining operations. An application for amendment of the Mining Right has been lodged with the DMR Limpopo Regional Office

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

Section 21 and 40 of the NWA, 1998 (Act No. 36 of 1998)

An application for Water Use Licence has been lodged with the Department of Water and Sanitation (DWS) North West Regional Office

National Environmental Management Biodiversity Act, 2004 (Act No. 10 of 2004) (NEMBA)

Section 54 of NEMBA, 2004 (Act. No. 10 of 2004)

Waste Management Licence has been applied and will follow the scoping and environmental impact processwhich involves compilation of the environmental management programme

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

Section 38 (8) of NHRA, 1999

Statutory comments from the South Africa Heritage Resources Agency has been obtained. Furthermore, heritage/ archaeological study was compiled for Thaba Cronimet Chrome Mine.

f) Need and desirability of the proposed activities.

(Motivate the need and desirability of the proposed development including the need and desirability of the activity in the context of the preferred location).

The needs and desirability of the proposed additional mining and processing activities has

taken into consideration the principles of NEMA, the sustainable development objectives,

programmes and broader community needs within the NDP, the Thabazimbi IDP

(2013/2014) and the 2008 Spatial Development Framework (SDF). While the importance of

job creation and economic growth for South Africa cannot be denied, the Constitution calls

for justifiable economic development. The specific needs of the broader community are to be

considered together with the opportunity, costs and consequences of the proposed activities

in order to determine whether or not the development will be socially, economically and

environmentally sustainable.

g) Motivation for the preferred development footprint within the approved site including a full description of the process followed to reach the proposed development footprint within the approved site. NB!! – This section is about the determination of

the specific site layout and the location of infrastructure and activities on site, having taken into consideration the issues raised by interested and affected parties, and the consideration of alternatives to the initially proposed site layout.

(i) Details of the development footprint alternatives considered.

With reference to the site plan provided as Appendix 4 and the location of the individual activities on site, provide details of the alternatives considered with respect to:(a) the property on which or location where it is proposed to undertake the activity;(b) the type of activity to be undertaken;(c) the design or layout of the activity;(d) the technology to be used in the activity;(e) the operational aspects of the activity; and(f) the option of not implementing the activity.

Cronimet Chrome Mining SA (Pty) Ltd is a holder of a Mining Right granted on portion 1 of the

farm Middellaagte 382 KQ, portion 1 of the farm Elandskuil 378 KQ, portion 8 of the farm

Roodedam 368 KQ, remaining extent of the farm Moddergat 389 KQ, and portion 6, 12, 18, 21,

of the farm Zwartkop 369 KQ and portion 1 and the remaining extent of the farm Schildpadnest

385 KQ.

The only preferred site for the proposed extension of TSF is north of the existing TSF and near

the processing plant area on portion 1 of the farm Middellaagte 382 KQ. Furthermore, the

proposed TSF on the remaining extent of the farm Moddergat 389 KQ will also be in close

proximity to the processing plant facility.

The proposed locations of the waste rock dumps were considered to be near the mined-out

areas for ease of backfilling during rehabilitation and closure phase of the mine. The proposed

sites are therefore regarded as the preferred sites and alternative sites were not considered.

Initial consideration for the placement of the plant and TSF was based on availability of land in

close proximity to the proposed mine, Farm Moddergat 389 KQ was identified as the most viable

location as it is adjacent to the proposed Cronimet mining operation and in close proximity to the

portal for the proposed underground mine. Having identified this land and securing its tenure,

Cronimet undertook further investigations to confirm the suitability of this land for placement of

the plant and TSF.

(ii) Details of the Public Participation Process Followed

Describe the process undertaken to consult interested and affected parties including public meetings and one on one consultation. NB the affected parties must be specifically consulted regardless of whether or not they attended public meetings. (Information to be provided to affected parties must include sufficient detail of the intended operation to enable them to assess what impact the activities will have on them or on the use of their land.

The following public engagement and consultation methodology was followed:

Authorities Cosultation Meeting

Pre-application meeting with DWS North West Regional Office at Hartbeespoort Office

on the 17th of December 2014

Pre-application meeting with the Department of Mineral Resources (DMR) Limpopo

Regional Office at Polokwane DMR Offices, on the 31st August 2015

Publishing of newspaper adverts

Die Kwevoel published in english- 25th September 2015

Die Kwevoel published in english and afrikaans- 11th of December 2015

Daily Sun published in english- 25th December 2015

Placement of site notices

Northam Clinic, Northam Shopping Centre, Northam Library, Smash Block Clinic,

Chromite Primary School- 22nd of July 2015

Northam Clinic, Northam Shopping Centre, Northam Library, Smash Block Clinic,

Chromite Primary School, entrance of Smash Block Settlement, and Thabazimbi Library-

23rd of September 2015

Thabazimbi Public Library, Thabazimbi Local Municipality, Thabazimbi Community Hall,

and at Thaba Cronimet Chrome Mine- 25th of September 2015

Public and Focus Group Meeting

Focus group meeting with Sebilong Community Property Association (CPA) on the 28 th

of January 2016 at Leadwood Lodge, Thabazimbi;

Focus group meeting with Mr. Danie Koekemoer on the 21st of January 2016 at Thaba

Cronimet Chrome Mine, Thabazimbi

Focus group meeting with Mr. Cornelius Monene on th 21st of January 2016 at Mawala

Lodge, Northam

Public consultation meeting wih the general public on the 14 th of January 2016 at

Merensky Lodge, near Northam

Consultation Letters

Registered letters were sent to the following interested and affected parties:

Mr. Danie Koekemoer- portion 1 of the farm Zwartkop 369 KQ

Mr. and Mrs. Moloko- portion 8 of the farm Roodedam 368 KQ

Rusternburg Platinum Mines Ltd- portion 1 of the farm Elandskuil 378 KQ,

portion 17 of the farm Zwartkop 369 KQ, and portion 0 of the farm Middellaagte

382 KQ

Sebilong Community Property Association (CPA)- portion 26 and 28 of the farm

Zwartkop 369 KQ

Department of Mineral Resources (DMR) Limpopo Regional Office

Department of Water and Sanitation (DWS)

Limpopo Department of Economic Development, Environment, and Tourism

(LEDET)

Department of Land Affairs (Official: Melton Tshililo)

Department of Environmental Affairs

Thabazimbi Department of Agriculture (Official: Mabel Makibelo)

Thabazimbi Ward 3 Councillor (representative: Stephen Lerumo)

(iii) Summary of Issues raised by Interested and Affected Parties

Interested and Affected Parties DateCommentsReceived

Issues raised EAPs response to issues as mandated by the applicant

AFFECTED PARTIES

Landowner/s

Mr. Danie Koekemoer (Property

owner for portion 1 of the farm

Middellaagte 382 KQ)

X 21 January 2016 A Landowner consultation meeting was held

with Danie Koekemoer where he indicated that

his email address had changed since end

October and supplied us with a new one.

Noted.

DK asked whether an unnamed stream

forming a tributary of the Bierspruit will also be

mined and how that is possible.

The wetland specialist have revised the

wetland assessment report and have

classified the watercourse on portion 1 of

the farm Middellaagte 382 KQ as a stream

(riparian zone) forming a tributary of the

Bierspruit.

DK was concerned with the terms of

compensation and whether the area to be

mined falls under his current agreement with

CCMSA.

CCMSA will discuss with DK

Rustenburg Platinum Mines Ltd

(Property owner of portion 1 of

the farm Elandskuil 378 KQ,

portion 0 of the farm

Middellaagte 382 KQ, and

portion 17 of the farm Zwartkop

369 KQ)

X

14 January 2014 Ms. Boipuso Semenya (an Environmental

Officer at Tumela Mine) was concerned with

why the National Water Act (Act 36 of 1996)

was not included in the Legislative Framework

guiding the WMLA and EIA Processes.

An Integrated Water Use Licence

Application (IWULA) for the planned mine

expansion of the operations at Thaba

Cronimet Chrome Mine has been lodged

with the Department of Water and

Sanitation (DWS) North West Regional

Office.The National Water Act, 1998 (Act

No. 36 of 1998) formed part of the

legislative frameworks for the waste

management licence processes. Thus, both

the waste rock and tailings stockpiles have

been included in the IWULA as section

21(g) water use activities.

Mr Philly Mofomme, an Environmental Officer Dust suppression at Thaba Cronimet

for Tumela Mine, wanted to find out if any

action plan regarding dust and water quality

monitoring was in place.

Chrome Mine will be carried out and has

been included in the IWULA as section

21(g) water use activity requiring

authorisation. Furthermore, water quality

monitoring plan has been included in the

Integrated Water and Waste Management

Plan technical report (together with the

mine action plan) submitted to the DWS.

Kerneck Jens (KJ), the chief land surveyor of

the mine expressed concern regarding the

different plan shown at the public meeting to

the one in the document circulated. He further

stated that correct co-ordinates would be

required to give proper comments as to the

impact of the proposed project on Amandelbut

mine.

A KMZ file was sent to the stakeholder

indicating the correct and updated sites for

the proposed Tailings Storage Facility and

waste rock dump sites.

KJ mentioned that the proposed TSF

expansion on portion 1 of the farm

Middellaagte 382 KQ might have a significant

impact on future planned project for

Amandelbult Mine near portion 1 of the farm

Middellaagte 382 KQ

It was indicated that the two mines should

share plans of the proposed activities in

order to avoid infringement of one`s

activities by the other.

KJ was also interested in finding out if the open

pits will remain or they will be backfilled with

the waste rock?

Once all chrome and PGMs reserves have

been exploited, the mined-out areas will be

backfilled and then revegetated.

KJ asked what rehabilitation measures will be

implemented at the TSF during mine closure.

The TSF at Thaba Cronimet Chrome Mine

will be revegetated during the

decommissioning phase of the mine.

21 January 2016 A focus group consultation meeting was held

with Anglo Tumela Mine where Nishi

Haripursad expressed concerns regarding the

KMZ files sent to them and requested to be

provided with shapefiles

Headwaters will provide updated KMZ files

and possibly shapefiles showing the

proposed waste rock and tailings stockpiles

01 February 2016

(Nishi Haripursad)

NH sent an e-mail to submit further comments

on the proposed project on behalf of Anglo

Tumela Mine, requesting for the location of the

all return water dams as they were not shown

in the draft environmental scoping report.

Headwaters will provide NH with the

positions or localities of the return water

dams

NH queried why the Waste Listed Activities

Category B, No 1, Storage of Waste has not

been included?

Waste rock and tailings stockpiles at Thaba

Cronimet Chrome Mine does not fall within

the ambit of waste listed activity No. 1 of

Category B

NH highlighted that there are new tailings

facilities that would require return water dams

yet this was not listed in the table on page 18

of the Draft Scoping Report.

CCMSA planned expansion of the

operations will also involve expansion of the

TSF located on portion 1 of the

Middellaagte 382 KQ and a new TSF

located on the remaining extent of the farm

Moddergat 389 KQ

NH requested that the rainfall trend be updated

as the data analysis beyond 2007 would

provide a more representative view of rainfall

trends.

Noted.

Sebilong Community Property

Association (CPA) (Property

owner for portion 26 and 28 of

the farm Zwartkop 369 KQ)

28 January 2016

Hennie Venter (HV) requested a copy of the

specialist reports and queried whether

Sebilong was on their Interested and Affected

Parties database. NZ indicated that Sebilong

would be included on the database.

Sebilong CPA has been included in the

interested and affected registration

database. Natalie Smith from Worley

Parsons has provided HV with the

requested specialist reports.

.

ER required clarity on why the bulk sampling

pits on Zwartkop were not licensed in terms of

the WUL.

Mandla from Headwaters indicated that the

pits did not require authorisation in terms of

the National Water Act, Act 36 of 1998.

ER queried why the Waste Management

License does not include the bulk sampling

areas on Zwartkop

Waste activities which took place prior to

the promulgation of the Regulations

pertaining to Waste listed activities did not

need to be licensed. Future /proposed

activities are subjected to licensing

conditions but more clarity to be obtained

from CCMSA.

SM indicated that the Sebilong CPA could not

fully engage with CCMSA or the appointed

consultants on the EIA, Waste and Water

licences until such a time that the lease

agreement and all other issues are addressed

in terms of equity and benefit of the

community.

CCMSA will engage with Sebilong CPA

ER asked whether CCMSA has applied for

closure on prospecting areas/bulk sampling.

These areas have been included in the

liability estimate and rehabilitation plan for

the mine closure

MT stated that CCMSA did not consult with the

Sebilong CPA when they did the bulk

sampling, they exploited the land for money

and didn’t undertaken required rehabilitation.

MT has requested meetings with the directors

of CCMSA. HV will provide a list of the

directors and persons from CCMSA that the

Sebilong CPA wish to engage with.

Information has been relayed to CCMSA for

the relevant meetings to be scheduled

SM indicated that the Sebilong CPA will

continue to object against all authorisation

processes until such a time that the lease

agreement and all other issues pertaining to

the equity and benefit of the community are

resolved

Has been relayed to CCMSA

HV has requested the following documentation

from CCMSA:

• Prospecting work programme and

plans (2008-2010);

• All DMR annual reports;

• Mine work programme.

Noted. Has been relayed to CCMSA

ER queried why the SLP has not been revised

as the five year validity period has expired.

The Sebilong CPA indicated that they have not

been consulted in this regard.

Has beenrelayed to CCMSA

ER stated that the bulk sampling was wrong

and the Sebilong CPA will push for withdrawal

of the rights as no lease agreement in place,

payment has not been made, the area has not

been rehabilitated and two children have

drowned. FT indicated that he will revert to the

MEC to stop the granting of licenses. SM

indicated that the last communication was

received on the 1 December 2015 in terms of

Has been relayed to CCMSA

the lease agreement

HV indicated that the Sebilong would like to

meet with the board of CCMSA. HV will

distribute an e-mail indicating who they would

like to attend the meeting with them. There

was no need for service providers to attend

this meeting as the issues are between

CCMSA and Sebilong CPA. SM indicated that

they will continue to object until CCMSA

engage with them and address their concerns.

Noted. Has been relayed to CCMSA.

Baphalane Ba Mantserre

Community Development Trust

(Represented by Mr. Cornelius

Monene) (Property owners for

portion 1 and the remaining

extent of the farm

Schildpadnest 385 KQ)

21 January 2016 Mr. Cornelius Monene asked when will

CCMSA commence operations for the planned

expansion at Thaba Cronimet Chrome Mine

and whether Schildpadnest is included in the

life of the mine

The proposed mine expansion at Thaba

Cronimet Chrome Mine will involve

additional opencast pits and underground

mining areas. The southern underground

mining areas will be located on portion 1

and the remaining extent of the farm

Schildpadnest. Operationa phase for the

underground mining areas is planned for

2026.

CM was interested in knowing whether another

EIA process will be conducted when CCMSA

starts mining on the farm.

Worley Parsons is currently undertaking the

EIA for the planned expansion of the

operation

CM highlighted that there is a heritage site on

the farm.

Noted. All identified sites for heritage or

cultural resources will be fenced-off.

CM expressed concern relating to the informal Only a shaft will be developed on the farm

shacks on the farm and whether locals will be

affected by blasting?

Schildpadnest 385 KQ. Blasting will be

carried out for the proposed opencast pits

located on portions of the farms Zwartkop

369 KQ, Middellaagte 382 KQ, Roodedam

368 KQ and Elandskuil 378 KQ. No blasting

will take place on the farm Schildpadnest

385 KQ.

CM was concerned with whether the land will

be suitable for development (e.g. houses) after

mining activities at site

The land will be useable after rehabilitation

and closure.

Organs of state (Responsible for infrastructure that may beaffected Roads Department,Eskom, Telkom, DWA e

X

OTHER AFFECTED PARTIES

Ward 3 Councillor (Stephen Lerumo) 25 September 2015 Correspondence was provided by Sazi

Environmental notifying the councillor of the

integrated waste management and water use

licence application for the proposed

construction of Thaba Cronimet Chrome Mine

additional tailings storage facility and waste

disposal

SL indicated that they are aware of the project

and public participation process however the

community is not happy because they get

invited to partake in public participation

processes and attend meetings but their issues

are never taken into consideration or

addressed accordingly especially that of

employing locals.

He further advised that the community is not

pleased with this and have threatened to

boycott the meetings or demonstrate at the

mine because when construction commences,

the mine hires people from far off places and

disregards locals.

Ward 5 Councillor (Mr. S. Manala) 25 September 2015 Notification of the integrated waste

management and water use licence application

for the proposed construction of Thaba

Cronimet Chrome Mine additional tailings

storage facility and waste disposal was given.

SM acknowledged receipt and urged us to

invite them when a meeting takes place as

they are quite interested in the socio-economic

aspects of the project.

Noted.

(iv) The Environmental attributes associated with the development footprint alternatives. (The environmental attributes described must include socio-economic,

social, heritage, cultural, geographical, physical and biological aspects)

(1) Baseline Environment

(a) Type of environment affected by the proposed activity.(its current geographical, physical, biological, socio- economic, and cultural

character).

ClimateThe project area consists of summer rainfall with dry winters. Effectively three seasons, namely

a cool dry season from May to mid-August, a hot dry season from mid-August to about October

and a hot wet season from about November to April. Mean Annual Precipitation (MAP) is about

628.10 mm.

Average monthly maximum temperatures are 32°C in January and 23°C (see figure below) in

July. Average monthly minimum for the area ranges from 19.5°C in January to 2.2°C in July.

Mean monthly maximum and minimum temperatures is about 31.3 °C and 3.1°C for November

and June, respectively (Mucina and Rutherford, 2006).

Historical temperature records obtained from the South African Weather Station number

05876972, located 3 km south-west of Thabazimbi was used to compute the average minimum

and maximum monthly temperatures for the area. The average minimum and maximum monthly

temperatures were calculated from the year 1983-2009 (26 years).

Table 3—2: Average Maximum and Minimum Monthly Temperatures

MonthAverage Maximum

TemperatureAverage Minimum

Temperature

Jan 32 19.5

Feb 31.6 18.9

Mar 30.2 17.2

Apr 28.1 12.6

May 25.6 6.5

Jun 23 3.1

Jul 23 2.2

Aug 26.2 6.3

Sep 29.7 12.5

Oct 31.4 16.7

Nov 31.3 18

Dec 31.6 18.9

Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec0

5

10

15

20

25

30

35

Average Monthly Temperature (°C)Average Maximum Temperature Average Minimum Temperature

Month

Aver

age

Tem

pera

ture

(°C)

Figure 3-1: Average Maximum and Minimum Monthly Temperatures (°C)

Regional ClimateThe proposed project area lies within the summer rainfall region of South Africa and thus

approximately 90 percent of the Mean Annual Precipitation (MAP) occurs within the six month

period between October and March, with only five percent of the MAP occurring between April

and September.

Historical rainfall records obtained from the South African Weather Station number 05876972,

was used to compute the mean annual precipitation. This meteorogical gauging station is

located 16 km north-east from the site (portion 1 of the farm Middellaagte 382 KQ) and 3 km

south-west of Thabazimbi, on the farm Wachteenbietjesdraii 350 KQ.

The average monthly rainfall is calculated from the year 1960-2009 (49 years).The vicinity of

Thaba Mine receives a mean annual precipitation of approximately 628.1 mm as shown in the

tabulation below.

The figure below shows average rainfall depth (mm) for the vicinity of the project area. The

monthly rainfall trend is in line with the seasonal rainfall distribution with the summer months

having the highest rainfall intensity (89.4-37.3 mm).

Table 3—3: Average Monthly Rainfall Depth (mm)

Month Mean Monthly Rainfall (mm)

Jan 124.9

Feb 94.9

Mar 77

Apr 37.3

May 10.8

Jun 6.8

Jul 1.5

Aug 3.9

Sep 12.8

Oct 48.7

Nov 89.4

Dec 120.1

Total 628.1

Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec0

20

40

60

80

100

120

140

Average Rainfall Depth (mm)

Mean Monthly Rainfall (mm)

Month

Aver

age

Rain

fall

(mm

)

Figure 3-2: Average Monthly Rainfall Depth (mm)

EvaporationAccording to the Final Environmental Impact Report (Worley Parsons, 2015), the mean annual

potential evaporation for Quaternary Catchments A24C and A24F is approximately 1840 mm

per annum. This value is in line with mean annual evaporation as measured from an S-pan by

Water Research Commission (WRC, 2005), which is in the range of 1800-2000 mm/yr.

Topography The majority of the area is characterised by undulating to flat plains with a high of 980 m above

mean sea level (mamsl) to the South West and 960 mamsl to the East, with the lowest point

being the Bierspruit River. This means that the site is generally flat with a slight gradient

towards the Crocodile River. One small hill on the farm Zwartkop 369 KQ is 1058.5 mamsl in

height.The area is drained to the north by the Bierspruit River and its associated tributaries.

GeologyThe project area is underlain by the Rustenburg Layered Suite Geological Formation of the

Bushveld Complex (Vaalian era)

The Bushveld Complex The igneous layering at Rustenburg area is north-north striking with an average dip of

approximately 30°. The UG2 reef at Lebowa occurs as a chromitite layer with an average

thickness of approximately 75 cm. Three leader chromitite layers also occur above the main

chromitite. The Bushveld Complex is unique because of its size, the persistence and regularity

of the layering of the mafic and ultramafic rocks, and the importance of the economic minerals it

contains. It is the most important depository of platinum group elements (PGEs) in the world,

hosting some 85% of the world’s resources, but is also one of the world’s foremost sources of

nickel, vanadium and chromite. The mafic portion of the Bushveld Complex has been dated at

2095Ma and consists of a 7 to 9km thickness of magmatic rocks exposed in four lobes with a

total surface area covering 65 000km².

The magmatic event that gave rise to the Bushveld Complex commenced with the extrusion of

large volumes of basaltic (Dullstroom) and felsic (Rooiberg) magmas at the end of Transvaal

sedimentation. This was subsequently intruded by pre-Bushveld sills, which collectively attain a

thickness of 2 km. This event was followed closely by the 2095 Ma main mafic sequence and,

ultimately by the intrusion of the various Bushveld granites. The mafic magmas spread upward

and laterally along shallow-angled fractures to produce the four main lobes.

The Bushveld Complex is described as clover-shaped, consisting of four lobes. The two

bracket-like Western and Eastern Lobes constitute the “main” Complex, which has an elliptical

form, measuring 370km in an east-west direction and 365km in a northwest-southeast direction.

The four lobes are:

The Western Lobe extends from near Pretoria westward to Rustenburg, northwards

around the Pilanesberg Complex and northwards to Thabazimbi;

The Southern Lobe is largely covered by the Karoo-age coal-bearing sediments around

Witbank, Middelburg and Bethal;

The Eastern Lobe extends northwards through the eastern Mpumalanga from near

Middelburg in the south to the east of Mokopane in the north; and

The Northern Lobe extends northwards from Mokopane.

A layered sequence of mafic and ultramafic rocks known as the Rustenburg Layered Suite

occurs within each of the four lobes. The general dip of the layering is towards the centre of

each lobe at angles varying between 10° and 25°. The Rustenburg Layered Suite comprises

five zones, from the base of the succession upwards – the Marginal, Lower, Critical, Main and

Upper Zones. Individual layers or groups of layers can be traced laterally for distances

exceeding 100km. The PGEs and chromium are the most important economic elements in the

Rustenburg Layered Suite. The largest deposits of chromite in the world occur in the Critical

Zone of the Eastern and Western Lobes. Those deposits in the lower part of the Critical Zone

are prefixed “LG chromitites” whereas those of the upper Critical Zone are prefixed “UG

chromitites”. The UG2 Chromitite is particularly significant for its PGE content.

Groundwater

Aquifer characterisation

According to the Geohydrological investigation assessment conducted by JMA Consulting (July,

2015), Thaba Mine is underlain by highly to slightly weathered shallow Gabbro and Norite

Aquifer and Deeper (fresh) fractured Gabbro and Norite aquifer. The shallow weathered aquifer

occurs from the surface to a depth of approximately 24 m below the earth`s surface, while the

deeper fractured aquifer lies below 24 m. However, average groundwater depth at the site is

about 19 m below ground. Thus, approximately less than 5 m of the weathered Norite and

Gabbro aquifer is saturated.

In addition, transmissivity tests were performed for the shallow weathered aquifer and the

values range between 1- 5 m2/day. According to the available information and data, the overall

borehole yielding capacity within the shallow aquifer is approximately 2 ℓ/s (see table below).

Table 3—4: Aquifer Yielding CapacityBorehole Borehole Depth Borehole Yield Property Details

CGW-4 28 m 2 ℓ/s @23-24 m Zwartkop 369 KQ

CGW-5 28 m 2 ℓ/s @11-13 m Zwartkop 369 KQ

Aquifer classification was carried out based on the methodology as shown in the tabulation

below by Roger Parsons in A South African Aquifer System Management Classification (1995).

According to this system, the shallow weathered Gabbro and Norite aquifer is classified as a

Minor Aquifer.

Two north-south striking faults zones occurs in the northern part of the site on the farm

Middellaagte 382 KQ. These geological features form preferential pathways for groundwater

flow and recharge of the deeper fresh fractured Gabbro and Norite aquifer. Boreholes yield test

have not been performed within these formations. However, the Geohydrological investigation

suggest that water yielding capacity decreases dramatically in depth due to high pressure

conditions.

Table3—5: Aquifer Classification System (Parsons, 1995)

Figure 3-3: Fault Zones within the study areaWater Management AreaThe proposed project falls within the Crocodile (West) and Marico water management area

(WMA). The Crocodile (West) and Marico Water Management Area lies primarily within the

North West Province with parts of it in the northern region of Gauteng and the south-western

periphery of the Limpopo Province. The Crocodile and Marico rivers are the two main rivers in

this WMA, which at their confluence forms the Limpopo River that flows eastwards to the Indian

Ocean.

The Crocodile (West) and Marico WMA comprises of Sub-WMA`s, that is, the Lower Crocodile,

Apies/Pienaars, Elands, Upper Crocodile, Upper Molopo, and Marico. Cronimet Thaba Chrome

Mine is located within the Lower Sub-WMA. The Lower Crocodile River has two large

tributaries, namely the Sand River and the Bierspruit which join the Crocodile River west of the

town of Thabazimbi

More than half of the total water use in the Crocodile (West) and Marico WMA comprises urban,

industrial and mining use, approximately a third is used by irrigation and the remainder of the

water requirements is for rural water supplies and power generation.

In order to meet the current demand, much of the water in the WMA is being imported mainly

from the Vaal River system for domestic and industrial use purposes. Rand Water, which is the

largest water board in South Africa, together with Magalies Water and Botshelo Water (the

North West Water Supply Authority), are the three water boards that supply water in this WMA.

The natural mean annual runoff (MAR) of the down the Crocodile River, while the Marico

catchment contributes 20 % and the Upper Crocodile (West) and Marico WMA is 855 million

m3/yr. Approximately 75 % of the total surface runoff from the WMA flows Molopo catchment 5

%.

Waste ClassificationGeochemical investigations of the tailing waste, overburden material, and waste rock material at

Thaba Cronimet Chrome Mine was undertaken by Hydro Science (May, 2015) and

Environmental Resources Management (ERM) (May, 2015). The investigation was carried out

in terms of the National Department of Environmental Affairs (DEA) Regulation 635- National

norms and standards for assessment of waste for landfill disposal, and Regulation 636-

National norms and standards for disposal of waste to landfill.

The objective of the assessment was to classify the residue waste. Waste classification will

make provision for the barrier lining required for the residue stockpiles.

A total of 15 samples of the waste rock material, 2 samples of the tailing waste, and 1 sample of

the overburden material were collected from the existing tailings storage facility, overburden

dump and the waste rock dump. The samples were analysed using the acid-base accounting

(ABA) and net-acid generation (NAG) techniques to determine the potential to generate acid

rock drainage.

From the results of analysis in the tabulation below, all samples of the tailing waste, overburden

and waste rock material falls within leachable concentration threshold zero (mg/ℓ) (LCT0),

except for Cr (total) for the waste rock sample Cron 3a with an average concentration of

approximately 0.181 mg/ℓ, which in this case falls within leachable concentration threshold 1

limit.

However, the total concentration for all the waste residue stockpiles are within the total

concentration threshold zero (mg/kg) (TCT0), except for the following chemical parameters:

Barium, Total Chromium, Manganese, Nickel, and Vanadium.

Total Chromium for the tailings sample 1 (fine tailing sample) was recorded at a maximum total

concentration threshold 69 150 mg/kg, with Vanadium at 361 mg/kg (fine tailings sample) and

326 mg/kg (coarse tailings sample).

Table 3—6: Total concentration of the residue stockpiles (mg/kg)

Variables Symbol LOD TCT0 TCT1 TCT2 Tailings WasteOverburden

Waste Waste Rock Material

Sample 1: fine slimes

Sample 2: course tailings

Sample 3: Overburden Cron 1a Cron 2a Cron 3a Cron 4b Cron 6a

pH 8.5 8.6 8.7 Aluminium Al 0.004 NT NT NT 2735 1069 2885 Arsenic As 0.02 5.8 500 2000 <0.1 <1 <1 <4 <4 <4 <4 <4Boron B 1 150 15000 60000 5.8 <0.8 <0.8 <10 <10 <10 <10 <10Barium Ba 0.1 62.5 6250 25000 110 34 69 40.4 96.8 55.2 73.6 79.2Calcium Ca 5 NT NT NT 9709 10802 13087 Cadmium Cd 0.1 7.5 260 1040 0.82 0.12 1.6 <2 <2 <2 12.8 11.2Cobalt Co 0.1 50 5000 20000 77 52 41 <10 14.8 46.4 154.4 143.2Chromium total Cr tot 0.3

46000 800000 NT 69150 41685 1500 229.6 560 2072 480 302.8

Chromium VI Cr VI 0.01 6.5 500 2000 2.4 3.8 3.0 <5 <5 <5 <5 <5Copper Cu 0.2 16 19500 78000 40 9.8 8.3 <10 <10 48.4 <10 <10Iron Fe 0.1 NT NT NT 77540 48595 44560 Mercury Hg 0.1 0.93 160 640 <0.1 <0.1 <0.1 <0.4 <0.4 <0.4 <0.4 <0.4Manganese Mn 0.1 1000 25000 100000 1084 494 785 116.8 484 904 1704 1568Magnesium Mg 1 NT NT NT 23510 10802 13087 Molybdenum Mo 0.1 40 1000 4000 <0.1 0.67 1.6 <10 <10 <10 <10 <10Sodium Na 2 NT NT NT 1354 855 6400 Nickel Ni 0.3 91 10600 42400 353 182 228 40.4 102 448 828 780Lead Pb 1 20 1900 7600 <1.0 <1.0 1.9 <8 <8 <8 <8 <8Antimony Sb 1 10 75 300 <1.0 <1.0 <1.0 9.2 <4 8.8 16.4 13.2Selenium Se 3 10 50 200 <3.0 <3.0 <3.0 <8 <8 <8 <8 <8Vanadium V 0.2 150 2680 10720 361 326 73 12 <10 <10 <10 14.8Zinc Zn 0.5 240 160000 640000 104 73 28 10 25.6 31.6 101.6 97.6

Variables Symbol LOD TCT0 TCT1 TCT2 Tailings WasteOverburden

Waste Waste Rock Material


Sample 2: course tailings


Chloride Cl NT NT NT 11.2 <10 <10 Sulphate SO₂ NT NT NT <0.01 <0.01 0.01 Nitrate-N NO₃ NT NT NT <0.5 5.0 2.5 Fluoride F 100 10000 40000 <10 <10 <10 94 122 167 137 86.4Cyanide CN 14 10500 42000 <0.1 <0.1 <0.1 <0.01 <0.01 <0.01 <0.01 <0.01

Table3—7: Leachable concentration of the residue stockpiles (mg/ℓ)

Variables Symbol LOD LCT0 LCT1 LCT2 LCT3 Tailings WasteOverburden Waste

Waste Rock Material


Sample 2: course slimes


pH 8.6 8.5 8.4 Aluminium Al 0.003 NT NT NT NT 0.15 0.13 0.35 Arsenic As 0.02 0.01 0.5 1 4 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01Boron B 0.006 0.5 25 50 200 0.01 <0.006 0.006 0.025 0.025 0.025 0.025 0.025Barium Ba 0.001 0.7 35 70 280 0.16 0.12 0.12 0.025 0.025 0.025 0.025 0.025Calcium Ca 0.05 NT NT NT NT 3.4 3.7 3.5 Cadmium Cd 0.001 0.003 0.15 0.3 1.2 <0.001 0.001 <0.001 <0.003 <0.003 <0.003 <0.003 <0.003Cobalt Co 0.001 0.50 25 50 200 <0.001 <0.001 <0.001 0.025 0.025 0.025 0.025 0.025Chromium total Cr tot 0.003 0.1 5 10 40 0.03 0.02 0.008 0.025 0.025 0.181 0.025 0.025Chromium VI Cr VI 0.01 0.05 2.5 5 20 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01Copper Cu 0.002 2.0 100 200 800 0.007 0.004 0.005 <0.025 <0.025 <0.025 <0.025 <0.025Iron Fe 0.001 NT NT NT NT 0.22 0.21 0.16 Mercury Hg 0.001 0.006 0.3 0.6 2.4 <0.001 <0.001 <0.001 <0.001 <0.001 <0.001 <0.001 <0.001Manganese Mn 0.001 0.5 25 50 200 0.004 0.003 0.003 <0.025 <0.025 0.137 <0.025 <0.025Magnesium Mg 0.01 NT NT NT NT 5.6 3.1 3.3 Molybdenum Mo 0.001 0.07 3.5 7 28 <0.001 <0.001 <0.001 <0.025 <0.025 <0.025 <0.025 <0.025Sodium Na 0.02 NT NT NT NT 7.2 4.2 3.5 Nickel Ni 0.003 0.07 3.5 7 28 <0.003 <0.003 <0.003 <0.025 <0.025 0.034 <0.025 <0.025Lead Pb 1 0.01 0.5 1 4 <0.01 <0.01 <0.01 <0.010 <0.010 <0.010 <0.010 <0.010Antimony Sb 1 0.02 1.0 2 8 <0.01 <0.01 <0.01 <0.010 <0.010 <0.010 <0.010 <0.010Selenium Se 3 0.01 0.5 1 4 <0.01 <0.01 <0.01 <0.010 <0.010 <0.010 <0.010 <0.010Vanadium V 0.002 0.2 10 20 80 0.04 0.03 0.03 <0.025 <0.025 <0.025 <0.025 <0.025Zinc Zn 0.005 5.0 250 500 2000 <0.005 <0.005 <0.005 <0.025 <0.025 <0.025 <0.025 <0.025Chloride Cl 300 15000 30000 120000 4.8 2.2 1.7 <5 <5 <5 <5 <5

Variables Symbol LOD LCT0 LCT1 LCT2 LCT3 Tailings WasteOverburden Waste

Waste Rock Material


Sample 2: course slimes


Sulphate SO₂ 250 12500 25000 100000 9.4 5.4 5.2 <5 <5 <5 <5 <5Nitrate-N NO₃ 11 550 1100 4400 1.2 0.1 0.2 <0.2 <0.2 <0.2 <0.2 <0.2Fluoride F 1.5 75 150 600 0.2 0.1 0.2 <0.2 <0.2 <0.2 <0.2 <0.2Cyanide CN 0.07 3.5 7 28 <0.01 <0.01 <0.01 <0.05 <0.05 <0.05 <0.05 <0.05

From the tabulation above, the tailings waste, overburden and waste rock samples were all

classified as Type 3 waste, which requires disposal into a Class C containment barrier. The

concentration of the material are effluenced by the geology of the study area, which is the

Bushveld Igneous Complex (BIC) formed during the Vaalian era.

FloraThe Thaba Cronimet Chrome Mine lies within the Savanna biome which is the largest in

Southern Africa. It is characterised by a grassy ground layer and a distinct upper layer of woody

plants (trees and shrubs). The environmental factors delimiting the biome are complex and

include altitude, rainfall, geology and soil types, with rainfall being the major delimiting factor.

Fire and grazing also keep the grassy layer dominant. The classification of the area was the

microphyllous woodland which is part of the Dwaalboom Thornveld vegetation type. The

Dwaalboom Thornveld vegetation type had threatened conservation status, with 14 percent

transformed and six percent statutorily conserved. Vegetation units were identified according to

plant species composition, previous land use soil types and topography. The state of the

vegetation of the proposed mining site varied from being natural to completely degraded

Surface and Ground Water Control and Monitoring

Water resources monitoring will be undertaken in terms of the Department of Water and

Sanitation (DWS) Best Practice Guidelines (BPG) for Water Monitoring Systems (2007). The

objective of monitoring system is to:

Develop environmental and water management plans base on impact monitoring;

Generate baseline data before project implementation;

Assess the impacts on receiving water environment;

Assess compliance with legal requirements.

Internal reporting will include monthly reports to the mine management on the performance

against management commitments and expectation against authorisations and permits.

External reporting requirements will be guided by the permit and licences received to that effect

and the mine commit to comply with these statutory requirements at all times. This will

encompass incident reporting which in terms of the EMS, requires classification of incidents into

three categories (Levels 1, 2 & 3) depending on their severity or potential consequence to the

environment.

Surface Water Monitoring

The major objective of surface water monitoring is to ensure that mining activities have a limited

adverse effect on surface water resources. The broad objective of the surface water monitoring

system is to ensure that the water management systems perform according to specifications, to

act as a pollution early warning system, to check compliance with legal requirements and for

reporting purposes.

Table 6—8: Surface Water Flow Monitoring

Aspect Points FrequencySurface water flows Return water dam Monthly

Sewage return flows Monthly

Slurry to TSF Monthly

Process water to the

processing plant

Monthly

Table 3—9: Surface water monitoring

Variables Points Frequency Coordinates

Water quality ZPR-1- Bierspruit upstream of

operations on portion 18 of the farm

Zwartkop 369 KQ

Monthly E 27° 18’ 14.6”

S 24° 46’ 48.5”

STR-1- Bierspruit downstream of

operations on portion 1 of the farm

Schildpadness 385KQ

Monthly E 27° 18’14.4”

S 24° 47’ 55.1”

MRT-1- Bierspruit downstream of

operations on the remaining extent

of the farm Moddergat 389 KQ

Monthly E 27° 15’ 52.9”

S 24° 51’ 06.1”

ZPR-2 – Unnamed tributary of the

Bierspruit on portion 12 of the farm

Zwartkop 369KQ

Monthly 24° 46’ 01” S27° 19’ 16” E

Process water Return water from the Middellaagte

TSF return water dam

Monthly E 27° 20’ 52.52”

S 24° 45’ 03.03”

Pollution control dam (MLPCD1) Monthly E 27° 20’ 10.02”

S 24° 45’ 53.04”


Pollution control dam (MLPCD2) Monthly E 27° 20’ 24.08”

S 24° 45’ 04.02”

Pollution control dam (ZK1) Monthly E 27° 19’ 41.03”

S 24° 45’ 34.05”

Pollution control dam (ZK2) Monthly E 27° 19’ 41.09”

S 24° 45’ 35.08”

Table 3—10: Surface Water Quality Monitoring Determinants

Water Quality Parameters/Determinants

Unit Timeframes for Measurement

Monthly Quarterly Annually

pH pH scale Electric Conductivity (EC) mS/m Total Dissolved Solid (TDS) mg/l Nitrate (NO3) mg/l Calcium (Ca) mg/l Arsenic (As) mg/l Magnesium (Mg) mg/l Sodium (Na) mg/l Potassium (K) mg/l Iron (Fe) mg/l Manganese (Mn) mg/l Chloride (Cl) mg/l Sulphate (SO4) mg/l Fluoride (F) mg/l Chromium VI (Cr (VI)) mg/l Total Chromium (Cr) mg/l Nickel (Ni) mg/l Vanadium (V) mg/l Cadmium (Cd) mg/l Copper (Cu) mg/l E.Coli cfu/100 ml Faecal Coliforms cfu/100 ml

Laboratory AnalysisAnalysis must be done by a lab that has SANS (South African Bureau of Standards)

accreditation in terms of the Standard Act, 1982 (Act No. 30 of 1982) for all the required water

quality determinants.

Groundwater Monitoring

Groundwater monitoring at Thaba Mine is currently being implemented according to the mine

water quality monitoring programme. The monitoring programme will be updated based on the

recommendations from the Geohydrological assessment report and wetland assessment report.

The main objective of the programme is to ensure that mining activities have a limited adverse

effect on local groundwater resources. The following key aspects will be as part of the

monitoring programme:

Generation of information regarding groundwater quality and quantity;

Determination and quantification of additional impacts as a results of the proposed

mining operation;

Managing the impacts on groundwater at the mine. These include development of

monitoring response protocol. This protocol shall describe the procedures to be followed

in the event pertinent issues arise on groundwater resources;

Prevention of possible further pollution on groundwater resources;

Updating and verification of the groundwater flow model;

Reviewing the mine water balance model and compilation of annual compliance reports.

Table 3—11: Groundwater Monitoring

Aspect Points FrequencyGroundwater quality Boreholes Quarterly

Groundwater levels Boreholes Quarterly

Dewatering flows Opencast workings Once every week

Underground workings Once every week

The tabulation below sets out groundwater quantity and quality monitoring points.

Table 6—12: Groundwater Monitoring Points

Aspect Location Coordinates

BH-1-North-east of

Middellaagte tailings storage

facility

E 27° 21’ 14.44”

S 24° 44’ 49.79”

BH-2- South of Middellaagte

tailings storage facility

E 27° 20’ 59.99”

S 24° 45’ 24.11”


BH-3- North-west of


facility

E 27° 20’ 39.97”

S 24° 44’ 59.56”

BH-4- South-east of


facility

E 27° 21’ 29.16”

S 24° 45’ 14.54”

CGW-1- North-east of the

Moddergat tailings storage

facility

E 27° 15’ 40.54”

S 24° 49’ 20.46”

CGW-2- South-east of the


facility

E 27° 16’ 08.80”

S 24° 50’ 06.68”

CGW-3- North-west of the


facility

E 27° 14’ 47.22”

S 24° 49’ 59.52”

CGW-4- North of the southern

underground mining areas

and north of ZK3 opencast pit

E 27° 18’ 39.13”

S 24° 46’ 11.14”

CGW-6- South-west of the

underground mining areas

E 27° 16’ 13.98”

S 24° 48’ 18.68”

CGW-8-West of MLPCD2

pollution control dam

E 27° 20’ 26.23”

S 24° 45’ 04.75”

ZP8-North of the southern

underground mining areas on


369 KQ

E 27° 18’ 08.1”

S 24° 45’ 57.0”

ZP9- North of the southern



369 KQ

E 27° 18’ 08.9”

S 24° 45’ 58.3”

ZP12- North of the southern



E 27° 18’ 06.8”

S 24° 46’ 33.1”


Zwartkop 369 KQ

ZP15- Located within the

Sebilong settlement on


Zwartkop 369 KQ

E 27° 16’ 36.7”

S 24° 47’ 03.2”

ZP18- Located within the

Sebilong settlement on


Zwartkop 369 KQ

E 27° 17’ 13.6”

S 24° 46’ 56.5”

According to the Geohydrological assessment undertaken by JMA Consulting (July, 2015),

additional recommended groundwater monitoring boreholes (BH-1, BH-2, BH-3, and BH-4) must

be drilled around the tailings storage facility located on portion 1 of the farm Middellaagte 382

KQ. The tabulation below sets out groundwater quality monitoring determinants.

Table 6—13: Groundwater Quality Monitoring Determinants




pH pH scale Electric Conductivity (EC) mS/m Total Dissolved Solid (TDS) mg/l Nitrate (NO3) mg/l Calcium (Ca) mg/l Arsenic (As) mg/l Magnesium (Mg) mg/l Sodium (Na) mg/l Potassium (K) mg/l Iron (Fe) mg/l Manganese (Mn) mg/l Chlorine (Cl) mg/l Sulphate (SO4) mg/l Fluoride (F) mg/l Chromium VI (Cr) mg/l Total Chromium (Cr) mg/l Nickel (Ni) mg/l Vanadium (V) mg/l Cadmium (Cd) mg/l Copper (Cu) mg/l Faecal Coliforms cfu/100 ml




E.Coli cfu/100 ml

Monitoring ProcedureThe mine water monitoring programme was developed and implemented using the following

guidelines and standards:

DWS, 2007. Best Practice Guideline for Protection of Water Resources in the South

African Mining Industry. G3: Water Monitoring Systems;

DWS, 2003. Quality of Domestic Water Supplies, Volume 2: Sampling Guide;

ISO 5667-3: 2006 Part 1: Guidance on the design of sampling programmes and

sampling techniques;

ISO 5667-3: 2003 Part 3: Guidance on sample preservation and sample handling;

ISO 5667-6: 2005 Part 6: Guidance on sampling of rivers and streams;

ISO 5667-11: 2006 Part 11: Guidance on sampling of groundwater.

Laboratory AnalysisAnalysis must be done by a lab that has SANS (South African Bureau of Standards)

accreditation in terms of the Standard Act, 1982 (Act No. 30 of 1982) for all the required water

quality determinants.

Bio-monitoringThaba Mine project area comprises of the following hydro-geomorphic units (wetland features)

and riparian zones on the central and southern parts of the site.

Unnamed stream forming the tributary of the Bierspruit on portion 1 of the farm

Middellaagte 382 KQ and portion 8 of the farm Roodedam 368 KQ

Channeled valley bottom wetland and the artificial seepage wetland on the farm

Zwartkop 369 KQ, and

Riparian zone draining the artificial seepage wetland on the farm Zwartkop 369 KQ

The flows from the riparian zones (streams) forms a tributary of the Bierspruit. The Bierspruit

forms a tributary of the Crocodile River, 6 km north from the farm Roodedam 368 KQ. This

perennial river straddles portion 18 of the farm Zwartkop 369 KQ and the remaining extent of

the farm Moddergat 389 KQ.

Thaba Mine will conduct bio-monitoring at various terrestrial and aquatic sites to monitor the

ecological health of Thaba mining area. Invertebrates play an integral role in the environment as

biological indicators of ecological integrity. These invertebrates react to disturbances (such as

dust deposition, water abstraction or poor land management) much faster than other biological

or physical components.

Terrestrial habitats should also be included in the bio-monitoring programme. As a minimum the

indicator species, site or aspects of the following will be included in the bio-monitoring

programme:

Water quality;

Aquatic macro-invertebrates;

Sediments

Terrestrial fauna (Avifauna, mammalian, terrestrial entomology, amphibian, and reptilian)

Terrestrial flora;

GIS analysis (Aerial Imagery)

The bio-monitoring proposed in the tabulation below is anticipated to assist in proactively

determining the possible impacts and thus assisting with implementation of management

measures. Data collected during the bio-monitoring programme will be included in a Geographic

Information System (GIS) to effectively identify trends and assist in managing the mine

properties and impacts. The GIS system will incorporate surface and groundwater quality as

well as the water balances for the mine.

Table 3—14: Bio-monitoring PointsVariables Points Frequency Coordinates

River health BSC01-Upstream of the

Bierspruit, on the southern

boundary of the farm Moddergat

389 KQ.

Quarterly or

Seasonal

E 27° 15’ 07.00”

S 24° 52’39.50”

BSC02-Upstream of the

Bierspruit and south-east of the


facility.

Quarterly or

Seasonal

E 27° 16’ 29.70”

S 24° 50’ 51.90”

BSC04- Downstream of the

Bierspruit, on portion 18 of the

farm Zwartkop

Quarterly or

Seasonal

E 27° 18’ 20.90”

S 24° 46’ 51.40”


369 KQ

BSC06- Downstream of the

Bierspruit, after discharge from

the tributary of the Bierspruit,

located at the old Zwartkop

Chrome Mine.

Quarterly or

Seasonal

E 27° 18’ 16.00”

S 24° 46’36.60”

MDL01- Located within the

unnamed stream forming a

tributary of the Bierspruit on


Middellaagte 382 KQ

Quarterly or

Seasonal

E 27° 20’ 31.86”

S 24° 45’ 01.98”

(b) Description of the current land uses.

For most of the mineral lease area, the soils were suited to extensive grazing as they were not

radically disturbed. The areas that have been disturbed by historic mining activities were not

suited to grazing or agriculture as these soils have been degraded significantly due to

disturbance. The land use was changing from grazing to rural dwellings in a large area of the

site and with this change the soil’s quality was also degrading. Low intensity agricultural

activities can be considered for the remaining open areas but the risk of crop failures will be

high if rainfall is erratic and if management is not optimal

Table 1:1 Land Use categories & surface Areas for the Thaba Cronimet Chrome Mine mining lease area

Land use Area (ha) Percentage (%)

Extensive grazing 1618.4 82.6

Irrigated agriculture 6.2 0.3

Informal housing 29.7 1.5

Historic mining impacts 266.4 13.6

Current mining impacts 37.5 1.9

Total 1958.2

The land-use on the different farms in 2009/2010 was as follows:

Farms Zwartkop 369 KQ and Schilpadnest 385 KQ was old mining activities and tribal

land

Middellaagte 382 KQ, Roodedam 368 KQ and Elandskuil 378 KQ was utilised for

livestock farming

FaunaBirds

A survey was conducted on the study site during October 2009 to identify specific bird habitats,

and to compare these habitats with habitat preferences of birds occurring in the quarter degree

grid according to Harrison et al. (1997). The list of red data species potentially occurring in the

area at that time is listed in the Table 1:2 below.

Table 1:2 List of Red Data Birds Potentially Occurring In The Study Area

English Name Afrikaans Name StatusProbability of

occurrence on sight

White Pelican Witpelikaan Vulnerable Low

Pinkbacked Pelican Kleinpelikaan Vulnerable Low

Whitebacked Night

Heron

Witrugnagreier Vulnerable Medium to low

Black Stork Groot swartooievaar Near threatened High

Marabou Stork Maraboe Near threatened High

Yellowbilled Stork Nimmersat Near threatened High

Greater Flamingo Grootflamink Near threatened Low

Lesser Flamingo Kleinflamink Near threatened Low

Secretarybird Sekretarisvoël Near threatened Medium

Cape Vulture Kransaasvoël Vulnerable Medium

Whitebacked Vulture Witrugaasvoël Vulnerable Medium

English Name Afrikaans Name StatusProbability of

occurrence on sight

Lappetfaced Vulture Swartaasvoël Vulnerable Medium

Tawny Eagle Roofarend Vulnerable Medium to high

Ayres' Eagle Kleinjagarend Near threatened Medium

Martial Eagle Breëkoparend Vulnerable Medium

African Marsh Harrier Afrikaanse Vleivalk Vulnerable Medium to low

Peregrine Falcon Swerfvalk Near threatened Low

Pallid Harrier Witborsvleivalk Near threatened Low

Lanner Falcon Edelvalk Near threatened Low

Lesser Kestrel Kleinrooivalk Vulnerable Medium to low

MammalsTable 1:3 below outlines red data mammal species that could occur according to Friedman and Daly (2004), in the study area in 2009/2010.

Table 1:3 List Of Red Data Mammals That May Occur In The Study Area

Scientific Name Vernacular Name Probability Of Occurrence

Status

Acinonyx jubatus Cheetah Low Vulnerable

Atelerix frontalis South African Hedgehog Marginal Near threatened

Hyaena brunnea Brown hyena Medium Near threatened

Laecon pictus African wild dog Low Endangered

Manis temminckii Pangolin Medium Vulnerable

Mellivora capensis Honey badger Medium Near threatened

Miniopterus schreibersii Schreibers’ long fingered bat High Near threatened

Herpetofauna

The Southern African Python (phython natalensis), an International Union for Conservation of

Nature (IUCN) red data species had a moderate to high probability of occurring in the mineral

lease area.

Domestic Fuel Burning

Domestic fuel burning had been identified throughout the various studies as one of the most

significant sources of atmospheric emissions impacting on human health and well-being. This is

due to the level of release of domestic fuel burning emissions within the breathing spaces of

people, with the main pollutants of concern being fine particulates (PM10) and sulphor dioxide.

The extent of household fuel combustion in the region of the Thaba Cronimet Chrome Mine was

not known

Economic Activities

The main economic activities within the region included agriculture, small scale farming,

commercial farming and mining. These activities were widely scattered throughout the region.

Cattle farms (primarily when operated on large scale) are significant sources of fugitive dust

especially when feedlots are used and the cattle trample in confined areas. The calf-cow sector

of the beef industry was found to be the large stemitter of methane emissions. Where animals

are confined densely, the main pollutants of concern include dust from the animal movements,

their feed and their manure, ammonia from the animal urine and manure, and hydrogen

sulphide from manure pits. This was not a likely problem in this region with farms only located

far away and covering large areas.

(c) Description of specific environmental features and infrastructure on the site.

Stone Age SitesThree sites with Stone Age material were on record for areas within the CCMSA mineral lease

area. These sites are all open air sites situated around hills and rock outcrops. The sites are

located on the farms Zwartkop 369 KQ and Moddergat 389 KQ. Diagnostic features on the tools

consist of facets on the striking platform indicating Middle Stone Age occupation. Raw material

consists of igneous rock, Hornfels and possibly Silcrete. Raw material was found in abundance

on the farm Zwartkop 369 KQ consisting of Quartzite, Chert, Banded Iron Stone and Rhyolite.

Details of the sites as follows:

Site 2: the site is located on the farm Zwartkop 369 KQ and consists of a high

concentration of artefacts scattered mostly on the northern side of Mooskop. Raw

material is abundant in this area consisting of Quartzite, Chert, Banded Iron Stone and

Rhyolite. Artefacts consist of diagnostic Middle Stone Age tools and includes amongst

other prepared cores and tools with facets on the striking platform. The tools are well

preserved and do not show much weathering and contain clear diagnostic features;

Site 7 and site 9 are located on the farm Moddergat and consist of a medium frequency

of artefacts scattered around small hills close to the Bierspruit. Because of sheet erosion

the artefacts are weathered and badly preserved and not much can be said about them.

Diagnostic features on the tools consist of facets on the striking platform indicating

Middle Stone Age occupation. Raw material consists of igneous rock, Hornfels and

possibly Silcrete

Iron Age Sites

Twenty nine Late Iron Age stone walled sites and one “spot find” site market by cultural material

in the form of undecorated ceramics was on record for the farms Zwartkop 369 KQ, Moddergat

389 KQ and Schildpadsnest 385 KQ. These Late Iron Age remains consist of cattle kraals and

smaller livestock (sheep/goat) enclosures, hut bays, granary platforms, the remains of huts and

other associated features such as ash middens and grinding hollows. Details as follows:

Late Iron Age Complex Sites

Site 1: This site is located on the farm Zwartkop 369 KQ to the east of Mooskop. Recent

mining activities have occurred on site and trace evidence of an Iron Age Site was found

in the vicinity.

Site 2: This site is also located on the farm Zwartkop 369 KQ and is situated on the north

of Mooskop. The site is highly overgrown but fairly well preserved.

Site 4: The site is situated on the farm Moddergat 389 KQ and is located on the eastern

boundary of the farm. The farm road and the construction of power lines impacted

negatively on the site. The site is located on turf soil but several decorated ceramic

fragments were exposed by the impact of the road on the site.

Site 5: The site is situated on the farm Moddergat 389 KQ around a small hill. Finds

include ceramics, cattle enclosures hut bays en grinding hollows.

Site 12: The site is located on the farm Moddergat 389 KQ and consists of several large

cattle enclosures. The site is located on a low running ridge close to the Bierspruit.

Site 17: The site consists of at least six enclosures of approximately 5 -10 meters in

diameter. The site is located on the farm Moddergat 389 KQ

Site 20: The site is located on the farm Schildpadsnest 385 KQ. The site is highly

overgrown and it is not possible to determine layout. This site is of interest because it

might have an outer enclosing wall that so far has not been documented at the other

complex site.

Site 21: The site consists of at least five enclosures with an average diameter of

between 5 -10 meters next to a rock outcrop. The natural rock has been included in the

design. The site is located on the farm Schildpadsnest 385 KQ.

Site 24: The site is located on the farm Schildpadsnest 385 KQ and consist of several

large cattle enclosures.

Site 25: The site is located on a low running ridge at the eastern boundary of the farm

Schildpadsnest 385 KQ and consist of several large cattle enclosures. The farm road

next to fence impacted negatively on the site, destroying several enclosures.

Site 29: The site is located on the farm Schildpadsnest 385 KQ and consists of an

extensive settlement. The site is how ever badly preserved and some of the walling

might have been robbed to construct farm labourer dwellings.

Late Iron Age Simplex Sites

Site 6: The site is located on the farm Moddergat 389 KQ. Two enclosures interpreted as

cattle kraals occur around a small hill. Grinding hollows are found on top of the small

outcrop.

Site 8: The site is located on the farm Moddergat 389 KQ. The site consists of a single

cattle enclosure next to a small rock outcrop close to the Bierspruit.

Site 10: The site consists of badly preserved stone walling around a small rock outcrop

on Moddergat 389 KQ.

Site 11: The site consists of badly preserved stone enclosures located in the saddle of a

small hill on the farm Moddergat 389 KQ.

Site 13: Site 13 is located on the farm Moddergat 389 KQ. The site consists of a cattle

enclosure on a low running ridge next to the Bierspruit.


enclosure and grinding hollows on a low running ridge next to the Bierspruit.


enclosure.

Site 16: Site 16 consists of the well preserved dry stone walls of a cattle enclosure next

to a rock outcrop.

Site 18: The site is located on the farm Moddergat 389 KQ and consists of a cattle kraal

of approximately 20 meters in diameter.

Site 22: The site is located on the farm Schildpadsnest 385 KQ. The site is overgrown

and consists of a large cattle enclosure.

Site 23: The site is located on the farm Schildpadsnest 385 KQ. The site is overgrown

and consists of a large cattle enclosure.

Site 28: The site is located on the western portion of the farm Moddergat far away from

the river. The site is classified as a find spot, consisting of the undecorated ceramic

fragments of two vessels. No other cultural material is present on site.

Site 30: The site is located on the farm Schildpadsnest 385 KQ and consists of

enclosure of approximately 7meter in diameter. The site is badly preserved and some of

the walling has been robbed.

Site 31: The site is located on the farm Schildpadsnest 385 KQ and consists of a badly

preserved enclosure of approximately seven meters in diameter.

Cemeteries

Details of cemeteries as follows:

Site 19: This is the location of a large overgrown cemetery on the farm Zwartkop. The

graves are aligned east west and the grave dressings consist of stone packed graves

and modern • granite headstones. Some of the inscriptions that are visible is of the

family Lehobye and Mpete. The oldest visible date of the deceased is 1921, giving the

impression that some of the graves might be even older. Due to the fact that the site is

so overgrown it was not possible to do an accurate count of the graves but it is

estimated that there are more than 120 graves present;

Site 26: This is the location of a cemetery with a single grave on the farm Moddergat.

The grave is of a child, Danie Groenewald who was born on the 22 June 1938 and

passed away on the 13 July 1938; and

Site 35: This is the location of a large cemetery in Smash Block. The cemetery is located

outside of the impact area of the mine, but is significant because this is where most of

the recently deceased who resided in the study area will be buried.

European Homestead

Several modern structures occured throughout the study area, but these structures were at

most not older than 20 years and were not considered as significant. However, one structure on

the farm Zwartkop 369 KQ was still being used and well preserved. The exact age of the

structure is not certain but based on the architecture it is assumed that the house could be

approaching 60 years and would then be protected by legislation. Details as follows:

Site 27: This is the remains of the demolished farmhouse of the farm Moddergat. The

house was constructed with red sun dried bricks that were plastered. It is assumed that

the structure is associated with the grave at site 26 and it can be deducted that the site

then must be dating to the 1930’s and therefore older than 60 years and protected by

legislation.

Site 37: This is the location of a farm house on a portion of the farm Zwartkop 369 KQ.

The house is still being used and well preserved. The exact age of the structure could

not be determined but based on the architecture it is assumed that the house could be

approaching 60 years

Historic/Recent Mining

The hill on the farm Zwarkop 369 KQ that is called Mooskop was previously mined in the recent

past by other mining entities and at least four disused adits remain of the old mine workings.

The current mining by other mining entities is the re-processing of the stockpiles.

Sensitive Areas Survey

The proposed project area comprises of wetland units in the central parts of the site on portion 8

of the farm Roodedam 368 KQ, and portion 12, 18, and 26 of the farm Zwartkop 369 KQ.

According to the Wetland Assessment Report (Wetland Consulting Services, 2015), two Hydro-

Geomorphic (HGM) units (including a riparian zone) were identified.

These HGM units represent wetlands on the proposed development site according to the

National Wetland Classification System (SANBI, 2009). These HGM units were identified and

delineated based on the procedure as set out in the “A practical field procedure for the

delineation of wetlands and riparian areas” document, developed by Kotze and Marneweck

(1990) and the Department of Water and Sanitation (2005). The following indicators were also

used to identify the wetland features:

Terrain unit indicator

Soil form indicator

Soil wetness indicator, and

Vegetation indicator

The HGM units identified have been classified as follows:

Artificial seepage wetland: HGM unit is located on the central parts of the study site

on portion 18 of the farm Zwartkop 369 KQ. This artificial wetland system has been

formed due to seepage from mining activities located outside the southern boundary of

the central underground mining area. The PES cannot be determined as it depends

upon comparison of the current state of the wetland with its reference or natural state.

However, it was assigned the PES category E, which is, seriously modified due to

artificial source of water, the presence of extensive reed beds which are not

characteristic of other wetlands in the area, as well as the likely impacted water quality

feeding the systems.

Channeled valley bottom wetland: This channeled valley bottom wetland formed

within Bierspruit on portion 26 of the farm Zwartkop 369 KQ is considered to be largely

modified (PES Category D) due to the discharge of water into the system.

Riparian zone draining the artificial seepage wetland: This artificial tributary of the

Bierspruit drains the artificial seepage wetland on portion 12 of the farm Zwartkop 369

KQ. The PES for this stream has been considered to be moderately modified (Category

C).

Riparian zone (unnamed stream) forming a tributary of the Bierpruit: This stream is

located on portion 1 of the farm Middellaagte 382 KQ and portion 8 of the farm

Roodedam 368 KQ. It is considered to be in a moderately modified state with PES at

Category C due to mining activities at Thaba Mine and other catchment activities such

as livestock grazing.

Demographics

The population of Limpopo Province in 2001 was approximately five million people. The

Waterberg District Municipality is located in the western part of the Limpopo province and has

Botswana as its international neighbour. The District Municipality accounts for approximately

twelve percent of the population of the province, and is comprised of six local municipalities;

Belabela, Lephalale, Modimolle, Mogalakwena, Naboomspruit and Thabazimbi. Thabazimbi is

situated in the south-western part of the District Municipality and accounts for about ten percent

of its population. The local municipality includes the towns of Rooiberg, Northam, Leeupoort,

Thabazimbi and Dwaalboom.

Ward three is one of the largest wards in the Local Municipality, but accounted for only about

ten percent of its population in 2001. Although Ward four is only about a quarter of the size of

ward three, its population in 2001 was roughly the same, thus implying a significantly greater

average population density. A significant proportion of this population is accounted for by

households situated on the outskirts of the town of Thabazimbi, which is situated just outside

the ward at its northern border. The remainder of the population is mostly accounted for by the

residents of surrounding farms.

Ward six is one of the smallest wards in the Local Municipality, but accounted for about six

percent of its population; its population density is some 50 times greater than that of Ward three.

This high population is mostly accounted for by the residents of Amandelbult Mine Village,

which is situated to the east of Amandelbult Mine on the opposite side of the R510.

Ward eight is situated to the south and east of the proposed project site. Both in terms of

surface area and population, it is about four times the size of ward six, which implies that it has

a similar average population density. However, most of this population is accounted for by

Smash Block; if this informal settlement is considered on its own, division of its population by its

surface area yields a population density some 30 times greater than that of ward six. Such

conditions are fairly typical of informal settlements, but nonetheless pose risks for their

inhabitants in terms of the spread of disease, fire hazard and social pathologies associated with

overcrowding.

The age distributions of the populations of Smash Block and wards three, four, six and eight

were compared with those of the local and district municipalities and the province. The Limpopo

Province and Waterberg District Municipality as a whole have age distributions that are typical

of populations with a high growth rate, in that the largest proportions of the population are found

in the youngest age brackets. Thabazimbi Municipality and the wards in the study area differ

from this profile, however, in that the largest proportion of their populations was concentrated in

the 20-29 year age bracket. The economy of the northern region of Limpopo Province was and

still is based on trading, game farming, cattle farming, while mining still is the major economic

activity in the south-western region, which includes the Thabazimbi Local Municipality. The local

municipal area is rich in mineral wealth, with iron, platinum and nickel among the key products.

The importance of its mining sector was reflected in the fact that Thabazimbi Local Municipality

alone accounts for about six percent of the national employment figures in mining. There are a

number of platinum-producing mines in the vicinity of the proposed project, including Northam

Platinum Mine, and the Anglo Platinum operations of Amandelbult and Union Mines. Other

minerals produced in the area include:

Andalusite, which was mined at the Rhino Andalusite Mine of Trollope Mining

Services; and

Limestone for the production of cement, which was mined by Pretoria Portland

Cement at Dwaalboom Palygorskite.

Apart from mining, agriculture constituted an important part of community life and economic

activities in the local municipality. Farming activities in the area included crops, livestock and

game farming (hunting and game ranches); these made a substantial contribution to the local

municipality’s gross geographic product, and were becoming increasingly popular.

Approximately 40 percent of the land situated within the municipal area was utilised for game

farming, two percent for irrigated cultivation and three percent for dry-land farming, of the

remaining area, most was used for extensive cattle farming (Thabazimbi Local Municipality,

2008)

(d) Environmental and current land use map. (Show all environmental, and current land use features)

(v) Impacts and risks identified including the nature, significance, consequence, extent, duration and probability of the impacts, including the degree to which these impacts

(Provide a list of the potential impacts identified of the activities described in the initial site

layout that will be undertaken, as informed by both the typical known impacts of such

activities, and as informed by the consultations with affected parties together with the

significance, probability, and duration of the impacts. Please indicate the extent to which they

can be reversed, the extent to which they may cause irreplaceable loss of resources, and can

be avoided, managed or mitigated).

Construction Phase:

Geology

Impact Assessment

Access to the underground chrome and PGM reserves will be via three declines at various locations

consisting of a downcast conveyor belt, a downcast chairlift and material decline. The excavation and

construction of the portals and associated declines will affect the geological strata. Soil and overburden

from these excavations will be stockpiled adjacent to the shaft for rehabilitation at closure. Negative

impacts associated with construction on the geology as a result of underground mining will definitely be of a short term SLIGHT intensity and of a low significance due to the restricted location of these

structures. The impact however, will be site specific and no impact is expected beyond the site

boundary. Impacts on the geology as a result of opencast mining will definitely be of an INTENSE

intensity and of a high significance, as the impacts will take place on a frequent basis and are long

term due to the fact that opencast mining will require the removal of the overburden to get to the ore

resource in addition to the removal of the ore resource. The impact however, will be site specific and no

impact is expected beyond the site boundary. The placement of surface infrastructure will definitely have no impact on the geology as the impact of infrastructure will be limited to the surface area. Only

vegetation and soils will be removed for the surface infrastructure. The cumulative impacts on the

geology with regards to construction will definitely be of an INTENSE intensity and of a high significance, as the impacts will take place on a continuous basis and are long term. The impacts will

be site specific and no impact is expected beyond the site boundary.

Residual Impact

The residual impact will be the same as the original impact assessment as there will be no mitigation

undertaken.

Topography

Impact Assessment

Changes to the topography of the areas where surface infrastructure is situated will include the

excavation of the shaft/portal areas, foundations, the the clean and dirty dams, canals, berms,

processing plants, stockpiling of overburden and soil and the tailings storage facilities. The cumulative

negative impact of these activities on the site specific topography will definitely be medium in the

medium to long term and of an INTENSE severity. The overall impact of these activities on the

topography will definitely be medium to high in the medium term and of an INTENSE severity. There

will be NO impact on the topography due to underground mining activities. Although the impacts for

Thaba Cronimet Chrome Mine will be site specific, there are multiple mining operations in the area and

the cumulative impact on the topography of the area will probably be medium in the long term.

Residual Impact

The residual impact will be the same as the original impact assessment as there will be little to impact

realized from the mitigation undertaken. The impact of mitigation will be significant in the operational,

decommissioning and closure phase.

Waste Management and Hazardous Substances

Impact Assessment

The impacts associated with waste management and hazardous substances handling include

legal non-compliance, potential soil and water contamination and lost opportunities for waste

recycling. Without mitigation, the negative impacts, of high probability certainty, are expected

to take place on a frequent basis and the duration of impacts are expected to be short term in

nature. The impacts, although varying in nature can be described at a worse-case scenario of

having a MODERATELY INTENSE severity as should the impact take place, the mitigation

measures are generally cost effective and easy to implement. The impacts thus associated for

mining and processing activities are expected to be (site specific), without mitigation of a

medium significance.

Residual Impacts

The residual impact is expected to be rated as a low negative significance if mitigation measures are

implemented as the intensity, certainty and the frequency of the impacts should decrease.

Soil, Land Use and Land Capability

Impact Assessment

The main impacts associated with the construction phase are soil compaction and topsoil loss leading

to reduced fertility, soil loss as a result of wind and water erosion and sediment release to land and

water (by removing vegetation); alteration of natural drainage lines; and the change of land use from

natural vegetation and agriculture (livestock grazing) to industrial within the planned development areas

of the proposed project. Limited impacts are expected outside of the mineral rights area, thus on a

local basis, with the exception along unpaved service roads within the region, where erosion can impact

on adjacent areas. These impacts will definitely occur and are expected on a frequent basis. They will

be permanent in duration, but significance of the impact will decrease when disturbed areas are

rehabilitated and re-vegetated during decommissioning of the mining infrastructure. Intensity will range

from MODERATELY INTENSE to INTENSE as natural functions of the soil will be altered. Impact

significance without mitigation will be high given the extent of the area affected.

Residue Impact

Much of the impacts to soil and land capability can be mitigated to a medium or low significance

because the certainty, intensity and duration of the impact will decrease. The impact of sterilisation on

the land will however not decrease and will remain high.

Flora and Fauna

Impact Assessment

Flora

Vegetation clearing associated with opencast mining and the construction of the surface infrastructure

for the mine will cause a disturbance and destruction to the flora ecosystem. The expected impacts are

fragmentation of the habitat, reduction in the extent of a habitat, destruction of rare, endangered,

endemic and protected species, the establishment and spread of declared weeds and alien invasives

and an increased risk of veld fires causing loss and damage to the natural vegetation. The certainty of

the impact is definite as flora will be removed or disturbed, and will be on a continuous basis. There

are also four protected tress species on site. The expected impact without mitigation will be of a VERY

INTENSE intensity, permanent and on a site specific to local basis. The rating prior to mitigation is

high negative. Removal of vegetation in the greater area has a low probability to lead to a decrease

in the carbon sink potential of the area which may have a high impact in the long term due to the

increased carbon emissions from mining related activities. In addition, the disturbance in the area will

lead to an influx of disturbance species and hence a loss in biodiversity.

Fauna

Vegetation clearing, habitat fragmentation and loss and increased human activity associated with

opencast mining and the construction of the surface infrastructure for the mine will cause a disturbance

and destruction to the fauna ecosystem. The certainty of the impact is definite as natural fauna will not

stay in the area. The expected impact without mitigation will be of a VERY INTENSE intensity,

permanent and on a site specific to local basis. The rating prior to mitigation is high negative.

Residual Impact

The residual impact will be of a medium significant rating, as the certainty, duration and intensity of the

impact will decrease due to mitigation

Noise

Impact Assessment

The environment is characterised by the presence of numerous mining operations. Therefore, the

current and proposed operations will not present a new type of source to it. Noise is in its very nature a

negative impact. The extent of the noise impacts, which will probably occur, will remain local and very

much centred around the activities. Construction will be continuous , but mainly limited to day-time

activities. Due to their limited extents and the long distances to noise sensitive receptors the severity of

the noise impacts will be SLIGHT. Due to the above considerations and the fact that the noise impacts

will be much reduced during night-time the significance of the noise impact is rated as low.

Residual Impact

The residual impact will remain as a low significance post mitigation measures.

Vibrations

Impact Assessment

Two impacts have essentially been identified for the construction phase, namely structural damage and

human discomfort. With regards to the general detrimental effect of blasting vibrations on structures,

due to the proximity to a number of structures and the use of blasting during construction of opencast

and underground mining activities, the expected vibrations yield a probable certainty to structural

damage. Typical blasting activities are expected to occur on a weekly basis and so the frequency of the

impact is classified as frequent. The vibrations from blasting is attenuated as distance increases from

the site of blasting. Only buildings within the mining boundary are likely to be threatened by blasting

damage – spatial impact is therefore classified as site specific. For the vulnerable buildings identified

(locations 7, 9, 11, 18 and 19) damage is expected to be cracked buildings. This is deemed to be a

marked deterioration and is classified as INTENSE. The construction activities are not expected to last

for more than 10 years, therefore the duration is classified as short-term. These factors combine to

yield a Medium negative rating.

Due to the proximity to the community and the use of blasting during construction of opencast

operations and underground mining activities, the expected vibrations yield a highly probable certainty

to human discomfort (this is a higher rating than for structures, as typical vibration levels for discomfort

are much less than for damage to structures. Typical blasting activities are expected to occur on a

weekly basis and so the frequency of the impact is classified as frequent. The vibrations from blasting

are attenuated as distance increases from the site of blasting. Humans outside the mining area may

experience vibration levels high enough to cause discomfort (even though buildings outside this area

may not be affected) – spatial impact is therefore classified as local. Human beings may find

themselves near enough to blasting zones to cause severe discomfort from the vibrations. This is

deemed to be a substation deterioration of human discomfort and is classified as VERY INTENSE. The

construction activities are not expected to last for more than 10 years, therefore the duration is

classified as short-term. These factors combine to yield a medium negative rating.

Residual Impact

Taking into consideration the above stipulated mitigation measures, for both the structural damage and

human discomfort, the rating of both the certainty and the intensity of the impacts from blasting will

decrease resulting in both of the impacts rated as low negative impacts.

Air QualityImpact Assessment

During construction the main dust generating sources will be vehicle activity on unpaved roads and

vegetation clearing and soil stripping for placement of the surface infrastructure. The dust generating

impacts will be improbable and on short term basis as the activities are intermittent in duration and the

construction period will be no longer than five years. The impact will be occasional as activities are not

continuous. The impact will be confined to the site and are expected to be SLIGHT in severity. The pre-

mitigated impact will be low in significance

Residual Impact

The residual impact will not change significantly from the impact pre-mitigation as the significance will

still remain low.

Surface Water

Impact Assessment

There are many surface water impacts that can be expected from the current and the proposed

opencast and underground mining operations, processing activities and associated infrastructure.

Impacts on surface water include the further decrease in the catchment yield, denuded areas are prone

to sheet erosion with resultant increased sediment load to the receiving environment and dust during

periods of high winds. Impacts will also include potential pollution by hazardous substances including

oil and diesel which in turn may pollute storm water which may affect the surrounding water regime.

Poor sanitation and poor storm water management as per the GN 704 requirements are more potential

impacts which may alter surface water quality.

Decrease in Catchment Yield

During the construction phase the impacts associated with the decrease in catchment yield for

opencast and underground mining and surface infrastructure will be of a short term nature as

construction activities will be less than ten years in duration and will be contained within the mineral

lease area. The certainty of the reduction of the surface water yield is highly probable but will most

likely only take place during rainy seasons, thus occasional to frequent in the winter and summer

months respectively. The severity is expected to be SLIGHT as the impacts are short lived and are

easily rectified through mitigation measures. Thus for the surface infrastructure, mining operations and

processing plants, the impact rating without mitigation will be low as the impacted areas and the

quantity of water which is extracted from the larger catchment area is negligible.

Effects on Water Quality

During the construction phase the impacts associated with the decrease in water quality for opencast

and underground mining and surface infrastructure will be of a short term nature as construction

activities will be less than ten years in duration. The impact on surface water qualities will be contained

within the mineral lease area. The certainty of the impact on surface water quality without mitigation

measures is definite due to the fact that contaminants/sediments will flow with storm water away from

the site of contamination. The severity is expected to be SLIGHT as the topography is generally flat

and the rainfall is low and mitigation measures will be easy and inexpensive to implement. The impact

will occur on a daily basis without mitigation measures. Thus for the surface infrastructure, mining

operations and processing plants, the rating for surface water quality impacts without mitigation will be

of a medium significance.

Residual Impacts


The impact for the decrease in catchment yield for the surface infrastructure, mining operations and

processing plants, post mitigation will remain low.

Effects On Water Quality

The impact on the water quality for the surface infrastructure, mining operations and processing plants,

post mitigation will decrease to a medium significance.

Ground WaterImpact Assessment

The potential impacts on ground water during construction phase include impacts on the availability of

ground water, ground water quality and the impact on the external user’s ground water quantity and

quality.

Impact On The Availability Of Ground Water

The impact on groundwater availability in the aquifer around the shaft construction sites will be small,

since groundwater flow towards the shaft will be a time-limited event. The maximum expected volume

of flow is 11 m3/day (average 4 m3/day, as described in the Baseline report), while the resultant cones

of depression will only reach a maximum radius of 20 m. The groundwater regime also shows seasonal

fluctuations in groundwater levels (according to WARMS data). Construction in post-winter months can

result in low to now-flow conditions. The shaft walls will be sealed as construction continues,

preventing significant inflows of groundwater into the shaft complex. After construction is completed,

the total shaft perimeter will be sealed off. No groundwater flow will take place to the mine workings via

the shaft due to operational and safety reasons. The construction of the processing plants and the

tailings storage facility footprints will have no impact on groundwater availability. No activity during the

construction phase will result in the increase or decrease in water resources below or around the

footprint. The construction of shafts and portals for underground mining will have an improbable low negative impact on groundwater availability of the area in The construction of box cuts will have a

definite low negative impact on groundwater availability of the area in the short term of a SLIGHT

intensity due to the restricted extents of the cones of depression. Cumulatively the impact on ground

water availability will be of a low negative impact in the short term of a SLIGHT intensity due to the

restricted locations.

Impact on Ground Water Quality

Groundwater entering the box cuts and shafts/portals will come in contact with the shaft perimeters and

mine floor. Deterioration in groundwater quality is expected to be limited to an increase in suspended

solids. Further to this, no additional impact is expected because of:

The small volumes of water entering the shafts and box cuts.

The un-impacted quality of groundwater entering the pit (elements like Mg are naturally

elevated and not an indication of pollution).

The short contact time of groundwater with the shaft walls and pit floors.

The natural buffering capacity of the groundwater.

The increase in suspended solids should not deteriorate the groundwater to qualities deemed non-

compliant to fitness-for-use standards, or the water quality objectives for the catchment. Any

groundwater resource at the shafts or tailings storage facilities that is considered polluted must be

disposed in polluted water facilities. The construction of shafts and portals for underground mining will

have an improbable low negative impact on groundwater quality of the area in the short term of a

SLIGHT intensity due to the restricted location of this structure and the low probability of pollution. The

impact will be restricted to the immediate area around the shafts / portals.

Impact On External Users Groundwater Quantity And Quality

During the construction phase, no activites will result in extensive drawdown of any aquifer zones at the

shaft complexes or the processing plant footprints. The maximum cone of dewatering around the box

cuts and the shaft complex is less than 50 m and thus the impact will be low prop. No registered

external user will at this stage be impacted. The construction of the box cuts, shaft complexes and the

processing plant will have definitely have a low significant impact on external user’s boreholes during

the construction phase (short term). The impacts will be restricted to site specific conditions and will be

of a SLIGHT intensity.

Residual Impacts

The ratings for the impacts on ground water during construction would remain unchanged at low significant status post mitigation. It is however to be noticed that for many of the impacts, the ratings for

the criteria certainty and frequency would decrease. As the initial cumulative rating for pre-mitigation

was already low, the mitigation measures would not be able to reduce that any further.

WetlandsImpact Assessment

Impacts associated with wetlands during the construction phase may include direct loss and

disturbance of wetland habitat; increased sedimentation within the wetlands due to sediment

rich runoff from the construction site, also leading to increased turbidity; obstruction of flows,

increased risk of erosion and water quality deterioration

All approved and proposed surface infrastructure associated with the underground mining, i.e.

the underground portals (shafts), the decline box cut and the central surface area (including

explosives magazine) will be located outside delineated wetland habitat and in fact more than

500m from any delineated wetland habitat. Given the flat nature of the terrain, it is our opinion

that the construction of the surface infrastructures will not result in any significant impact to the

wetlands. Without this mitigation, the impact of surface infrastructure on wetlands would highly probably to definitely result in a MODERATELY INTENSE frequent impact on a short terms

basis. Thus the impact without mitigation would range between low to medium significance.

The proposed underground mining will extend under the upper reach of the Trollope wetland

system, which is considered an artificial wetland. It is understood that underground mining will

be undertaken at depth, and that no surface subsidence is expected – the proposed opencast

mining and stockpiles located over the underground mining area attest to this. As a result, the

underground mining is not expected to have any impact on surface flows or on the shallow,

unconfined aquifer. As such, it is improbable that a low negative impact on an occasional basis

(local extent) to the wetlands is expected due to the proposed underground mining.

Both the proposed chrome plant and the PGM plant are located within an existing disturbed

footprint within an existing dirty water area of the mine. Both plants will also be located more

than 500m from the Anglo wetland area. These activities are therefore expected to have NO

impact on the wetlands on site. The proposed tailings storage facility extension is also located

well away from the Anglo wetland system, with approximately 300m separating the proposed

footprint from the delineated wetland boundary at its nearest point. The return water dam will

also be approximately 400m from the delineated wetland edge. There is thus a low probability

of negative impacts to the wetlands on an occasional and short term basis, which may have an

impact locally. The impacts, without mitigation are expected to have a MODERATELY INTENSE

significance. The anticipated impacts, without mitigation are expected to have low significant

ratings, with the most significant being the seepage of water out of the tailings storage facility

and return water dam leading to increased flows in the adjacent wetland area and possibly the

formation of a new artificial seepage wetland area.

With regards to cumulative impacts during the construction phase to general degradation of

wetland habitat, the anticipated impact pre-mitigation is expected to be definite and occurring

on a continuous basis, with impacts potentially extending beyond the mineral lease area (local).

The impact is expected to be of INTENSE severity as significant degradation to wetland habitat

will take place resulting to habitat loss in some places. The impacts will remain long term. The

resultant cumulative impact will thus be high negative.

Residual Impact

On a cumulative basis, with proposed mitigation measures in place, it can be expected that the rating of

the impacts will decrease to a medium significance due to the decrease in frequency, intensity and

extent of the impact.

ArchaeologyImpact Assessment

The potential impact associated with pre-construction and construction activities for the proposed

additional mining and processing activities and associated infrastructure is that Iron Age and Stone Age

sites will be destroyed. Without mitigation, the anticipated negative impact will be probable and

permanent as damage to heritage sites is irreversible. The significance of the impact is expected to be

VERY INTENSE as it is of a permanent nature. The destruction of the sites will impact on the

archaeological record of the area (thus local extent). Thus the expected impact without mitigation will

be high negative

Residual Impact

The residual impact will probably be of a low significant nature on a regional basis, SLIGHT in

intensity and in the short term as construction will not be longer than ten years in duration.

Traffic

Impact Assessment

The proposed access roads to Thaba Cronimet Chrome Mine are located approximately 17 km, from

Northam and 30 km from Thabazimbi respectively. Although the anticipated additional vehicles on the

road as a result of the operations will probably be low, the traffic to and from Northam will be affected

as well as that to and from Thabazimbi on a frequent daily basis. The impact will be of a SLIGHT

intensity and will be on a regional basis. The intersections operate as T-junctions and disruption to peak

hour (morning and afternoon) vehicle traffic flow will occur. It is therefore preferable to restrict mine

construction traffic to the off-peak hours, to minimize the impact on the traffic flows on the public roads

in the vicinity of the mine. Additional impacts associated with traffic expected during the construction

phase will be dust generation and noise generation.

Residual Impact


intensity and in the short term as construction will not be longer than ten years in duration.

VisualImpact Assessment

It is highly probable that there would be impacts an aesthetic quality and sense of place during the

construction phase. The frequency of occurrence of these impacts would range between on a

continuous and on a daily basis. The spatial extent of the impacts would all be regional, within 50 km

from the mineral lease area as in some instances these could be seen from such a distance. The

duration of the impacts of the construction phase would be in the short term (less than 10 years). The

intensity of the construction phase impacts are anticipated to be MODERATE and the significant rating

of medium. The cumulative visual impact in the area will probably be of a medium significance and in

the short term, as the area is already comprised of mining activity infrastructure, desensitizing the

viewer from the visual impact.

Residual Impact

The residual impact will remain at a medium significance level

Socio-EconomicImpacts during the construction phase on socio-economic conditions include the effects of the project

on the local economy (including job creation, multiplier effects on the local economy, etc.); impacts

related to the effects of the project on the physical environment (such as safety impacts arising from

increased traffic, visual, acoustic and air quality impacts, etc.); and impacts related to an influx of

workers and job-seekers (such as an increase in social pathologies, etc.)

Job Creation

Job creation will be a highly probable low positive impact that will extend to the short term as

construction period is approximately five years in length. The majority of the construction workers will

be contract positions, thus the impact will be of a SLIGHT intensity and the extent of the impact will be

site specific as most of the positions will be filled by people living in the local municipal area

Multiplier effects on local economy

Multiplier effects on the local economy will be a low probability low significant positive impact that will

depend on the proportion of local spending by employees and availability local enterprises to supply

required goods/services. The impact which is expected to be of a MODERATELY INTENSE severity

will take place on an occasional basis and will continue through the construction phase (short term) and

will extend locally as the impact will include micro and macroeconomic elements.

Continued Corporate Investment In Host Communities

Continued corporate investment in host communities will be a low probability low significant positive

impact that without appropriate mitigation, forecasts of local infrastructure development might not be

achieved. The impact which is expected to be of a MODERATELY INTENSE severity as it may result in

much required access to services will take place on an occasional basis and will continue through the

construction period (short term) and will extend locally as the impact will affect surrounding

communities.

Physical Intrusion

It is expected that physical intrusion, a negative impact, will be highly probable and on a continuous

basis if mitigation measures are not implemented. The impact will be on a regional and short term scale

as the impact will continue throughout the construction phase. The severity is expected to be INTENSE

as this impact could negatively impact on quality of life. The impact is thus rated as high negative

significance.

Increased Social Pathologies

It is expected that increased pathologies, a negative impact, will be a low probability and on a

frequent basis if mitigation measures are not implemented. The impact will be on a local scale and the

effects will extend beyond the operational phase of the mine and may be permanent. The severity is

expected to be INTENSE as this impact could severely affect well-being of communities, especially as

cumulative impact combining with existing effects of other mining operations in the area. The impact is

thus rated as medium negative significance.

Increased Pressure on Resources and Services

It is expected that increased pressure on resources and services in the local area will probably be a

MODERATLEY INTENSE severity as backlogs already occur in the municipal area. It is expected that

without mitigation, the impact would take place on a frequent basis and may be of a medium term

duration as impacts will probably persist post construction. The impact is thus rated as medium negative significance

Residual Impacts

The ratings of the positive impact will be increased from a low positive to a medium positive if mitigation

measures as outlined above are implemented. With mitigation measures, the negative impacts will move

from either high to low in the case of physical intrusions or medium to low due to the intensity of the

impact reducing.

Operational Phase

Geology

Impact Assessment

Impacts on the geology as a result of opencast mining will definitely be of a INTENSE severity and of a

high significance, as the impacts will take place on a continuous basis and are long term due to the fact

that opencast mining will require the removal of the overburden to get to the ore resource in addition to

the removal of the ore resource. The impact however, will be site specific and no impact is expected

beyond the site boundary. Impacts on the geology as a result of underground mining will definitely be

of a MODERATELY SEVERE intensity and of a high significance, as the impacts will take place on a

continuous basis and are long term due to the fact that underground mining will require the removal of

the ore resource. The impact however, will be site specific and no impact is expected beyond the site

boundary. The placement of surface infrastructure will have no impact on the geology as the impact of

infrastructure will be limited to the surface area.

The cumulative impacts on the geology will definitely be of an INTENSE severity and of a high significance, as the impacts will take place on a continuous basis and are long term. The impacts will

be site specific and no impact is expected beyond the site boundary. It is proposed that specialist

geochemistry investigations be undertaken to further investigate the impacts of the geology (waste rock

deposits) on the environment and the identification of mitigation measures.

Residual Impact

The residual impact will be the same as the original impact assessment as there will be no mitigation

undertaken. The impacts associated with waste management and hazardous substances handling

include legal non-compliance, potential soil and water contamination and lost opportunities for waste

recycling. Without mitigation, the negative impacts, of high probability certainty, are expected to take

place on a frequent basis and the duration of impacts are expected to be short term in nature. The

impacts, although varying in nature can be described at a worse-case scenario of having a

MODERATELY INTENSE severity as should the impact take place, the mitigation measures are

generally cost effective and easy to implement. The impacts thus associated for mining and processing

activities are expected to be, without mitigation of a medium significance. The residual impact is

expected to be rated as a low negative significance if mitigation measures are implemented as the

intensity, certainty and the frequency of the impacts should decrease.

Soil, Land Use and Land CapabilityImpact Assessment

The main impacts associated with the operational phase are soil compaction and topsoil loss leading to

reduced fertility, soil loss as a result of wind and water erosion and sediment release to land and water

(by removing vegetation); alteration of natural drainage lines; and the change of land use from natural

vegetation and agriculture (livestock grazing) to industrial within the planned development areas of the

proposed project. Limited impacts are expected outside of the mineral rights area, thus on a local

basis, with the exception along unpaved service roads within the region, where erosion can impact on

adjacent areas. These impacts will definitely occur and are expected on a frequent basis. They will be

permanent in duration, but significance of the impact will decrease when disturbed areas are

rehabilitated and re-vegetated during decommissioning of the mining infrastructure. Intensity will range

from MODERATELY INTENSE to INTENSE as natural functions of the soil will be altered. Impact

significance without mitigation will be high given the extent of the area affected.

Residue Impact


because the certainty, intensity and duration of the impact will decrease. The impact of sterilisation on

the land will however not decrease and will remain high.

Flora and FaunaImpact Assessment

Flora

Opencast operations and the footprints of the tailings storage facility and surface infrastructure for the

mine will cause a disturbance and destruction to the flora ecosystem. The expected impacts are

fragmentation of the habitat, reduction in the extent of a habitat, destruction of rare, endangered,

endemic and protected species, the establishment and spread of declared weeds and alien invasives

and an increased risk of veld fires causing loss and damage to the natural vegetation. Due to the

nature of the opencast operations, the certainty of the impact is definite as flora will be removed or

disturbed, and will be on a continuous basis. The expected impact without mitigation will be of a VERY

INTENSE intensity, permanent and on a site specific to local basis. The rating prior to mitigation is

high negative. Removal of vegetation in the greater area has a low probability to lead to a decrease

in the carbon sink potential of the area which may have a high impact in the long term due to the

increased carbon emissions from mining related activities. In addition, the disturbance in the area will

lead to an influx of disturbance species and hence a loss in biodiversity.

Fauna

Vegetation clearing, habitat fragmentation and loss and increased human activity associated with

opencast mining will cause a disturbance and destruction to the fauna ecosystem. The certainty of the

impact is definite as natural fauna will not stay in the area. The expected impact without mitigation will

be of a VERY INTENSE intensity, permanent and on a site specific to local basis. The rating prior to

mitigation is high negative.

Residual Impact

The residual impact will be of a medium significant rating, as the certainty, duration and intensity of the

impact will decrease due to mitigation

NoiseImpact Assessment

Noise is in its very nature a negative impact. The extent of the noise impacts during the operational

phase will remain local and very much centred around the activities (site specific). Underground

operations will have no effect on above ground ambient noise levels. Open cast operations will be

continuous but will only take place during day-time. Occurrence of noise impacts for opencast mining is

probable. Due to their limited extents and the long distances to noise sensitive receptors the severity of

the noise impacts will be SLIGHT. Due to the above considerations and the fact that the noise impacts

will be much reduced during night-time the significance of the noise impact is rated low.

Residual Impact


VibrationsImpact Assessment

Two impacts have essentially been identified for the operational phase, namely structural damage and

human discomfort. Due to the proximity to a number of structures and the use of blasting during

construction of OC and underground mining activities, the expected vibrations yield a probable certainty to structural damage. Typical blasting activities is expected to occur on a weekly basis and so

the frequency of the impact is classified as frequent. The vibrations from blasting are attenuated as

distance increases from the site of blasting. Only buildings within the mining boundary are likely to be

threatened by blasting damage – spatial impact is therefore classified as site specific. For the

vulnerable buildings identified (locations 7, 9, 11, 18 and 19) damage is expected to be cracked

buildings. This is deemed to be a marked deterioration and is classified as INTENSE. These aspects to

the impact will be present for the operation life of the mine and is classified as medium-term. These

factors combine to yield a medium negative rating.

Due to the proximity to the community and the use of blasting during construction of opencast and

underground mining activities, the expected vibrations yield a highly probable certainty to human

discomfort (this is a higher rating than for structures, as typical vibration levels for discomfort are much

less than for damage to structures). Typical blasting activities is expected to occur on a weekly basis

and so the frequency of the impact is classified as frequent. The vibrations from blasting are attenuated

as distance increases from the site of blasting. Humans outside the mining area may experience

vibration levels high enough to cause discomfort (even though buildings outside this area may not be

affected) – spatial impact is therefore classified as local. Human beings may find themselves near

enough to blasting zones to cause severe discomfort from the vibrations. This is deemed to be a

substation deterioration of human discomfort and is classified as VERY INTENSE. These aspects to

the impact will be present for the operation life of the mine and is classified as medium-term. These

factors combine to yield a medium negative rating.

Residual Impacts


The impact for the decrease in catchment yield for the surface infrastructure, mining operations

and processing plants, post mitigation will be reduced to low.

Effects on Water Quality

The impact on the water quality for the surface infrastructure, mining operations and processing plants,

post mitigation will decrease to a medium significance.

Ground Water

Impact Assessment

Influx of ground water into mine workings

The natural recharge of rainfall from surface to deep level mining is very low. This is due to the

geohydrological regime, where shallow weathered Pyroxenite/Gabbro/Norite aquifers essentially have

horizontal discharge of rainfall recharge. The vertical permeability to the deep, fractured

Pyroxenite/Gabbro/Norite aquifer is an order of magnitude smaller than the horizontal component.

During underground mining the only significant influxes of groundwater to mine workings will occur with

the intersection of preferential groundwater flow zones (dykes or fissures).

Known geological features were investigated over the study area. The main geological features are two

north-south striking fault zones in the northern part of the study area. Although these features can act

as preferential flow zones near surface (<100 m), the water yielding capacity decreases dramatically in

depth due to high pressure conditions. The quantity and water bearing capacity of deep level fissures

are not known at this stage. These are normally features that are encountered during operational phase

activities. The water yielding capacity of these individual features vary between 10 m3/day and 200

m3/day. Prior to mining it is basically impossible to identify the position, strike, extent and yield of these

features.

Therefore, the water make to be expected does not pose a threat to operational phase safety and

production and all water make is incorporated into the operational phase water balance. In the table

below the total influx of groundwater expected in a steady state environment are indicated.

Table 2:1 Groundwater Influx for A Steady State Environment.

Mining ScheduleTotal

Mining Area (Ha)

Natural Groundwater Recharge (M3/Day)

Maximum Influx From Fissures*

(M3/Day)Year 1 2 0.6 0

Year 5 22 7 100

Year 10 135 37 100 - 200

Year 20 342 92 100 – 400

Year 30 478 128 200 - 600

Year 34 (LOM) 503 134 200 - 900

*Assuming a fissure/fault density of 1/100 ha of mining area, with variable water make of

10-200 m3/day.

From the table above it is evident that a single mining fissure can yield more water make than the total

mining area. Underground mining activities will have a low negative impact on groundwater availability

of the site in the long term due to the low recharge characteristics of deep mining activities in the area.

The impact will take place frequently and will be of an INTENSE severity. The water make from the fault

zones will be handled as part of the operational phase water balance.

Water influx into opencast workings will consist of water accruing from rainfall events, release of

groundwater stored in saturated nits and groundwater influx through pit walls. Rainfall will accrue on

active (open) cuts and onto rehabilitated sections of the open casts. The following rainfall data was

used in calculating volumes.

Table 2.2: Rainfall data for the study area.Oct Nov Dec Jan Feb Mar Apr May Jun Jul Aug Sep Total*

Mm 52 88 101 128 91 86 41 14 6 4 4 13 627*Based in rainfall data from 3 nearest stations, 30 year data.

The release of groundwater stored in saturated units takes place from a depth of the first level where

groundwater is intersected, up to the maximum depth of mining. In the case of Thaba Cronimet

Chrome Mine an average water level of 22 m below surface is used. The maximum indicated depth of

mining is 65 m. Therefore, the maximum saturated thickness of aquifer units is 43 m. Also, not all

interstitial groundwater is released during blasting activities. Groundwater make below a depth of 30m

is typically an order of magnitude lower than what is expected in the shallow weathered zone

aquifer. . The permeability of un-weathered pyroxenite aquifers was taken under low gradient

conditions (low level of drawdown) and the volume of flux was calculated.

From the baseline study (2010) it is evident that the groundwater component decrease on a relative

basis from the start of mining towards the end of life of mine. During the first year the groundwater

component is 39% of the total water balance, decreasing to 16% at the end of mining. Opencast

mining activities will have a low negative impact on groundwater availability within the site area in the

long term due to the small areas affected. The certainty of the impact expected will be low probability and will occur on a frequent basis with a MODERATELY INTENSE severity. Relatively deep water

tables mean that a small volume of water is released from storage, and the expected cone of

dewatering will remain small. The water make from the dykes/fault zones will be handled as part of the

operational phase water balance.

Depletion Of External Users Groundwater Resources And Fountains

A number of groundwater users were identified during the 2009 hydrocensus, with farms Zwartkop and

Moddergat being the closest to the proposed underground mining activities. The majority of the

boreholes identified on farms closer to the activities were drilled for the purposes of monitoring (at

Amandelbult section). Due to the nature of deep level mining activities, no impact on the groundwater

quality or quantity of the external user’s boreholes are expected. The only borehole that can be

affected by opencast mining activities is borehole ZP -11, adjacent to Pit ML2. According to

hydrocensus data this borehole is registered to Trollope Mining services. This borehole will be

commissioned by Thaba Cronimet Chrome Mine, once mining activities start. No other external user’s

borehole is in a radius of 500 m from opencast activities.

Underground mining activities will have a low impact on groundwater availability of external users

boreholes in the long term due to the low recharge characteristics of deep mining activities in the area

and the absence of users close to opencast activities. The impact will occur infrequently and will be of

a MODERATE INTENSITY. Opencast operations will have a medium significant rating on

groundwater availability of external users boreholes in the immediate vicinity in the long term due to

the low, but continuous recharge characteristics of deep mining activities in the area and the absence

of users close to opencast activities. There is a low probability of the impact which will have a

MODERATE INTENSITY severity.

Deterioration of Groundwater Quality In The Mining Section And Seepage Into The Receiving

Environment

Groundwater draining into the underground mine workings from natural recharge will be of a good to

marginal quality, due to naturally elevated cations (Mg). Fissure/fault water make is normally of a

poorer quality due to natural elevated salt loads. In addition to that, certain mining activities can add

pollutants to the water. The total underground water make will therefore consist of a combination of the

following:

Natural recharge from the Pyroxenite/Gabbro/Norite fractured aquifer. The water

quality will emulate the natural background groundwater quality, with an alkaline pH

and total dissolved solids (TDS) values of 400-500 mg/l.

Recharge from fissures/major fault zones normally contains elevated values for Na and

Cl. Other parameters like F and SO4 can also be elevated. The expected pH is neutral,

with TDS ranging between 1000 and 2000 mg/l. Underground blasting activities have a

residual NO3 component. Due to continuous recycling of underground process water,

the NO3 levels can be concentrated above 500 mg/l.

Different sections of the mine will have a variable combination of the three different

sources quoted above.

The mining sections will be operated on a dry basis and all excess water will be used in the

mining process, or pumped to the process plant. Therefore no impact can arise from migrating

water from the mining sections. Underground mining activities will have a medium negative

impact on groundwater quality of the local area in the long term due to poorer quality expected

from fault zones and operational impacts. The impact will have a probable certainty, frequent

occurrence and will be of an INTENSE severity.

Table 2.3: Calculation Of Recharge To Aquifer

Height of tailing dam Maximum flux to aquifer (m3/month)

3 560

5 1 040

10 1 200

15* 1 800

* Maximum stacking height. Note this is not the overall water balance, but only the maximum (conservative) volume of water that can seep into the underlying aquifer units.

Nett evaporation data and the capillary retention potential suggest that the majority of excess water is

either evaporated or remain in the dump, while the pen stock of the facility will remove a substantial

volume of water. The volumes of water that recharge to the aquifer, in comparison to the overall water

balance, are small (1-3%) and will gradually increase towards the end of life of the facility.

The tailings storage facilities at Thaba Cronimet Chrome Mine will have a definite high negative

impact on groundwater quality on a continuous basis around the facility in the long term. The impact

will be permanent with a MODERATE INTENSITY

Residual Impacts

The ratings for the impacts on ground water during the operational phase would all remain unchanged at

low significant status post mitigation other than for the deterioration of ground water quality from

opencast and underground mining operations which would be reduced from a medium significance to a

low significance. The impact of the tailings storage facility on the ground water quality with mitigations

would decrease from high negative significance to a medium negative significance.


Impacts associated with wetlands during the operational phase may include direct loss and disturbance

of wetland habitat; increased sedimentation within the wetlands due to sediment rich runoff from the

construction site, also leading to increased turbidity; obstruction of flows, increased risk of erosion and

water quality deterioration

With regards to cumulative impacts during the operational phase to general degradation of wetland

habitat, the anticipated impact pre-mitigation is expected to be definite and occurring on a continuous

basis, with impacts potentially extending beyond the mineral lease area (local). The impact is expected to

be of INTENSE severity as significant degradation to wetland habitat will take place resulting to habitat

loss in some places. The impacts will remain long term. The resultant cumulative impact will thus be high negative.

Residual Impact

On a cumulative basis, with proposed mitigation measures in place, it can be expected that the rating of

the impacts will decrease to a medium significance due to the decrease in frequency, intensity and

extent of the impact.

AquaticImpact Assessment

During the operational phase, although runoff from the surface areas may take place, especially during

the wet seasons, resulting in increased sedimentation, the Bierspruit is not situated in close vicinity to

the proposed mining and processing areas and thus there would be a low probability of a low significant cumulative impact on a local scale of a MODERATELY INTENSE on an occasional

frequency.

Residual Impact

The residual impact will probably be of a SLIGHT intensity on an occasional frequency resulting in a

low significance on a local scale and in the short term.


The significance of the impact during the operational phase is expected to be low as specialist studies

have been done and archaeological sites have been identified. However there is an improbable likelihood of encountering artifacts occasionally during the operational phase of the operation as no

construction activities should take place. The impact will be confined to the site on a permanent basis.

Removal of archaeological sites in the area without the documentation will have a high negative impact

in terms of the Archaeological history associated with the area.

Unchanged from the pre-mitigation impact assessment.

TrafficImpact Assessment

The proposed access roads to Thaba Cronimet Chrome Mine are located approximately 17 km, from

Northam and 30 km from Thabazimbi respectively. Although the anticipated additional vehicles on the

road as a result of the operations will definitely be low, the traffic to and from Northam will be affected

as well as that to and from Thabazimbi on a continuous daily basis. The impact will be of a SLIGHT

intensity and will be on a regional basis. The intersections operate as t-junctions and disruption to

peak hour (morning and afternoon) vehicle traffic flow will occur. It is therefore preferable to restrict

mine construction traffic to the off-peak hours, to minimise the impact on the traffic flows on the public

roads in the vicinity of the mine. Additional impacts associated with traffic expected during the

operational phase will be dust generation and noise generation.

Residual Impact


intensity and in the medium term.


It is highly probable that there would be impacts an aesthetic quality and sense of place during the

operational phase. The frequency of occurrence of these impacts would range between on a

continuous and on a daily basis. The spatial extent of the impacts would all be regional, within 50 km

from the mineral lease area as in some instances these could be seen from such a distance. The

duration of the impacts of the construction phase would be in the medium term. The intensity of the

construction phase impacts are anticipated to be MODERATELY SLIGHT and the significant rating of

medium. The cumulative visual impact in the area will probably be of a medium significance and in the

short term, as the area is already comprised of mining activity infrastructure, desensitizing the viewer

from the visual impact.

Residual Impact


Socio-EconomicImpacts during the operational phase on socio-economic conditions include the effects of the project on

the local economy (including job creation, multiplier effects on the local economy, etc.); impacts related

to the effects of the project on the physical environment (such as safety impacts arising from increased

traffic, visual, acoustic and air quality impacts, etc.); and impacts related to an influx of workers and job-

seekers (such as an increase in social pathologies, etc.).

Job Creation

Job creation will be a highly probable low positive impact that will extend to the long term (life of

mine). The majority of the construction workers will be contract positions, thus the impact will be of a

SLIGHT intensity and the extent of the impact will be site specific as most of the positions will be filled

by people living in the local municipal area

Multiplier effects on local economy

Multiplier effects on the local economy will be a low probability low significant positive impact that will

depend on the proportion of local spending by employees and availability local enterprises to supply

required goods/services. The impact which is expected to be of a MODERATELY INTENSE severity

will take place on an occasional basis and will continue through the life of the mine and potentially

beyond (long term) and will extend locally as the impact will include micro and macroeconomic

elements. With regards to the cumulative impacts on job creation and effects on the economy the

following applies: Several nearby mining operations employ substantial numbers of people; other mines

planned for the area will also potentially add to the number of people employed in the mining sector.

The contribution of mining related industries to job creation will therefore be enhanced through the

proposed project. Secondly, the proposed project, together with other existing and planned mining

related operations, will result in several economic benefits for local communities through direct and

multiplier effects. These effects are usually stimulated by wage bills, local and regional procurement

spend, and investment into local economic development and skills development.

Dependency on Mine For Sustaining Local Economies

Dependency on mine for sustaining local economies will be a definite long term high significant

negative impact that without appropriate mitigation. The impact is expected to be of an INTENSE

severity on a local scale as the local economy relies heavily on mining activities. With regards to

cumulative impacts, in relation to agricultural activities, mining creates a much larger number of jobs

than these activities and others in the services sector. Furthermore, because mineworkers tend to earn

better salaries than those employed in many other sectors, it is fair to deduce that the local economy is

becoming more dependent on the mines or mining related industries. All mines have a finite lifespan.

Inevitably, mining operations in the area will at some point in the future begin to scale down and close,

affecting all mining dependant industries. Unless significant investment is made into economic

diversification, the area is destined for a considerable economic slump once this process commences.

Thus the negative cumulative impact will be definite, of a long term extent with an INTENSE severity.

The impact rating of cumulative impacts will be high.

Continued Corporate Investment In Host Communities

Continued corporate investment in host communities will be a low probability low significant positive

impact that without appropriate mitigation, forecasts of local infrastructure development might not be

achieved. The positive impact which is expected to be of a MODERATELY INTENSE severity as it may

result in much required access to services will take place on an occasional basis and will continue

through the life of the mine and potentially beyond (long term) and will extend locally as the impact will

affect surrounding communities.

Physical Intrusion

It is expected that physical intrusion, a negative impact, will be highly probable and on a continuous

basis if mitigation measures are not implemented. The impact will be on a regional and long term scale

as the impact will continue throughout the operational phase. The severity is expected to be INTENSE

as this impact could negatively impact on quality of life. The impact is thus rated as high negative

significance.



frequent basis if mitigation measures are not implemented. The impact will be on a local scale and the

effects will ex extend beyond the operational phase of the mine and may be permanent. The severity is

expected to be INTENSE as this impact could severely affect well-being of communities, especially as

cumulative impact combining with existing effects of other mining operations in the area The impact is

thus rated as medium negative significance.

Increased Pressure On Resources And Services

It is expected that increased pressure on resources and services in the local area will probably be a

MODERATLEY INTENSE severity as backlogs already occur in the municipal area. It is expected that

without mitigation, the impact would take place on a frequent basis and may be of medium term

duration as impacts will probably persist post construction. The impact is thus rated as medium negative significance

The project area has already experienced a significant influx of people in search of work at nearby

mining operations. It is likely that this existing impact will be exacerbated once recruitment for the

TCCM has started (even if recruitment is limited). Population influx is also likely to exacerbate pressure

on existing infrastructure and services, the growth or establishment of informal settlements and

changes in property value. The capacity of service delivery infrastructure is under threat in the region,

particularly in Smash Block. The influx of job-seekers into these areas, combined with the presence of

an operational workforce and the influx already caused by mining will place substantial pressure on

local infrastructure such as roads, water supply, food security and energy. The combination of the

permanent workforce of mining operations and residual employees/ work-seekers of the other

operations in the area may have a significant impact on service delivery, especially housing. This

impact also relates to the availability of schooling and healthcare in the area. The current and planned

mining operations are contributing to increased rate of in-migration and the resultant pressure on

schools. This influx and large-scale settlement in the area is also causing health healthcare services to

become strained, with further influx from surrounding development creating further strain on the

provision of services. Influx will definitely continue to place pressure on the already limited and

expensive housing and land in the area (local basis) on a daily basis, and the cumulative impacts are

expected to be INTENSE and of a high significance.

Residual Impacts

The ratings of the positive impacts will be increased from a low positive to a medium positive if

mitigation measures as outlined above are implemented. With mitigation measures, the negative

impacts will move from either high to low in the case of physical intrusions or medium to low due to the

intensity of the impact reducing. In the case of the dependency On Mine For Sustaining Local

Economies, the impact will be reduced to a medium significance.

Decommissioning Phase

Geology

Impact Assessment

No additional impacts on the geology are incurred as a result of the decommissioning and closure

activities.

TopographyImpact Assessment

With rehabilitation of the shafts, conveyor belts, processing plants, other surface infrastructure

and the opencast mining operations, the topography will need to be re-established by sloping

the landscape to its original gradient to create the natural drainage flow. The only structure that

will remain post decommissioning is the tailings storage facilities which will have definitely a

MODERATELY INTENSE long term effect on the topography on a local basis. The impact will

be of a high significant pre-mitigation.

Residual Impact

As a result of the on-going opencast rehabilitation during the operational phase, removal of

infrastructure and with the additional mitigation measures outlined above, the overall impact of

these activities on the topography will probably be reduced to a medium significance in the

medium term and of MODERATELY INTENSE severity

Waste Management and Hazardous SubstancesImpact Assessment

The impacts associated with waste management and hazardous substances handling include

legal non-compliance, potential soil and water contamination and lost opportunities for waste

recycling. Without mitigation, the negative impacts, of high probability certainty, are expected

to take place on a frequent basis and the duration of impacts are expected to be short term in

nature. The impacts, although varying in nature can be described at a worse-case scenario of

having a MODERATELY INTENSE severity as should the impact take place, the mitigation

measures are generally cost effective and easy to implement. The impacts thus associated for

mining and processing activities are expected to be, without mitigation of a medium

significance.

Residual Impacts

The residual impact is expected to be rated as a low negative significance if mitigation

measures are implemented as the intensity, certainty and the frequency of the impacts should

decrease.


The main impacts associated with the decommissioning phase are soil compaction and topsoil

loss leading to reduced fertility, soil loss as a result of wind and water erosion and hydrocarbon

pollution. Limited impacts are expected outside of the mineral rights area, thus on a local basis,

with the exception along unpaved service roads within the region, where erosion can impact on

adjacent areas. These impacts will definitely occur and are expected on a frequent basis. They

will be permanent in duration, but significance of the impact will decrease when disturbed areas

are rehabilitated and re-vegetated during decommissioning of the mining infrastructure.

Intensity will range from MODERATELY INSTENSE to INTENSE as natural functions of the soil

will be altered. Impact significance will be medium given the extent of the area affected.

Residue Impact


because the certainty, intensity and duration of the impact will decrease.


The decommissioning phase involves the removal of the mining related infrastructure within the

already disturbed footprint, which will definitely have a medium significant impact on the

remaining vegetation and animal life after the life of mine in the long term as all such activities

will take place within the parameters of the existing disturbance footprint.

Residual Impact

The residual impact will be of a low significant rating, as the certainty, duration and intensity of

the impact will decrease.

NoiseImpact Assessment

The numbers of equipment during decommissioning will be considerably less than during the

construction and operational phases. In addition activities will most likely only happen during

day-time. Therefore, the extents of noise impacts will be much reduced when compared to the

construction and operational phases. Activities will most likely be frequent but will only take

place during day-time. The occurrence of noise impacts has a low probability. Due to their

limited extents and the long distances to noise sensitive receptors the severity of the noise

impacts will be SLIGHT. Due to the above considerations and the fact that the noise impacts will

be much reduced during night-time the significance of the noise impact is rated low.

Residual Impact


VibrationsImpact Assessment

Due to the small magnitude of the expected vibrations, structural damage is considered to be

improbable. Machinery vibrations capable of being measureable at key locations is expected to

occur very sporadically, therefore the frequency is classified as occasional. The magnitude of

the effects of vibration due to machinery is so low, that it is unlikely to be felt beyond the mining

boundary. Therefore the spatial impact is classified as site specific. Due to the low level of

vibrations, structures are expected to be unaffected. On this account, the intensity is classified

as SLIGHT. The decommissioning activities are not expected to last for more than 10 years,

therefore the duration is classified as short-term. These factors combine to yield a low negative

rating.

Due to the small magnitude of the expected vibrations, human comfort level not likely to be

affected and is therefore considered to be improbable. Machinery vibrations capable of being

measureable at locations where the community members are expected, is expected to occur

very sporadically, therefore the frequency is classified as occasional. The magnitude of the

effects of vibration due to machinery is so low, that it is unlikely to be felt beyond the mining

boundary. Therefore the spatial impact is classified as site specific. Due to the low level of

vibrations, human comfort levels are expected to be unaffected. On this account, the intensity is

classified as SLIGHT. The decommissioning activities is not expected to last for more than 10

years, therefore the duration is classified as short-term. These factors combine to yield a low negative rating.

Residual Impact

The impacts from blasting will remain as low negative impacts.

Air QualityImpact Assessment

During the decommissioning and rehabilitation phase the main air quality impacts sources will

be particulate emissions and NOx exhaust emissions from vehicle activity on unpaved roads

and decommissioning activities The dust generating impacts will be improbable as activities

are intermittent in duration. The impacts will be experienced on a short term basis. The impact

will be occasional as decommissioning activities are not constant. The impact will be site

specific. The impacts are expected to be SLIGHT in severity. The pre-mitigated impact will be

low in significance.

Residual Impact

The residual impact will not change significantly from the impact pre-mitigation as the

significance will still remain low

Surface WaterImpact Assessment

The removal of surface infrastructure and shaping and rehabilitation of the tailings storage

facility will potentially cause an increase in suspended solids in runoff from the site during the

clearing, top-soiling and grassing process. However, in most respects the removal of

infrastructure and reshaping of the tailings dam will have positive benefits in terms of storm

water management. No cumulative impacts during the decommissioning phase are foreseen as

the phase is relative short and the impacts generated by the normal operational activities will

seize to exist.

Ground WaterImpact Assessment

During the decommissioning phase, mining activities will stop. The mine water balance will

consist of recharge to the mining areas, without mine water use and mining sections will start to

fill up with recharge. Tailing dam activities will stop. No additional water will be pumped to the

facility in the form of slurry. Final rehabilitation and capping of the facilities will take place


Impacts associated with wetlands during the decommissioning phase may include increased

sedimentation within the wetlands, alien species and water quality deterioration.

With regards to the deterioration in water quality during the decommissioning phase the

anticipated impact on habitat degradation pre-mitigation is expected to be probable and

occurring on an infrequent basis, with impacts potentially extending beyond the mineral lease

area (local). This is due to decommissioning of infrastructure in dirty water areas mobilising

contaminants. The impact is expected to be of a MODERATELY INTENSE during larger rainfall

events. The impacts will be short term. The resultant cumulative impact will thus be low negative.

The impact of the increase in sedimentation will result in an anticipated impact on habitat

degradation. The certainty of the impact will be highly probable as large areas of sediment will

be disturbed during decommissioning, some in close proximity to wetland areas. The impact

will take place on a frequent basis (during rainfall events) and is likely to extend marginally

beyond the mineral rights area (thus local extent). The impact is expected in the short term and

will be of a MODERATELY INTENSE severity as this could result in a change to species

composition and increased alien and invader species. The result significance will thus be

medium negative.

An increase in alien vegetation will probably result in habitat degradation on a continuous basis

in the long term, with the extent initially limited to within the mineral lease area but may result in

spreading beyond the site. The severity is anticipated to be INTENSE and if uncontrolled,

infestations could replace indigenous species. The result significance will thus be medium negative.

Residual Impact

On a cumulative basis, with proposed mitigation measures in place, it can be expected that the

rating of the impacts will either remain rating prior to mitigation or they will decrease to a low or

medium significance due to the decrease in frequency, intensity and extent of the impact.


During the decommissioning phase, although runoff from the surface areas may take place,

especially during the wet seasons, resulting in increased sedimentation, the Bierspruit is not

situated in close vicinity to the proposed mining and processing areas and thus there would be a

low probability of a low significant cumulative impact on a local scale of a MODERATELY

INTENSE on an occasional frequency.

Residual Impact

The impact rating will remain unchanged


There is expected to be no impacts during the decommissioning phase as there will be no

activity outside of the footprint areas which would have been already disturbed.


Use for the demolition of the surface infrastructure will travel on the R510 to get to the site. The

possible impacts will be noise, dust due to potentially increased traffic volumes on the R510.

The impact is anticipated to be experienced frequently in the short term. The certainty of the

impact is probably with a SLIGHT intensity. The significance will be low negative.

Residual Impact

No residual impact


Cessation of mining will result in a reduction of vehicular, equipment and human movement as

well as a reduction in the generation of dust, generation of materials to store / dump, lights / light

up areas required at night. Demolition of mining infrastructure will result in vehicular, equipment

and human movement, dust generation and lights at night. Demolition activities would add to the

existing negative impacts from the Thaba Cronimet mine as well as other mines within the study

area. It is highly probable that there would be impacts an aesthetic quality and sense of place

during the decommissioning phase. The frequency of occurrence of these impacts would range

between on a continuous and on a daily basis. The spatial extent of the impacts would all be

regional, within 50 km from the mineral lease area as in some instances these could be seen

from such a distance. The duration of the impacts of the decommissioning phase would be in

the short term. The intensity of the decommissioning phase impacts are anticipated to be

MODERATELY SLIGHT and the significant rating of medium.

Residual Impact


Socio-EconomicImpacts during the decommissioning phase on socio-economic conditions include the impacts

associated with the increase in social pathologies and dependency on the mine.

Dependency On Mine For Sustaining Local Economies

Dependency on mine for sustaining local economies will be a definite long term high significant

negative impact. The impact is expected to be of an INTENSE severity on a local scale as the

local economy relies heavily on mining activities. With regards to cumulative impacts, in relation

to agricultural activities, mining creates a much larger number of jobs than these activities and

others in the services sector. Furthermore, because mineworkers tend to earn better salaries

than those employed in many other sectors, it is fair to deduce that the local economy is

becoming more dependent on the mines or mining related industries. All mines have a finite

lifespan. Inevitably, mining operations in the area will at some point in the future begin to scale

down and close, affecting all mining dependant industries. Unless significant investment is

made into economic diversification, the area is destined for a considerable economic slump

once this process commences. Thus the negative cumulative impact will be definite, of a long

term extent with an INTENSE severity. The impact rating of cumulative impacts will be high.



frequent basis if mitigation measures are not implemented. The impact will be on a local scale

and the effects will extend beyond the decommissioning phase of the mine and may be

permanent. The severity is expected to be INTENSE as this impact could severely affect well-

being of communities, especially as cumulative impact combining with existing effects of other

mining operations in the area. The impact is thus rated as medium negative significance.

Residual Impacts

The ratings of the positive impacts will be increased from a low positive to a medium positive if

mitigation measures as outlined above are implemented. In the case of the dependency on the

mine for sustaining local economies, the impact will be reduced to a medium significance.

Closure PhaseGeologyThere will be no impact during the closure phase on the geology.

TopographyIf the site is sloped to be free draining, there will be no impact on the topography during closure

as all infrastructure and impoundments would have been removed. The tailings storage facilities

and waste rock residue deposits associated with underground mining, however will remain post

closure although the anticipated impact will have a low - medium significance on a permanent

basis with a SLIGHT intensity. The impact will be continuous and on a local basis.

Waste Management and Hazardous SubstanceThere will be no impact from waste management and hazardous substance during the closure

phase, provided that rehabilitation and decommissioning was undertaken effectively and all

polluting substances removed off site.


All areas that were covered by infrastructure and stockpiles before decommissioning are now

bare, compacted and sterile. These impacts are cumulatively rated as medium to low significance prior to mitigation.

Residual Impact

The residual impact will be of a low negative significance


The impacts on flora and fauna during the closure phase pre-mitigation will be of a medium negative significance with a long term duration and confined to the site. The impact will be

probable and of a SLIGHT severity.

Residual impact

The mitigation measures will result in a low residual impact of SLIGHT intensity in the medium

term on a continuous basis on site. Although the status of flora and fauna will improve from the

decommissioning phase, the impact is still negative compared to the situation prior to mining.

Vibrations There will be no impact

NoiseThere will be no impact

Air QualityDuring the decommissioning and rehabilitation phase the main air quality impacts sources will

be particulate emissions and NOx exhaust emissions from vehicle activity on unpaved roads

and decommissioning activities The dust generating impacts will be improbable as activities

are intermittent in duration. The impacts will be experienced on a short term basis. The impact

will be occasional as decommissioning activities are not constant. The impact will be site

specific. The impacts are expected to be SLIGHT in severity. The pre-mitigated impact will be

low in significance.

Residual Impact

The residual impact will not change significantly from the impact pre-mitigation as the

significance will still remain low

Surface WaterImpact Assessment

No cumulative impacts on the surface water are expected as there is no operational or

decommissioning impact or any impacts from the adjacent properties, provided that

rehabilitation has been done effectively

Ground Water

After closure, the shaft complexes and process plant will be rehabilitated and closed off, while

the tailings storage facility will be managed as a defunct tailing dam facility.

Potential Surface Decant

The mine workings at the study area after closure will consist of decommissioned and closed-off

underground mining levels. The “average” time of flooding is based on the assessment that the

fissures encountered will continuously contribute to the underground water make, albeit at a

reduced rate. In the event that these fissures run dry, or that water pressure differentials

dissipate, the only recharge to the mine is that of normal recharge through the fractured

Pyroxenite/Gabbro/Norite aquifer. In that event the time to flooding the total mine complex

increase to more than 110 years. The geological and topographical setting of the underground

mine units will not create a hydraulic pressure to a point close to, or above the topographical low

of the study area. This means that the final rest water level of the mine will eventually be the

same as that of the undisturbed aquifers. No surface decant from the mine will take place. The

flooded underground sections of Thaba Cronimet Chrome Mine will have a low significant

negative impact on groundwater resources in terms of groundwater quantity and quality in the

long term. This situation will change if water is taken from the underground reservoir for external

use.

Long Term Quality of All Mine Water Seepage

As stated in the previous sections, no surface decant or uncontrollable mine water seepage will

take place away from the mining complex. The only potential post-closure impact is that of the

deterioration of underground mine water in-situ in the long term. The long term impact on mine

water quality in the underground mine complex and the continuous, post-closure impacts are

discussed below:

The water quality will emulate the natural background groundwater quality, with an

alkaline pH and an average TDS of ~500 mg/l. The contact of this water with the host

rock will not induce further salts, due to the inert nature of the waste/host rock.

Recharge from fissures normally contains elevated values for Na and Cl and other

parameters like F and SO4 can also be elevated. The expected pH is neutral, with TDS

ranging between 1000 and 2000 mg/l for fissure recharge water. Contact of this fissure

water with the host rock will not induce any further water quality deterioration due to

geochemical or geohydrochemical reactions.

Underground blasting activities have a residual NO3 component and due to continuous

recycling of underground process water, the NO3 levels can be concentrated above 500

mg/l. Apart from Suspended Solids, no additional parameter is present in notable

concentrations. When the mine fills up with water, the additional NO3 component will be

very small due to the large volumes of underground recharge. The resultant NO3 load

added is expected to be below 1 mg/l.

The impact of flooded underground mine workings will have a low significant impact on

groundwater resources in the long term.

Long Term Quality Of Seepage From The Tailings Storage Facilities

Two Tailings Storage Facilities are planned for the life of mine. The predicted groundwater flux

during the operational phase varied between 560 and 1 800 m3/month. After rehabilitation and

capping of the tailing dam, the recharge to the aquifers is expected to decrease dramatically to

less than 200 m3/month. This is due to the following reasons:

The tailing dams are no longer operational.

Due to rehabilitation and shaping, the natural recharge through the dam will

reduce dramatically.

Piezometric water levels will reduce.

In terms of groundwater qualities, the following can be stated:

Previous studies by ERM (Draft Report: Geochemical Investigation of Waste Rock Dump

Material for the Cronimet Chrome Mining Operation, 2015) have indicated that the waste

material has no risk for Acid Rock Drainage. Four of the five samples tested by ERM

were classified as Type 3 waste and one sample was classified as Type 4 waste, in

terms of waste classification. Both, Type 3 and Type 4 wastes are considered low risk

wastes which can be disposed of at a Class C landfill or a GLB+ landfill.

The only water added to the system is clean rainfall recharge. No process water will be

pumped to the facility after closure.

The groundwater quality around the sites will be continuously monitored for any type of

impact.

The predicted salt loads (post closure) will reduce to less than 0.5 tons/month. The

polluted water must be monitored and captured post-closure.

The impact of the tailings storage facility on groundwater qualities will be continuous and

highly probable and of a medium significance in the long term. The severity is

expected to be MODERATELY INTENSE and the impact may move beyond the mineral

lease boundary area given the close proximity of the dams to the boundary.

Residual Impact

Post mitigation, the tailings storage facilities impact on ground water qualities will remain a

medium significance. The other ground water impacts discussed above will be reduced to a low significance.


Impacts associated with wetlands during closure and post closure may include increased

sedimentation within the wetlands and water quality deterioration.

With regards to the increase in sedimentation during the closure phase the anticipated impact

on habitat degradation pre-mitigation is expected to be highly probable and occurring on a

frequent basis, with impacts potentially extending beyond the mineral lease area (local). This is

due to decommissioning of infrastructure in dirty water areas mobilising contaminants. The

impact is expected to be of a MODERATELY INTENSE during larger rainfall events. The

impacts will be long term. The resultant cumulative impact will thus be medium negative.

The impact of the decrease in water quality will result in an anticipated impact on habitat

degradation. The certainty of the impact will be improbable as decant is considered unlikely.

The impact will take place on an occasional basis and is not likely to extend beyond the mineral

rights area (thus site specific extent). The impact is expected in the long term and will be of a

SLIGHT severity as water quality in is not expected to be heavily impacted upon. The result

significance will thus be low negative.

Residual Impact

On a cumulative basis, with proposed mitigation measures in place, it can be expected that the

rating of the impacts will either remain as a low significance or decrease to a low significance

due to the decrease in frequency, intensity and extent of the impact.


There will be no further impact


There is expected to be no impacts during the decommission phase as there will be no activity

outside of the footprint areas which would have been already disturbed.


No further impact on traffic, albeit positively


Closure will result in a reduction of vehicular, equipment and human movement as well as a

reduction in the generation of dust, generation of materials to store / dump, lights / light up areas

required at night. It is highly probable that there would be impacts an aesthetic quality and

sense of place during the closure phase. The frequency of occurrence of these impacts would

range between on a continuous and on a daily basis. The spatial extent of the impacts would all

be regional, within 50 km from the mineral lease area as in some instances these could be seen

from such a distance. The duration of the impacts of closure and post closure would be in the

short term. The intensity of the impacts are anticipated to be MODERATELY SLIGHT and the

significant rating of medium.

Residual Impact

With the correct and effective implementation of mitigation measures, the resultant significance

for post closure is anticipated to be low.

Socio-EconomicThe impacts associated with closure and beyond closure of the mining operations is the

persistence of social pathologies (e.g: HIV/AIDS). This impact will remain of a medium negative significance.

(vi) Methodology used in determining and ranking the nature, significance, consequences, extent, duration and probability of potential environmental impacts and risks;

(Describe how the significance, probability, and duration of the aforesaid identified impacts

that were identified through the consultation process was determined in order to decide the

extent to which the initial site layout needs revision).

Qualitative Impact Assessment MethodologyEach impact identified with regards to the proposed additional mining and processing activities

and associated infrastructure has been qualitatively assessed with and without mitigation

providing context and reasons for the description that has been chosen. In order to make the

EIR easier to read, the following notation format has been used to highlight the various

components of the assessment.

Significance, colour coded as follows

Red for high negative;

Orange for medium negative;

Yellow for low negative;

Green for high positive

Purple for medium positive

Blue for low positive

Duration will be underlined

Certainty has been typed in bold

Severity/Intensity has been typed in CAPITALS

Frequency has been typed with italics

Spatial has been typed in normal font

Quantitative Impact Assessment MethodologyStatus of the ImpactThe nature of the impact can be described as negative or positive and can be derived from the

significance rating of the impacts.

Table 3.1.1: Status of the Impact and Ratings

Rating Description Quantitative rating

Positive A benefit to the holistic environment -1

Negative A detriment to the holistic environment 1

Certainty of ImpactThe certainty or probability of the impact describes the likelihood of the impact actually occurring.

Table 3.1.2: Certainty of Impact And RatingsRating Description Quantitative

rating

Improbable In all likelihood the impact will not occur. Less than 20 percent

probability of a particular fact or of the likelihood of an impact

occurring.

1

Low probability

Possibility of the impact to materialise is low. Between 20 and 50

percent probability of a particular fact or of the likelihood of an impact

occurring.

2

Probable A distinct possibility that the impact will occur. Between 50 and 80


occurring.

3

Highly probable

Most likely that the impact will occur. More than 80 percent probability

of a particular fact or of the likelihood of an impact occurring.

4

Definite The impact will occur regardless of any prevention measures. 100


occurring.

5

Frequency of ImpactThe frequency of the impact refers to the temporal scale of the impact or benefit, in terms of the period

of time that the surrounding environment will be affected or altered by the proposed project. This is

determined by the following scale:

Table 3.1.3: Frequency Of Impact And RatingsRating Description Quantitative rating

Continuous Occurs on a daily basis 4

Frequent Occurs on a weekly basis 3

Infrequent Occurs on a monthly basis 2

Occasional Occurs less than on a monthly basis 1

Spatial Extent of ImpactThe extent of the impact refers to the spatial scale of the impact or benefit of the proposed project and

the area over which it extends. A description is provided of whether effects are limited in extent or

affects a wide area or group of people.

Table 3.1.4: Spatial Extent Of ImpactRating Description Quantitative

rating

Site specific

Effects occur within the mining right boundary 1

Local Effects extend beyond the mining right boundary, up to five kilometres

from the mining right boundary

2

Regional Widespread effect with impacts extending far beyond the mining right

boundary, but within a 50 kilometre radius of the boundary

3

National Within the boundaries of South Africa but further than the Limpopo

Province

4

International

Beyond the boundaries of South Africa 5

Intensity of ImpactThe severity or intensity of an impact is an attempt to quantify the magnitude of the impacts and benefits

associated with the proposed activities.

Table 3.1.5: Intensity of Impact And Ratings

Rating DescriptionQuantitative

Rating

Very

intense

Substantial deterioration/substantial improvement or benefit

Irreversible or permanent change/permanent improvement

Negative impacts cannot be mitigated

4

Intense Marked deterioration/improvement

Long term duration

3

Mitigation for negative impacts is very expensive, difficult or time

consuming

Moderately intense

Moderate deterioration/improvement

Medium term to long term duration

Negative impacts are fairly easily mitigated

2

Slight Minor deterioration/improvement

Short to medium term duration

Mitigation for negative impacts is easy, cheap or quick

1

Duration of ImpactThe duration of the impact refers to the temporal scale of the impact or benefit, in terms of the period of

time that the surrounding environment will be affected or altered by the proposed project.

Table 3.1.6: Duration Of Impact and Ratings

Rating DescriptionQuantitative

rating

Short term The environmental impact identified will be present for less than 10

years

1

Medium

term

The environmental impact identified will be present for life of mine 2

Long term The environmental impact identified will be present beyond the life of

mine

3

Permanent The environmental impact identified will be irreversible and will remain

post closure

4

Assessing SignificanceAfter assessment of an impact in accordance to the preceding six criteria, the significance of an impact

can be determined through a synthesis of the aspects produced in terms of their status, probability,

duration, extent and severity. The significance of an impact is an expression of the cost or value of an

impact to society. The focus must be a judgement as to whether or not impacts are significant, based

upon the value system of society, or groups of people (Thompson, 1988, 1990). The evaluation of

significance is subject to, contingent with values, and dependent upon the environmental and

community context (Sadler, 1996). This subsection presents the criteria used to define significant

effects on the environment. The rankings of each of the different impacts relates to the maximum and

minimum totals that can be achieved for each possible impact. The total of the criteria’s multiplied by

the value of either negative or positive impact value is used to calculate the threshold “classes” to

determine the significance of the impact.

Table 3.1.7: Assessing Significance (Negative Impacts)

Rating DescriptionThreshold of significance

High Long term or permanent change to the natural and social environment.

Of the highest order possible within the bounds of impacts which could

occur. In the case of adverse impacts, there is no possible mitigation

and/or remedial activity which could offset the impact. In the case of

beneficial impacts, there is no real alternative to achieving this benefit.

17-22

Medium Impact is real but not substantial in relation to other impacts which might

take effect within the bounds of those which could occur. In the case of

adverse impacts, mitigation and/or remedial activity are both feasible

and possible. In the case of beneficial impacts, other means of achieving

this benefit are feasible but they are more difficult, expensive, time-

consuming or some combination of these.

11-16

Low Impact is of a low order and therefore likely to have little real effect. In

the case of adverse impacts, mitigation and/or remedial activity are not

required, easily achieved, inexpensive or a combination of these. In the

case of beneficial impacts, alternative means for achieving this benefit

are likely to be easier, cheaper, more effective, less time consuming, or

a combination of these.

5-10

Some impacts have been assessed and proved to be positive and a benefit to the social and or natural

environment. Although these impacts have been rated in accordance with the methodology provided

above, high significance values were obtained. The nature or status of the impact proved to be the key

indicator. Should the nature of the activity, as assessed, be positive the significance threshold is

reversed.

Table 3.1.8: Assessing Significance (Positive Impacts)

Rating DescriptionThreshold of significance

High A large benefit to the holistic environment 17-22

Medium A benefit to the holistic environment 11-16

Low No real benefit to the holistic environment 5-10

(vii) The positive and negative impacts that the proposed activity (in terms of the initial site layout) and alternatives will have on the environment and the community that may be affected.

(Provide a discussion in terms of advantages and disadvantages of the initial site layout compared to alternative layout options to accommodate concerns raised by affected parties)

Environmental aspects and associated impacts associated with activities which have

been considered during the assessment are summarised below

Positive impacts Local employment opportunities

Skills transfer

Social and labour plan- local economic development initiatives (procurement of goods

and services from local enterprises), bursaries, learnerships

Salaries and wages- cash flows to the national tax revenue

Unlocking mineral potential

Increase of gross geographic product

Negative impacts Groundwater and surface water pollution

Erosion

Loss of vegetation and fauna habitats

Change in landscape

Visual impact

Dust generation

(viii) The possible mitigation measures that could be applied and the level of risk.

Impact

Rating before mitigation

Summary of mitigation measures

Rating after mitigation

Stat

us

Cer

tain

ty

Freq

uenc

y

Spat

ial

exte

nt

Dur

atio

n

Inte

nsity

Sign

ifica

nce

ratin

g

Stat

us

Cer

tain

ty

Freq

uenc

y

Spat

ial

exte

ntD

urat

ion

Inte

nsity

Sign

ifica

nce

ratin

g

Geology

Removal of ore bodies -1 5 5 1 3 4 -18 Not required -1 5 5 1 3 4 -18

Topography

Disturbances/changes to the topography of the are

-1 5 3 1 3 3 -15 Impact will be slightly mitigated through mitigation measures for flora and fauna and soil management.

-1 5 3 1 3 3 -15

Waste Management And Hazardous Substance Management

Inadequate storage of hazardous substances resulting in potential soil and water contamination

-1 4 3 1 1 2 -11 Store all hydrocarbon sources inside bunded areas with impermeable floors.

Filter all surface water from these bunded areas through hydrocarbon management facilities.

Store all hazardous substances (oils, diesel, chemicals) in containers of sufficient strength and structural integrity to ensure that it is unlikely to burst or leak during ordinary use.

Handle, manage and store all chemicals according to their material safety data sheets which are to be located at all points of storage and where the chemical is used.

Ensure that the surface where oil and diesel is delivered and handled is impermeable and not connected to surface

-1 2 2 1 1 1 -7

ImpactRating before mitigation

Summary of mitigation measuresRating after mitigation

water drainage systems, including stormwater drains

Inspect all bunds, tanks and pipework regularly for signs of damage to ensure integrity

Implement a proper and robust vehicle maintenance programme to reduce the risk of spillages of reagents and hydrocarbons during transportation

Separate waste into various categories as defined by the operational procedures to ensure optimal waste recycling and correct disposal

Train all employees and contractors on the separation of waste as defined by the operational procedures

Treat and dispose of waste as near as possible to the point of production as is technically and environmentally possible

Dispose of hazardous waste at either a permitted H:H or H:h landfill site depending on the waste characteristics and maintain safe disposal certificates.

Dispose of general waste at a permitted general landfill site. Waybills of disposal are to be recorded.

Collect hazardous waste at the stipulated maximum weight or at a minimum frequency of every 90 days whether or not the container is full.

Train all relevant employees in cleaning up of a spillage and ensure that all necessary spill kits containing the correct equipment to clean up spills are made available at strategic points in the plant area

Optimise the recycling, re-use and reduction of both general and hazardous waste



Soil, Land Use and Land Capability Management

Soil compaction because of vehicle movement and the construction of facilities.

-1 5 4 1 4 3 -17 Use existing roads and minimise new roads. The width of service roads must be minimised as much as possible

Maintain grass cover for as long as possible

Erosion control measures must be constructed

Stripped soils should be stockpiled as a berm upslope (majority) and surrounding the disturbed area.

Stripping machinery should be used when soil moisture content is below approximately 8% to limit soil compaction.

Stripping of topsoil should not be done earlier than required.

An intercept drain should be constructed upslope of construction and operational areas, in order to re-direct clean water away.

An intercept drain should possibly be constructed downslope of polluted areas, in order to drain potentially polluted water into a pollution control dam.

Conduct proper chemical waste management to avoid spillage of chemicals

Use tracked vehicles rather than wheeled vehicles due to their lower point loading and slip, thereby minimise compaction;

Soil stockpiles must be sampled, ameliorated (fertilized) and re-vegetated as soon after construction as possible

1 4 4 1 2 2 13

Soil loss as a result of wind and water erosion where vegetation is cleared

-1 5 4 2 4 3 -18 1 3 3 1 2 1 10

The change of land use from natural vegetation and agriculture (livestock grazing) to industrial.

-1 5 4 1 4 3 -17 1 3 3 1 2 1 10

The sterilisation of the soil resource where the support facilities will be constructed.

-1 5 4 1 4 4 -18 1 5 4 1 4 3 17

Construction activities may lead to pollution of soil due to hydrocarbon and cement spillages

-1 4 4 2 4 3 -17 1 3 3 1 2 1 10

Flora And Fauna

Cumulative impacts on flora and fauna including:Habitat loss and harm to flora and

-1 5 4 2 4 4 -19 Clearly demarcate the development footprint prior to initial site clearance and prevent construction personnel from leaving

-1 4 4 2 2 2 -14



faunaFragmentation of the habitat resulting in harm to flora and faunaFauna mortalitiesPresence of alien and invasive species resulting in habitat degradation

the demarcated area; Retain where possible, vegetation between

infrastructural elements associated with the project;

Conduct flora species search and rescue efforts before ground clearing begins;

Remove and relocate any plants of botanical or ecological significance (protected species);

Provide upfront and regular environmental training to construction workers to ensure the protection of the habitat, fauna and flora and their sensitivity to conservation;

Where trenches pose a risk to animal safety, ensure that the trench is secured to prevent animals falling in and getting trapped and/or injured;

Avoid the use of poisons for the control of problem animals and where it is necessary obtain approval from the Environmental Officer on type of poison to be used.

Use existing facilities (e.g., access roads, parking lots, graded areas) to the extent possible to minimize the amount of new disturbance;

Establish protective buffers in areas where there is sensitive habitat such as ravines

Avoid all sensitive habitats by construction vehicles and equipment, wherever possible, in order to reduce potential impacts

Do not undertake any activities outside of the defined construction areas and the road servitudes.

In areas where the speed limit tends to be disobeyed, consider installing speed bumps.

Limit or avoid travelling at night as much as possible.

Where possible, position lighting five meters

Impact



Rating after mitigationfrom the roads or paved areas.

Destroy alien invasive plants present, and the seedlings which emerge

Establish and manage an alternative plant cover to limit re-growth and re-invasion.

Institute strict control over materials brought onto site, which should be inspected for seeds of noxious plants and steps taken to eradicate these before transport to the site. Routinely fumigate or spray all materials with appropriate low-residual herbicides prior to transport to site or in a quarantine area on site.

Develop a detailed plan for the control of invader fauna species, noxious weeds and invasive plants that could colonize the area as a result of new surface disturbance activities at the site. The plan should address monitoring, weed identification, the manner in which weeds spread, and methods for treating infestations.

Vibrations

Structural damage -1 3 3 1 3 1 -11 Blasting designed and performed by person holding a National Certificate in Rock Breaking (qualification ID 62869) or equivalent. Inform community of schedule.

Close public roads during blasting. Community may need to be evacuated

based on proximity. Avoid blasting during quiet hours.

-1 2 3 1 2 1 -9

Human discomfort 1 4 3 2 4 1 -14 1 2 3 2 2 1 -10

Air Quality

Cumulative particulate emissions -1 1 2 1 1 1 -6 Apply wet suppression or chemical stabilisation on unpaved roads.

Restrict haul trucks to specified haul roads Reduce unnecessary traffic and strict

-1 1 2 1 1 1 -6



speed control in areas where speed limits are disobeyed

Stabilise (chemical, rock cladding or vegetative) disturbed soil and early re-vegetation

Surface Water

Deterioration in water quality -1 4 1 2 1 1 -8 The laydown and contractor areas must be kept as small as possible;

Ensure berms and structures are constructed around these sites to ensure clean overland flow is directed into the natural drainage channels.

All wetlands and flood lines must be clearly marked and no activity is allowed inside these boundaries.

Natural drainage channels must only be crossed at specific areas and water management structures must be constructed before the road is commissioned.

All laydown areas and construction roads must be ripped and vegetated after the construction phase is complete.

Water emanating from contractor workshops and stores must be directed to a proper hydrocarbon management unit. All other surface water from the contractor area must be collected in a pond inside the boundaries of the contractor yard.

Parking areas for yellow machine must have spill kits and drip trays in-case of leaking vehicles.

No manufacturing and/or maintenance must be done in any area outside the workshops and manufacturing zone.

All topsoil stripped from the contractor area must be stored on topsoil dumps.

Clean overland flow must be directed around

-1 2 2 2 1 2 -8

Decrease in the catchment yield -1 4 1 2 1 1 -8 1 3 1 2 1 1 -6

Impact



Rating after mitigation

the contractor area.Ground Water

Impact on the availability of ground water

-1 5 2 1 1 1 -10 Manage excess water that accumulates during the construction phase as part of the construction phase water balance.

Construction of the shaft complex where possible is to be undertaken during post winter months. Shaft walls will be sealed off preventing significant inflow into the mine workings after construction.

Discharge all unwanted water accumulating in the excavations into pollution control dams for re-use as soon as possible. Limit contact time with shaft perimeter and pit floor

-1 4 2 1 1 1 -9

Impact on ground water quality -1 1 2 3 1 1 -8 -1 1 2 1 1 1 -6

Wetland

Degradation of wetland habitat -1 5 4 2 3 3 -17 In the case of the northern settler dam, the proposed location of the dam was moved to over a 100m from the boundary of the Middellaagte Riparian Zone;

All stockpiles extending into the Trollope wetland/riparian habitat should however be adjusted to remain outside the delineated area. No stockpiling of material may take place within the wetland and/or riparian areas and temporary construction camps and infrastructure should also be located away from these areas, with a minimum buffer of 100m maintained from delineated wetland and/or riparian boundaries.

Clearly demarcate all wetland areas as such to alert mining staff on site and where activities take place in close vicinity to wetland habitat, fence

-1 4 2 1 2 2 -11

Impact



Rating after mitigationoff the opencast and surface infrastructure areas so as to prevent machinery and personnel accessing adjacent wetland areas outside the disturbance footprint.

Educate all mine staff and contractors on the importance and sensitivity of the wetland systems on site

Upgrade the existing crossing over the riparian zone with culverts.

Wetland crossings must make allowance for flow connectivity across the full wetland system to be maintained. Install box culverts as opposed to pipe culverts.

No impoundments upstream should be allowed

Im[plement erosion control and the separation of dirty and clean water. Dirty water areas

should be kept as small as possible, while still ensuring the effective separation of clean and dirty water. All clean water from upslope of the dirty water areas should be diverted around the dirty water areas and discharged back into the environment. Clean water diversions should ideally take the form of grassed swales rather than simple excavated trenches that present an erosion risk. The clean water diversion discharge points should be protected against erosion and must incorporate energy dissipating structures to prevent erosion in receiving wetlands. Discharge points should be regularly inspected and maintained to ensure efficient



functioning. Any observed erosion damage should be repaired immediately and the cause addressed.

To minimise the impacts of mining through the Middellaagte Riparian Zone and Trollope Wetland, it is critical that flow and habitat connectivity be maintained across these watercourses both during and after mining. A stream diversion will therefore be required. Such a stream diversion should be unlined if at all possible and should be vegetated with locally occurring indigenous grass species. Both the diversion floor and side slopes should be vegetated. The diversion should be designed to cater for flood events that might occur. Where required, erosion protection measures should be installed along the diversion. Mining through the Middellaagte riparian zone should be undertaken over as short a time as possible to reduce time that soil is stockpiled, as this could affect the viability of the seed bank.

Aquatic

Destruction / disturbance of the Bierpruit and other rivers in the area

-1 2 1 1 1 2 -7 Comply with the requirements of GN 704 in terms of storm water management and comply with the proposed mitigation measures as outlined in the surface water section and as outlined in the section on flora and fauna management.

-1 2 1 1 1 1 -6

Archaeology And Heritage

Destruction of archaeological and -1 3 4 2 4 4 -17 Fence off all archaeological sites identified -1 3 2 2 2 4 -13

Impact



Rating after mitigationheritage sites to date in close proximity to the proposed

mining and processing areas prior to commencement of construction in the area

Include within the training programme, general awareness on archaeological artefacts and the protocol to be established on identification of an artefact. Compile and undertake training on an operational procedure.

Cease work immediately and contact the Archaeological Specialist should an object of archaeological or heritage importance be discovered or suspected to be of importance

Fence off all archaeological sites identified to date in close proximity to the proposed mining and processing areas prior to commencement of construction in the area

Appoint an archaeologist to undertake the necessary recordings and documentation at site two and to obtain a permit from SAHRA prior to the destruction or interference with site one from construction activities. If possible re-route the access road to avoid this site.

Appoint an archaeologist to undertake the necessary recordings and documentation at site one and to obtain a permit from SAHRA prior to the destruction or interference with site one from construction activities.

Noise

New total resulting ambient noise levels elevated above pre-development levels and the actual increase in ambient noise levels

-1 3 3 1 1 1 10 All diesel powered equipment must be of high quality and well maintained

Maintenance must be regular, schedules adhered to and include the exhaust and intake mufflers of engines

Maintenance must include a sound check

-1 3 3 1 1 1 10



of the equipment During operating conditions changes in

the perceived noise characteristics must result it being withdrawn for maintenance/repairs

Traffic

Increased traffic -1 3 2 3 1 1 -10 Avoid breaking of traffic laws and non-compliance with road signs

Provision of the appropriate traffic signs (warning and directional) to aid with the control of the traffic flow, at the access roads, during the construction phase.

Dust suppression measures will be implemented during the construction phase to reduce dust liberations resultants from traffic.

Construction activities will be restricted to day time hours to prevent noise disturbance during night time.

-1 3 2 3 1 1 -10

Visual

Impacts on aesthetic value and sense of place

1 4 4 3 1 2 -14 Prevent light pollution by avoiding light spillage outside of the project activity areas, the application of directional lighting, security lighting that is only activated upon illegal entry in restricted areas

Rehabilitate the tailing storage facilities soon as possible with indigenous vegetation that will blend in with the character of the existing vegetation

Avoid cutting down of trees If possible, cluster the sewage disposal

and electricity generation facilities together with other mining structures in order to reduce the visual impact

1 4 4 3 1 1 -13



Socio-Economic

Job creation during construction +1 4 1 1 1 1 +8 Maximise and monitor local recruitment coordinated through the Department of Labour

Promote the employment of women and youth

Avoid hiring illegal immigrants and child labour.

Where possible use labour-intensive methods of construction

Train and increase the skill level of the workforce

Develop and maintain a register of local SMMEs and the types of goods and services provided by them.

Where appropriate SMMEs do not exist, investigate the possibility of launching a training/ skills development initiative to develop local entrepreneurial skills

Where possible, assist communities in responsible investing and savings through a reputable financial institution to take advantage of increasing disposable income

Establish linkages with other institutions involved in skills development and SMME development, such as the community development programme of the local municipality

Take steps to ensure that planned initiatives dovetail with those of other development institutions active in the area, including the district and local government

As far as possible, undertake the selection, design and implementation of development initiatives in collaboration with their intended beneficiaries.

Determine what the communities’ expectations are regarding development

1 5 3 2 1 2 -13Multiplier effect on local economy +1 2 1 2 3 2 +10 1 4 2 3 3 2 +14Continued corporate investment in host communities

+1 2 1 2 3 2 +10+1 3 3 2 3 2 +13

Physical intrusion -1 5 4 3 3 2 -17 -1 3 2 2 3 2 -12Increased social pathologies -1 2 3 2 4 2 -13 -1 1 2 1 4 2 -10Increased pressure on services and resources

-1 3 3 2 2 2 -12 -1 1 2 2 2 2 -9



Ensure that diversions and major disturbances to national and provincial roads occurs during low peak times;

When necessary, ensure that local residents are kept informed on an on-going basis of construction progress and when access will be blocked in certain areas

Investigate the establishment of a community forum to serve as a dedicated communication channel with the local population

Implement measures to ensure that these speed restrictions are enforced. Such measures may include monitoring vehicle speeds, erecting speed limit signs and installing speed humps;

Maintain roads to prevent deterioration of roads surfaces due to heavy vehicle traffic.

Identify measures to manage/promote road safety and traffic control, taking into account the cumulative effects of traffic generated by multiple development projects

Prevent unauthorized access to the mine site through appropriate fencing and security;

Restrict the making of fires by construction workers to areas where tight control can be exerted, or that the making of fires be prohibited.

Increase awareness of the mine’s complaints and grievance procedures and hold feedback sessions with community forums to assess the impact of this programme

implement HIV/AIDS and alcohol abuse campaigns in the communities;

Include HIV/AIDS and sexually transmitted infections awareness and prevention programmes as a condition of contract for

Impact Rating before mitigation Summary of mitigation measures Rating after mitigation

suppliers and sub-contractors. Introduce a voluntary counseling and testing

programme Undertake a voluntary HIV/AIDS and

sexually transmitted disease prevalence survey on a regular basis.

Control access at the construction sites to prevent sex workers and petty traders from visiting and/or loitering

Establish formal liaison structures with the local police to monitor local social dynamics during both construction and eventually operation;

Establish and maintain liaison with existing crime control organisations, such as bona fide Community Policing Forums and Farm Watch organisations;

Quantitative Assessment of Impacts during The Operational Phase

Impact

Rating Before Mitigation

Summary Of Mitigation Measures

Rating After Mitigation

Stat

us

Cer

tain

ty

Freq

uenc

y

Spat

ial

exte

nt

Dur

atio

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Inte

nsity

Sign

ifica

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Stat

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Freq

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Spat

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urat

ion

Inte

nsity

Sign

ifica

nce

ratin

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Geology

Removal of ore bodies -1 5 5 1 3 4 -18 Not required -1 5 5 1 3 4 -18

Topography

Disturbances/changes to the topography of the are

-1 5 5 1 4 2 -17 Impact will be mitigated through concurrent opencast rehabilitation as well as stipulated mitigation measures for flora and fauna and soil management.

-1 5 5 1 2 2 -15


Inadequate storage of hazardous substances resulting in potential soil and water contamination

-1 4 3 1 1 2 -11 Store all hydrocarbon sources inside bunded areas with impermeable floors.

Filter all surface water from these bunded areas through hydrocarbon management facilities.

Store all hazardous substances (oils, diesel, chemicals) in containers of sufficient strength and structural integrity to ensure that it is unlikely to burst or leak during ordinary use.

Handle, manage and store all chemicals according to their material safety data sheets which are to be located at all points of storage and where the chemical is used.

Ensure that the surface where oil and diesel is delivered and handled is impermeable and not connected to surface

-1 2 2 1 1 1 -7

ImpactRating Before Mitigation

Summary Of Mitigation MeasuresRating After Mitigation

water drainage systems, including stormwater drains

Inspect all bunds, tanks and pipework regularly for signs of damage to ensure integrity

Implement a proper and robust vehicle maintenance programme to reduce the risk of spillages of reagents and hydrocarbons during transportation

Separate waste into various categories as defined by the operational procedures to ensure optimal waste recycling and correct disposal

Train all employees and contractors on the separation of waste as defined by the operational procedures

Treat and dispose of waste as near as possible to the point of production as is technically and environmentally possible

Dispose of hazardous waste at either a permitted H:H or H:h landfill site depending on the waste characteristics and maintain safe disposal certificates.

Dispose of general waste at a permitted general landfill site. Waybills of disposal are to be recorded.

Collect hazardous waste at the stipulated maximum weight or at a minimum frequency of every 90 days whether or not the container is full.

Train all relevant employees in cleaning up of a spillage and ensure that all necessary spill kits containing the correct equipment to clean up spills are made available at strategic points in the plant area

Optimise the recycling, re-use and reduction of both general and hazardous waste




Soil compaction and topsoil loss leading to reduced fertility.

-1 5 4 1 4 3 -17 Use existing roads and minimise new roads.

The width of service roads must be minimised as much as possible







An intercept drain should possibly be constructed downslope of polluted areas, in order to drain potentially polluted water into a pollution control dam.

Conduct proper chemical waste management to avoid spillage of chemicals

Use tracked vehicles rather than wheeled vehicles due to their lower point loading and slip, thereby minimise compaction

Soil stockpiles must be sampled, ameliorated (fertilized) and re-vegetated as soon after construction as possible

1 4 4 1 2 2 13

The change of land use from natural vegetation and agriculture (livestock grazing) to industrial.

-1 5 4 1 4 3 -17 1 3 3 1 2 1 10

The sterilisation of the soil resource where the support facilities will be constructed.

-1 5 4 1 4 4 -18 1 5 4 1 4 3 17

Loss of current land capability. -1 5 4 1 4 3 -17 1 3 3 1 2 1 10

Chemical pollution of soil. -1 4 4 2 4 3 -17 1 3 3 1 2 1 10

Flora And Fauna

Cumulative impacts on flora and fauna including:Habitat loss and harm to flora and

-1 5 4 2 4 4 -19 Clearly demarcate the development footprint prior to initial site clearance and prevent construction personnel from leaving

-1 4 4 2 2 3 -15



faunaFragmentation of the habitat resulting in harm to flora and faunaFauna mortalitiesPresence of alien and invasive species resulting in habitat degradation

the demarcated area; Retain where possible, vegetation between

infrastructural elements associated with the project;

Conduct flora species search and rescue efforts before ground clearing begins;

Remove and relocate any plants of botanical or ecological significance (protected species);

Provide upfront and regular environmental training to construction workers to ensure the protection of the habitat, fauna and flora and their sensitivity to conservation;

Where trenches pose a risk to animal safety, ensure that the trench is secured to prevent animals falling in and getting trapped and/or injured;

Avoid the use of poisons for the control of problem animals and where it is necessary obtain approval from the Environmental Officer on type of poison to be used.

Use existing facilities (e.g., access roads, parking lots, graded areas) to the extent possible to minimize the amount of new disturbance;

Establish protective buffers in areas where there is sensitive habitat such as ravines

Avoid all sensitive habitats by construction vehicles and equipment, wherever possible, in order to reduce potential impacts

Do not undertake any activities outside of the defined construction areas and the road servitudes.

In areas where the speed limit tends to be disobeyed, consider installing speed bumps.

Limit or avoid travelling at night as much as possible.

Where possible, position lighting five meters

Impact



Rating After Mitigationfrom the roads or paved areas.

Destroy alien invasive plants present, and the seedlings which emerge

Establish and manage an alternative plant cover to limit re-growth and re-invasion.

Institute strict control over materials brought onto site, which should be inspected for seeds of noxious plants and steps taken to eradicate these before transport to the site. Routinely fumigate or spray all materials with appropriate low-residual herbicides prior to transport to site or in a quarantine area on site.

Develop a detailed plan for the control of invader fauna species, noxious weeds and invasive plants that could colonize the area as a result of new surface disturbance activities at the site. The plan should address monitoring, weed identification, the manner in which weeds spread, and methods for treating infestations.

Vibrations

Structural damage -1 3 3 1 4 2 -13 Blasting designed and performed by person holding a National Certificate in Rock Breaking (qualification ID 62869) or equivalent. Inform community of schedule.

Close public roads during blasting. Community may need to be evacuated

based on proximity. Avoid blasting during quiet hours.

-1 2 3 1 2 2 -10

Human discomfort -1 4 3 2 5 2 -16 -1 2 3 2 2 2 -11

Air Quality

Cumulative particulate emissions and NOX emissions

-1 4 4 2 3 2 -15 Apply wet suppression or chemical stabilisation on unpaved roads.

Restrict haul trucks to specified haul roads Reduce unnecessary traffic and strict

-1 4 3 2 2 2 -13



speed control in areas where speed limits are disobeyed


Surface Water

Deterioration in water quality -1 4 1 2 1 1 -8 The laydown/contractor areas and footprints must be kept as small as possible;

Ensure berms and structures are constructed around these sites to ensure clean overland flow is directed into the natural drainage channels.

All wetlands and flood lines must be clearly marked and no activity is allowed inside these boundaries.

Natural drainage channels must only be crossed at specific areas and water management structures must be constructed before the road is commissioned.

All laydown areas and construction roads must be ripped and vegetated after the construction phase is complete.

Water emanating from contractor workshops and stores must be directed to a proper hydrocarbon management unit. All other surface water from the contractor area must be collected in a pond inside the boundaries of the contractor yard.

Parking areas for yellow machine must have spill kits and drip trays in-case of leaking vehicles.

No manufacturing and/or maintenance must be done in any area outside the workshops and manufacturing zone.

All topsoil stripped from the contractor

-1 2 2 2 1 2 -8

Decrease in the catchment yield -1 4 1 2 2 1 -10 1 2 1 2 1 1 -7

Impact




area must be stored on topsoil dumps. Clean overland flow must be directed

Ground Water

Influx of ground water into mine workings

-1 4 3 1 3 3 -14 Manage all excess water as part of the operational phase water balance

In the case of proven depletion of water resources, negotiate alternative supplies of water to replace existing usage with affected groundwater users, based on a structured compensation protocol.

Where water is not used during mining, or pumped back to the plant area, disposal must take place in the correct polluted water facility.

Should in the event that water flows naturally or due to pumping between adjacent sections, keep strict records of volumes of water pumped, quality of water pumped, delineation of reservoirs created for the storage of water.

Investigate and implement a ground water abstraction system in the event that an unacceptable impact is identified

-1 2 3 1 1 1 -8

Depletion of external users groundwater resources and fountains

-1 2 5 3 2 2 -14 -1 2 1 1 1 1 -6

Impact on external users groundwater quantity and quality

-1 3 3 2 3 2 -13 -1 2 1 1 2 1 -7

Groundwater quality deterioration from infrastructure on surface

-1 5 5 2 2 4 -18 -1 3 3 1 2 3 -12

Wetland

Degradation of wetland habitat -1 5 4 2 3 3 -17 Strong emphasis should be placed on the rehabilitation of these areas post opencast mining, and a watercourse resembling the downstream reaches of the Trollope system (i.e. downstream of the tar road) should be re-established across the mined out areas.

All stockpiles extending into the Trollope wetland/riparian habitat should however be adjusted to remain outside the delineated

-1 4 2 1 2 2 -11



area. Clearly demarcate all wetland areas as

such to alert mining staff on site and where activities take place in close vicinity to wetland habitat, fence off the opencast and surface infrastructure areas so as to prevent machinery and personnel accessing adjacent wetland areas outside the disturbance footprint.



Construct wetland crossings as follows: Wetland crossings must make allowance for flow connectivity across the full wetland system to be maintained. Install box culverts as opposed to pipe

culverts. No impoundments upstream should be

allowed Erosion protection must be installed on

downstream discharge

Aquatic



-1 2 1 1 1 1 -6


Destruction of archaeological and heritage sites

-1 5 2 1 1 1 -10 Should artifacts be discovered during the opencast pit operations, an archaeologist must be contacted and in turn the SAHRA.

Effective training programmes to be

-1 2 1 1 2 4 -10

Impact Rating Before Mitigation Summary Of Mitigation Measures Rating After Mitigationimplemented

Noise




Maintenance must include a sound check of the equipment

During operating conditions changes in the perceived noise characteristics must result it being withdrawn for maintenance/repairs

-1 3 3 1 1 1 10

Traffic



-1 3 2 3 1 1 -10

Visual

Impacts on the aesthetic value and sense of place



Avoid cutting down of trees

1 4 4 3 1 2 -14



Socio-Economic

Job creation +1 4 1 1 1 1 +8 Maximise and monitor local recruitment coordinated through the Department of Labour

Promote the employment of women and youth

Avoid hiring illegal immigrants and child labour.

Where possible use labour-intensive methods of construction

Train and increase the skill level of the workforce

Develop and maintain a register of local SMMEs and the types of goods and services provided by them.

Where appropriate SMMEs do not exist, investigate the possibility of launching a training/ skills development initiative to develop local entrepreneurial skills

Where possible, assist communities in responsible investing and savings through a reputable financial institution to take advantage of increasing disposable income

Establish linkages with other institutions involved in skills development and SMME development, such as the community development programme of the local municipality

Take steps to ensure that planned initiatives dovetail with those of other development institutions active in the area, including the district and local government

As far as possible, undertake the selection, design and implementation of development initiatives in collaboration with their intended beneficiaries.

Determine what the communities’ expectations are regarding development

1 5 3 2 1 2 +13Multiplier effect on local economy +1 2 1 2 3 2 +10 1 4 2 3 3 2 +14Dependency on mine for sustaining local economy

-1 5 5 2 3 3 -18 -1 4 3 2 3 2 -14

Continued corporate investment in host communities

+1 2 1 2 3 2 +10 +1 3 3 2 3 2 +13

Physical intrusion -1 5 4 3 3 2 -17 -1 3 2 2 3 2 -12Increased social pathologies -1 2 3 2 4 2 -13 -1 1 2 1 4 2 -10Increased pressure on services and resources

-1 3 3 2 2 2 -12 -1 1 2 2 2 2 9



Ensure that diversions and major disturbances to national and provincial roads occurs during low peak times;

When necessary, ensure that local residents are kept informed on an on-going basis of construction progress and when access will be blocked in certain areas

Investigate the establishment of a community forum to serve as a dedicated communication channel with the local population

Implement measures to ensure that these speed restrictions are enforced. Such measures may include monitoring vehicle speeds, erecting speed limit signs and installing speed humps;

Maintain roads to prevent deterioration of roads surfaces due to heavy vehicle traffic.

Identify measures to manage/promote road safety and traffic control, taking into account the cumulative effects of traffic generated by multiple development projects

Prevent unauthorized access to the mine site through appropriate fencing and security;

Restrict the making of fires by construction workers to areas where tight control can be exerted, or that the making of fires be prohibited.

Increase awareness of the mine’s complaints and grievance procedures and hold feedback sessions with community forums to assess the impact of this programme

implement HIV/AIDS and alcohol abuse campaigns in the communities;

Include HIV/AIDS and sexually transmitted infections awareness and prevention programmes as a condition of contract for

Impact Rating Before Mitigation Summary Of Mitigation Measures Rating After Mitigation

suppliers and sub-contractors. Introduce a voluntary counseling and testing

programme Undertake a voluntary HIV/AIDS and

sexually transmitted disease prevalence survey on a regular basis.

Control access at the construction sites to prevent sex workers and petty traders from visiting and/or loitering

Establish formal liaison structures with the local police to monitor local social dynamics during both construction and eventually operation;

Establish and maintain liaison with existing crime control organizations, such as bona fide Community Policing Forums and Farm Watch organizations;

Quantitative Assessment Of Impacts During Decommissioning Phase

Impact




Stat

us

Cer

tain

ty

Freq

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y

Spat

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nt

Dur

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n

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nsity

Sign

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Freq

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Geology

No further impact

Topography

Resultant waste rock residue deposits and tailings storage facilities

-1 2 3 2 4 1 -12 -1 2 3 2 4 1 -12


No further impact provided that rehabilitation was undertaken effectively and all contaminants removed from site


Soil compaction by vehicles removing rubble and by machinery doing the backfilling

-1 5 4 2 1 3 15 Use existing roads and minimise new roads.

The width of service roads must be minimised as much as possible





-1 4 4 1 1 2 12

Erosion on newly denuded areas where and infrastructure stockpiles were removed. Replaced topsoil and rehabilitated roads are also sensitive for erosion.

-1 5 4 2 4 3 18 -1 3 3 1 2 1 10

Hydrocarbon pollution by vehicles and machinery

-1 4 4 2 4 3 17 -1 3 3 1 2 1 10

Impact






An intercept drain should possibly be constructed downslope of polluted areas, in order to drain potentially polluted water into a pollution control dam.Flora And Fauna

Cumulative impacts on flora and fauna including:Habitat loss and harm to flora and faunaFragmentation of the habitat resulting in harm to flora and faunaFauna mortalitiesPresence of alien and invasive species resulting in habitat degradation

-1 3 3 2 1 4 -13 Plant vegetation species for rehabilitation that will effectively bind the loose material and which can absorb run-off from the mining areas. Rehabilitate all the land where infrastructure has been demolished.

Monitor the establishment of the vegetation cover on the rehabilitated sites to the point where it is self-sustaining.

Protect rehabilitation areas until the area is self-sustaining.

Diversion trenches and storm water measures must be maintained

-1 2 2 2 2 2 -10

Vibrations

No impact

Impact



Rating After MitigationAir Quality

Cumulative particulate emissions -1 1 2 1 1 1 -6 Apply wet suppression or chemical stabilisation on unpaved roads.

Reduce unnecessary traffic and strict speed control in areas where speed limits are disobeyed

Stabilize (chemical, rock cladding or vegetative) disturbed soil and early re-vegetation

-1 1 2 1 1 1 -6

Surface Water

No further impact

Ground Water

No further impact

Wetland

Degradation of wetland habitat -1 3 2 2 2 1 -11 Strong emphasis should be placed on the rehabilitation of these areas post opencast mining, and a watercourse resembling the downstream reaches of the Trollope system (i.e. downstream of the tar road) should be re-established across the mined out areas.

All stockpiles extending into the Trollope wetland/riparian habitat should however be adjusted to remain outside the delineated area.

Clearly demarcate all wetland areas as such to alert mining staff on site and where activities take place in close vicinity to wetland habitat, fence off the opencast and surface infrastructure areas so as to prevent machinery and personnel accessing adjacent wetland areas outside the disturbance footprint.

-1 3 2 1 2 1 -9





Construct wetland crossings as follows: Wetland crossings must make allowance for flow connectivity across the full wetland system to be maintained. Install box culverts as opposed to pipe

culverts. No impoundments upstream should be

allowed Erosion protection must be installed on

downstream discharge

Aquatic



-1 2 1 2 1 2 -8


No impact

Noise




Maintenance must include a sound check of the equipment

-1 3 3 1 1 1 10



Traffic



-1 3 3 2 1 1 -10

Visual




Avoid cutting down of tress

1 4 4 3 1 1 -13

Socio-Economic

Dependency on mine for sustaining local economy

-1 5 5 2 3 3 -18 Implement HIV/AIDS and alcohol abuse campaigns in the communities;

Include HIV/AIDS and sexually transmitted infections awareness and prevention programmes as a condition of contract for suppliers and sub-contractors

Provide an adequate supply of free condoms to workers

Introduce a voluntary counseling and testing programme

Undertake a voluntary HIV/AIDS and sexually transmitted disease prevalence survey on a regular basis.

Establish formal liaison structures with the local police to monitor local social dynamics

-1 4 3 2 3 2 -14

Increased social pathologies -1 2 3 2 4 2 -13 -1 1 2 1 4 2 -10



during both construction and eventually operation;

Establish and maintain liaison should be maintained with existing crime control organizations, such as bona fide Community Policing Forums and Farm Watch organisations;

Quantitative Assessment Of Impacts During Closure Phase

Impact




Stat

us

Cer

tain

ty

Freq

uenc

y

Spat

ial

exte

nt

Dur

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n

Inte

nsity

Sign

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Stat

us

Cer

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ty

Freq

uenc

y

Spat

ial

exte

ntD

urat

ion

Inte

nsity

Sign

ifica

nce

ratin

g

Geology

No further impact

Topography

No further impact


No further impact


Soil erosion, especially water erosion because of poor infiltration of rain due to the compaction.

1 5 4 2 1 3 15 Rip soils immediately after operations cease and revegetate

Sample, test and ameliorate soil on rehabilitated areas to improve conditions for re-vegetation.

Prevent the concentration of surface runoff through channels, trenches or preferential flow paths created by vehicle tracks. Install sediment barriers, e.g. straw bales or bidim fences, along the downslope edge of disturbed areas until sufficient vegetation cover has been established.

Where rehabilitation activities take place on steep slopes or areas of high surface runoff volumes and velocities, consider

1 3 3 1 2 1 10

Loss of land capability namely grazing land capability

1 3 1 1 1 3 9 1 2 1 1 1 2 7

Loss of land use namely livestock farming

1 3 1 1 1 3 9 1 2 1 1 1 2 7



the installation of a geomembrane to hold the soil

Rehabilitate as close to possible to the Flora And Fauna

Cumulative impacts on flora and fauna including:Habitat loss and harm to flora and faunaFragmentation of the habitat resulting in harm to flora and faunaFauna mortalitiesPresence of alien and invasive species resulting in habitat degradation

-1 2 3 2 3 1 -11 Plant vegetation species for rehabilitation that will effectively bind the loose material and which can absorb run-off from the mining areas. Rehabilitate all the land where infrastructure has been demolished.

Monitor the establishment of the vegetation cover on the rehabilitated sites to the point where it is self-sustaining.

Protect rehabilitation areas until the area is self-sustaining.

Diversion trenches and storm water measures must be maintained

-1 2 2 2 2 1 -10

Vibrations

No impact

Air Quality


-1 1 2 1 1 1 -6 Apply wet suppression or chemical stabilisation on unpaved roads.

Reduce unnecessary traffic and strict speed control in areas where speed limits are disobeyed


-1 1 2 1 1 1 -6

Impact



Rating After MitigationSurface Water

No further impact

Ground Water

Potential surface decant -1 2 1 2 5 2 -12 Investigate an abstraction scheme should the monitoring data indicate a requirement for intervention in this regard.

Monitoring

-1 1 1 1 1 1 -12

Long term quality of seepage from the tailings storage facilities

-1 4 2 2 3 3 -14 -1 4 2 2 3 3 -14

Wetland

Degradation of wetland habitat -1 3 2 2 2 1 -11 The mitigation measures are covered in the section on flora and fauna management and on soil, land use and land capability.

-1 3 2 1 2 1 -9

Aquatic

No further impact


No impact

Noise

No impact

Traffic

No negative impact, there will be an improvement in traffic post operational phase

Visual


1 4 4 3 2 1 -14 Prevent light pollution by avoiding light spillage outside of the project activity areas, the application of directional lighting, security lighting that is only activated upon

-1 1 1 1 1 3 -7

Impact Rating Before Mitigation Summary Of Mitigation Measures Rating After Mitigationillegal entry in restricted areas


Socio-Economic

Persistent social pathologies -1 2 3 2 4 2 -13 -1 2 3 2 4 2 -13

(ix) Motivation where no alternative sites were considered.

Cronimet Chrome Mining SA (Pty) Ltd is a holder of a Mining Right granted on portion

1 of the farm Middellaagte 382 KQ, portion 1 of the farm Elandskuil 378 KQ, portion 8

of the farm Roodedam 368 KQ, remaining extent of the farm Moddergat 389 KQ, and

portion 6, 8, 12, 18, 21, 26, and 28 of the farm Zwartkop 369 KQ and portion 1 and the

remaining extent of the farm Schildpadnest 385 KQ.

The only preferred site for the proposed extension of TSF is north of the existing TSF

and near the processing plant area on portion 1 of the farm Middellaagte 382 KQ.

Furthermore, the proposed TSF on the remaining extent of the farm Moddergat 389 KQ

will also be in close proximity to the processing plant facility.

The proposed locations of the waste rock dumps were considered to be near the

mined-out areas for ease of backfilling during rehabilitation and closure phase of the

mine. The proposed sites are therefore regarded as the preferred sites and alternative

sites were not considered. Moreover, site alternatives were not considered due to lack

of surface depositional footprint area for the waste.

From a mining and environmental perspective, all residual deposits (tailings and waste

rock material) must disposed of on the land surface in order to sterilize the chrome and

platinum group metals minerals within upper and lower critical zones of the Bushveld

Igneous Complex (BIC)

(x) Statement motivating the alternative development location within the overall site.

(Provide a statement motivating the final site layout that is proposed)

No alternative site were considered due to lack of surface depositional footprint area

for the waste rock material and tailings waste.

h) Full description of the process undertaken to identify, assess and rank the impacts and risks the activity will impose on the preferred site (In respect of the final site layout plan) through the life of the activity. (Including (i) a description of all

environmental issues and risks that were identified during the environmental impact assessment process and (ii) an

assessment of the significance of each issue and risk and an indication of the extent to which the issue and risk could

be avoided or addressed by the adoption of mitigation measures.)

The Department of Environmental Affairs (DEA) Environmental Risk Assessment Approach

(ERA), as well as the Department of Water and Sanitation (DWS) Best Practice Guideline 4 on

Impact Prediction will be used in the assessment and ranking of negative impacts. The ERA

method assesses the significance of potential impacts in terms of Occurrence (Probability and

Duration) and Severity (Magnitude/Intensity and Scale). The combined effect of these two

aspects defines the Significance of each potential impact.

DURATION (D)

5 - Permanent

4 - Long term (ceases with operational life)

3 - Medium term (5-15 years)

2 - Short term (0-5 years)

1 - Immediate

MAGNITUDE (M)

10 - Very high/do not know

8 - High

6 - Moderate

4 - Low

2 - Minor

SCALE (S)

5 - International

4 - National

3 - Regional

2 - Local

1 - Site

0 - None

PROBABILITY (P)

5 - Definite/do not know

4 - Highly probable

3 - Medium probability

2 - Low probability

1- Improbable

0 - None

SIGNIFICANCE POINTS (SP) = (D+M+S) X P

HIGH (H) = >60 POINTS

MODERATE (M) = 30-60 POINTS

LOW (L) = <30 POINTS

NO SIGNIFICANCE = 0

POSITIVE IMPACT

i) Assessment of each identified potentially significant impact and risk

(This section of the report must consider all the known typical impacts of each of the activities (including those that could or should have been identified by

knowledgeable persons) and not only those that were raised by registered interested and affected parties).

ACTIVITYWhether listed or not listed.

(E.g. Excavations, blasting, stockpiles, discard dumps or dams, Loading, hauling and transport, Water supply dams and boreholes, accommodation, offices, ablution, stores, workshops, processing plant, storm water control, berms, roads, pipelines, power lines, conveyors, etc.…etc.…etc.).

POTENTIAL IMPACT

(e.g. dust, noise, drainage surface disturbance, fly rock, surface water contamination, groundwater contamination, air pollution etc….etc…)

ASPECTS AFFECTED

PHASEIn which impact is anticipated

(e.g. Construction, commissioning, operationalDecommissioning, closure, post-closure)

SIGNIFICANCE if not mitigated

MITIGATION TYPE

(modify, remedy, control, or stop)

through(E.g. noise control measures, storm-water control, dust control, rehabilitation, design measures, blasting controls, avoidance, relocation, alternative activity etc. etc.)

E.g.Modify through

alternative method.Control through noise

controlControl through management and monitoring through rehabilitation..

SIGNIFICANCE if mitigated

Excavation, stockpiling,

channelling and berms

Disturbances/changes

to the topography of

the area

(Temporal)

Topography Medium Remedy through

rehabilitation

Medium

Disposal of waste on

land and Inadequate

storage of hazardous

substances

Potential soil and

water contamination;

legal non-compliance;

lost opportunities for

waste recycling

Waste and

hazardous

substances

Medium Control through

management

Low

Construction of support Soil compaction; soil Soil and Land High Control through Medium – Low

facilities and vegetation

clearing.

loss due to wind and

water erosion; change

of land-use from

natural to industrial;

soil pollution due to

hydrocarbon and

cement spillages;

sterilisation of the soil

resource

capability erosion control

measures; remedy

through

rehabilitation;

avoidance through

chemical waste

management;

monitor through

rehabilitation.

Opencast mining,

vegetation clearing and

construction of surface

infrastructure

Habitat loss and harm

to flora and fauna;

Fragmentation of the

habitat resulting in

harm to flora and

fauna;

Fauna mortalities;

habitat degradation

Flora and

Fauna

High negative Control through

management;

Avoidance; modify

through alternative

methods.

Medium

Blasting Human discomfort

and structural

damage; New total

resulting ambient

noise levels elevated

above pre-

development levels

and the actual

increase in ambient

noise levels

Noise/

Vibrations


noise control

measures; manage

through monitoring;

Avoidance, control

through blasting

controls.

low

Topsoil and subsoil

stripping, Transport and

hauling.

Cumulative particulate

emissions

Air Quality Low Control through

management; control

through traffic and

speed control

measures;

low

Storm water control,

stripping, overburden

and berms.

Sheet erosion; dust;

potential pollution by

hazardous

substances; Poor

sanitation and poor

storm water

management;

Deterioration in water

Quality and decrease

in catchment Yield;

Surface Water Medium Control through

management; control

through water

management

structures; monitor

through hydrocarbon

management unity;

remedy through

rehabilitation.

Medium; Low

Tailings storage facility. Groundwater

Availability and

groundwater quality

Ground Water Low Control through

management (water

balance); stop

through shaft design

measures, monitor

through pollution

control dams.

Low

Surface infrastructure Degradation of

wetland Habitat;

increased

sedimentation within

Wetland Low Remedy through

rehabilitation;

relocation;

avoidance; Control

through

Low

the wetlands

increased turbidity;

obstruction of flows,

increased risk of

erosion and water

quality deterioration

management; design

measures.

Storm water control,

topsoil and subsoil

stripping.

Destruction /

disturbance of the

Bierpruit and other

rivers in the area

Aquatic Low Control through

management; control

through water

management

structures; monitor

through hydrocarbon

management unity;

remedy through

rehabilitation.

Low

Construction of facilities,

structures and

associated

infrastructure.

Destruction of

archaeological and

heritage sites

Archaeology

and Heritage

High Control through

management

Low

Construction of access

roads, Hauling and

transport

Increased traffic flow;

dust generation and

noise generation.

Traffic Low Dust control, traffic

and noise control

measures;

Avoidance.

Low

Construction of surface

infrastructure and

tailings storage facility

Aesthetic value and

sense of place

Visual Medium Avoidance; Remedy

through

rehabilitation; Control

Medium

through

management.

Job creation during

construction;

Multiplier effect on

local economy;

Continued corporate

investment in host

communities;

Physical intrusion

Increased social

pathologies;

Increased pressure

on services and

resources.

Socio-

economic

Low Avoidance (hiring of

illegal immigrants

and child labour);

Control through

management;

Increase Awareness

through training,

campaigning and

skills development;

design measures;

traffic control

measure; control

through access

monitoring.

Medium

Opencast mining

activities; Overburden

Removal of ore

bodies; Removal of

the overburden

Geology Operational High None necessary High

Stockpiling of waste

rock residue, tailings

storage facilities,

hauling and transport

Disturbances/changes

to the topography of

the are

Topography Medium to High Rehabilitation,

Control through

management;

Avoidance; modify

through alternative

methods.

Medium

Disposal of waste on

land and Inadequate

Potential soil and

water contamination,

Waste and

Hazardous

Medium Avoidance, Control Low

storage of hazardous

substances

legal non-compliance,

lost opportunities for

recycling.

Substances through management

Construction of facilities,

Stockpiles and berms

Soil compaction; soil

loss due to wind and

water erosion; change

of land-use from

natural to industrial;

chemical pollution of

soil due to

hydrocarbon and

cement spillages;

sterilisation of the soil

resource.

Soil and Land

capability


erosion control

measures; remedy

through

rehabilitation;

avoidance through

chemical waste

management;

monitor through

rehabilitation.

Medium

Opencast operations,

tailings storage facilities

and surface

infrastructure


to flora and fauna,

Fauna mortalities,

Presence of alien and

invasive species

resulting in habitat

degradation

Flora and

Fauna


management;

Avoidance; modify

through alternative

methods, traffic

control measures,

alien and invasive

species control

Medium

Blasting, Structural damage

and Human

discomfort, New total

resulting ambient

noise levels elevated

Vibrations and

noise

Medium to low Control through

noise control

measures; manage

through monitoring;

Avoidance, control

Low

above pre-

development levels

and the actual

increase in ambient

noise levels

through blasting

controls.

Hauling and transport,

opencast mining,

vegetation clearing,


emissions and NO2

emissions

Air Quality Medium Traffic and speed

controls, Control

through

management.

Medium

mining operations,

processing plants,

berms, surface

infrastructure

Sheet erosion; dust;

potential pollution by

hazardous

substances; Poor

sanitation and poor

storm water

management;

Deterioration in water

Quality and decrease

in catchment Yield;

Surface Water Medium Control through

management; control

through water

management

structures; monitor

through hydrocarbon

management unity;

remedy through

rehabilitation.

Low

Underground activities,

opencast works, tailings

storage facility,

processing plants,

tailings dams, stores

Influx of ground water

into mine workings,

Depletion of external

users groundwater

resources and

fountains

Deterioration of

Ground Water High Control through

management, Modify

through alternative

methods,

rehabilitation.

Medium

groundwater quantity

and quality

Opencast mining and

surface infrastructure,

stockpiles.

Degradation of

wetland habitat

Wetland High Rehabilitation,

Avoidance; Control

through

management; design

measures.

Medium

Storm water control Destruction /

disturbance of the

Bierpruit and other

rivers in the area

Aquatic Low Control through

management; control

through water

management

structures; monitor

through hydrocarbon

management unity;

remedy through

rehabilitation, storm-

water control

Low

Opencast pit operations Destruction of

archaeological and

heritage sites

Archaeology

and Heritage

Low Control through

management.

Low

Hauling and transport. Increased traffic flow,

dust generation and

noise generation

Traffic Low Dust control, traffic

and noise control

measures;

Avoidance.

Low

Surface infrastructure Aesthetic value and Visual Medium Avoidance, modify, Medium

sense of place. rehabilitation

Community,

Accommodation, offices,

workshop, cumulative

Job creation ,

Multiplier effect on

local economy,

Dependency on mine

for sustaining local

economy,

Continued corporate

investment in host

communities,

Physical intrusion,

Increased social

pathologies.

Socio-

economic

Medium to High Avoidance (hiring of

illegal immigrants

and child labour);

Control through

management;

Increase Awareness

through training,

campaigning and

skills development;

design measures;

traffic control

measure; control

through access

monitoring.

High

No further impact Geology Decommissioning

Tailings storage

facilities, Hauling and

transport

Resultant Waste Rock

Residue

Topography Medium Control through

management;

Avoidance; modify

through alternative

methods.

Low

No further impact provided rehabilitation

was taken

Waste

Management

Transport and hauling,

Access roads,

demolition

Soil compaction

Erosion on newly

denuded areas,

Soil & Land

capability


management,

Erosion control

Medium to Low

replaced topsoil and

rehabilitated roads

Hydrocarbon pollution

measures, remedy,

design measures,

monitoring through

rehabilitation.

Removal of mining

infrastructure, Access

roads.


to flora and fauna,

Fragmentation of the

habitat,

Fauna mortalities,

Presence of alien and

invasive species

resulting in habitat

degradation.

Flora and

Fauna


management, stop

through destroyal of

invasives, modify

through alternative

method, alien control

measures, traffic

controls

Low

Machinery and

equipment, Cumulative

Ambient noise levels Noise/

Vibrations

Low Noise control,

monitoring.

Low

Hauling and transport,

roads


emissions

Air Quality Low Traffic control

measures,

monitoring through

rehabilitation, dust

control.

Low

No cumulative impact

Surface Water

No impact Ground Water

Cessation of mining Increased

sedimentation within

the wetlands,

Wetland Medium Control through

management, stop

through destroyal of

invasives, modify

Medium to Low

alien species and

water quality

deterioration. Wetland

habitat degradation

through alternative

method, alien control

measures, Remedy.

Mining and processing

plants

Runoff from nearby

rivers resulting in

sedimentation

Aquatic Low None Low

No impact Archaeology

and Heritage

Demolition of surface

infrastructure

Noise due to

increased traffic

volumes

Traffic Low negative None necessary Low

Roads, Cessation of

mining, demolition of

infrastructure

Aesthetic quality and

sense of place

Visual Medium Control through

management;

Rehabilitation

Medium

Cessation of mining,

Communities,

accommodation, offices.

Dependency on mine


economy

Increased social

pathologies

Socio-

economic

Medium to High Avoidance (hiring of

illegal immigrants

and child labour);

Control through

management;

Increase Awareness

through training,

campaigning and

skills development;

design measures;

traffic control

measure; control

Medium

through access

monitoring.

No further impact Geology Closure Phase

No further impact Topography

No further impact Waste

Management

Bare, compacted and

sterile areas

Soil erosion, water

erosion,

Loss of land capability

Loss of land use

Soil and land

capability

Medium to low Rehabilitation;

Control through

monitoring, design

measures, remedy.

Low negative

Rehabilitation sites,

demolished

infrastructure, trenches.

Cumulative Flora and

Fauna

Medium Rehabilitation;

Monitor through

rehabilitation, control

through

management.

Low

No impact Vibrations

Decommissioning

activities, Transport and

hauling, Roads.


emissions and NOX

emissions

Air Quality Low Traffic control

measures,

monitoring through

rehabilitation, dust

control.

Low

No further impact Surface Water

Defunct tailing dam,

underground blasting

activity, backfilling

Potential surface

decant, Long term

quality of seepage

from the tailings

Ground Water Medium Monitoring, modify

through alternative

method.

Medium - Low

storage facilities

Rehabilitation Wetland Habitat

Degradation

Wetland Medium to low

negative

Rehabilitation,

Avoidance; Control

through

management; design

measures.

No further Impact Aquatic

No further Impact Archaeology

and Heritage

No further Impact Noise

No negative impact there will be

improvement in traffic

post operational

phase

Traffic

Aesthetic Value and

sense of place

Visual Medium Control;

Rehabilitation

Communities,

accommodation, offices,

stores.

Dependency on mine


economy

Increased social

pathologies

Socio-

Economic

Medium Avoidance (hiring of

illegal immigrants

and child labour);

Control through

management;

Increase Awareness

through training,

campaigning and

skills development;

design measures;

traffic control

measure; control

through access

monitoring.

The supporting impact assessment conducted by the EAP must be attached as an appendix, marked Appendix 2

j) Summary of specialist reports.

(This summary must be completed if any specialist reports informed the impact assessment and final site layout process and must be in the following tabular

form):-

LIST OFSTUDIES UNDERTAKEN

RECOMMENDATIONS OF SPECIALIST REPORTS

SPECIALIST RECOMMENDATIONS THAT HAVE BEEN INCLUDED IN THE EIA REPORT

(Mark with an X where applicable)

REFERENCE TO APPLICABLE SECTION OF REPORT WHERE SPECIALIST RECOMMENDATIONS HAVE BEEN INCLUDED.

Vibrations It is strongly discouraged to commence blasting operations closer than

250m to occupied structures, as the ground vibrations may be very

disturbing to the community. Indeed, if large enough charges are used,

the ground vibrations may cause damage to structures.

Because of the potential for exceeding acceptable limits with respect to

ground vibration, it is strongly advised that a comprehensive monitoring

programme be instituted to measure ground vibration levels, according to

X

the BS 7385-2:1993 standard.

There are no legal requirements in South Africa for blasting, nor is there

an official protocol regarding frequency of measurement. It is therefore

suggested to monitor the ground vibrations at the sites mentioned when

blasting near them, with the intention being to provide feedback to the

blasters regarding the measured vibration levels. This information may

guide them in designing further blasts in the area.

Air Quality • It is recommended that mitigation measures for the proposed

project be focused on the unpaved haul roads facilitating the transport of

Topsoil, Waste Rock, RoM and product off site. This should be

implemented for Scenario 1, 2 and 3. A control efficiency of 75% through

watering can be achieved for onsite haul roads.

• It is recommended for crushing activities, specifically at the

relative processing plants, that mitigation be managed by means of

enclosing the crusher. 50% control efficiency can be achieved from

enclosing a crusher with a crusher hood.

• It is recommended for materials handling activities, specifically

conveying ore at the Moddergaat Plant to the stockpile and subsequent

loading for external

X

Ecological

Recommendations: Acacia tortilis – Ziziphus mucronata – Peltophorum

africanum Woodland

Considering that the area occurs in between degraded areas the

proposed mining development can be supported in this vegetation unit

X

provided that strict mitigation measures are implemented. Mitigation

measures needed for the development will be discussed under

Recommendations and Management Strategies for Flora

Recommendations: Acacia tortilis – Acacia nilotica Woodland

The mining development can be supported in this vegetation unit. Specific

mitigation measures would be needed considering the pristine state of the

vegetation in general. It is recommended that a section of this woodland

area be conserved adjacent to the drainage channel (flood line zone)

Recommendations: Dense Knob thorn Thickets

Development of the opencast mining development and infrastructure can

be supported in the area, especially considering the encroached state of

the vegetation.

General Recommendations: Old Fields

The proposed activities can be supported in both areas, although

mitigation measures are needed in some areas. The mitigation measures

and recommendations for both major areas are discussed later in the

report.

Recommendations: Rocky Outcrops and Regions

Preferably no development should occur on this high sensitivity rocky

areas. The impact on these areas will be low considering that none of the

proposed activities are planned in the rocky areas and subsequently no

impact rating was considered necessary.

General Recommendations: Degraded Bushveld

The proposed activities can be supported in the degraded areas.

Groundwater

In the case of groundwater the quality thereof is less variable than that of

surface water and can therefore accommodate lower sampling

frequencies. It is therefore recommended that groundwater samples be

taken on a 3-monthly basis if no formal permit conditions are specified

The following data capture protocols are recommended to be considered

during the groundwater monitoring at Cronimet upon commencement of

operations.

a) Monitoring / Sampling Technique

b) Sample Preservation / Submission to Laboratory

c) Variables to be analysed: It is recommended that consideration be

given to the analyses of the groundwater for the following water quality

variables: pH, Electrical Conductivity (EC), Total Dissolved Solids (TDS),

Calcium as Ca, Magnesium as Mg, Sodium as Na, Potassium as K, Total

Alkalinity as HCO3, Chloride as Cl, Sulphate as SO4, Fluorite as F, Iron

as Fe, Manganese as Mn and Aluminium as Al.

d) Database Entry and Backup: In order to ensure that accurate and fast

decisions can be taken, it is recommended that an environmental

monitoring database be used, that allows for complex queries and which

facilitates seamless transformation of data into reports and maps. The

electronic storage of data is thus of utmost importance. The database

should typically have full GIS capabilities and hold data in such a manner

that it can easily be accessed.

X

Surface water and storm

water management

• Contain all dirty runoff from the TSF in a system compliant with

Regulation GN704 and return all process water to the process plant

system. This will require inter alia:

o A RWD with sufficient capacity and liner system

o Upgraded seepage channels around the toe of the TSF

o Sediment trap facilities to facilitate effective maintenance and

ensure serviceability of structures

• Improve the separation of clean and dirty water especially around

the TSF and contractor’s yard areas

o Clean runoff from the solar panel area currently comes into

contact with dirty water seepage from the RWD and the channel and berm

system must be upgraded or rerouted

o This may include the option to include the runoff from the solar

panel area with the rest of the dirty storm water system

• Contain all affected runoff from the disturbed areas with a system

compliant with legislation.

o Construct a SWD with sufficient capacity and liner system

o Upgrade and extend the current channel and berm system to

improve drainage

o Sediment trap facilities to facilitate effective maintenance and

ensure serviceability of structures

Furthermore, he monitoring of areas where water is being handled must

continue as per current practice. This will support to quantify the exact

impact of mining on surface water and may be used in future to indicate

the extent and severity of any possible impact.

X

The client is advised and encouraged to take regular water samples at as

many points as possible where surface runoff may pond for some time,

e.g. toe paddocks around soft and hard overburden stockpiles. This will

give an indication of the actual water quality from mining related activities

and disturbance and if acceptable will allow the client to discharge of

excessive runoff instead of constructing facilities to contain all possible

runoff.

. It is imperative that the proposed water management structures at the

TSF is upgraded and the area effectively fenced off in order to address

the concern from the affected parties that livestock can utilise the

contaminated water.

Wetlands

The mining activities should not traverse across the riparian zone forming

the tributary of the Bierspruit and existing impacts should be minimised by

carefully planning access routes. The following mitigation measures apply:

To minimise the disturbance to wetland areas, care should be taken to

locate all construction servitudes outside the wetland areas. The wetland

areas should be fenced off prior to the start of construction to prevent

injudicious driving of heavy machinery within the wetlands. Where the

servitudes do intrude into the wetlands, these areas will need to be ripped

and re-vegetated following the completion of construction.

X

Soil, land-use and capability

Soil management during construction is the key process in determining

X

rehabilitation effectiveness. Therefore soil stripping guidelines should be

developed for the construction crews which define clearly the soil horizons

to be removed and where and how to store them.

The aim of the soil management plan is to provide these guidelines that

should be followed during any phase of land preparation, clearing of

vegetation or general construction activities.

1. Planning of topsoil stripping

2. Supervision during topsoil stripping

3. Timing of topsoil stripping

4. Strip and replace in one action wherever possible

5. Locate soil stockpiles so that re-handling of soil is minimised

6. Ensure free draining location

7. Minimise compaction during stockpile creation

Cumulative impacts are related to increase in the surface footprint. These

can be reduced by keeping the footprint minimised where possible and

strictly following soil management measures pertaining to topsoil stripping,

stockpiling and conservation of the soil quality of topsoil stockpiles.

Noise

Due to the low significance of the noise impact the application of specific

noise mitigation measures is not required. However, the following

recommendations concerning good engineering practice are made:

• All diesel powered equipment must be of high quality and well

maintained

X

• Maintenance must be regular, schedules adhered to and include

the exhaust and intake mufflers of engines

• Maintenance must include a sound check of the equipment

• During operating conditions changes in the perceived noise

characteristics must result it being withdrawn for maintenance/repairs

Heritage

• It is recommended that a heritage resources management plan

must be developed for managing the heritage resources in the study area

during construction and operation of the development. This can include

basic training for construction staff on possible finds, action steps for

mitigation measures and communication routes to follow in the case of a

discovery.

• It is recommended that a heritage audit report is compiled

together with the heritage management plan that will include the status

quo of sites previously identified.

• According to the paleontological map the paleontological

sensitivity of the area is insignificant and according to SAHRIS no further

studies are required.

• Any change to the current layout will have to be assessed by an

archaeologist/heritage specialist.

X

Visual

From the discussions and assessment in the report it is clear that the

proposed mining amendment will be located within an area that already

contains similar mining activities and structures. The views from the

X

nearest sensitive viewers already include the existing mining structures

and activities. However, a higher visual exposure would result as the

proposed amendment activities and structures are nearer that the existing

ones. This higher exposure should however not prevent environmental

authorization. From a visual perspective, it therefore appears that there

are no logical reason that environmental authorization could not be

granted.

Social In order to enhance the benefits of employment creation for these

communities, it is recommended that the measures be implemented as

follows:

■ In order to ensure that employment practices comply with

TCMM’s local recruitment policy, it is recommended that recruitment be

coordinated through the local Department of Labour (DoL) rather than on-

site. A registry should be kept at the local DoL offices where job-seeking

individuals can document their relevant qualifications, work experience

and contact details;

■ If required, the local resident status of applicants should be

verified in consultation with community representatives;

■ In order to promote the creation of employment opportunities for

women and youth, it is recommended 10% of local employment

opportunities be reserved for women and younger persons, respectively.

These positions may only be filled with persons outside of these

categories if it can be demonstrated that no suitable persons are recorded

in the skills registry to fill these positions. The performance indicator for

the promotion of employment of women and youth would be the number

of local women and persons

X

TCMM’s local recruitment policy, it is recommended that recruitment be

coordinated through the local Department of Labour (DoL) rather than on-

site. A registry should be kept at the local DoL offices where job-seeking

individuals can document their relevant qualifications, work experience

and contact details;

If required, the local resident status of applicants should be

verified in consultation with community representatives;

In order to promote the creation of employment opportunities for

women and youth, it is recommended 10% of local employment

opportunities be reserved for women and younger persons,

respectively. These positions may only be filled with persons

outside of these categories if it can be demonstrated that no

suitable persons are recorded in the skills registry to fill these

positions. The performance indicator for the promotion of

employment of women and youth would be the number of local

women and persons under the age of 35 who are employed in the

construction phase of the project;

Establish a monitoring system to ensure that the Contractor

honours the specified employment policy;

Where possible use labour-intensive methods of construction; and

Provide training and upskilling to contract employees.

It is recommended that the mitigation and enhancement measures

included in the report be incorporated into the Environmental Management

Plan (EMP) for the mine and, where relevant, into the contract conditions

to be issued to the contractors. Measures must also be put in place to

monitor and assess implementation of these mitigation measures and to

take corrective action where necessary.

Potential linkages and synergies with local and regional development

planning:

An influx of workers and job-seekers into the area could contribute toward

the spread of HIV/AIDS, and that this risk could be mitigated through an

awareness and support campaign. It is strongly recommended that such

a campaign be aligned with the activities of Thabang Children’s Project,

which has extensive experience of working in the area and of the specific

challenges faced by its inhabitants

Attach copies of Specialist Reports as appendices

Environmental impact statement

(i) Summary of the key findings of the environmental impact assessment;

The leaching of contaminants to surface and groundwater from waste rock that has been

backfilled has been identified as a potential impact. These contaminants may include

chromium, manganese and nickel. The significance of the impact will depend on the

extent to which there are receptors (such as ecosystems, communities, farmers) whom

are reliant on surface and/or groundwater for their livelihoods, as well as the fate and

transport of these contaminants within the surface and groundwater. Based on the

waste classification, the impact can be mitigated through appropriate construction and

management of the waste facilities.

The proposed additional mining and processing activities at Thaba Cronimet Chrome

Mine will definitely impact on the flora and fauna of the area. Vegetation clearing and

topsoil stripping will have the most definite and permanent direct negative impact on the

flora and fauna of the area during the construction phase of the mine. Considering the

cumulative impacts of the mining phases on the fauna and flora of the area, it can be

concluded that the current degraded state of the vegetation and fauna habitats caused

by the surrounding and on site mining activities, will cause some negative impacts,

although the implementation of a rehabilitation and revegetation plan will allow the

vegetation to recover over time and the fauna to return to the area. The mining

development can be considered as viable as a result of the fragmented state of the

vegetation and fauna habitats and the degraded state of the ecosystem caused by

nearby villages and other local mining activities

Although the land capability and soil quality of land affected by surface footprint

expansion of mining and processing activities will be compromised, the clayey nature of

soils present in the area reduces its erodibility and makes it more stable for stockpiling

purposes. The proposed opencast mining operations will not impact on any current crop

production and will therefore not affect primary grain production, only livestock farming

activities. As long as soil management measures are followed and land be rehabilitated

to the highest standard possible, it is of the opinion that the activity may be authorised.

From an air quality management perspective, all three scenarios (based on the mining

and development schedules) included as part of the air quality assessment resulted in

simulated impacts within the relative NAAQS and NDCR at all sensitive receptors. With

mitigation measures in place, comprising mainly of dust suppression on haul roads, the

impact areas are significantly reduced than without mitigation. From an air quality

perspective, the proposed additional mining and processing activities and associated

infrastructure can proceed provided the recommended mitigation measures are

implemented

The majority of anticipated impacts on the wetland system at Thaba Cronimet Chrome

Mine can be adequately mitigated and restricted to within the mining rights area. In

addition, the wetland system which will be most impacted by the proposed

developments, the Trollope Wetland, is considered a seriously modified and artificially

maintained wetland system. The impact to this wetland is therefore not considered to be

of high significance. We would therefore suggest that, from a wetland perspective, the

proposed additional mining and processing activities and associated infrastructure may

be authorised, under condition of full implementation of the mitigation measures

proposed in this report.

From a surface water and storm water management perspective, the Thaba Cronimet

Chrome Mine footprint lies on a flat area and the clayey soils are not prone to erosion.

The process used to wash and recover chromite does not contain hazardous chemicals

and there is no risk of acid mine drainage in the natural geological formations.

Additionally the natural vegetation is not sensitive and the water sources are not

declared protected. The closest river is not at risk of pollution even if an unforeseen

storm event or accident occurs. If CCMSA follows the directives in this report and

rectifies the non-compliances currently on site, there is no logical reason why the

environmental authorisation cannot be issued for the proposed additional mining and

processing activities and associated infrastructure

From a geohydrological perspective, the proposed additional mining and processing

activities and associated infrastructure at Thaba Cronimet Chrome Mine could be

authorised, under condition of full implementation of the mitigation measures proposed

in this report as the aquifer units are not classified as sensitive and/or high yielding;

ground water make is a small component of the overall water balance, mining activities

will not influence the surface/groundwater interface in terms of interline or intersection

flow and ore and waste rock classification show a low to very low potential for

deterioration in ground water qualities.

It has been established from an archaeological and heritage perspective, that two sites

will be directly impacted by the proposed additional mining and processing activities and

associated infrastructure at Thaba Cronimet Chrome Mine, namely site one and site two.

If the mitigation measures as per Section 26 are adhered to and based on approval from

SAHRA, it is of the opinion that the development can continue as the impact of the

development on heritage resources will be acceptable after mitigation measures are

implemented successfully prior to the construction phase. If during construction, any

archaeological finds are made

(E.g. graves, stone tools, and skeletal material), the operations must be stopped, and

the archaeologist must be contacted for an assessment of the finds

With regards to impacts from vibrations, structures are unlikely to get damaged,

regardless of blast design, at locations further than 250m to the blasting site. Humans

will get disturbed at 250m, if the charges are more than 150kg. Therefore, in cases

where humans may be disturbed it is recommended to carefully design the blast so as to

limit the explosive charge as much as possible. For sensitive receptors closer than

100m, blasting should be reconsidered as occupant discomfort is highly likely and

structural damage a reasonable possibility. Due to these sensitivities, blasts should be

designed by a person holding a National Certificate in Rock Breaking (qualification ID

62869) or equivalent. A monitoring programme, according to the BS 7385-2:1993

standard, is recommended to measure and evaluate the blasts and may provide further

insights to the actual vibration levels experienced during blasts

The current ambient noise levels generally fall within those recommended in SANS

10103 5. The modelling results indicate that impacts of noise emissions from the Thaba

Cronimet Chrome Mine during all the phase, i.e. construction, above ground and

underground operations will at most be of an insignificant severity. This means that the

total resulting ambient noise levels caused by the noise emissions will still fall within

those recommended by SANS 10103 5. In terms of this document’s guidelines the

expected community reaction to increases in ambient noise levels will at most be ‘little’

with ‘sporadic complains’. The overall the significance of the noise impact caused by

Thaba Cronimet Chrome Mine have been rated as low.

From a visual assessment is clear that the proposed additional mining and processing

activities and associated infrastructure will be located within an area that already

contains similar mining activities and structures. The views from the nearest sensitive

viewers already include the existing mining structures and activities. However, a higher

visual exposure would result as the proposed additional activities and structures are

nearer than the existing infrastructure and activities. This higher exposure would

however not result in much higher rated significant impacts. The qualitative and

quantitative assessment resulted in medium rated impacts for all mining and processing

activities and infrastructure during all phases. After successful rehabilitation, already

starting in the operational phase, the post closure phase will however result in a ‘low’

significance of the impact on the visual resource. From a visual perspective, it therefore

appears that there is no logical reason that environmental authorization could not be

granted.

With regards to socio-economic impacts, if all mitigation measures are implemented

according to the recommendations provided in the specialist report, it is anticipated that

the consequence and/or probability of the majority of the negative impacts will be

reduced. The post-mitigation significance ratings of positive impacts, on the other hand,

are higher than their pre-mitigation ratings, being rated as medium as opposed to low.

However, the most significant cumulative impacts are expected to arise because of the

combined effects of the proposed project and other, existing mining operations in the

area. These cumulative impacts relate to the large-scale rather than site- specific

impacts associated with a concentration of mining projects – namely, their tendency to

dominate the local economy, thereby causing the local economy to become increasingly

dependent on mines that inevitably have a finite lifespan, and their tendency to dominate

the landscape and irrevocably alter an area’s sense of place.

CCMSA realise that long-term economic success can only be achieved through

sustainable operation and their understanding that their business activities can have

social and environmental impacts. In line with CCMSA’s approach and given the legal

framework of South Africa, it is our considered opinion, based on the conclusions of the

specialist studies, that provided that if CCMSA strictly implement all mitigation measures

and monitoring requirements as outlined in Sections 27 and 28 there is no reason why

the authorisation for proposed additional mining and processing facilities at Thaba

Cronimet Chrome Mine should not be granted. It is of our opinion that provided the EMP

is implemented effectively and timeously, the resultant environmental and social impacts

would not be of an unacceptable significance and post closure all residue environmental

and social impacts, other than seepage from the tailings storage facilities and social

pathology impacts as a result of the mine, will be of a low significance.

(ii) Final Site Map

Provide a map at an appropriate scale which superimposes the proposed overall activity and its associated structures and infrastructure on the environmental sensitivities of the preferred site indicating any areas that should be avoided, including buffers .Attach as Appendix 4

(iii) Summary of the positive and negative implications and risks of the proposed activity and identified alternatives;

Geology

Removal of Ore bodies and overburden

Topography

Disturbances or changes to the topography area

Waste and hazardous substances

Potential soil and water contamination, legal non-compliance and lost opportunities for

waste recycling

Soil and Land capability

Soil compaction, soil loss due to wind and water erosion;

Change of land-use from natural to industrial

Soil pollution due to hydrocarbon and cement spillages

sterilisation of the soil resource

Flora and Fauna

Habitat loss and harm to flora and fauna

Fragmentation of the habitat resulting in harm to flora and fauna;

Fauna mortalities and Habitat degradation

Noise/ Vibrations

Human discomfort and structural damage;

New total resulting ambient noise levels elevated above pre-development levels and the

actual increase in ambient noise levels

Air Quality

Cumulative particulate and NO2 emissions

Surface Water

Sheet erosion and dust generation

Potential pollution by hazardous substances

Poor sanitation and poor storm water management

Deterioration in water Quality and decrease in catchment Yield;

Ground Water

Groundwater Availability and groundwater quality

Wetland

Increased sedimentation within the wetlands

Increased turbidity and obstruction of flows,

Increased risk of erosion and water quality deterioration

Aquatic


Archaeology and Heritage


Traffic

Increased traffic flow

Dust generation and noise generation.

Visual

Aesthetic value and sense of place

Socio-economic

Job creation during construction;

Multiplier effect on local economy;

Continued corporate investment in host communities;

Physical intrusion

Increased social pathologies;

Increased pressure on services and resources

l) Proposed impact management objectives and the impact management outcomes for inclusion in the EMPr; (Based on the assessment and where applicable the recommendations from specialist reports, the

recording of proposed impact management objectives, and the impact management outcomes for the

development for inclusion in the EMPr as well as for inclusion as conditions of authorisation.)

The waste management licence report will address all negative environmental impacts as a

result of the residual deposits (tailing waste and waste rock material) on portions of the farm

Middellaagte 382 KQ and Moddergat 389 KQ.

Description of the appropriate objectives, technical/management options and action plans

selected for each environmental impact and action plans will be made.

The impact management objectives will seek to:

1. Prevent and minimise pollution on the environment

2. Rehabilitate the site to its pre-existing land use

CONSTRUCTION PHASE

Impacts Objectives

Inadequate storage of hazardous

substances resulting in potential

soil and water contamination

Eliminate the potential to pollute soil and water resources

Incorrect disposal of wastes

resulting in potential soil and

water contamination

To dispose of waste in a legal and responsible manner and in line

with the duty of care and precautionary principle of waste

management

Lost opportunity for recycling or

re-use

To reduce the disposal of waste in line with the duty of care and

precautionary principles of waste management.

Loss of soil Minimise soil loss through water and wind erosion

Habitat loss and harm to flora

and fauna

Limit habitat loss due to an increase of the mining footprint

Habitat loss and fragmentation

resulting in impact on fauna

Limit habitat loss and thus impact on fauna populations due to an

increase of the mining footprint and unnecessary fragmentation

Impacts Objectives

populations

Fauna mortalities Prevent fauna mortalities as a result of vehicle movement

Presence of alien and invasive

species on site resulting in legal

compliance and habitat

degradation

To manage and control alien species on the mine

Unacceptable levels of vibration

resulting in structural or cosmetic

damage

Reduce ground vibrations to levels where no structural or cosmetic

damage is incurred by nearby structures.

Higher ambient noise levels

Keep ambient noise levels outside of the mineral lease area within

the requirements of SANS 10103

Impacts Objectives

Minimize community reactions to an increase in ambient noise

levels

Detect changes in equipment noise emissions level

Effectively respond to noise complaints

Communities reacting to an

increase in ambient noise levels

Increased dust generation Dust fall in the immediate vicinity of various sources should be less

than 1 200 mg/m2/day.

Dust fall immediately downwind of the discard dump, tailings

storage facility, product and storage piles to be <1 200 mg/m²/day.

For active haul roads on-site of the mine it is recommended that

dustfall in the immediate vicinity be <1 200 mg/m2/day.

Dust fall at sensitive receptors to be <600 mg/m²/day.

Achieve a road efficiency of 75%.

Ground water contamination To prevent contamination of groundwater at the box cuts, shaft

complex, process plant and the tailing dam footprint during the

construction phase.

Inadequate dirty water and clean

water separation resulting in

water and soil contamination

Maintain clean and dirty water separation at all times according to

GN 704 of the NWA

Illegal water uses Obtain authorisation for all water uses

Impacts Objectives

Deterioration of ecological

sensitivity of wetland areas

Avoid activities being undertaken within wetland areas

Eliminate impacts on the ecological sensitivity of wetland areas

Disturbance/damage to

archaeological/heritage artefacts

To comply with the requirements of The National Heritage

Resources Act (Act No 25 of 1999)

Increased traffic flow Minimise the effects of construction vehicles on the traffic flow in

the area

Loss of aesthetic value To minimise the impacts of the proposed operations on the scenic

quality of the visual resource

Job creation (positive) To increase the percentage of the workforce from the local area

To have 10% of local employment opportunities reserved for

women and younger persons

Comply with labour legislation

To improve work opportunities for the local community

To enhance the skills and knowledge of the workforce.

Multiplier effects on the economy

(positive)

Contribute to the local economy

Continued corporate investment

in host communities (positive)

Upliftment of communities where CCMSA operations

Physical intrusion in terms of

disruption in movement patterns

Minimise disruption in movement patterns within the local

community

Impacts Objectives


increased risk to community

health and safety

Reduce risk of proposed operations to community health and safety


community education

Enhance community awareness of forums and procedures in place

Population influx resulting in

increased social pathologies

Reduce social pathologies as a result of the mine expansion


increased pressure on services

Minimal to no increase in the pressure on services and resources

OPERATIONAL PHASE

Impact Objectives

Inadequate environmental

management

Implement and maintain an Environmental Management

System in compliance with the requirements of the ISO 14 001

(2004) South African National Standard as well as with the

requirements of the IFC


substances resulting in potential soil


Impact Objectives

and water contamination

Incorrect disposal of wastes

resulting in potential soil and water

contamination

To dispose of waste in a legal and responsible manner and in

line with the duty of care and precautionary principle of waste

management.

Lost opportunity for recycling or re-

use

To reduce the disposal of waste in line with the duty of care and

precautionary principles of waste management.

Loss of soil, soil capability and

fertility, soil pollution and sterilisation

of soil. Land use change from

natural to grazing

Minimise impacts such as erosion, compaction and chemical

pollution of soils.

Habitat loss and harm to flora and

fauna

Limit habitat loss due to an increase of the mining footprint

Impact Objectives

Habitat loss and fragmentation

resulting in impact on fauna

populations

Limit habitat loss and thus impact on fauna populations due to

an increase of the mining footprint and unnecessary

fragmentation

Fauna mortalities Prevent fauna mortalities as a result of vehicle movement and

hunting



compliance and habitat degradation


Unacceptable levels of vibration

resulting in structural or cosmetic

damage

Reduce ground vibrations to levels where no structural or

cosmetic damage is incurred by nearby structures.

Higher ambient noise levels Keep ambient noise levels outside of the mineral lease area

within the requirements of SANS 10103


levels



Communities reacting to an increase

in ambient noise levels

Increased particulate matter/dust

generation

Dust fall in the immediate vicinity of various sources should be

less than 1 200 mg/m2/day.

Dustfall immediately downwind of the discard dump, tailings

storage facility, product and storage piles to be <1 200

Impact Objectives

mg/m²/day.

For active haul roads on-site of the mine it is recommended that

dustfall in the immediate vicinity be <1 200 mg/m2/day.

Dustfall at sensitive receptors to be <600 mg/m²/day.Deterioration of ecological sensitivity

of wetland areas

Avoid activities being undertaken within wetland areas

Eliminate impacts on the ecological sensitivity of wetland areas

Disturbance/damage to

archaeological/heritage artefacts

To comply with the requirements of The National Heritage

Resources Act (Act No 25 of 1999)

Inadequate dirty water and clean

water separation resulting in water

and soil contamination

Maintain clean and dirty water separation at all times according

to GN 704 of the NWA.

Unknown water use Optimise the use of dirty water

Influx of ground water To not discharge dirty/contaminated water into the environment

Depletion of external users water

resources

To not compromise the supply of ground water to existing users

Impact Objectives

Deterioration of groundwater quality

in the mining section and seepage

into the receiving environment

To not discharge dirty/contaminated water into the environment

Interflow between adjacent mines Effectively maintain records should water flow or be pumped to

adjacent sections

Potential pollution from tailings

storage facility

Minimise impact on ground water

Increased traffic flow

Loss of aesthetic value To minimise the impacts of the proposed operations on the

scenic quality of the visual resource

Job creation (positive) To increase the percentage of the workforce from the local area

To have 10% of local employment opportunities reserved for

women and younger persons

Comply with labour legislation

To improve work opportunities for the local community

To enhance the skills and knowledge of the workforce.

Multiplier effects on the economy

(positive)

Contribute to the local economy

Dependency on the mine for

sustaining local economy

Reduce dependency on mine in event of reducing production or

down scaling

Continued corporate investment in

host communities

Upliftment of communities where CCMSA operations


disruption in movement patterns

Minimise disruption in movement patterns within the local

community


increased social pathologies

Reduce social pathologies as a result of the mine expansion

Impact Objectives


increased pressure on services and

resources

Minimal to no increase in the pressure on services and

resources

DECOMMISSIONING AND REHABILITATION PHASE

Components Objectives


management


System in compliance with the requirements of the ISO 14

001 (2004) South African National Standard as well as with

the requirements of the IFC


substances resulting in potential soil

and water contamination


Incorrect disposal of wastes resulting

in potential soil and water

contamination

To dispose of waste in a legal and responsible manner and in

line with the duty of care and precautionary principle of waste

management.

Loss of soil, soil capability and fertility,

soil pollution and sterilisation of soil.

Land use change from natural to

grazing

Minimise compaction and erosion of soils by backfilling and

rehabilitating correctly



compliance and habitat degradation


Fauna mortalities Prevent fauna mortalities as a result of vehicle movement and

hunting


Higher ambient noise levels Keep ambient noise levels outside of the mineral lease area

within the requirements of SANS 10103


levels



Communities reacting to an increase

in ambient noise levels


generation

Dust fall in the immediate vicinity of various sources should be


Dust fall immediately downwind of the discard dump, tailings


mg/m²/day.

For active haul roads on-site of the mine it is recommended

that dustfall in the immediate vicinity be <1 200 mg/m2/day.

Dustfall at sensitive receptors to be <600 mg/m²/day.

Road efficiency of 75%

Soil and water pollution Minimise impacts to the surface water during

decommissioning phase

Influx of ground water To not discharge dirty/contaminated water into the

environment

Depletion of external users water

resources

To not compromise the supply of ground water to existing

users

Deterioration of groundwater quality in

the mining section and seepage into

the receiving environment

To not discharge dirty/contaminated water into the

environment

Interflow between adjacent mines Effectively maintain records should water flow or be pumped

to adjacent sections

Potential pollution from tailings Minimise impact on ground water


storage facility

Loss of aesthetic value To minimise the impacts of the operations on the scenic

quality of the visual resource

Population influx resulting in increased

social pathologies

Reduce social pathologies

Dependency on the mine for

sustaining local economy

Reduce dependence on mine in event of reducing production

or down scaling

CLOSURE AND POST CLOSURE PHASE

Impact Objectives


management


System in compliance with the requirements of the ISO 14 001

(2004) South African National Standard as well as with the

requirements of the IFC

Unacceptable environmental impacts

during and post closure

To eliminate unacceptable environmental impacts and to

minimise risk and liability

Soil erosion, especially water erosion

because of poor infiltration of rain due

to the compaction.


To rip, vegetate and ameliorate soils with fertilizer and

compost

Decreased habitat quality and effects

on fauna populations

To rehabilitate all disturbed areas to a suitable post closure

land use and standard as agreed with the landowners

Impact Objectives


generation

Dustfall in the immediate vicinity of various sources should be


Dustfall immediately downwind of the discard dump, tailings


mg/m²/day.

For active haul roads on-site of the mine it is recommended

that dustfall in the immediate vicinity be <1 200 mg/m2/day.

Dustfall at sensitive receptors to be <600 mg/m²/day.

Road efficiency of 75%

Ground water deterioration To stabilize the alternative water supply to external users

whose groundwater resources have been impacted and to

prevent any migration of polluted water from the mining

sections and the tailing dam

Loss of aesthetic value To minimise the impacts of the proposed operations on the

scenic quality of the visual resource

m) Final proposed alternatives.

(Provide an explanation for the final layout of the infrastructure and activities on the overall site as shown

on the final site map together with the reasons why they are the final proposed alternatives which respond

to the impact management measures, avoidance, and mitigation measures identified through the

assessment)

Refer to annexure A for the proposed site layout plan.

n) Aspects for inclusion as conditions of Authorisation. (Any aspects which have not

formed part of the EMPr that must be made conditions of the Environmental Authorisation)

The operational activities and relevant rehabilitation of disturbed areas should be monitored

against the approved EMPr, the Environmental Authorization (once issued) and all other

environmental legislation.

Relevant conditions to be adhered to include:

- The Tailings Storage Facility and associated structures and infrastructures must be well

maintained

- The tailings and waste rock dumps as well as quantities should be monitored on a

regular basis

- - A properly qualified person should be appointed to manage the TSF

- The EMPr should be binding on all managers and contractors operating/ utilizing the

site.

o) Description of any assumptions, uncertainties and gaps in knowledge. (Which

relate to the assessment and mitigation measures proposed)

The processes of investigation which have led to the production of this report, harbours several

assumptions, which include the following:

All information provided by CCMSA to Worley Parsons RSA was correct and valid at the

time that it was provided;

The mining schedule used in the assessment of impacts was the schedule that was

approved by CCMSA on the 11 June 2015.

The public received a fair and reoccurring opportunity to participate in the EIA process,

through the provision of public participation timeframes stipulated in the Regulations;

The need and desirability was based on strategic national, provincial and local plans and

policies which reflect the interests of both statutory and public viewpoints;

The information provided by specialists is accurate and unbiased;

Soil, Land Use and Capability Specialist Study

The scope of the work done is as per the areas outlined

Access to a portion of land belonging to the Sebilong CPA was denied for the purposes

of the site visit. Properties of land in this area has been derived with digital soil mapping

techniques;

A portion of land to the southern end of the subject area is mainly occupied by human

settlement and survey points could only be evaluated at much lower density than the

surrounding areas;

The study does not include land contamination assessment of the areas currently being

mined and in close vicinity to the mining areas. Metal analysis of soil was only for the

purposes of determining current baseline values of natural veld conditions.

Ecological Specialist Study

In order to obtain a comprehensive understanding of the dynamics of the flora and fauna

of the study area, surveys should ideally be replicated over several seasons and over a

number of years. However, due to project time constraints such long-term studies are

not feasible and this floral study was conducted over two seasons;

The large study area did not allow for the finer level of assessment that can be obtained

in smaller study areas. Therefore, data collection in this study relied heavily on data from

representative, homogenous sections of vegetation units, as well as general

observations, aerial photograph analysis, generic data and a desktop analysis;

Visibility proved to be a constraint in encroached areas where plant species might have

been missed beneath the densely overgrown and obstructed by surface vegetation

Thus, even though it might be assumed that survey findings are representative of the

ecosystem of the project area, it should be stated that the possibility exists that individual

plants species might have been missed due to the nature of the terrain (dense

vegetation). Therefore, maintaining due cognisance of the integrity and accuracy of the

ecological survey, it should be stated that the ecological resources identified during the

study do not necessarily represent all the ecological resources present on the property.

Vibration Specialist Study

The composition of the ground has an effect on the severity of the vibration propagation

due to blasting. As chrome is mined in hard rock, the worst case “hard rock” parameters

were selected as further detailed in section 4.2 of the Vibration Specialist Report in

Appendix 3.

Locations 8, 11 and 18 as outlined in the Vibration Specialist Report were not measured

due to being very close in proximity to points 7, therefore negating the need for separate

measurements. For a similar reason, location 16 and 19 was not measured, due to its

proximity to location 9. Location 15 was found to be inaccessible. As it lies between

locations 8 and 12, the average peak particle velocity of these two locations were used

as an estimate to the background peak particle velocity of 15.

Air Quality Specialist Study

No meteorological data are available for the immediate area with the nearest

meteorological station to site located at Thabazimbi, 27 km to the north. For dispersion

simulations, a minimum of three years of meteorological data is required. MM5 data for

the study region was used for the period of January 2011 to December 2013;


approved by CCMSA on the 11 June 2015. It however can be noted that the changes to

the mining schedule subsequent to the finalisation of the air quality model and impact

assessment does not result in a significant change to results simulated in the air quality

model. This change in schedule does not result in a new ‘worst case’ scenario on which

the model is based and we are of the opinion that the “worst case” scenarios have been

investigated and that Receptor 4 remains the most effected, whether using the old

mining schedule or the new one.

Current operating conditions were included in the 2010 Air Quality Assessment. These

simulations are considered still relevant and correct, thus only approved opencast,

proposed opencast and post 2030 underground operations are included in this

assessment

No ambient monitored concentration data are available for the site (PM10 and PM2.5);

The impact assessment was limited to airborne particulates as well as gaseous

pollutants from blasting and vehicle exhaust emissions (including Total Suspended

Particles, PM10 and PM 2.5, NOx and SO2);

Gaseous emissions from vehicle exhaust include NO2 and SO2. All NOx was assumed

to be NO2 as a conservative approach;

It was provided that cartridge explosives are planned for in-stope, with Anfex for

development in the conventional mining sections and emulsion for all the mechanised

sections. The amount of explosive used per blast was not provided and information from

similar operations was used;

Only diesel fuel is included in this assessment and assumed to be used by vehicles in

both the proposed underground (trackless – North section) and opencast operations;

Vehicle tailpipe emissions were calculated on generic fuel use parameters for different

diesel powered vehicles operating at the proposed site. It was assumed that the sulphur

content of the fuel used is 50 parts per billion, or 0.05%;

Opencast haul trucks (to transport overburden and ore) are assumed to have a 40 tonne

load-carrying capacity. Haul trucks transporting product off-site are assumed to have a

40 tonne load-carrying capacity;

Since it is a proposed mine, no site specific particle size fraction data for the various

sources were available and use was made of information obtained from the existing

mines in the region and from available EIAs;

The dispersion model (AERMOD) cannot compute real time mining processes, therefore

average mining process throughputs were utilised. Thus even though the nature of the

open pit mining operations (pit utilisation and roads) change over the life of mine, the

proposed open pit mining area was modelled to reflect the worst case condition (i.e.

resulting in the highest impacts);

Routine emissions for the proposed operations were simulated – based on maximum

mine production rates. Atmospheric releases occurring as a result of non-routine

conditions were not accounted for;

All on-site roads in use and surface activities were indicated by the client. These were

digitised from a site layout diagram, which was provided by the client. It is assumed that

this information is accurate and correct;

Crushing activities are assumed to include primary, secondary and tertiary crushing;

Two underground exhaust vents were modelled (responsible for majority of underground

emissions), each releasing 300 m³/s of air and having a release height of 4.5 meters;

Detailed information for underground emissions was not available. It is assumed that

each vent’s emissions will comply with the Mine Health and Safety Regulations limit

value for the relative pollutants (10 mg/m³ for PM10, 3 mg/m³ for PM2. 5, 5 mg/m³ for

both NO2 and SO2);

The amount of surface area available to wind erosion for all stockpiles was assumed to

be 100% availability. This is a conservative approach and emissions from these sources

will in reality be lower;

It has been provided that a maximum production rate for the mine will be 75 000 t/m

month of product from underground mining and 30 000 t/m of product from opencast

mining. It was provided that opencast operations and underground operations will not

occur simultaneously;

A strip ratio of 1:3.5 (ore: waste-rock) was provided by the client. This ratio is assumed

accurate and correct for the current assessment of proposed opencast operations;

A strip ratio of 2.3:1 (ore: waste-rock) was used in the 2010 assessment for underground

operations at Cronimet. This ratio is assumed accurate and correct for the current

assessment of proposed underground operations;

It was assumed that the opencast benches/active areas for drilling and blasting would be

the same dimensions as included in the 2010 Air Quality Assessment - 4000 m². It was

also assumed blasting would take place once a day, five days a week for open cast

operations.

Surface Water Specialist Study

This study excludes any underground operations and ground water studies;

The same hydrological parameters used in the 2010 study are used in this report;

The area drains overland mainly to the north-west and surface water originating from the

Northern Platinum – Zondereinde Mine, south of the Thaba Cronimet Chrome Mine

operation, may have an impact on the surface water at Thaba Cronimet Chrome Mine.

The Zondereinde Mine return water dam below their tailing dams lies directly in the

drainage channel which runs through Thaba Cronimet Chrome Mine and any spillage

may have an impact on the surface water regime at the mine. As it is highly

unpredictable and outside the control of CCMSA, the possibility is excluded from this

study;

The operational status of the sewage facility is excluded from this study;

Implementation of a waste policy and efficiency of the water management structures at

the waste management site and salvage yard to prevent surface water pollution is

excluded from this study;

Ground Water Specialist Study

Since no ground water use changes took place in the immediate surroundings of the

mining lease area, the hydro census data of the previous studies were used. It is

assumed that no further development of ground water abstraction will take place within

500m of mining activities.


approved by CCMSA on the 11 June 2015. It however can be noted that although the

changes to the mining schedule subsequent to the finalisation of the ground water model

and impact assessment will result in changes to the outcome of the ground water model,

we are of the opinion that there will be an insignificant change to the impact on ground

water reserves.

Sufficient data were generated to show very little seasonality in ground water level

fluctuations.

The WARMS database (used as background check) for the previous study has not

changed since the previous study.

Borehole data used for the baseline study shows very low permeabilities. This

assumption was carried forward and will remain, unless future boreholes yield higher

values.

During previous baseline investigations, some external users did not allow access to

land. These owners were in excess of 1km from site and will not be influenced by mining

activities.

Any pollution plume movement from the tailings dam and associated infrastructure will

be monitored by boreholes to be drilled around the facilities, once commissioned.

Experience shows that geohydrological boreholes must be commissioned only once the

footprint areas have been completed.

As surface infrastructure is added or production rates changed during the Life of Mine,

additional monitoring points will have to be added to ensure full compliance in terms of

ground water monitoring.

Wetland Specialist Study

A number of generally accepted assessment methods were utilised within the current

study for the assessment of the wetland and aquatic habitats on site, namely the WET-

EcoServices (Kotze et al., 2009) and the WET-Health (Macfarlane et al., 2009).

Although there are limitations associated with each of these methods, the methods are

generally accepted and widely applied within environmental impact assessments in

South Africa and are deemed adequate for the purpose of this study;

Reference conditions are unknown. This limits the confidence with which the present

ecological category (PES) is assigned;

While an effort was made to visit every wetland within the study area, not every wetland

boundary was walked. Wetland boundaries were verified in the field through sampling a

number of points along transects running perpendicular to the wetland edge and located

along the wetland edge. The wetland edge was then delineated by interpolating between

sampling points along these transects using aerial imagery, and the wetness signatures

visible on these, as a background image. Further to this, due to the scale of the remote

imagery used (1:10 000 orthophotos and Google Earth Imagery), as well as the

accuracy of the handheld GPS unit used to delineated wetlands in the field, the

delineated wetland boundaries cannot be guaranteed beyond an accuracy of about 20 m

on the ground;

Aquatic ecosystems vary both temporally and spatially. Once-off surveys such as this

are therefore likely to miss substantial ecological information, thus limiting accuracy,

detail and confidence; and

Detailed groundtruthing for the wetland delineation was limited to the study area

boundaries and immediate vicinity. The delineations provided for areas outside the study

area are based on desktop wetland mapping only.

Archaeological And Cultural Heritage Specialist Study

Due to the fact that most cultural remains may occur below surface, the possibility exists

that some features or artefacts may not have been discovered/ recorded during the

survey. Low ground visibility of parts of the study area is due to high vegetation and

impact from previous mining activities, and the possible occurrence of unmarked graves

and other cultural material cannot be excluded. This study did not assess living or

intangible heritage.

Only the surface infrastructure footprint area was surveyed as indicated in the location

map, and not the entire farm. Although the area was surveyed as thoroughly as possible,

it is incumbent upon the developer to stop operations and inform the relevant heritage

agency should further cultural remains, such as stone tool scatters, artefacts, bones or

fossils, be exposed during the process of development. It is assumed that the sites

recorded in 2009 are still intact, but this will have to be verified if development in the

area of the sites will proceed prior to mitigation.

Future changes in layout will require a heritage walk through (of areas not previously

covered) and assessment of the impact on known sites. This report must be read in

conjunction with the study conducted in 2009.

Noise Specialist Study

The following assumptions were made in this noise study:

The sampled ambient noise levels are representative of their environments in terms of

location and time of day- and night-time;

The identified habilitated noise sensitive points were based on visual inspection of

satellite images on Google Earth;


approved by CCMSA on the 11 June 2015. It however can be noted that although the

changes to the mining schedule subsequent to the finalisation of the noise model and

impact assessment will result in changes to the outcome of the model, we are of the

opinion that there will be an insignificant change to the impact resulting from noise

generation.

It was decided to determine the combined above and underground construction noise

emissions, thereby presenting a ‘worst case’ – scenario. However, the operational noise

impacts were considered separately; and

The noise emission levels of equipment and processes, operational procedures (e.g.

work cycles), meteorological, atmospheric and ground conditions used in the

calculations are realistic estimates of the actual conditions;

Wherever uncertainties occurred assumptions were made to rather over- than

underestimate the severity of a noise impact;

The propagation of noise is a very complex process, especially over longer distances

between the source and receiver. The basis on which the calculations were made are

average conditions. On the other hand reliable noise level measurements also depend

on a large number of factors that may have an effect on the results. Consequently the

actually measured noise levels may differ significantly from the calculated values; and

The processing of measurement results provides very useful insights. However, it must

be clearly understood that they can only provide an indication of what the noise level

could have been without the specific noise energy contributions in the time or frequency

dominion.

Visual Specialist Study

Digital terrain modelling makes use of the current publically available topographical data

as supplied by the Land Surveyor General.

It is assumed that the mining will be a 24-hour operations.


approved by CCMSA on the 11 June 2015. It however can be noted that the changes to

the mining schedule subsequent to the finalisation of the visual model and impact

assessment will be insignificant to the impact on ground water reserves.

All portals for underground mining will be built at the same time.

For the visual analysis modeling examples of similar structures were used. It is

assumed that the duration of the decommissioning phase would be less than 10 years

Closure Liability Assessment

The closure cost estimate output is aligned to the Guideline Document for the Evaluation

of the Quantum of Closure Related Financial Provision Provided by a Mine, by the DMR

(January, 2005);

Currency of estimate: South African Rand’s (ZAR);

The closure costs for the site could comprise a number of cost components. This report

only addresses the decommissioning and reclamation costs, equating to an outside

(third party) contractor establishing on-site and conducting reclamation-related work.

Other components such as staffing of the site after decommissioning, the infrastructure

and support services (e.g. power supply, etc.) for this staff as well as workforce matters

such as separation packages, re- training /re-skilling, etc. are outside the scope of this

report;

Based on the above, dedicated contractors would be commissioned to conduct the

demolition and reclamation work on the site. This would inter alia require establishment

costs for the contractors and hence, the allowance for preliminary and general (P&Gs) in

the cost estimate;

Allowance has also been made for third party contractors and consultants to conduct

post-closure care and maintenance work as well as compliance monitoring;

Closure costs have been determined for both the premature forecast and Life of

Mine closure situations:

- Life of Mine closure takes place at a planned date and/or within a time horizon, in

accordance with overall mine planning;

- Premature closure entails immediate closure of a site, representing decommissioning

and reclamation of the site in its present state.

In accordance with the DMR guideline, no cost off-sets due to possible salvage values

were considered and therefor gross reclamation costs are reported; and

Fixed percentages for P&Gs and Contingencies have been applied:

o P&G’s – 6%(Due to high value contract); and

o Contingency – 20% (Due to limited and accuracy of information available).

Construction of the chrome plant expansion has already taken place;

The current end land use is grazing;

Quantities of new infrastructure were taken from available plans, where no data was

available assumptions were made based on similar projects and experience;

Steel and related material from the demolition which has a salvage value will be

stockpiled on site to be sold or auctioned off. However as per the DMR guideline, the

salvage value of the steel and salvageable equipment has not been considered as part

of the closure costing;

All inert building waste will be disposed of on-site (open pit), all non-inert waste will be

removed to a licenced disposal facility;

Andru Mining is the current mining contractor, it was assumed that the contractor will be

responsible to remove his own infrastructure in the event of closure. Cronimet is

however still responsible for the rehabilitation of the footprint area;

Main perimeter fence will remain to sustain the end land use;

It has been assumed that all costs related to closure

p) Reasoned opinion as to whether the proposed activity should or should not be authorised

(i) Reasons why the activity should be authorized or not.

In line with CCMSA’s approach and given the legal framework of South Africa, it is our

considered opinion, based on the conclusions of the specialist studies, that provided that if

CCMSA strictly implement all mitigation measures and monitoring requirements as outlined

in Sections 27 and 28 there is no reason why the authorisation for proposed additional

mining and processing facilities at Thaba Cronimet Chrome Mine should not be granted.

Provided the EMP is implemented effectively and timeously, the resultant environmental and

social impacts would not be of an unacceptable significance and post closure all residue

environmental and social impacts, other than seepage from the tailings storage facilities and

social pathology impacts as a result of the mine, will be of a low significance.

(ii) Conditions that must be included in the authorisation

The operational activities and relevant rehabilitation of disturbed areas should be mon-

itored against the approved EMPr, the Environmental Authorization (once issued) and all

other environmental legislation.

Relevant conditions to be adhered to include:

- The Tailings Storage Facility and associated structures and infrastructures must be well

maintained

- The tailings and waste rock dumps as well as quantities should be monitored on a

regular basis

- A properly qualified person should be appointed to manage the TSF

- The EMPr should be binding on all managers and contractors operating/ utilizing the

site.

(1) Specific conditions to be included into the compilation and approval of EMPr

The content of the EMPr is consistent with the requirements as set out in Regulation

19(4) and information contained in Appendix 4 of the EIA regulations (December 2014)

stated below,

1. (1) An EMPr must comply with section 24N of the Act and include-

(a) details of

(i) the EAP who prepared the EMPr; and

(ii) the expertise of that EAP to prepare an EMPr, including a curriculum vitae;

(b) a detailed description of the aspects of the activity that are covered by the EMPr as

identified by the project description;

(c) a map at an appropriate scale which superimposes the proposed activity, its

associated structures, and infrastructure on the environmental sensitivities of the

preferred site, indicating any areas that any areas that should be avoided, including

buffers;

(d) a description of the impact management objectives, including management

statements, identifying the impacts and risks that need to be avoided, managed and

mitigated as identified through the environmental impact assessment process for all

phases of the development including-

(i) planning and design;

(ii) pre-construction activities;

(iii) construction activities;

(iv) rehabilitation of the environment after construction and where applicable

post closure; and

(v) where relevant, operation activities;

(e) a description and identification of impact management outcomes required for the

aspects contemplated in paragraph (d);

(f) a description of proposed impact management actions, identifying the manner in

which the impact management objectives and outcomes contemplated in paragraphs (d)

and (e) will be achieved, and must, where applicable, include actions to –

(i) avoid, modify, remedy, control or stop any action, activity or process which

causes pollution or environmental degradation;

(ii) comply with any prescribed environmental management standards or

practices;

(iii) comply with any applicable provisions of the Act regarding closure, where

applicable; and

(iv) comply with any provisions of the Act regarding financial provisions for

rehabilitation, where applicable;

(g) the method of monitoring the implementation of the impact management actions

contemplated in paragraph (f);

(h) the frequency of monitoring the implementation of the impact management actions

contemplated in paragraph (f); an indication of the persons who will be responsible for

the implementation of the impact management actions;

(i) the time periods within which the impact management actions contemplated in

paragraph (f) must be implemented;

(j) the mechanism for monitoring compliance with the impact management actions

contemplated in paragraph (f); a program for reporting on compliance, taking into

account the requirements as prescribed by the Regulations;

(k) an environmental awareness plan describing the manner in which-

(i) the applicant intends to inform his or her employees of an environmental risk

which may result from their work; and

(ii) risks must be dealt with in order to avoid pollution or the degradation of the

environment; and

(l) any specific information that may be required by the competent authority.

2. Rehabilitation requirements

The Guidelines for the Rehabilitation of Mined Land (as provided by the South African

Chamber of Mines) states that soil management during construction is the key process

in determining rehabilitation effectiveness and that soil stripping guidelines should be

developed for the construction crews which clearly defines the soil horizons to be

removed and where and how to store them.

Stripping and stockpiling of topsoil is usually executed before the waste dumps are

created in order to preserve topsoil for re-vegetation of the waste dumps. The aim of the

soil management plan is to provide guidelines that should be followed during any phase

of land preparation, clearing of vegetation or general construction activities.

q) Period for which the Environmental Authorisation is required.

Thaba Cronimet Chrome Mine LoM is planned for 29 year. The opencast mining

operations are scheduled for 4 years from 2017 to 2022, while the underground mining

areas will be mined for 21 years. Construction phase of the underground mining areas

will commence from 2020 to 2025, with the operational phase in 2026.

r) Undertaking (Confirm that the undertaking required to meet the requirements of this section is provided at the end of

the EMPr and is applicable to both the Basic assessment report and the Environmental Management

Programme report.)

The undertaking required to meet the requirements of this section is provided at the end of the

EMPr and is applicable to both the Basic assessment report and the Environmental Manage-

ment Programme report.

s) Financial Provision (State the amount that is required to both manage and rehabilitate the environment in

respect of rehabilitation)

(i) Explain how the aforesaid amount was derived.

A quantum of financial rehabilitation for negative environmental impact due to the planned mine

expansion and associated waste deposal at Thaba Cronimet Chrome Mine will be determined

based on the requirements of Chapter 2.4.1 of the Guideline Document for the Evaluation of

Quantum of Closure Related Financial Provision provided by the Mine (DMR, 2005).

The closure cost estimates form part of an authorization process with the DMR and are aligned

to the DMR guideline. This section summarises the calculated closure cost estimates. Closure

cost estimates were calculated for the following closure scenarios:

Premature (Immediate/Unforeseen)

Closure (1-10 Year forecast); and

Life of Mine (LoM) Closure.

The closure cost estimates for the proposed additional mining and processing activities and

associated infrastructure (excluding P&G’s and contingencies) have been estimated to be as

follows:

Premature closure forecast – Year 1 (Y2015): R28 100 million;

Premature closure forecast – Year 2 (Y2016): R99 346 million









Life of mine closure liability – (Y2038): R37 539 million

(ii) Confirm that this amount can be provided for from operating expenditure. (Confirm that the amount, is anticipated to be an operating cost and is provided for as such in the

Mining work programme, Financial and Technical Competence Report or Prospecting Work Programme as the case

may be).

It is estimated that a total of R47 299 964.96 will be set aside for rehabilitation of negative environmental impacts.

t) Deviations from the approved scoping report and plan of study.

(i) Deviations from the methodology used in determining the significance of potential environmental impacts and risks.

(Provide a list of activities in respect of which the approved scoping report was deviated from, the reference in this report identifying where the deviation was made, and a brief description of the extent of the deviation).

No deviation have been made from the approved environmental scoping report

(ii) Motivation for the deviation.

No deviation have been made from the approved environmental scoping report

u) Other Information required by the competent Authority

(i) Compliance with the provisions of sections 24(4)(a) and (b) read with section 24 (3) (a) and (7) of the National Environmental Management Act (Act 107 of 1998). the EIA report must include the:-

1) Impact on the socio-economic conditions of any directly affected person. (Provide the results of Investigation, assessment, and evaluation of the impact of the mining, bulk sampling or alluvial diamond prospecting on any directly affected person including the landowner, lawful occupier, or, where applicable, potential beneficiaries of any land restitution claim, attach the investigation report as Appendix 2.19.1 and confirm that the applicable mitigation is reflected in 2.5.3; 2.11.6.and 2.12.herein).

Impacts of the proposed additional mining and processing activities on socio-economic

conditions include the effects of the project on the local economy (including job creation,

multiplier effects on the local economy, etc.); impacts related to the effects of the project

on the physical environment (such as safety impacts arising from increased traffic,

visual, acoustic and air quality impacts, etc.); impacts from the dependency of the

community on the mine and impacts related to an influx of workers and job-seekers

(such as an increase in social pathologies, etc.). With regards to socio-economic

impacts, if all mitigation measures are implemented according to the recommendations

provided in the specialist report, it is anticipated that the consequence and/or probability

of the majority of the negative impacts will be reduced. The post-mitigation significance

ratings of positive impacts, on the other hand, are higher than their pre-mitigation

ratings, being rated as medium as opposed to low.

In light of the above, it is not expected that the proposed development will

unacceptability impact on people’s health and wellness should mitigation be adopted in

full.

2) Impact on any national estate referred to in section 3(2) of the National Heritage Resources Act. (Provide the results of Investigation, assessment, and evaluation of the impact of the mining, bulk sampling or alluvial diamond prospecting on any national estate referred to in section 3(2) of the National Heritage Resources Act, 1999 (Act No. 25 of 1999) with the exception of the national estate contemplated in section 3(2)(i)(vi) and (vii) of that Act, attach the investigation report as Appendix 2.19.2 and confirm that the applicable mitigation is reflected in 2.5.3; 2.11.6.and 2.12.herein).

The combined assessments recorded 5 heritage sites within the proposed

expansion areas. Only two of these will be directly impacted by the proposed

development: Site 1 and 2 (Iron Age and Stone Age Sites) on the farm Zwartkop.

The impacts are as follows:

a) Destruction of heritage sites and depletion of archaeological record of the

area.

b) Destruction of heritage sites during construction.

The impact on the identified sites will result from pre-construction and

construction activities

The impact will be MODERATE on a local scale and it will be a long term impact

after mitigation.

v) Other matters required in terms of sections 24(4)(a) and (b) of the Act.

(the EAP managing the application must provide the competent authority with detailed, written proof of an investigation as required by section 24(4)(b)(i) of the Act and motivation if no reasonable or feasible alternatives, as contemplated in sub-regulation 22(2)(h), exist. The EAP must attach such motivation as Appendix 4).

Cronimet Chrome Mining SA (Pty) Ltd is a holder of a Mining Right granted on portion

1 of the farm Middellaagte 382 KQ, portion 1 of the farm Elandskuil 378 KQ, portion 8

of the farm Roodedam 368 KQ, remaining extent of the farm Moddergat 389 KQ, and

portion 6, 18, 21 of the farm Zwartkop 369 KQ and portion 1 and the remaining extent

of the farm Schildpadnest 385 KQ.

The only preferred site for the proposed extension of TSF is north of the existing TSF

and near the processing plant area on portion 1 of the farm Middellaagte 382 KQ.

Furthermore, the proposed TSF on the remaining extent of the farm Moddergat 389 KQ

will also be in close proximity to the processing plant facility.

Various disposal options have been considered for the TSF. These include “paste

slurry” deposition, and conventional thickened slurry deposition. As the conventional

thickened slurry deposition technique is more commonly used and as the

environmental conditions is suitable for this method it was therefore selected.

The proposed locations of the waste rock dumps were considered to be near the mined-

out areas for ease of backfilling during rehabilitation and closure phase of the mine. The

proposed sites are therefore regarded as the preferred sites and alternative sites were

not considered. Moreover, site alternatives were not considered due to lack of surface

depositional footprint area for the waste.

PART BENVIRONMENTAL MANAGEMENT PROGRAMME REPORT

1) Draft environmental management programme. a) Details of the EAP,

(Confirm that the requirement for the provision of the details and expertise of the EAP are

already included in PART A, section 1(a) herein as required).

The details and expertise of the EAP are already included in PART A, section 1(a) as required

b) Description of the Aspects of the Activity (Confirm that the requirement to describe the aspects of the activity that are covered by the draft environmental management programme is already included in PART A, section (1)(h) herein as required).

The aspects of the activity that are covered by the draft environmental management

programme is already included in PART A, section 1(h)

c) Composite Map

Provide a map (Attached as an Appendix) at an appropriate scale which superimposes the proposed

activity, its associated structures, and infrastructure on the environmental sensitivities of the preferred

site, indicating any areas that any areas that should be avoided, including buffers)

Refer to Annexure A for the mine site layout plan.

d) Description of Impact management objectives including management statement.

(i) Determination of closure objectives. (ensure that the closure objectives are informed by the type of environment described in 2.4 herein)

Closure for the Thaba Cronimet Chrome Mine opencast and underground mining operations

and associated residual deposits will be undertaken in terms of the following principles:

To leave site in a safe state for humans and animals.

To ensure that the water resources (surface and ground) are not affected by both mining

and rehabilitation activities.

To promote indigenous vegetation growth suitable for animals that graze over the

disturbed areas on the site.

Backfilling of all excavated areas with waste rocks, overburden and topsoil material to

adopt a shape similar to its initial state.

Revegetate the tailings storage facility to ensure blending with the surrounding

environment.

(ii) The process for managing any environmental damage, pollution, pumping and treatment of extraneous water or ecological degradation as a result of undertaking a listed activity.

The generation and deposition of the waste rock material and tailing waste on land as detailed

in section 3(d)(ii), associated with Thaba Cronimet Chrome Mine planned expansion of the

operation may result in ecological degradation, environmental damage and pollution.

Potential impacts which have been identified in relation to these activities and have been

assessed for each environmental aspect. In addition to this, mitigation and management

measures have been recommended accordingly as detailed in section 3(g) (viii) of this report.

The mitigation measures were recommended to reduce the significance of the impacts.

Monitoring programmes have also been provided to monitor the potential impacts which will

allow alternative mitigation measures to be implemented if necessary. The construction and

expansion of the TSF and deposition of the waste rock material on site will result in various

impacts such as the loss of topsoil, floral species/vegetation types, and biodiversity.

Sedimentation could also potentially occur due to surface runoff accumulation. Additionally, the

mixing of upstream clean water runoff with dirty water runoff from within infrastructure areas

could potentially result in dirty water reporting to the downstream water catchment. The

locations of all infrastructure placements were selected strategically, taking into consideration

and avoiding ecological sensitivities such as wetlands and streams where possible. Managing

environmental damage within Thaba Cronimet Mining Right area requires the establishment and

implementation of Storm Water Management Plan (attached as an annexure to this report)

outlining clear dirty water and clean water separation channels.

(iii) Potential risk of Acid Mine Drainage. (Indicate whether or not the mining can result in acid mine drainage).

Mining at Cronimet Thaba Chrome Mine will not result in acid mine drainage.

(iv) Steps taken to investigate, assess, and evaluate the impact of acid mine drainage.

Geochemical investigations of the tailing waste, overburden material, and waste rock material at

Thaba Mine was undertaken by Hydro Science (May, 2015) and Environmental Resources

Management (ERM) (May, 2015). The investigation was carried out in terms of the National

Department of Environmental Affairs (DEA) Regulation 635- National norms and standards for

assessment of waste for landfill disposal, and Regulation 636- National norms and standards

for disposal of waste to landfill.

(v) Engineering or mine design solutions to be implemented to avoid or remedy acid mine drainage.

Not applicable No acid mine drainage will be generate at the site.

(vi) Measures that will be put in place to remedy any residual or cumulative impact that may result from acid mine drainage.

Not applicable No acid mine drainage will be generate at the site.

(vii) Volumes and rate of water use required for the mining, trenching or bulk sampling operation.

Approximately 3 423 m3 of input makeup water is required for the mine`s daily operations.

(viii) Has a water use licence has been applied for?

Yes. An Integrated Water Use Licence Application (IWULA) for Thaba Cronimet Chrome Mine

planned expansion of the operation has been lodged with the Department of Water and

Sanitation (DWS) North West Regional Officer on the 29th of March 2016. Refer to the Annexure

for proof of application and acknowledgment of application by DWS.

(ix) Impacts to be mitigated in their respective phases

Measures to rehabilitate the environment affected by the undertaking of any listed activityACTIVITIES

(as listed in 2.11.1)

PHASE

Of operation in which

activity will take place.

State;

Planning and design,

Pre-Construction’

Construction,

Operational,

Rehabilitation,

Closure, Post closure.

SIZE AND SCALE of disturbance(volumes,

tonnages and

hectares or

m²)

MITIGATION MEASURES

(describe how each of the

recommendations in herein will

remedy the cause of pollution or

degradation and migration of

pollutants)

COMPLIANCE WITH STANDARDS

(A description of how each

of the recommendations

herein will comply with any

prescribed environmental

management standards or

practices that have been

identified by Competent

Authorities)

TIME PERIOD FOR IMPLEMENTATION

Describe the time period when the

measures in the environmental

management programme must be

implemented Measures must be

implemented when required.

With regard to Rehabilitation specifically

this must take place at the earliest

opportunity. .With regard to Rehabilitation,

therefore state either:-.

Upon cessation of the individual activity

Or.

Upon the cessation of mining, bulk

sampling or alluvial diamond prospecting

as the case may be.

Excavation, stockpiling, channelling and berms

Construction Impact will be slightly mitigated through mitigation measures for flora and fauna and soil management.

NEMA CARA GN R983

Ongoing, post construction and 6 monthly

Disposal of waste on land and Inadequate storage of hazardous substances

Construction • Store all hydrocarbon sources inside bounded areas with impermeable floors. • Filter all surface water from these bounded areas through hydrocarbon management facilities.• Store all hazardous

NEMWA Ongoing

substances (oils, diesel, and chemicals) in containers of sufficient strength and structural integrity to ensure that it is unlikely to burst or leak during ordinary use.• Handle, manage and store all chemicals according to their material safety data sheets which are to be located at all points of storage and where the chemical is used. • Ensure that the surface where oil and diesel is delivered and handled is impermeable and not connected to surface water drainage systems, including storm water drains• Inspect all bunds, tanks and pipework regularly for signs of damage to ensure integrity• Implement a proper and robust vehicle maintenance programme to reduce the risk of spillages of reagents and hydrocarbons during transportation• Separate waste into various categories as defined by the operational procedures to ensure optimal waste recycling and correct disposal• Train all employees and contractors on the separation of waste as defined by the operational procedures

• Treat and dispose of waste as near as possible to the point of production as is technically and environmentally possible• Dispose of hazardous waste at either a permitted H:H or H:h landfill site depending on the waste characteristics and maintain safe disposal certificates.• Dispose of general waste at a permitted general landfill site. Waybills of disposal are to be recorded.• Collect hazardous waste at the stipulated maximum weight or at a minimum frequency of every 90 days whether or not the container is full. • Train all relevant employees in cleaning up of a spillage and ensure that all necessary spill kits containing the correct equipment to clean up spills are made available at strategic points in the plant area• Optimise the recycling, re-use and reduction of both general and hazardous waste

Construction of support facilities and vegetation clearing.

Construction • Use existing roads and minimise new roads. The width of service roads must be minimised as much as possible• Maintain grass cover for as long as possible

NEMA CARA GN R983

Ongoing, Post construction, 6 monthly.

• Erosion control measures must be constructed• Stripped soils should be stockpiled as a berm upslope (majority) and surrounding the disturbed area.• Stripping machinery should be used when soil moisture content is below approximately 8% to limit soil compaction.• Stripping of topsoil should not be done earlier than required.• An intercept drain should be constructed upslope of construction and operational areas, in order to re-direct clean water away.• An intercept drain should possibly be constructed downslope of polluted areas, in order to drain potentially polluted water into a pollution control dam.• Conduct proper chemical waste management to avoid spillage of chemicals• Use tracked vehicles rather than wheeled vehicles due to their lower point loading and slip, thereby minimise compaction;• Soil stockpiles must be sampled, ameliorated (fertilized) and re-vegetated as soon after construction as

possible

Opencast mining, vegetation clearing and construction of surface infrastructure

Construction • Clearly demarcate the development footprint prior to initial site clearance and prevent construction personnel from leaving the demarcated area;• Retain where possible, vegetation between infrastructural elements associated with the project;• Conduct flora species search and rescue efforts before ground clearing begins;• Remove and relocate any plants of botanical or ecological significance (protected species);• Provide upfront and regular environmental training to construction workers to ensure the protection of the habitat, fauna and flora and their sensitivity to conservation;• Where trenches pose a risk to animal safety, ensure that the trench is secured to prevent animals falling in and getting trapped and/or injured;• Avoid the use of poisons for the control of problem animals and where it is necessary obtain approval from the Environmental Officer on type of poison to be used.

NEMA Regulation 543 Section 32

NEMBA Section 56 (1), 57 (1), 57 (2) and 57 (4)

Limpopo Environmental Management Act Schedules 2, 3, 11 and 12


National Environmental Management Biodiversity Act (NEMBA) Section 56 (1), 57 (1), 57 (2) and 57 (4)


NEMBA Section 56 (1), 57 (1), 57 (2) and 57 (4)NEMA Regulation 543 Section 32

Alien and Invasive Species Regulations

Prior to ground clearing and when required

• Use existing facilities (e.g., access roads, parking lots, graded areas) to the extent possible to minimize the amount of new disturbance;• Establish protective buffers in areas where there is sensitive habitat such as ravines• Avoid all sensitive habitats by construction vehicles and equipment, wherever possible, in order to reduce potential impacts• Do not undertake any activities outside of the defined construction areas and the road servitudes.• In areas where the speed limit tends to be disobeyed, consider installing speed bumps. • Limit or avoid travelling at night as much as possible. • Where possible, position lighting five meters from the roads or paved areas.• Destroy alien invasive plants present, and the seedlings which emerge• Establish and manage an alternative plant cover to limit re-growth and re-invasion. • Institute strict control over materials brought onto site, which should be

(GNR 599 of 2014) as part of the NEMBA

inspected for seeds of noxious plants and steps taken to eradicate these before transport to the site. Routinely fumigate or spray all materials with appropriate low-residual herbicides prior to transport to site or in a quarantine area on site.• Develop a detailed plan for the control of invader fauna species, noxious weeds and invasive plants that could colonize the area as a result of new surface disturbance activities at the site. The plan should address monitoring, weed identification, the manner in which weeds spread, and methods for treating infestations.

Blasting Construction Blasting designed and performed by person holding a National Certificate in Rock Breaking (qualification ID 62869) or equivalent. Inform community of schedule.

Close public roads during blasting.

Community may need to be evacuated based on proximity.

Avoid blasting during quiet hours.

National and Provincial Noise Regulations. SANS 10103

Prior to blasting, duration of blast.

Topsoil and subsoil stripping, Transport

Construction • Apply wet suppression or chemical

Compliance with NEMAQA and with

Ongoing

and hauling. stabilisation on unpaved roads. • Restrict haul trucks to specified haul roads• Reduce unnecessary traffic and strict speed control in areas where speed limits are disobeyed• Stabilise (chemical, rock cladding or vegetative) disturbed soil and early re-vegetation

the South African National Dust Control Regulations

Storm water control, stripping, overburden and berms.

Construction • The laydown and contractor areas must be kept as small as possible;• Ensure berms and structures are constructed around these sites to ensure clean overland flow is directed into the natural drainage channels.• All wetlands and flood lines must be clearly marked and no activity is allowed inside these boundaries.• Natural drainage channels must only be crossed at specific areas and water management structures must be constructed before the road is commissioned.• All laydown areas and construction roads must be ripped and vegetated after the construction phase is complete.• Water emanating from contractor workshops and stores must be directed

NWA GN 704 Prior to construction and ongoing

to a proper hydrocarbon management unit. All other surface water from the contractor area must be collected in a pond inside the boundaries of the contractor yard.• Parking areas for yellow machine must have spill kits and drip trays in-case of leaking vehicles.• No manufacturing and/or maintenance must be done in any area outside the workshops and manufacturing zone.• All topsoil stripped from the contractor area must be stored on topsoil dumps.• Clean overland flow must be directed around the contractor area.

Processing plants, tailings storage facility.

Construction • Manage excess water that accumulates during the construction phase as part of the construction phase water balance.• Construction of the shaft complex where possible is to be undertaken during post winter months. Shaft walls will be sealed off preventing significant inflow into the mine workings after construction.• Discharge all unwanted water accumulating in the excavations into pollution control dams for re-use as soon as possible.

NWA Ongoing

Limit contact time with shaft perimeter and pit floor

Surface infrastructure

Construction • In the case of the unnamed stream the proposed opencast mining operations were adjusted to exclude the wetland from the mining footprint;• In the case of the northern settler dam, the proposed location of the dam was moved to over a 100m from the boundary of the unnamed stream;• Strong emphasis should be placed on the rehabilitation of these areas post opencast mining, and a watercourse resembling the downstream reaches of the Trollope system(I.e. downstream of the tar road) should be re-established across the mined out areas.• All stockpiles extending into the Trollope wetland/riparian habitat should however be adjusted to remain outside the delineated area.• Clearly demarcate all wetland areas as such to alert mining staff on site and where activities take place in close vicinity to wetland habitat, fence off the opencast and surface infrastructure areas so as to prevent machinery and personnel accessing

Section 21 of the NWA

Prior to commencement of activity, when necessary and ongoing.

adjacent wetland areas outside the disturbance footprint.• Educate all mine staff and contractors on the importance and sensitivity of the wetland systems on site• Upgrade the existing crossing over the riparian zone forming the tributary of the Bierspruit with culverts.• Construct wetland crossings as follows:• Wetland crossings must make allowance for flow connectivity across the full wetland system to be maintained. • Install box culverts as opposed to pipe culverts.• No impoundments upstream should be allowed• Erosion protection must be installed on downstream discharge

Storm water control, topsoil and subsoil stripping.

Construction • Comply with the requirements of GN 704 in terms of storm water management and comply with the proposed mitigation measures as outlined in the surface water section and as outlined in the section on flora and fauna management.

NWA Ongoing and when required

Construction of facilities, structures and associated infrastructure.

Construction • Fence off all archaeological sites identified to date in close proximity to the proposed mining and processing areas prior to commencement of

Section 3 of the National Resources Act (Act 25 of 1999)

Prior to construction and ongoing

construction in the area• Include within the training programme, general awareness on archaeological artefacts and the protocol to be established on identification of an artefact. Compile and undertake training on an operational procedure.• Cease work immediately and contact the Archaeological Specialist should an object of archaeological or heritage importance be discovered or suspected to be of importance• Appoint an archaeologist to undertake the necessary recordings and documentation at site two and to obtain a permit from SAHRA prior to the destruction or interference with site one from construction activities. If possible re-route the access road to avoid this site.• Appoint an archaeologist to undertake the necessary recordings and documentation at site one and to obtain a permit from SAHRA prior to the destruction or interference with site one from construction activities.

Construction of access roads,

Construction • Avoid breaking of traffic laws and non-

National road Agency

Ongoing

Hauling and transport

compliance with road signs • Provision of the appropriate traffic signs (warning and directional) to aid with the control of the traffic flow, at the access roads, during the construction phase.• Dust suppression measures will be implemented during the construction phase to reduce dust liberations resultants from traffic.• Construction activities will be restricted to day time hours to prevent noise disturbance during night time.

Construction of surface infrastructure and tailings storage facility

Construction Prevent light pollution by avoiding light spillage outside of the project activity areas, the application of directional lighting, security • lighting that is only activated upon illegal entry in restricted areas• Rehabilitate the tailing storage facilities soon as possible with indigenous vegetation that will blend in with the character of the existing vegetation• Avoid cutting down of trees• If possible, cluster the sewage disposal and electricity generation facilities together with other mining structures in order to reduce

None Once tailings storage facility has been decommissioned, ongoing and when required.

the visual impactCommunities Construction • Maximise and

monitor local recruitment coordinated through the Department of Labour• Promote the employment of women and youth • Avoid hiring illegal immigrants and child labour.• Where possible use labour-intensive methods of construction• Train and increase the skill level of the workforce• Develop and maintain a register of local SMMEs and the types of goods and services provided by them.• Where appropriate SMMEs do not exist, investigate the possibility of launching a training/ skills development initiative to develop local entrepreneurial skills• Where possible, assist communities in responsible investing and savings through a reputable financial institution to take advantage of increasing disposable income• Establish linkages with other institutions involved in skills development and SMME development, such as the community development programme of the local municipality

South African Mining Charter

Prior to commencement of social projects, ongoing and verify every 6 months.

• Take steps to ensure that planned initiatives dovetail with those of other development institutions active in the area, including the district and local government• As far as possible, undertake the selection, design and implementation of development initiatives in collaboration with their intended beneficiaries.• Determine what the communities’ expectations are regarding development• Ensure that diversions and major disturbances to national and provincial roads occurs during low peak times;• When necessary, ensure that local residents are kept informed on an on-going basis of construction progress and when access will be blocked in certain areas• Investigate the establishment of a community forum to serve as a dedicated communication channel with the local population• Implement measures to ensure that these speed restrictions are enforced. Such measures may include monitoring vehicle speeds, erecting speed limit signs and installing speed humps;

• Maintain roads to prevent deterioration of roads surfaces due to heavy vehicle traffic.• Identify measures to manage/promote road safety and traffic control, taking into account the cumulative effects of traffic generated by multiple development projects• Prevent unauthorized access to the mine site through appropriate fencing and security;• Restrict the making of fires by construction workers to areas where tight control can be exerted, or that the making of fires be prohibited.• Increase awareness of the mine’s complaints and grievance procedures and hold feedback sessions with community forums to assess the impact of this programme• implement HIV/AIDS and alcohol abuse campaigns in the communities;• Include HIV/AIDS and sexually transmitted infections awareness and prevention programmes as a condition of contract for suppliers and sub-contractors.• Introduce a voluntary counselling and testing programme• Undertake a voluntary HIV/AIDS and

sexually transmitted disease prevalence survey on a regular basis.• Control access at the construction sites to prevent sex workers and petty traders from visiting and/or loitering• Establish formal liaison structures with the local police to monitor local social dynamics during both construction and eventually operation;• Establish and maintain liaison with existing crime control organisations, such as bona fide Community Policing Forums and Farm Watch organisations;• Ensure that contractors prioritise employment of local community members• Maintain strategy of liaising with the local municipality to ensure that expected population influx is taken into account in infrastructure development planning of the Thabazimbi Local Municipality• Where possible, assist local government with the identification of measures to mitigate and/or control the expansion of informal settlements• Frequent monitoring of the broader area to detect the establishment of new

informal settlements or rapid expansion of existing settlements

Excavation,channelling and berms, stockpiling of waste rock residue, tailingsstorage facilities, hauling and transport

Operational • Impact will be mitigated through concurrent opencast rehabilitation as well as stipulated mitigation measures for flora and fauna and soil management.

NEMA CARA GN R983

Prior to construction, ongoing, post construction, 6 monthly.


Operational • Store all hydrocarbon sources inside bounded areas with impermeable floors. • Filter all surface water from these bounded areas through hydrocarbon management facilities.• Store all hazardous substances (oils, diesel, and chemicals) in containers of sufficient strength and structural integrity to ensure that it is unlikely to burst or leak during ordinary use.• Handle, manage and store all chemicals according to their material safety data sheets which are to be located at all points of storage and where the chemical is used. • Ensure that the surface where oil and diesel is delivered and handled is impermeable and not connected to surface water drainage systems, including storm water drains

The Hazardous substances Act (Act 15 of 1973) and the NWA.

Relevant SANS Standard and NEMWA.

Ongoing

• Inspect all bunds, tanks and pipework regularly for signs of damage to ensure integrity• Implement a proper and robust vehicle maintenance programme to reduce the risk of spillages of reagents and hydrocarbons during transportation• Separate waste into various categories as defined by the operational procedures to ensure optimal waste recycling and correct disposal• Train all employees and contractors on the separation of waste as defined by the operational procedures• Treat and dispose of waste as near as possible to the point of production as is technically and environmentally possible• Dispose of hazardous waste at either a permitted H:H or H:h landfill site depending on the waste characteristics and maintain safe disposal certificates.• Dispose of general waste at a permitted general landfill site. Waybills of disposal are to be recorded.• Collect hazardous waste at the stipulated maximum weight or at a minimum frequency of every 90 days whether or not the

container is full. • Train all relevant employees in cleaning up of a spillage and ensure that all necessary spill kits containing the correct equipment to clean up spills are made available at strategic points in the plant area• Optimise the recycling, re-use and reduction of both general and hazardous waste

Construction of facilities, Stockpiles and berms

Operational • Use existing roads and minimise new roads.• The width of service roads must be minimised as much as possible• Maintain grass cover for as long as possible• Erosion control measures must be constructed• Stripped soils should be stockpiled as a berm upslope (majority) and surrounding the disturbed area.• Stripping machinery should be used when soil moisture content is below approximately 8% to limit soil compaction.• Stripping of topsoil should not be done earlier than required.• An intercept drain should be constructed upslope of construction and

NEMA CARA GN R983

Prior construction, ongoing, post construction, 6 monthly.

operational areas, in order to re-direct clean water away.• An intercept drain should possibly be constructed downslope of polluted areas, in order to drain potentially polluted water into a pollution control dam.• Conduct proper chemical waste management to avoid spillage of chemicals• Use tracked vehicles rather than wheeled vehicles due to their lower point loading and slip, thereby minimise compaction• Soil stockpiles must be sampled, ameliorated (fertilized) and re-vegetated as soon after construction as possible

Opencast operations, tailings storage facilities and surface infrastructure

Operational • Clearly demarcate the development footprint prior to initial site clearance and prevent construction personnel from leaving the demarcated area;• Retain where possible, vegetation between infrastructural elements associated with the project;• Conduct flora species search and rescue efforts before ground clearing begins;• Remove and relocate any plants of botanical or ecological significance (protected species);





National Environmental

Prior to ground clearing, prior to construction, when required and ongoing.

• Provide upfront and regular environmental training to construction workers to ensure the protection of the habitat, fauna and flora and their sensitivity to conservation;• Where trenches pose a risk to animal safety, ensure that the trench is secured to prevent animals falling in and getting trapped and/or injured;• Avoid the use of poisons for the control of problem animals and where it is necessary obtain approval from the Environmental Officer on type of poison to be used.• Use existing facilities (e.g., access roads, parking lots, graded areas) to the extent possible to minimize the amount of new disturbance;• Establish protective buffers in areas where there is sensitive habitat such as ravines• Avoid all sensitive habitats by construction vehicles and equipment, wherever possible, in order to reduce potential impacts• Do not undertake any activities outside of the defined construction areas and the road servitudes.• In areas where the

Management Biodiversity Act (NEMBA) Section 56 (1), 57 (1), 57 (2) and 57 (4)



Alien and Invasive Species Regulations (GNR 599 of 2014) as part of the NEMBA

speed limit tends to be disobeyed, consider installing speed bumps. • Limit or avoid travelling at night as much as possible. • Where possible, position lighting five meters from the roads or paved areas.• Destroy alien invasive plants present, and the seedlings which emerge• Establish and manage an alternative plant cover to limit re-growth and re-invasion• Institute strict control over materials brought onto site, which should be inspected for seeds of noxious plants and steps taken to eradicate these before transport to the site. Routinely fumigate or spray all materials with appropriate low-residual herbicides prior to transport to site or in a quarantine area on site.• Develop a detailed plan for the control of invader fauna species, noxious weeds and invasive plants that could colonize the area as a result of new surface disturbance activities at the site. The plan should address monitoring, weed identification, the manner in which weeds spread, and

methods for treating infestations.

Opencast mining, blasting,

Operational • Blasting designed and performed by person holding a National Certificate in Rock Breaking (qualification ID 62869) or equivalent. Inform community of schedule. • Close public roads during blasting. • Community may need to be evacuated based on proximity. • Avoid blasting during quiet hours.

National and provincial noise regulations. SANS 10103

When required

Hauling and transport, opencast mining, vegetation clearing,

Operational • Apply wet suppression or chemical stabilisation on unpaved roads. • Restrict haul trucks to specified haul roads• Reduce unnecessary traffic and strict speed control in areas where speed limits are disobeyed• Stabilise (chemical, rock cladding or vegetative) disturbed soil and early re-vegetation

NEMAQA and the South African Dust Regulations

Ongoing and prior to commencement of conveyor belt.

Mining operations, processing plants, berms, surface infrastructure

Operational • Manage all excess water as part of the operational phase water balance• In the case of proven depletion of water resources, negotiate alternative supplies of water to replace existing usage with affected groundwater users, based on

NWA When required and ongoing

a structured compensation protocol.• Where water is not used during mining, or pumped back to the plant area, disposal must take place in the correct polluted water facility.• Should in the event that water flows naturally or due to pumping between adjacent sections, keep strict records of volumes of water pumped, quality of water pumped, delineation of reservoirs created for the storage of water.• Investigate and implement a ground water abstraction system in the event that an unacceptable impact is identified• Strong emphasis should be placed on the rehabilitation of these areas post opencast mining, and a watercourse resembling the downstream reaches of the Trollope system (i.e. downstream of the tar road) should be re-established across the mined out areas.• All stockpiles extending into the Trollope wetland/riparian habitat should however be adjusted to remain outside the delineated area.• Clearly demarcate all wetland areas as such to alert

mining staff on site and where activities take place in close vicinity to wetland habitat, fence off the opencast and surface infrastructure areas so as to prevent machinery and personnel accessing adjacent wetland areas outside the disturbance footprint.• Educate all mine staff and contractors on the importance and sensitivity of the wetland systems on site• Upgrade the existing crossing over the riparian zone forming the tributary of the Bierspruit with culverts.• Construct wetland crossings as follows:• Wetland crossings must make allowance for flow connectivity across the full wetland system to be maintained. • Install box culverts as opposed to pipe culverts.• No impoundments upstream should be allowed• Erosion protection must be installed on downstream discharge

Underground activities, opencast works, tailings storage facility, processing plants, tailings dams, stores

Operational • The laydown/contractor areas and footprints must be kept as small as possible;• Ensure berms and structures are constructed around these sites to ensure clean overland flow is

NWA GN 704 Ongoing, Prior to contract commencement, commissioning of infrastructure and operation of sewage facilities

directed into the natural drainage channels.• All wetlands and flood lines must be clearly marked and no activity is allowed inside these boundaries.• Natural drainage channels must only be crossed at specific areas and water management structures must be constructed before the road is commissioned.• All laydown areas and construction roads must be ripped and vegetated after the construction phase is complete.• Water emanating from contractor workshops and stores must be directed to a proper hydrocarbon management unit. All other surface water from the contractor area must be collected in a pond inside the boundaries of the contractor yard.• Parking areas for yellow machine must have spill kits and drip trays in-case of leaking vehicles.• No manufacturing and/or maintenance must be done in any area outside the workshops and manufacturing zone.• All topsoil stripped from the contractor area must be stored on topsoil dumps.

• Clean overland flow must be directed around the contractor area.

Opencast mining and surface infrastructure, stockpiles.

• Strong emphasis should be placed on the rehabilitation of these areas post opencast mining, and a watercourse resembling the downstream reaches of the Trollope system (i.e. downstream of the tar road) should be re-established across the mined out areas.• All stockpiles extending into the Trollope wetland/riparian habitat should however be adjusted to remain outside the delineated area.• Clearly demarcate all wetland areas as such to alert mining staff on site and where activities take place in close vicinity to wetland habitat, fence off the opencast and surface infrastructure areas so as to prevent machinery and personnel accessing adjacent wetland areas outside the disturbance footprint.• Educate all mine staff and contractors on the importance and sensitivity of the wetland systems on site• Upgrade the existing crossing over the riparian zone forming the tributary of the Bierspruit with culverts.• Construct wetland

NWA Once off, when required and when necessary.

crossings as follows:• Wetland crossings must make allowance for flow connectivity across the full wetland system to be maintained. • Install box culverts as opposed to pipe culverts.• No impoundments upstream should be allowed• Erosion protection must be installed on downstream discharge

Storm water control Operational• Comply with the requirements of GN 704 in terms of storm water management and comply with the proposed mitigation measures as outlined in the surface water section and as outlined in the section on flora and fauna management.

Opencast pit operations

Operational Should artefacts be discovered during the opencast pit operations, an archaeologist must be contacted and in turn the SAHRA.• Effective training programmes to be implemented

Section 3 of the National Heritage Resources Act (Act 25 of 1999)


Hauling and transport.

Operational • Avoid breaking of traffic laws and non-compliance with road signs • Provision of the appropriate traffic signs (warning and directional) to aid with the control of the traffic flow, at the access

National Road Agency

Ongoing

roads, during the construction phase.


Operational • Prevent light pollution by avoiding light spillage outside of the project activity areas, the application of directional lighting, security lighting that is only activated upon illegal entry in restricted areas• Rehabilitate the tailing storage facilities soon as possible with indigenous vegetation that will blend in with the character of the existing vegetation• Avoid cutting down of trees

None Ongoing and when required

Community, Accommodation, offices, workshop, cumulative

Operational +8 • Maximise and monitor local recruitment coordinated through the Department of Labour• Promote the employment of women and youth • Avoid hiring illegal immigrants and child labour.• Where possible use labour-intensive methods of construction• Train and increase the skill level of the workforce• Develop and maintain a register of local SMMEs and the types of goods and services provided by them.• Where appropriate SMMEs do not exist, investigate the possibility of launching a training/ skills


Ongoing, construction phase, prior to commencement of social projects, prior to planning of retrenchments.

development initiative to develop local entrepreneurial skills• Where possible, assist communities in responsible investing and savings through a reputable financial institution to take advantage of increasing disposable income• Establish linkages with other institutions involved in skills development and SMME development, such as the community development programme of the local municipality• Take steps to ensure that planned initiatives dovetail with those of other development institutions active in the area, including the district and local government• As far as possible, undertake the selection, design and implementation of development initiatives in collaboration with their intended beneficiaries.• Determine what the communities’ expectations are regarding development• Ensure that diversions and major disturbances to national and provincial roads occurs during low peak times;• When necessary, ensure that local residents

are kept informed on an on-going basis of construction progress and when access will be blocked in certain areas• Investigate the establishment of a community forum to serve as a dedicated communication channel with the local population• Implement measures to ensure that these speed restrictions are enforced. Such measures may include monitoring vehicle speeds, erecting speed limit signs and installing speed humps;• Maintain roads to prevent deterioration of roads surfaces due to heavy vehicle traffic.• Identify measures to manage/promote road safety and traffic control, taking into account the cumulative effects of traffic generated by multiple development projects• Prevent unauthorized access to the mine site through appropriate fencing and security;• Restrict the making of fires by construction workers to areas where tight control can be exerted, or that the making of fires be prohibited.• Increase awareness of the mine’s complaints and grievance procedures and hold feedback sessions with

community forums to assess the impact of this programme• implement HIV/AIDS and alcohol abuse campaigns in the communities;• Include HIV/AIDS and sexually transmitted infections awareness and prevention programmes as a condition of contract for suppliers and sub-contractors.• Introduce a voluntary counselling and testing programme• Undertake a voluntary HIV/AIDS and sexually transmitted disease prevalence survey on a regular basis.• Control access at the construction sites to prevent sex workers and petty traders from visiting and/or loitering• Establish formal liaison structures with the local police to monitor local social dynamics during both construction and eventually operation;• Establish and maintain liaison with existing crime control organisations, such as bona fide Community Policing Forums and Farm Watch organisations;• Ensure that contractors prioritise employment of local community members

• Maintain strategy of liaising with the local municipality to ensure that expected population influx is taken into account in infrastructure development planning of the Thabazimbi Local Municipality• Where possible, assist local government with the identification of measures to mitigate and/or control the expansion of informal settlements• Frequent monitoring of the broader area to detect the establishment of new informal settlements or rapid expansion of existing settlements

Transport and hauling, Access roads, demolition

Decommissioning • Use existing roads and minimise new roads.• The width of service roads must be minimised as much as possible• Maintain grass cover for as long as possible• Erosion control measures must be constructed• Stripped soils should be stockpiled as a berm upslope (majority) and surrounding the disturbed area.• Stripping machinery should be used when soil moisture content is below

NEMA CARA GN R983

Post operational phase and ongoing

approximately 8% to limit soil compaction.• Stripping of topsoil should not be done earlier than required.• An intercept drain should be constructed upslope of construction and operational areas, in order to re-direct clean water away.• An intercept drain should possibly be constructed downslope of polluted areas, in order to drain potentially polluted water into a pollution control dam.• Conduct proper chemical waste management to avoid spillage of chemicals• Use tracked vehicles rather than wheeled vehicles due to their lower point loading and slip, thereby minimise compaction• Soil stockpiles must be sampled, ameliorated (fertilized) and re-vegetated as soon after construction as possible

Removal of mining infrastructure, Access roads.

• Plant vegetation species for rehabilitation that will effectively bind the loose material and which can absorb run-off from the mining areas. Rehabilitate all the land where infrastructure has been demolished.• Monitor the establishment of the

NEMBA GNR 599 of 2014

Prior to construction phase and ongoing

vegetation cover on the rehabilitated sites to the point where it is self-sustaining.• Protect rehabilitation areas until the area is self-sustaining.• Diversion trenches and storm water measures must be maintained

Hauling and transport, roads

• Apply wet suppression or chemical stabilisation on unpaved roads. • Reduce unnecessary traffic and strict speed control in areas where speed limits are disobeyed• Stabilise (chemical, rock cladding or vegetative) disturbed soil and early re-vegetation

NEMAQA and with the South African National Dust Regulations

Ongoing

Cessation of mining • Strong emphasis should be placed on the rehabilitation of these areas post opencast mining, and a watercourse resembling the downstream reaches of the Trollope system (i.e. downstream of the tar road) should be re-established across the mined out areas.• All stockpiles extending into the Trollope wetland/riparian habitat should however be adjusted to remain outside the delineated area.• Clearly demarcate all wetland areas as such to alert

Waste Act Ongoing

mining staff on site and where activities take place in close vicinity to wetland habitat, fence off the opencast and surface infrastructure areas so as to prevent machinery and personnel accessing adjacent wetland areas outside the disturbance footprint.• Educate all mine staff and contractors on the importance and sensitivity of the wetland systems on site• Upgrade the existing crossing over the riparian zone forming the tributary of the Bierspruit with culverts.• Construct wetland crossings as follows:• Wetland crossings must make allowance for flow connectivity across the full wetland system to be maintained. • Install box culverts as opposed to pipe culverts.• No impoundments upstream should be allowed• Erosion protection must be installed on downstream discharge

Cessation of mining, Communities, accommodation, offices.

• Prevent light pollution by avoiding light spillage outside of the project activity areas, the application of directional lighting, security lighting that is only activated upon illegal entry in restricted areas

None When required and once tailings storage facility has been decommissioned.

• Rehabilitate the tailing storage facilities soon as possible with indigenous vegetation that will blend in with the character of the existing vegetation• Avoid cutting down of tress

Communities • Implement HIV/AIDS and alcohol abuse campaigns in the communities;• Include HIV/AIDS and sexually transmitted infections awareness and prevention programmes as a condition of contract for suppliers and sub-contractors• Provide an adequate supply of free condoms to workers• Introduce a voluntary counselling and testing programme• Undertake a voluntary HIV/AIDS and sexually transmitted disease prevalence survey on a regular basis.• Establish formal liaison structures with the local police to monitor local social dynamics during both construction and eventually operation;• Establish and maintain liaison should be maintained with existing crime control organisations, such as bona fide Community Policing Forums and Farm


Prior to planning retrenchments and ongoing.

Watch organisations;• Identify mechanisms to save jobs and avoid job losses and a decline in employment;• Identify mechanisms to provide alternative solutions and procedures for creating job security where job losses cannot be avoided

Bare, compacted and sterile areas

Closure • Rip soils immediately after operations cease and revegetate

• Sample, test and ameliorate soil on rehabilitated areas to improve conditions for re-vegetation.

• Prevent the concentration of surface runoff through channels, trenches or preferential flow paths created by vehicle tracks. Install sediment barriers, e.g. straw bales or bidim fences, along the downslope edge of disturbed areas until sufficient vegetation cover has been established.

• Where rehabilitation activities take place on steep slopes or areas of high surface runoff volumes and velocities, consider the installation of a geomembrane to hold the soil

• Rehabilitate as close to possible to the situation prior to mining

NEMA CARA GN R983

During rehabilitation and annually for 5 years.

Rehabilitation sites, demolished infrastructure, trenches.

Closure • Plant vegetation species for rehabilitation that will effectively bind the loose material and which can absorb run-off from the mining areas. Rehabilitate all the land where infrastructure has been demolished.• Monitor the establishment of the vegetation cover on the rehabilitated sites to the point where it is self-sustaining.• Protect rehabilitation areas until the area is self-sustaining.• Diversion trenches and storm water measures must be maintained


Ongoing, verify 6 monthly and at closure.

Decommissioning activities, Transport and hauling, Roads

Closure • Apply wet suppression or chemical stabilisation on unpaved roads. • Reduce unnecessary traffic and strict speed control in areas where speed limits are disobeyed• Stabilise (chemical, rock cladding or vegetative) disturbed soil and early re-vegetation

NEMAQA and with the South African National Dust Regulations

At closure

Defunct tailing dam, underground blasting activity, backfilling

Closure • Investigate an abstraction scheme should the monitoring data indicate a requirement for intervention in this regard. • Monitoring

NWA When required


Closure • Prevent light pollution by avoiding light spillage

None Once tailings storage facility has been decommissioned.

Demolition outside of the project activity areas, the application of directional lighting, security lighting that is only activated upon illegal entry in restricted areas• Rehabilitate the tailing storage facilities soon as possible with indigenous vegetation that will blend in with the character of the existing vegetation

e) Impact Management Outcomes

(A description of impact management outcomes, identifying the standard of impact management required for the aspects contemplated in paragraph ()

ACTIVITY Whether listed or not

listed.

(E.g. Excavations, blasting, stockpiles, discard dumps or dams, Loading, hauling and transport, Water supply dams and boreholes, accommodation, offices, ablution, stores, workshops, processing plant, storm water control, berms, roads, pipelines, power lines, conveyors, etc…etc…etc.).

POTENTIAL IMPACT

(E.g. dust, noise, drainage surface disturbance, fly rock, surface water contamination, groundwater contamination, and air pollution etc….etc…)

ASPECTSAFFECTED

PHASEIn which impact is

anticipated

(e.g. Construction, commissioning,

operationalDecommissioning,

closure, post-closure)

MITIGATIONTYPE

(modify, remedy, control, or stop) through (e.g. noise control measures, storm-water control, dust control, rehabilitation, design measures, blasting controls, avoidance, relocation, alternative activity etc. etc)

E.g. Modify through alternative

method. Control through noise

control Control through

management and monitoring

Remedy through rehabilitation..

STANDARD TO BE ACHIEVED

(Impact avoided, noise levels, dust levels,

rehabilitation standards, end use objectives) etc.

Excavation, stockpiling,

Disturbances/changes to the topography of the area

Topography Construction Remedy through rehabilitation

Rehabilitation standards

channelling and berms (Temporal)Disposal of waste on land and Inadequate storage of hazardous substances

Potential soil and water contamination;legal non-compliance; lost opportunities for waste recycling

Waste and Hazardous Substances

Construction Control through management

End use objectives


Soil compaction; soil loss due to wind and water erosion; change of land-use from natural to industrial; soil pollution due to hydrocarbon and cement spillages; sterilisation of the soil resource

Soil and Land Capability

Construction Control through erosion control measures; remedy through rehabilitation; avoidance through chemical waste management; monitor through rehabilitation.



Habitat loss and harm to flora and fauna;Fragmentation of the habitat resulting in harm to flora and fauna;Fauna mortalities;habitat degradation

Flora and Fauna Construction Control through management; Avoidance; modify through alternative methods.

End-use objectives

Blasting Human discomfort and structural damage; New total resulting ambient noise levels elevated above pre-development levels and the actual increase in ambient noise levels

Vibrations and Noise

Construction Control through noise control measures; manage through monitoring; Avoidance, control through blasting controls.

Noise levels

Topsoil and subsoil stripping, Transport and hauling.

Cumulative particulate emissions

Air Quality Construction Control through management; control through traffic and speed control measures;

Dust levels


Sheet erosion; dust; potential pollution by hazardous substances; Poor sanitation and poor storm water management; Deterioration in water

Surface water Construction Control through management; control through water management structures; monitor through hydrocarbon


Quality and decrease in catchment Yield;

management unity; remedy through rehabilitation.

Processing plants, , tailings storage facility.


Groundwater Construction Control through management (water balance); stop through shaft design measures, monitor through pollution control dams.

End-use objectives

Surface infrastructure Degradation of wetland Habitat; increased sedimentation within the wetlandsincreased turbidity; obstruction of flows, increased risk of erosion and water quality deterioration

Wetland Construction Remedy through rehabilitation; relocation; avoidance; Control through management; design measures.


Storm water control, topsoil and subsoil stripping.


Aquatic Construction Control through management; control through water management structures; monitor through hydrocarbon management unity; remedy through rehabilitation.




Archaeology and Heritage sites

Construction Control through management

Impact avoided

Construction of access roads, Hauling and transport

Increased traffic flow; dust generation and noise generation.

Traffic Construction Dust control, traffic and noise control measures, Avoidance

Traffic levels



Visual Construction Avoidance; Remedy through rehabilitation; Control through management.


Communities Job creation during construction;

Socio-economic Construction Avoidance (hiring of illegal immigrants and

Maintenance and monitoring

Multiplier effect on local economy;Continued corporate investment in host communities;Physical intrusionIncreased social pathologies;Increased pressure on services and resources.

child labour); Control through management; Increase Awareness through training, campaigning and skills development; design measures; traffic control measure; control through access monitoring.

Opencast mining activities; Overburden

No further impact Geology Operational None necessary Impact avoided

Excavation,channelling and berms, stockpiling of waste rock residue, tailingsstorage facilities, hauling and transport

Resultant Waste Rock Residue

Topography Operational Rehabilitation, Control through management; Avoidance; modify through alternative methods.



No further impact provided rehabilitation was taken

Waste Management

Operational Avoidance, Control through management

Impact avoided


Soil compaction Erosion on newly denuded areas, replaced topsoil and rehabilitated roads Hydrocarbon pollution


Operational Control through erosion control measures; remedy through rehabilitation; avoidance through chemical waste management; monitor through rehabilitation.



Habitat loss and harm to flora and fauna,Fragmentation of the habitat,Fauna mortalities, Presence of alien and invasive species resulting in habitat degradation.

Flora and Fauna Operational Control through management; Avoidance; modify through alternative methods, traffic control measures, alien and invasive species control

End-use objectives

Opencast mining, blasting,

Ambient noise levels Noise and Vibrations

Operational Control through noise control measures;

Noise levels

manage through monitoring; Avoidance, control through blasting controls.



Air Quality Operational Traffic and speed controls, Control through management.

Dust levels


No cumulative impact Groundwater Operational Control through management; control through water management structures; monitor through hydrocarbon management unity; remedy through rehabilitation

Impact avoided


No impact Surface water Operational Control through management, Modify through alternative methods, rehabilitation.

Impact avoided


Increased sedimentation within the wetlands, alien species and water quality deterioration. Wetland habitat degradation

Wetland Operational Rehabilitation, Avoidance; Control through management; design measures.


Storm water control Runoff from nearby rivers resulting in sedimentation

Aquatic Operational Control through management; control through water management structures; monitor through hydrocarbon management control measure; control through access monitoring.

End-use objectives

Opencast pit operations

No impact Archaeology and Heritage

Operational Control through management

Impact avoided

Hauling and transport. Noise due to increased traffic volumes

Traffic Operational Dust control, traffic and noise control measures;

Noise levels

Avoidance.Surface infrastructure Aesthetic quality and

sense of placeVisual Operational Avoidance, modify,

rehabilitationImpact avoided


Dependency on mine for sustaining local economyIncreased social pathologies

Socio-economic Operational Avoidance (hiring of illegal immigrants and child labour); Control through management; Increase Awareness through training, campaigning and skills development; design measures; traffic control measure; control through access monitoring.

No further impact Geology Decommissioning Impact AvoidedTailings storage facilities, Hauling and transport

No further impact Topography Decommissioning Control through management; Avoidance; modify through alternative methods.

Impact Avoided

No further impact Waste Management

Decommissioning Impact Avoided


Soil erosion, water erosion,Loss of land capability Loss of land use

Soil and land capability

Decommissioning Control through management, Erosion control measures, remedy, design measures, monitoring through rehabilitation.


Removal of mining infrastructure, Access roads.

Cumulative Flora and Fauna Decommissioning Control through management, stop through destroyal of invasives, modify through alternative method, alien control measures, traffic controls

End-use objectives

Machinery and equipment, Cumulative

No impact Vibrations Decommissioning Noise control, monitoring Impact avoided



Air Quality Decommissioning Traffic control measures, monitoring through rehabilitation, dust control.

Dust levels

No further impact Surface Water Decommissioning Impact AvoidedPotential surface decant, Long term quality of seepage from the tailings storage facilities

Ground water

Cessation of mining Wetland Habitat degradation

Wetland Decommissioning Control through management, stop through destroyal of invasives, modify through alternative method, alien control measures, Remedy.


Mining and processing plants

No further impact Aquatic Decommissioning Impact avoided

No further impact Archaeology and Heritage

Decommissioning Impact avoided

Demolition of surface infrastructure

No further impact Noise Decommissioning Impact avoided

Roads, Cessation of mining, demolition of infrastructure

No negative impact there will be improvement in traffic post operational phase

Traffic Decommissioning None necessary Impact avoided


Aesthetic Value and sense of place

Visual Decommissioning Control through management; Rehabilitation


Community Dependency on mine for sustaining local economyIncreased social pathologies

Socio-economic Decommissioning Avoidance (hiring of illegal immigrants and child labour); Control through management; Increase Awareness through training, campaigning and skills development; design measures; traffic control measure; control through access monitoring

End use objectives

No further impact Geology Closure Impact avoidedNo further impact Topography Closure Impact avoided

No further impact Waste and Hazardous Substances

Closure Impact avoided


Soil erosion, water erosion,Loss of land capability Loss of land use


Closure Rehabilitation; Control through monitoring, design measures, remedy.



Cumulative Flora and Fauna Closure Rehabilitation; Monitor through rehabilitation, control through management.


No impact Vibrations Impact avoidedDecommissioning activities, Transport and hauling, Roads


Air Quality Closure Traffic control measures, monitoring through rehabilitation, dust control.

Dust levels

No further impact Surface water Closure Impact avoidedDefunct tailing dam, underground blasting activity, backfilling

Potential surface decant, Long term quality of seepage from the tailings storage facilities

Ground water Closure Monitoring, modify through alternative method.

End use objectives

Rehabilitation Wetland Habitat Degradation

Wetland Closure Rehabilitation, Avoidance; Control through management; design measures.


No further Impact Aquatic Closure Impact avoidedNo further Impact Archaeology and

Heritage sitesImpact avoided

No further Impact Noise Closure Impact avoidedNo negative impact there will be improvement in traffic post operational phase

Traffic Closure Impact avoided

Surface infrastructure Demolition


Visual Closure Control; Rehabilitation Rehabilitation Standards

Communities Dependency on mine for sustaining local economyIncreased social

Socio-economic Closure Avoidance (hiring of illegal immigrants and child labour); Control

End use objectives

pathologies through management; Increase Awareness through training, campaigning and skills development; design measures; traffic control measure; control through access monitoring.

f) Impact Management Actions

(A description of impact management actions, identifying the manner in which the impact management objectives and outcomes contemplated in paragraphs (c) and (d) will be achieved).

ACTIVITY Whether listed or not

listed.

(E.g. Excavations, blasting, stockpiles, discard dumps or dams, Loading, hauling and transport, Water supply dams and boreholes, accommodation, offices, ablution, stores, workshops, processing plant, storm water control, berms, roads, pipelines, power lines, conveyors, etc.…etc.…etc.).

POTENTIAL IMPACT

(E.g. dust, noise, drainage surface disturbance, fly rock, surface water contamination, groundwater contamination, and air pollution etc.….etc…)

MITIGATIONTYPE

(modify, remedy, control, or stop) through (E.g. noise control measures, storm-water control, dust control, rehabilitation, design measures, blasting controls, avoidance, relocation, alternative activity etc. etc)

E.g. Modify through alternative

method. Control through noise control Control through management

and monitoringRemedy through rehabilitation..

TIME PERIOD FOR IMPLEMENTATION

Describe the time period when the

measures in the environmental

management programme must be

implemented Measures must be

implemented when required.

With regard to Rehabilitation

specifically this must take place at the

earliest opportunity. .With regard to

Rehabilitation, therefore state either:-...

Upon cessation of the individual

activity

Or.

Upon the cessation of mining, bulk sampling or alluvial diamond prospecting as the case may be.

COMPLIANCE WITH STANDARDS

(A description of how each of the recommendations in 2.11.6 read with

2.12 and 2.15.2 herein will comply with any prescribed environmental

management standards or practices that have been identified by

Competent Authorities)

CONSTRUCTION PHASE

Excavation, stockpiling, channelling and berms

Disturbances/changes to the topography of the area(Temporal)

Remedy through rehabilitation Ongoing, Post construction, 6 monthly

NEMACARAGN R983


Potential soil and water contamination;legal non-compliance; lost opportunities for waste recycling

Control through management Ongoing NEMWA


Soil compaction; soil loss due to wind and water erosion; change of

Control through erosion control measures; remedy through rehabilitation; avoidance

Ongoing, Post construction, 6 monthly

NEMA CARA GN R 983

land-use from natural to industrial; soil pollution due to hydrocarbon and cement spillages; sterilisation of the soil resource

through chemical waste management; monitor through rehabilitation.


Habitat loss and harm to flora and fauna;Fragmentation of the habitat resulting in harm to flora and fauna;Fauna mortalities;habitat degradation

Control through management; Avoidance; modify through alternative methods.

Prior to ground clearing and when required








Alien and Invasive Species Regulations (GNR 599 of 2014) as part of the NEMBA

Blasting Human discomfort and structural damage; New total resulting ambient noise levels elevated

Control through noise control measures; manage through monitoring; Avoidance, control

Prior to blasting, Duration of blast

National and provincial noise regulations. SANS 10103

above pre-development levels and the actual increase in ambient noise levels

through blasting controls.

Topsoil and subsoil stripping, Transport and hauling.


Control through management; control through traffic and speed control measures;

On-going Compliance with NEMAQA and with the South African National Dust Control Regulations


Sheet erosion; dust; potential pollution by hazardous substances; Poor sanitation and poor storm water management; Deterioration in water Quality and decrease in catchment Yield;

Control through management; control through water management structures; monitor through hydrocarbon management unity; remedy through rehabilitation.


NWA GN 704

Processing plants, tailings storage facility.


Control through management (water balance); stop through shaft design measures, monitor through pollution control dams.

On-going NWA

Surface infrastructure Degradation of wetland Habitat; increased sedimentation within the wetlands

increased turbidity; obstruction of flows, increased risk of erosion and water quality deterioration

Remedy through rehabilitation; relocation; avoidance; Control through management; design measures.

Prior to commencement of activity, when necessary and ongoing

Section 21 of the NWA

Storm water control, topsoil and subsoil

Destruction / disturbance of the

Control through management; control through water

Ongoing and when required. NWA

stripping. Bierpruit and other rivers in the area

management structures; monitor through hydrocarbon management unity; remedy through rehabilitation.



Control through management Prior to construction and ongoing

Section 3 of The National Heritage Resources Act (Act No 25 of 1999)

Construction of access roads, Hauling and transport

Increased traffic flow; dust generation and noise generation.

Dust control, traffic and noise control measures, Avoidance

Ongoing National Road Agency



Avoidance; Remedy through rehabilitation; Control through management.

Once tailings storage facility has been decommissioned, ongoing and when required.

None

Communities Job creation during construction;Multiplier effect on local economy;Continued corporate investment in host communities;Physical intrusionIncreased social pathologies;Increased pressure on services and resources.

Avoidance (hiring of illegal immigrants and child labour); Control through management; Increase Awareness through training, campaigning and skills development; design measures; traffic control measure; control through access monitoring.

Prior to commencement of social projects, ongoing and verify every 6 months.


OPERATIONAL PHASE

Excavation,

channelling and berms, stockpiling of waste rock residue, tailings

storage facilities, hauling and transport

Resultant Waste Rock Residue

Rehabilitation, Control through management; Avoidance; modify through alternative methods.

Prior construction, ongoing, post construction, six monthly.

NEMA

CARA

GN R983


No further impact provided rehabilitation was taken

Avoidance, Control through management

Ongoing The Hazardous substances Act (Act 15 of 1973) and the NWA.

Relevant SANS Standard and NEMWA.


Soil compaction

Erosion on newly denuded areas, replaced topsoil and rehabilitated roads

Hydrocarbon pollution

Control through erosion control measures; remedy through rehabilitation; avoidance through chemical waste management; monitor through rehabilitation.

Prior construction, ongoing, post construction, six monthly

NEMA CARA

GN R983


Habitat loss and harm to flora and fauna,

Fragmentation of the habitat,

Fauna mortalities, Presence of alien and invasive species resulting in habitat degradation.

Control through management; Avoidance; modify through alternative methods, traffic control measures, alien and invasive species control

Prior to ground clearing, prior to construction, when required and ongoing.







NEMBA Section 56 (1), 57 (1),

57 (2) and 57 (4)



Opencast mining, blasting, Ambient noise levels Control through noise control measures; manage through monitoring; Avoidance, control through blasting controls.

When required National and provincial noise regulations. SANS 10103



Traffic and speed controls, Control through management.

Prior to commencement of conveyor belt and ongoing.

NEMAQA and the South African National Dust Regulations


No cumulative impact Control through management; control through water management structures; monitor through hydrocarbon management unity; remedy through rehabilitation

When required and ongoing NWA


No impact Control through management, Modify through alternative methods, rehabilitation.

Ongoing, Prior to contract commencement, commissioning of infrastructure and operation of sewage facilities.

NWA

GN 704


Increased sedimentation within the wetlands,

Alien species and water quality deterioration. Wetland habitat degradation

Rehabilitation, Avoidance; Control through management; design measures.

Once off, when required and when necessary.

NWA

Storm water control Runoff from nearby rivers resulting in sedimentation

Control through management; control through water management structures;

monitor through hydrocarbon management control measure; control through access monitoring.

Opencast pit operations No impact Control through management Prior to construction and ongoing.

Section 3 of The National Heritage Resources Act (Act No 25 of 1999)

Hauling and transport. Noise due to increased traffic volumes

Dust control, traffic and noise control measures; Avoidance.

Ongoing National Road Agency

Surface infrastructure Aesthetic quality and sense of place

Avoidance, modify, rehabilitation

Ongoing and when required None


Dependency on mine for sustaining local economy

Increased social pathologies

Avoidance (hiring of illegal immigrants and child labour); Control through management; Increase Awareness through training, campaigning and skills development; design measures; traffic control measure; control through access monitoring.

Ongoing, construction phase, prior to commencement of social projects, prior to planning retrenchments, verify 6 monthly.


DECOMMISSIONING PHASE

Tailings storage facilities, Hauling and transport

No further impact Control through management; Avoidance; modify through alternative methods.


NEMA CARA

GN R983


Soil erosion, water erosion,


Loss of land use

Control through management, Erosion control measures, remedy, design measures, monitoring through rehabilitation.


NEMA CARA

GN R983

Removal of mining infrastructure, Access

Cumulative Control through management, stop through destroyal of

Prior to construction and phase


roads. invasives, modify through alternative method, alien control measures, traffic controls

Machinery and equipment, Cumulative

No impact Noise control, monitoring When required



Traffic control measures, monitoring through rehabilitation, dust control.

Ongoing NEMAQA and with the South African National Dust Regulations

Cessation of mining Wetland Habitat degradation

Control through management, stop through destroyal of invasives, modify through alternative method, alien control measures, Remedy.

On-going

Demolition of surface infrastructure

No further impact None necessary When required National and provincial noise regulations. SANS 10103



Rehabilitation When required and once tailings storage facility has been decommissioned.

None

Community Dependency on mine for sustaining local economy

Increased social pathologies

Avoidance (hiring of illegal immigrants and child labour); Control through management; Increase Awareness through training, campaigning and skills development; design measures; traffic control measure; control through access monitoring

Prior to planning retrenchments and ongoing.

None

CLOSURE PHASE


Soil erosion, water erosion,Loss of land capability

Rehabilitation; Control through monitoring, design measures,

During rehabilitation and annually for 5 years.

NEMA CARA

Loss of land use remedy. GN R983


Cumulative Rehabilitation; Monitor through rehabilitation, control through management.

Ongoing, at closure and verify 6 monthly.


Decommissioning activities, Transport and hauling, Roads


Traffic control measures, monitoring through rehabilitation, dust control.

At closure NEMAQA and with the South African National Dust Regulations

Defunct tailing dam, underground blasting activity, backfilling

Potential surface decant, Long term quality of seepage from the tailings storage facilities

Monitoring, modify through alternative method.

When required NWA

Surface infrastructure Demolition


Control; Rehabilitation Once tailings storage facility has been decommissioned.

None

(i) Financial Provision

1. Determination of the amount of Financial Provision.

(a) Describe the closure objectives and the extent to which they have been aligned to the baseline environment described under Regulation 22 (2) (d) as described in 2.4 herein.

Closure for the Cronimet Thaba Chrome Mine opencast and underground mining operations

and associated residual deposits will be undertaken in terms of the following principles:

To leave site in a safe state for humans and animals.

To ensure that the water resources (surface and ground) are not affected by both mining

and rehabilitation activities.

To promote indigenous vegetation growth suitable for animals that graze over the

disturbed areas on the site.

Backfilling of all excavated areas with waste rocks, overburden and topsoil material to

adopt a shape similar to its initial state.

Revegetate the tailings storage facility to ensure blending with the surrounding

environment.

(b) Confirm specifically that the environmental objectives in relation to closure have been consulted with land owner and interested and affected parties.

The environmental objectives in relation to closure have been consulted with landowner and

interested parties during the public participation process.

(c) Provide a rehabilitation plan that describes and shows the scale and aerial extent of the main mining activities, including the anticipated mining area at the time of closure.

The site covers an area of approximately 2129 Ha in extent, of which 136.392122 Ha is required

for residual deposit (tailing waste and waste rock material). A comprehensive closure and

rehabilitation plan will be developed in consultation will all interested and affected parties (I and

APs) and submitted with the draft EIR.

It is proposed that progressive approach to the rehabilitation of disturbed areas is adopted on

this site to ensure that where practicable, areas where mining or overburden placement are

completed, are quickly shaped , top soiled and vegetated to provide a stable land form. The

progressive formation of the post-mining landform and the establishment of a vegetative cover

will reduce the amount of disturbed land at any one time and also reduce the visibility of mine-

related activities from surrounding properties and roads. Early re-profiling and vegetation of

external batter slopes of the emplacement areas is particularly important and will be targeted as

a priority

(d) Explain why it can be confirmed that the rehabilitation plan is compatible with the closure objectives.

As detailed in the closure plan, the rehabilitation plan relates to each objective identified for the

mine. Therefore, the rehabilitation plan is considered to be compatible with the closure object-

ives.

(e) Calculate and state the quantum of the financial provision required to manage and rehabilitate the environment in accordance with the applicable guideline.

The quantum of financial rehabilitation for negative environmental impact has been estimated at

a total cost of R47 299 964.96.

(f) Confirm that the financial provision will be provided as determined.

The quantum of financial rehabilitation of negative environmental will be provided as determined.

Mechanisms for monitoring compliance with and performance assessment against the environmental management programme and reporting thereon, including

a) Monitoring of Impact Management Actionsb) Monitoring and reporting frequencyc) Responsible personsd) Time period for implementing impact management actionse) Mechanism for monitoring compliance

SOURCE ACTIVITY IMPACTS REQUIRING MONITORING

PROGRAMMES

FUNCTIONAL REQUIREMENTS FOR MONITORING

ROLES AND RESPONSIBILITIES

(FOR THE EXECUTION OF THE MONITORING PROGRAMMES)

MONITORING AND REPORTING FREQUENCY and TIME PERIODS FOR

IMPLEMENTING IMPACT MANAGEMENT ACTIONS


- Quantities of non-hazardous waste to landfill

- Quantities of hazardous waste to landfill

- Quantities of domestic waste recycled

- Quantities of hazardous waste recycled

- Quantities of mining waste generated

- Total volume of non-hazardous waste material accepted into licensed landfill sites.

- Total volume of hazardous waste material accepted into licensed landfill sites.

- Total volume of waste from the operations used by a third party for recycling, separated into paper, glass, plastic, steel.

- Total volume of hazardous waste from the operations used by a third party for recycling, including oil and batteries

- Total volume of mining waste generated including waste rock residue and tailings

- Determine quantities of non-hazardous waste disposed of

- Determine quantities of hazardous waste disposed of

- Determine quantities of general waste recycled

- Determine quantities of hazardous waste recycled

- Determine quantities of mining waste generated

Monthly, Annual Sustainability Report.

Resource use Quantities of resources and materials used

Total quantity of the following resources used:• Diesel

Determine quantities of resources and materials used

Monthly, Annual Sustainability Report.


PROGRAMMES






• Petrol• Gas• Electricity (Eskom)• Solar energy• Magalies Water• Ground water• Water re-cycled

Land Management Total area Land Use Management

Total area of the following aspects:• Area rehabilitated• Area disturbed• Area impacted by opencast mining• Area impacted by surface infrastructure• Area impacted by waste rock residue deposits and tailings storage facility

Determine extent of mining footprint and impacts

Annually, Annual Sustainability Report.

Flora and Fauna Management

Biodiversity indicator monitoring

Biodiversity indicators to include the following:• Extent of the footprint• Extent and condition of wetlands;• Habitat transformation;• Distribution and abundance of selected alien plant species;• Presence and viability of endangered endemic species• Soil erosion• Rehabilitation – flora succession over time

Determine the state of biodiversity and associated parameters

Annually, Internal Monitoring Report.


PROGRAMMES






Noise management - Noise emissions that will cause impacts on pre-development ambient noise levels

- Sample environmental noise levels at the Thaba Cronimet Chrome Mine boundary

- Determine noise level with equipment operating at a distance of 10 m

- Measure at complainants location when equipment and processes are in operation

- Determine ambient noise levels at Thaba Cronimet Chrome Mine boundary which can serve as references

- Create a reference base for equipment emission levels which will assist in keeping maintenance levels optimised

- Responding effectively to complaints

First monitoring before start of construction. Thereafter 6 monthly for the duration of construction.

Report on the noise ambient levels at the mine.

Vibration Management

Vibrations from blasting

Establish permanent seismograph stations at locations 7, 9, 11, 18 and 19 according to the BS 7385-2:1993 standard. Should locations 7, 9, 11 be demolished this would not be necessary at those stations. Monitoring stations to be erected should blasting take place within 250 m of these structures

Ascertain and evaluate current vibrations and guide blasters for further blasting

Daily measurements and during blasting, Internal

Air Quality Management

Dust fall out (PM 10) Establishment of six additional dust buckets as follows (refer to Figure 28-1)• DB1 directly downwind of the existing processing plant at Middelaagte 382 KQ – between the RoM stockpile and plant (the dust fallout at this site

To assess compliance with dust fall limits within the main impact zone of the operation and to facilitate the measurement of progress against environmental targets within the main impact zone of the operation.

On-going, continuous monitoring to be implemented facilitating data collection over one month averaging period. Annually to DMR


PROGRAMMES






should not exceed 1200 mg/m²/day);• DB2 downwind of the access road (the dust fallout at this site should not exceed 1 200 mg/m²/day) • DB3 on the mining right boundary (the dust fallout at this site should not exceed 1 200 mg/m²/day)• DB4 located between Thaba Cronimet Chrome Mine and R4, within 50 m oR4 (the dust fallout at this site should not exceed 600 mg/m²/day)• DB5 located at starting point of conveyor used for Moddergat operation (the dust fallout at this site should not exceed 1 200 mg/m²/day);• DB5 located downwind of Moddergat processing plant operations (the dust fallout at this site should not exceed 1 200 mg/m²/day)Placement of a PM10 monitor at the receptor labelled R4, which falls within the mining right boundary. This is the receptor nearest the mining operations and monitoring is recommended to confirm concentrations falling below the relative standards.

Analyse the temporal trends to determine the potential for nuisance impacts within the main impact zone of the operation so as to inform the public of the extent of localised dust nuisance impacts occurring in the vicinity of the mine operations.

Surface Water Management

- Surface water quality (natural

- The inclusion of an additional thirteen

- Identify and determine the extent

- Monthly, Annually to DWS.- Bi-annually (once in the


PROGRAMMES






water bodies and process water)

- Bio-monitoring (Invertebrate Habitat Assessment System

monitoring points as depicted by Figure 28-3. It is not possible to provide the exact positioning of all these points as these will be determined as the infrastructure is constructed. It is also to be noted that the process water points will only be monitored once construction has taken place.

- Monitoring done on the Bierspruit at five locations and one location within the mining process water. It includes an assessment of in situ biota specific water quality, habitat integrity and suitability for aquatic

of possible impacts on surface water qualities

- To determine the impact of activities on the invertebrate habitat according to the South African Scoring System

winter and once in the summer months), annually to DWS.

Ground Water Management

Ground water quality and levels

Newly drilled boreholes and proposed boreholes will be used for groundwater monitoring and have been included in the monitoring plan for the mine

- Identify and determine the extent of possible groundwater impacts

- Determine ground water levels and fluctuations

Quarterly, Annually to the DWS.

Closure Liability Closure Liability Closure liability update assessment

Determine the closure liability that is required for premature mine closure

Annually, Report to be submitted to the DMR

l) Indicate the frequency of the submission of the performance assessment report.

The performance assessment report for the implementation of the commitments made in the

approved EMP reports for CCMSA will be submitted yearly as required in terms of Regulation

527 of MPRDR (Regulation 55) and other related regulations.

m) Environmental Awareness Plan

1. Manner in which the applicant intends to inform his or her employees of any environmental risk which may result from their work.

A site induction and environmental training programme will be generated for the project. All

staff commissioned during pre-construction and construction, including subcontractors will be

advised of the EMP and EMS requirements through the induction programme.

General awareness – this training applies to all employees and contractors. General

awareness training is provided during induction training which is mandatory for all

employees and contractors on appointment at Thaba Cronimet Chrome Mine.

Subsequently all employees and contractors will undergo induction training on an annual

basis. The general awareness training is to provide information on the following:

- Cronimet’s environmental responsibility;

- Employee and contractor responsibilities;

- Environmental legislation and authorisations;

- Environmental commitments;

- Cronimet’s SHE policy;

- Introduction on ISO 14 001;

- Key system and operational requirements;

- Key requirements in terms of the management water, waste, land and soil,

archaeological, traffic, noise and flora and fauna as aligned with the

Environmental Management Programme Report, water use licenses and general

legislation.

2. Manner in which risks will be dealt with in order to avoid pollution or the degradation of the environment.

The conditions and proposals of contained in this Environmental Impact Report and

Environmental Management Programme will beimplemented in order to protect the

environment and comply with environmental legislation.

The EMP provides assurance that the project proponent has made suitable provision for

mitigation. Methods and procedures for mitigating and monitoring impacts will be

described in it. This document will be used throughout the project lifecycle and regularly

updated to remain aligned with the project as it progresses from construction to

operation, decommissioning and closure phase.

Furthermore, environmental management system will be included which provides a

systematic framework and approach to minimize risks and control environmental aspects

as well as impacts.

n) Specific information required by the Competent Authority(Among others, confirm that the financial provision will be reviewed annually).

o) UNDERTAKING

The EAP herewith confirms

a. the correctness of the information provided in the reports

b. the inclusion of comments and inputs from stakeholders and I&APs ;

c. the inclusion of inputs and recommendations from the specialist reports where relevant; and

d. the acceptability of the project in relation to the finding of the assessment and level of mitigation proposed;

REFERENCES

Brinson, M. M. 1993. A hydrogeomorphic classification for wetlands. Wetlands Research Program.

Technical Report WRP-DE-4. U. S. Army Corps of Engineers, Waterway ExperimentStation. Vicksburg, MS: Bridgham and Richardson

Consulmet Metals (Pty) Ltd, 2014. Thaba Mine Expansion Project Chrome Recover Plant: Process, Operation and Control Philosophy.

Council for Geosciences, 1974: 1:250 000 Geological Map Series of South Africa – Sheet 2426 Thabazimb

Department of Environmental Affairs. 2010. Companion to the EIA Regulations 2010, Integrated Environmental Management Guideline Series 9; Pretoria, South Africa



Department of Environmental Affairs. (2012). Air Quality Graphs. Retrieved August 28, 2012, from South African Air Quality Information System: http://www.saaqis.org.za

Department of Environmental Affairs and Tourism. 2002. Integrated Environmental Management, Information series 2: Scoping

Department of Mineral Resources. 2002. Guideline for the Compilation of a Scoping Report; Pretoria, South Africa

DRA Mining (Pty) Ltd, 2012. Cronimet Project Bankable Feasibility Study

Gardiner, T 2009. EIA/EMP for the proposed Thaba Cronimet Chrome Mine and Process Plant. Johannesburg.

Greenline Projects. 2014. Thaba TSF Locality Plan

Marneweck, G.C. and Batchelor, A. 2002. Wetland inventory and classification. In: Ecological andeconomic evaluation of wetlands in the upper Olifants River catchment. (Palmer, R.W.,Turpie,

J., Marneweck, G.C and Batchelor (eds.). Water Research Commission Report No.1162/1/02.

Municipal Demarctation Board (2001). Census statistics 2001. Retrieved from the Worldwide Web on 30 March 2009. URL: www.demarcation.org.za.

Schulze, R. (1986). Weather Bureau 40. Climate of South Africa. Climate Statistics up to 1984.

South Africa. 1983. Conservation of Agricultural Resources Act (43 of 1983); Governmental Printer.

South Africa. 1998. National Environmental Management Act, Act 107 of 1998. Governmental Printer.

South Africa. 1998. National Water Act (36 of 1998). Governmental Printer.

South Africa. 1999. Heritage Resources Act, Act 25 of 1999. Governmental Printer.

South Africa. 2002. Minerals and Petroleum Resources Development Act, (Act 28 of 2002). Governmental Printer.

South Africa. 2004. National Environmental Management: Air Quality Act (39 of 2004). Governmental Printer.

South Africa. 2004. National Environmental Management: Biodiversity Act (10 of 2004). Governmental Printer.

South Africa. 2008. National Environmental Management: Waste Act, 2008 (Act No. 59 of 2008). Governmental Printer.

South Africa. 2009. National Environmental Management Act, 2008 (Act No. 107 of 1998). Government Notice 719. Amendment of Notices Nos. R. 386 and R. 387 of 2006. Governmental Printer.

South Africa. 2009. National Environmental Management: Waste Act, 2008 (Act No. 59 of 2008). 2009. Government Notice 718. List of Waste Management Activities that have, or are likely to have a detrimental effect on the environment. Governmental Printer.

South Africa. 2011. National Development Plan, Vision for 2030. National Planning Commission.

Governmental Printer.

South Africa. 2014. Medium Term Strategic Framework (2014-2019). Governmental Printer.

Thabazimbi Local Municipality. 2013. Integrated Development Plan for 2013/2014

Thabazimbi Local Municipality (2008). Integrated Development Plan 2008-2009.

Thabazimbi Local Municipality. 2008. Spatial Development Plan

Thabazimbi Local Municipality, 2014: Land Use Scheme

Tiwary, A., & Colls, J. (2010). Air Pollution: Measurement, Modelling and Mitigation.

Tiwary, A., & Colls, J. (2010). Air pollution: measurement, monitoring and mitigation (3rd Edition

ed.). Oxon: Routledge.

www.angloplatinum.com/pdf%5C2009%5Cwater.pdf

www.cronimet-mining.com

(http://www.matthey.com/)

www.minerals.usgs.gov/minerals/pubs/commodity/chromium/mcs-2013-chrom.pdf

www.nationsencyclopedia.com/economies/Africa/South-Africa

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