SCOPING REPORT
WASTE MANAGEMENT LICENCE APPLICATION FOR THE PROPOSED TAILINGS STORAGE FACILITIES AND MINE
WASTE ROCK DUMP SITES AT CRONIMET THABA CHROME MINE, LIMPOPO PROVINCE
11 DECEMBER 2015
NAME OF APPLICANT: Cronimet Chrome Mining SA (Pty) Ltd
DMR REFERENCE NUMBER: LP 30/5/1/3/2/1 (115) EM
STANDARD DIRECTIVE
All applicants for, mining rights, in terms of the provisions of Section 29 (a) and in terms of
Regulation 49 (4) of the Mineral and Petroleum Resources Development Act, are herewith
directed to submit a Scoping Report strictly in accordance with parts G and H of this
guideline, within 30 days of notification by the Regional Manager of the acceptance of such
application.
PREAMBLE
The scoping report contemplated in Regulation 49 is founded on the principle of consultation
with interested and affected parties, which consultation process and its result is an integral
part of the fairness process. The decision to grant a mining right cannot be fair if the
administrator did not have full regard to precisely what happened during the consultation
process in order to determine whether the consultation was sufficient to render the grant of
the application procedurally fair.
The State acknowledges the importance of the involvement of communities where mining is
taking place at the earliest stages of applications for prospecting and mining rights and
permits. This entails the communities being informed and consulted on any mining activities
applied for by mining companies in their area.
Issues around consultation have been problematic in that there have been no guidelines on
how it should be conducted, and as a result there has been resistance on the part of many
landowners and communities against mining activities in their land. This has been
exacerbated by the lack of clarity concerning the relationship between the provisions of
section 10 of the Act and those in sections 16, 22 and 27 regarding the notification of and
consultation with interested and affected parties, and the submission of the results of such
consultation.
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YOUR COMMENTS ON THE DRAFT SCOPING REPORT
Draft Scoping Report (DSR) will be available for comment for a period of 30days from Friday
11 December 2015 to Monday 01 February 2016
Copies of the DSR, are available at the following public places and upon request from the
stakeholder engagement office:
PUBLIC PLACE LOCALITY CONTACT DETAILS
Thabazimbi Public Library 4th Avenue L. Mokwena (014 777 1525)
Thabazimbi LocalMunicipality Office
7 Riebok Street T. Masilo (083 552 9341)
Northam Library 313 Tungsten St Miriam Manyako(014 784 0128)
An electronic version of the DSR can be found at www.sazienvironmental.co.za
The following methods of public review of the DSR are available:
Additional written submissions; and
Comment by email, fax or telephone.
DUE DATE FOR COMMENTMonday 01 February 2016
Please submit comments to the Stakeholder Engagement Officers:
Ms Sandisiwe Ndlazi
Sazi Environmental Consulting
B16 Lone Creek, Waterfall Office Park, Vorna Valley, 1684
Phone: (011) 312 2608/ 079 446 9319
Fax: (011) 312 7208
Email: [email protected]/[email protected]
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PROJECT INFORMATION
PROJECT TITLE: WASTE MANAGEMENT LICENCE APPLICATION FOR THE PROPOSED TAILINGS STORAGE FACILITIES AND MINE WASTE ROCK DUMP SITES AT CRONIMET THABA CHROME MINE, LIMPOPO PROVINCE
.
DATE: DECEMBER 2016
PROPONENT:Company Name: CRONIMET CHROME MINING SA (PTY) LTD
Registration Number: 2003/008407/07
Contact Person: Silvia Costa
Designation: Chief Executive Officer (CEO)
Tel: 011 958 0544
Fax: 011 958 0467
Email: [email protected]
Postal Address: P. O. Box 3319, Witkoppen, 2068
CONSULTANT:Company Name: SAZI ENVIRONMENTAL CONSULTING cc.
Contact Person: Mrs Nonkanyiso Zungu
Designation: Managing Director
Tel: 084 8000 187/ 011 312 2806
Email: [email protected]/
Physical Address: B16 Lone Creek, Waterfall Park, Vorna Valley, Midrand, 1684.
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TABLE OF CONTENTS
STANDARD DIRECTIVE..........................................................................................................ii
PREAMBLE..............................................................................................................................ii
YOUR COMMENTS ON THE DRAFT SCOPING REPORT...................................................iii
PROJECT INFORMATION......................................................................................................iv
EAP EXPERIENCE.................................................................................................................xi
DEFINITIONS.........................................................................................................................xii
1 INTRODUCTION..............................................................................................................1
1.1 PURPOSE OF THE SCOPING REPORT.................................................................1
1.2 SUMMARY OF CONTENT OF DRAFT SCOPING REPORT...................................1
2 PROJECT BACKGROUND..............................................................................................3
2.1 PROJECT LOCALITY................................................................................................4
3 NEED AND DESIRABILITY..............................................................................................6
4 ALTERNATIVES CONSIDERED......................................................................................7
4.1 LOCATION ALTERNATIVES....................................................................................7
4.2 NO GO OPTION......................................................................................................10
5 LAND OWNERSHIP.......................................................................................................12
6 LEGISLATIVE CONTEXT...............................................................................................14
6.1 NATIONAL ENVIRONMENTAL MANAGEMENT ACT............................................14
6.2 NATIONAL ENVIRONMENTAL MANAGEMENT: WASTE AMENDMENT ACT,
2014 (ACT 26 OF 2014).....................................................................................................14
6.3 NATIONAL HERITAGE RESOURCES ACT, 1999 (ACT 25 OF 1999)...................14
6.4 NATIONAL ENVIRONMENTAL BIODIVERSITY ACT, 2004 (ACT 10 OF 2004)....15
6.5 LEGISLATIVE CONTEXT OF THE PROPOSED ACTIVITIES...............................16
7 BASELINE ENVIRONMENT...........................................................................................20
7.1 CLIMATE.................................................................................................................20
7.1.1 Mean Annual Wind Speed And Direction.........................................................20
7.1.2 Mean Monthly Ambient Temperature...............................................................21
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7.1.3 Precipitation......................................................................................................21
7.2 TOPOGRAPHY.......................................................................................................22
7.3 SOILS AND LAND CAPABILITY.............................................................................22
7.3.1 Land Use Categories........................................................................................22
7.3.2 Soil Categories.................................................................................................22
7.3.3 Land Capability.................................................................................................23
7.3.4 Soil Quality and Land Use................................................................................23
7.3.5 Agricultural Potential.........................................................................................24
7.4 GEOLOGY...............................................................................................................24
7.4.1 Faults................................................................................................................26
7.4.2 Iron Rich Pegmatoids.......................................................................................26
7.4.3 Dykes................................................................................................................26
Figure 7:4 Aeromagnetic Map for the Mineral Lease Area.............................................27
7.5 FLORA AND FAUNA...............................................................................................27
7.5.1 Flora.................................................................................................................27
7.5.2 Sensitivity.........................................................................................................28
7.5.3 Fauna...............................................................................................................29
7.6 AIR QUALITY..........................................................................................................31
7.6.1 Mining Operations in the Region......................................................................32
7.6.2 Industrial Operations in the Region..................................................................32
7.6.3 Vehicle Tailpipe Emissions...............................................................................33
7.6.4 Domestic Fuel Burning.....................................................................................33
7.6.5 Agricultural Activities........................................................................................33
7.6.6 Biomass Burning..............................................................................................34
7.6.7 Fugitive Dust Sources......................................................................................34
7.7 NOISE......................................................................................................................35
7.7.1 Measurement Position One..............................................................................36
7.7.2 Measurement Position 2...................................................................................37
7.7.3 Measurement Position 3...................................................................................38
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7.7.4 Measurement Position 4...................................................................................38
7.7.5 Measurement Position 5...................................................................................39
7.7.6 Measurement Position 6...................................................................................39
7.8 ARCHEOLOGY.......................................................................................................40
7.8.1 Late Iron Age Simplex Sites.............................................................................41
7.8.2 Stone Age Sites................................................................................................42
7.8.3 Iron Age Sites...................................................................................................43
7.8.4 Late Iron Age Complex Sites............................................................................43
7.8.5 Cemeteries.......................................................................................................44
7.8.6 European Homestead.......................................................................................45
7.8.7 Historic/Recent Mining......................................................................................45
7.9 WETLANDS.............................................................................................................45
7.9.1 Wetland Delineation and Classification............................................................45
7.9.2 Functional Assessment....................................................................................48
7.9.3 Present Ecological Status.................................................................................49
7.9.4 Ecological Importance and Sensitivity..............................................................49
7.10 AQUATIC.................................................................................................................50
7.10.1 In Situ Water Quality.........................................................................................51
7.10.2 Habitat Assessment..........................................................................................51
7.11 GROUNDWATER....................................................................................................58
7.11.1 Depth of the Water Table.................................................................................58
7.11.2 Presence of Boreholes and Springs and their Estimated Yields......................59
7.11.3 Ground Water Quality.......................................................................................59
7.11.4 Groundwater Quality Distribution and Compliance..........................................60
7.11.5 Groundwater Use.............................................................................................61
7.11.6 Groundwater Zone............................................................................................62
8 INITIAL APPLICATION AND SCOPING PROCESS......................................................64
8.1 APPLICATION PHASE............................................................................................64
8.2 SCOPING PHASE...................................................................................................64
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8.2.1 Stakeholder Review Prior to Submission.........................................................65
8.2.2 Submission and Decision-Making....................................................................65
9 PUBLIC PARTICIPATION UNDERTAKEN TO DATE....................................................66
9.1 INTERESTED AND AFFECTED PARTIES ISSUES AND RESPONSES...............67
10 AN IDENTIFICATION OF THE ANTICIPATED ENVIRONMENTAL, SOCIAL OR
CULTURAL IMPACTS...........................................................................................................72
11 PLAN OF STUDY FOR THE ENVIRONMENTAL IMPACT ASSESSMENT...............74
11.1 TASKS TO BE UNDERTAKEN DURING THE ENVIRONMENTAL IMPACT
ASSESSMENT PHASE......................................................................................................74
11.1.1 Specialist Studies.............................................................................................78
11.1.2 Terms of reference for specialist studies..........................................................78
11.1.3 Stakeholder Review Prior to Submission.........................................................87
11.1.4 Submission and Decision-Making....................................................................87
11.2 IMPACT ASSESSMENT RATING AND ASSESSING SIGNIFICANCE
METHODOLGY..................................................................................................................88
11.2.1 Qualitative Impact Assessment Methodology...................................................88
11.2.2 Quantitative Impact Assessment Methodology................................................88
TABLE OF FIGURES
Figure 2:1 Cronimet Thaba Chrome Mine Locality Map..........................................................5
Figure 4:1 Proposed Tailings Storage Facility and Waste Rock Dump Locality Alternatives. .9
Figure 4:2 Chromium Production and Reserves....................................................................10
Figure 7:1 Period, Daytime and Night-Time Wind Roses For Cronimet For The Period 2006.
...............................................................................................................................................20
Figure 7:2 Monthly Precipitation at Thabazimbi for the Period 2006-2007............................21
Figure 7:3 Regional Geological Map for the Cronimet Study Area (Council For Geosciences)
...............................................................................................................................................25
Figure 7:4 Aeromagnetic Map for the Mineral Lease Area....................................................27
Figure 7:5 Recorded Heritage Artefacts for the Area.............................................................41
Figure 7:6 Delineated Wetlands and Riparian Zones within the Mineral Lease Area............46
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LIST OF TABLES
Table 5:1 Property description...............................................................................................12
Table 5:2 Land ownership details..........................................................................................12
Table 6:1 Description of the listed activities...........................................................................16
Table 6:2 Details of the TSF and WRD sites.........................................................................18
Table 7:1 Land Use Categories and Surface Areas for the Thaba Cronimet Chrome Mine
Mining Lease Area.................................................................................................................22
Table 7:2 Soil Groups and the surface area they cover.........................................................23
Table 7:3 Land Capability Derived From Soil and Land Use Data for the Survey Site..........23
Table 7:4 Vegetation Units Occurring in the Study Area........................................................28
Table 7:5 List of Red Data Birds Potentially Occurring in the Study Area.............................29
Table 7:6 List of Red Data Mammals that may occur in the Study Area...............................30
Table 7:7 Atmospheric Stability Classes................................................................................31
Table 7:8 Recommended Noise Levels SANS 10103:2008..................................................35
Table 7:9 Summary of Noise Monitoring Positions and Results............................................35
Table 7:10 Noise Measurements Taken At Position 1...........................................................37
Table 7:11 Noise Measurements Taken At Position 2...........................................................37
Table 7:12 Noise Measurements Taken At Position 3...........................................................38
Table 7:13 Noise Measurements Taken At Position 4...........................................................38
Table 7:14 Noise Measurements Taken At Position 5...........................................................39
Table 7:15 Noise Measurements Taken At Position 6...........................................................39
Table 7:16 Heritage Site Significance and Mitigation Measures............................................40
Table 7:17 The Hydro-Geomorphic Classification System (Adapted From Brinson, 1993;
Kotze, 1999 And Marneweck And Batchelor, 2002)..............................................................46
Table 7:18 Location, Description and Significance of the Chosen Bio-Monitoring Sites at
Thaba Mine............................................................................................................................50
Table 7:19 Classification of Present State Classes in terms of Habitat Integrity (DWAF,
1999)......................................................................................................................................52
Table 7:20 Intermediate Habitat Assessment Results...........................................................53
Table 7:21 Summary of the Water Levels in External and Monitoring Boreholes in the Study
Area........................................................................................................................................58
Table 7:22 Typical Background Ground Water Quality for the Study Area............................60
Table 7:23 The Current Groundwater Use in the Study Area................................................62
Table 9:1 Summary of Issues raised by Interested and Affected Parties..............................67
Table 11:1 Description of specialist studies...........................................................................78
Table 11:2 Status of the Impact and Ratings.........................................................................88
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Table 11:3 Certainty of Impact and Ratings...........................................................................89
Table 11:4 Frequency Of Impact And Ratings.......................................................................89
Table 11:5 Spatial Extent of Impact.......................................................................................90
Table 11:6 Intensity of Impact And Ratings...........................................................................90
Table 11:7 Duration of Impact and Ratings............................................................................91
Table 11:8 Assessing Significance (Negative Impacts).........................................................91
Table 11:9 Assessing Significance (Positive Impacts)...........................................................92
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EAP EXPERIENCE
The Environmental Assessment Practitioners’ qualifications and CV are attached as
Appendix 1 and Appendix 2 respectively.
Nonkanyiso Zungu is a Professional Natural Scientist (Pr.Sci.Nat) with 10 years’ experience
in the environmental field. She has a Masters Degree in Environmental Management, and
specializes on Water Resource Management. She has extensive experience in obtaining
environmental authorisations (air, water, waste) across sectors that include: power
generation, infrastructure (Construction), transportation (rail), mining, 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.
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DEFINITIONS
‘consultation’ means a two way communication process between the applicant and the
community or interested and affected party wherein the former is seeking, listening to, and
considering the latter’s response, which allows openness in the decision making process.
‘community’ means a group of historically disadvantaged persons with interest or rights in a
particular area of land on which the members have or exercise communal rights in terms of
an agreement, custom or law: Provided that, where as a consequence of the provisions of
the Act negotiations or consultations with the community are required, the community shall
include the members or part of the community, directly affected by prospecting or mining, on
land occupied by such members or part of the community.
‘Interested and affected’ parties include, but are not limited to; –
(i) Host Communities
(ii) Landowners (Traditional and Title Deed owners)
(iii) Traditional Authority
(iv) Land Claimants
(v) Lawful land occupier
(vi) The Department of Land Affairs,
(vii) Any other person (including on adjacent and non-adjacent properties)
whose socio-economic conditions may be directly affected by the
proposed prospecting or mining operation
(viii) The Local Municipality,
(ix) The relevant Government Departments, agencies and institutions responsible for the
various aspects of the environment and for infrastructure which may be affected by the
proposed project.
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1 INTRODUCTION
1.1 PURPOSE OF THE SCOPING REPORT
The draft Scoping Report (DSR) describes the proposed project, the environment in which
the project is to be located and the specialist studies that will be undertaken as part
of the Impact Assessment Phase. It also aims to solicit inputs and comments from Interested
and Affected Parties (I&AP’s) on the proposed project. I&APs are given the opportunity to
comment on the proposal and scope for the EIA phase by reviewing the DSR.
This DSR is considered preliminary and has been compiled based on desktop analysis and
a literature review of the study area. It will serve as a start point to communicate project
details and further solicit public comments on the project. Specialist studies will be
completed in the meantime, after which the DSR will be updated and then made available for
public comment.
A number of information sessions will take place during the scoping phase of the project.
The comments received on the DSR and information sessions will be captured in an Issues
and Response Report (IRR) which will accompany the Final Scoping Report which is
submitted to DMR for approval.
This initial scope and public inputs guide the authorising authority in determining whether
there are gaps in information and whether additional measures are necessary to assess the
potential impacts of the development on the biophysical and social environment. DMR seeks
such input to support their decision making process and determine whether all potential
issues have been identified or whether further information is required.
1.2 SUMMARY OF CONTENT OF DRAFT SCOPING REPORT
Project background:
Project description and locality,
Alternatives considered,
Land ownership,
Needs and desirability,
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Legislative context,
Baseline environment;
Scoping and Environmental Impact Assessment methodology;
An overview of the EIA process;
Public participation followed to date including a list of interested and affected parties
identified and consulted;
A description of the existing environment within the project area based on desktop
analysis and a literature review;
The potential environmental issues and impacts which have been identified based on
desktop analysis and literature review;
Plan of study for EIA:
The preliminary scope of the specialist studies proposed to be undertaken as part of
this EIA;
Methodology for assessing impact
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2 PROJECT BACKGROUND
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 Cronimet Thaba 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 Cronimet Thaba 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 to include the following pits: ZK4, ZK3, ZK2,
ZK1.1, ZK1, ZK4A, ZK3A, ZK1A, ZK4B, ZK3B, ZK1B, ZK1C, ZK4C, ZK5B, EK2, ML3, ML4,
ZK5A, EK1, central and northern 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 an expansion of an existing Tailings
Storage Facility (TSF) and construction of new a new TSF as well as Waste Rock Dump
(WRD) sites.
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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 (Act 28 of 2004) together with the associated Environmental Impact
Assessment Regulations, 2014 (GNR 984), the proposed support infrastructure require a
Waste Management Licence (WML) from the Department of Mineral Resources (DMR)
through the undertaking of a full Environmental Impact Assessment process, 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.
2.1 PROJECT LOCALITY
Cronimet Thaba Chrome Mine (Thaba Mine) is located on the south-eastern part of the
Limpopo Province. The Limpopo Province is located on the northern border of South Africa
and is bordered by Mpumalanga Province to the south-east, Gauteng Province to the south,
and North West Province to the south-west. The site is located approximately 18 km North of
Northam and 30 km South-West from the town of Thabazimbi. In terms of the current
administrative boundaries, the project area falls within the jurisdictions of the Thabazimbi
Local Municipality which is under the jurisdiction of the Waterberg District Municipality.
Access to Thaba Cronimet Chrome Mine is via a gravel road connected to the R510 main
road, about 2 km North from the Chromedale railway siding.
The project area falls within ward 3, 5, and 8 of Thabazimbi Local Municipality which is under
the jurisdiction of the Waterberg District Municipality. Mining operations are located on
portions of the farm Elandskuil 378 KQ, Middellaagte 382 KQ, Moddergat 389 KQ,
Roodedam 368 KQ, Schildpadness 385 KQ, and Zwartkop 369 KQ, near the village of
Sebilong and Zwartkop, with Rethabile village located south from the mining lease area. The
site is located approximately 18 km north of Northam and 30 km south-west from the town of
Thabazimbi, at geographical coordinates 27.350272° east and -24.755931° South. An
overview of the site locality is indicated on the map below.
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Figure 2:1 Cronimet Thaba Chrome Mine Locality Map
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3 NEED AND DESIRABILITY
The needs and desirability of the proposed support infrastructure (TSF and WRD)
associated with Thaba Mine expansion takes into consideration the principles of NEMA, the
sustainable development objectives, programs and broader community needs within the
Thabazimbi Integrated Development Planning (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.
Mining has been earmarked within the Thabazimbi Local Municipality’s IDP as a significant
contributor of employment and economic growth. Thaba Mine realizes the importance of
programmes to ensure that local communities are sourced for employment opportunities.
Agriculture land use (grazing) can continue on the majority of the mineral lease area as the
largest component of mining will be underground mining, which will minimally affect
agriculture grazing land. In addition, agriculture may recommence once opencast mining is
complete and rehabilitation has taken place.
Furthermore, mining activities are fundamental to national economic growth as outlined in
the NDP and the Medium Term Strategic Framework which states that ‘We need to ensure
growth in the core productive sectors of manufacturing, mining and agriculture and open new
areas of economic growth’. Additionally the proposed project will provide for employment
and skills development, which are of national concern.
In addition, according to the SDF (2008) “larger Thabazimbi area is characterised by many
mining enterprises. The mining sector is the primary pillar of the Thabazimbi economy,
however from a development and environmental perspective it is important that mining takes
place in a responsible manner.” The Thabazimbi mining sector is the key sector towards the
overall economy of the Waterberg District and it also plays an important role in the provincial
economy (contributes 11% to the provincial economy).
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4 ALTERNATIVES CONSIDERED
“Alternatives” are defined in the NEMA EIA Regulations of 2014, as “different means of
meeting the general purpose and requirements of the activity”. The consideration of
alternatives is a key component of an EIA process. While an EIA process should investigate
and comparatively consider all alternatives that have been identified, only those found to be
“feasible” and “reasonable” must be comparatively assessed, in terms of the advantages and
disadvantages that the proposed activity and alternatives will have on the environment and
on the community that may be affected by the activity (DEA&DP, 2011b).
The “feasibility” and “reasonability” of an alternative are measured by:
General purpose and requirements of the activity;
Need and desirability of the activity;
Opportunity costs;
Need to avoid and/or minimize negative impacts;
Need to maximize benefits; and
How it impacts on the community that may be affected by the activity
(DEA&DP, 2011b).
The different types of alternatives that can be considered as part of an EIA process include
the following:
Property on which or location where it is proposed to undertake the activity;
Type of activity to be undertaken;
Design or layout of the activity;
Technology to be used in the activity;
“No-go option”.
4.1 LOCATION ALTERNATIVES
An area of approximately 60ha is required for the storage of 4.5million m3 of tailings for a
period of 20 years on the farm Middellaagte 382 KQ. The only possibility for the location of
the proposed extension to the approved tailings storage facility in close proximity to the
existing tailings facility and processing plant is north of the existing tailings dam up until the
mineral lease boundary. The tailings storage facility cannot be located to the east due to
stockpiled areas and to the west due to demarcated opencast mining areas. It is however to
Page 7 of 108
be noted that a temporary return water dam will be constructed further south within the
tailings storage facility footprint to allow for opencast mining to take place in the area prior to
constructing the final return water dam further north but still within the proposed footprint for
the tailings storage facility.
The locality alternatives considered for this application are indicated on the Figure below.
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Figure 4:2 Proposed Tailings Storage Facility and Waste Rock Dump Locality Alternatives
Page 9 of 108
4.2 NO GO OPTION
Chromite is an iron chromium oxide. It is an oxide mineral belonging to the spinel group. It is
an industrially important mineral for the production of metallic chromium, used as an alloying
ingredient in stainless and tool steels and for ferrochromium . As a major source of the
metal chromium, the extracted chromium from chromite is used in chrome plating and
alloying for production of corrosion resistant superalloys, nichrome, and stainless steel.
Chromium is used as a pigment for glass, glazes, and paint, and as an oxidizing agent for
tanning leather (http://www.nationsencyclopedia.com/economies/Africa/South-Africa).
South Africa holds 68% of the world's chromium reserves. The Bushveld Complex, a sill-like
geological feature occupying about 50 000 km2, contains more than half of the world's
chrome ore and platinum. South Africa provides 53 percent of the world’s exports of
ferrochromium, 47 percent of platinum group metals, and 41 percent of chrome ore
(http://www.nationsencyclopedia.com/economies/Africa/South-Africa). Although the demand
for chrome has declined from 2006 due to the steep economic downturn resultant from the
global credit crunch crises, it is estimated that South Africa has the largest chromium
production in the world as illustrated by the figure below.
(http://minerals.usgs.gov/minerals/pubs/commodity/chromium/mcs-2013-chrom.pdf).
Mine production 2011 Mine production 2012 Reserves (shipping grade)
0
50000
100000
150000
200000
250000
IndiaKazakhstanSouth AfricaOther countries
Figure 4:3 Chromium Production and Reserves
Page 10 of 108
In addition to the large chromium and PGM reserves in South Africa, and in particular, the
Bushveld Complex which has the potential to harness economic growth and beneficiation for
not only the Limpopo Province but for South Africa, the proposed mining and processing
activities at Thaba Mine has numerous advantages as. Should the proposed activities not
proceed, the benefits of such will not be realised. The advantages include the following:
The employment of approximately 800 contractor employees at the steady state of
underground mining;
Thaba Mine has an approved Social and Labour Plan in place which outlines the
Company’s local economic development programmes. The key projects which
Thaba Mine are involved in are outlined below:
- Adult based education and training within the local community (Smash Block)
- Computer classes in the community
- Vegetable gardens in the community
- Sanitation project within the Thabazimbi area, in terms of constructing ablution
blocks
- Assistance in terms of accessing of water within the Smash Block
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5 LAND OWNERSHIP
The table below indicates the property that will be affected by the proposed TSF and WRD.
Table 5:1 Property description
Farm Name:
Portion 1 of the farm Elandskuil 378 KQPortion 1 of the farm Middellaagte 382 KQRemaining extent of the farm Moddergat 389 KQPortion 8 of the farm Roodedam 368 KQRemaining extent and portion 1 of the Schildpadness 385 KQPortion 17, 18, 21, 26, and 28 of the farm Zwartkop 369 KQ
Application area (Ha) 2129ha
Magisterial district: Waterberg
Distance and direction from nearest town 30 km North East of Thabazimbi
21 digit Surveyor General Code for each farm portion
T0KQ00000000038200001 (Middelaagte Portion 1)T0KQ00000000038900000 (Moddergat Remaining extent)T0KQ00000000036900018 (Zwartkop Portion 18)T0KQ00000000037800001 (Elandskuil Portion 1)T0KQ00000000036800008 (Roodedam Portion 8)T0KQ00000000038500001 (Schildpadnest Portion 1)T0KQ00000000038500000 (Schildpasnest Remaining extent)T0KQ00000000036900017 (Zwartkop Portion 17)T0KQ00000000036900021 (Zwartkop Portion 21)T0KQ00000000036900026 (Zwartkop Portion 26)T0KQ00000000036900028 (Zwartkop Portion 8)
Cronimet Thaba Chrome Mine is located on portions of the farm Elandskuil 378 KQ,
Middellaagte 382 KQ, Moddergat 389 KQ, Roodedam 368 KQ, Schildpadnest 385 KQ, and
Zwartkop 369 KQ. Most of the property surface rights are held in trust by the Department of
Rural Development and Land Reform, while other properties are privately owned by entities
and individuals. No record of land claim has been made on these properties at this stage.
Page 12 of 108
Table 5:2 Land ownership details
Property Name Property Number
Registration Divisional
Property Portion Owner of the Surface
Middellaagte 382 KQ Portion 1 Danie Koekemoer
Moddergat 389 KQ RemainingExtent
Cronimet Chrome Mining SA (Pty) Ltd
Zwartkop 369 KQ Portion 18 Trollope Property (Pty) Ltd
Elandskuil 378 KQ 1 Rustenburg Platinum Mines Ltd
Roodedam 368 KQ 8 Mr and Mrs. Moloko
Schildpadnest 385 KQ 1 Baphalane Ba Mantserre Community Development Trust
Schildpadnest 385 KQ Remaining Extent Baphalane Ba Mantserre Community Development Trust
Zwartkop 369 KQ 17 Rustenburg Platinum Mines Ltd
Zwartkop 369 KQ 21 Trollope Property cc
Zwartkop 369 KQ 26 Sebilong Communal Property Association
Zwartkop 369 KQ 28 Sebilong Communal Property Association
Page 13 of 108
6 LEGISLATIVE CONTEXT
This section provides a brief overview of both the national and international requirements
that must be met by this project.
6.1 NATIONAL ENVIRONMENTAL MANAGEMENT ACT
In terms of the National Environmental Management Act, 1998 (Act No. 107 of 1998)
(NEMA), as amended and the EIA Regulations, 2014, an application for environmental
authorisation for certain listed activities must be submitted to either the provincial
environmental authority, or the national authority (Department of Environmental Affairs,
DEA), depending on the types of activities being applied for.
The current EIA regulations, GN R.982, GN R.983, GN R.984 and GN R.985, promulgated in
terms of Sections 24(5), 24M and 44 of the NEMA and subsequent amendments,
commenced on 08 December 2014. GN R.983 lists those activities for which a Basic
Assessment is required, GN R.984 lists the activities requiring a full EIA (Scoping and
Impact Assessment phases) and GN R.985 lists certain activities and competent authorities
in specific identified geographical areas. GN R.982 defines the EIA processes that must be
undertaken to apply for Environmental Authorisation.
6.2 NATIONAL ENVIRONMENTAL MANAGEMENT: WASTE AMENDMENT ACT, 2014 (ACT 26 OF 2014)
A list of waste management activities which require a Waste Management Licence (WML)
have been published GN 921 and Thaba Mine’s proposed TSF and WRD sites are listed in
Category A of Schedule 3 as hazardous waste. These activities require a Waste
Management Licence from the Department of Mineral Resources (DMR) through the
undertaking of a full Environmental Impact Assessment process, prior to commencement
with the activities.
6.3 NATIONAL HERITAGE RESOURCES ACT, 1999 (ACT 25 OF 1999)
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The National Heritage Resources Act, 1999 (NHRA) protects all structures and features
older than 60 years (Section 24), archaeological sites and material (Section 35) and graves
and burial sites (Section 36). Potential impacts on heritage and archaeological
resources during the construction phase include the likelihood of unearthing of heritage
and archaeological resources especially during the construction phase of the project. The
NHRA thus protects:
Burial sites
Buildings of more than 60 years
Paleontological objects
Special geological features (fossil prints, bushman rock art)
A Heritage Impact Assessment as required in terms of section 38 of the National Heritage
Resource Act (Act 25 of 1999) would be commissioned during the EIA phase of the project
to:
Establish whether any of the type and ranges of heritage resources as outlined in
section 3 of the National Heritage Resource Act(Act 25 of 1999) do occur in or near
the proposed site, and if so, to establish the significance of these heritage resources.
Establish whether such heritage resources will be affected by the proposed activities,
and if so, to determine possible mitigation measures that can be applied to these
heritage resources.
6.4 NATIONAL ENVIRONMENTAL BIODIVERSITY ACT, 2004 (ACT 10 OF 2004)
The purpose of the Biodiversity Act is to provide for the management and conservation of
South Africa’s biodiversity within the framework of the NEMA and the protection of species
and ecosystems that warrant national protection. As part of its implementation strategy, the
National Spatial Biodiversity Assessment was developed.
The list of threatened and protected species issued in terms of Section 56 (1) of the NEMB
would be considered in this application and occurrence of species on site would be
assessed.
South Africa also uses the internationally endorsed World Organisation-International
Union for Conservation of Nature (IUCN) IUCN Red List Categories and Criteria in the Red
List of South African plants.
Page 15 of 108
6.5 LEGISLATIVE CONTEXT OF THE PROPOSED ACTIVITIES
Thaba Cronimet Chrome Mine plans to increase production through the expansion of the
opencast mining operations and underground mining areas. As part of the expansion,
additional support infrastructure is required.
To service the opencast mining operations, Thaba Cronimet Chrome Mine proposes to
expand the existing Tailings Storage Facility (TSF) located on Middellaagte Farm by
constructing an additional 60ha facility with a 720 000t/annum capacity. On the same farm,
an 8.9ha Waste Rock Dump (WRD) site with a capacity of 100,000t/annum is proposed.
Another WRD is proposed on Portion 18 of the farm Zwartkop 369 KQ, which will cover
10.6ha of land for the 100 000t/annum disposal of waste rock.
Underground mining support infrastructure includes the construction of the TSF and WRD
site on the Remainder of the farm Moddergat 389KG, where 6.9ha of land will be cleared for
the disposal of 120 000t/annum tailings. All tailings from the Cr and PGMs processing will be
pumped into this TSF through a pipe and discharged through spigot outlets. The WRD will
clear 7.4ha of land for the disposal of 1 000 000t/annum of waste rock. Another WRD is
proposed on Portion 18 of the farm Zwartkop 369 KQ, which will cover 8ha for the disposal
of 1 000 000t/annum of waste rock.
According to the Waste Amendment Act, Act 26 of 2014, the Thaba Cronimet Mine’s
proposed TSF and WRD sites are listed in Category A of Schedule 3 as hazardous waste.
These activities require a Waste Management Licence from the Department of Mineral
Resources (DMR) through the undertaking of a full Environmental Impact Assessment
process, prior to commencement with the activities.
A Waste Management Licence application (Ref. No. LP 30/5/1/3/2/ (1115) EM) has been
lodged with the Department of Mineral Resources (DMR) Limpopo Region in terms of the
Waste Amendment Act, Act 26 of 2014. The listings are described on the table below.
Table 6:3 Description of the listed activities
RELEVANT NOTICE
ACTIVITY NUMBER
DESCRIPTION
GNR 921 Category B,
No. 7
The disposal of any quantity of hazardous waste on land.
GNR 921 Category B, The construction of a facility for a waste management
Page 16 of 108
RELEVANT NOTICE
ACTIVITY NUMBER
DESCRIPTION
No. 10 activity listed in Category B of this Schedule (not in
isolation to associated waste management activity).
A detailed description of the listed activities is provided on the table below.
Page 17 of 108
Table 6:4 Details of the TSF and WRD sites
Activity Description Capacity Co-ordinates Property Description Applicable Listed Activities and Notice
Tailings storage facility
(expansion)
(60 Ha)
720 000 t/annum
24° 45’ 03.34” S; 27° 20’ 52.52” E
24° 45’ 01.08” S; 27° 20’ 52.05” E
24° 44’ 55.77” S; 27° 21’ 04.87” E
24° 45’ 00.88” S; 27° 21’ 14.51” E
24° 45’ 02.70” S; 27° 21’ 16.17” E
24° 45’ 06.78” S; 27° 21’ 15.29” E
24° 45’ 11.04” S; 27° 21’ 02.59” E
24° 45’ 08.78” S; 27° 20’ 59.57” E
24° 45’ 10” S; 27° 20’ 53” E
24° 45’ 08” S; 27° 20’ 51” E
Portion 1 of the farm
Middellaagte 382 KQ
Government Notice 921 (Category
B): 7 and 10
Tailings storage facility (6.9 Ha)
120 000 t/annum
24° 50’ 02.3” S; 27° 15’ 23.3” E
24° 49’ 57.6”S; 27° 15’ 31.9”E
24° 50’ 04.7”S; 27° 15’ 36.1” E
24° 50’ 09.1” S; 27° 15’ 27.8” E
24° 50’ 02.3”S; 27° 15’ 23.3”E
Remainder of the farm
Moddergat 389 KQ
Government Notice 921 (Category
B): 7 and 10
Waste rock dump 1 (8.9 Ha)
100 000 t/annum
24° 44’ 50.3”S; 27° 21’ 00.4”E
24° 44’ 48.1”S; 27° 21’ 03.6”E
24° 45’ 04.5”S; 27° 21’ 17.3”E
24° 45’ 06.7”S; 27° 21’ 14.0”E
24° 44’ 50.3”S; 27° 21’ 00.4”E
Portion 1 of the farm
Middellaagte 382 KQ
Government Notice 921 (Category
B): 7 and 10
Waste rock dump 2 (7.4 Ha) 24° 49’ 44.3” S; 27° 15’ 28.4” E Remainder of the farm Government Notice 921 (Category
Page 18 of 108
Activity Description Capacity Co-ordinates Property Description Applicable Listed Activities and Notice
1 000 000 t/annum 24° 49’ 42.3” S; 27° 15’ 32.3” E
24° 50’ 02.1”S; 27° 15’ 44.8” E
24° 50’ 04.2” S; 27° 15’ 40.9” E
24° 49’ 44.3” S; 27° 15’ 28.4” E
Moddergat 389 KQ B): 7 and 10
Waste rock dump 3 (10.6 Ha)
100 000 t/annum
24° 45’ 28”S; 27° 20’ 06.0”E
24° 45’ 31”S; 27° 20’ 14”E
24° 45’ 41”S; 27° 20’ 03.0”E
24° 45’ 43”S; 27° 20’ 12.0”E
Portion 18 of the farm
Zwartkop 369 KQ
Government Notice 921 (Category
B): 7 and 10
Waste rock dump 4 (8.0 Ha)
1 000 000 t/annum
24° 46’ 21”S; 27° 18’ 56”E
24° 46’ 15”S; 27° 19’ 10”E
24° 46’ 10”S; 27° 19’ 06”E
24° 46’ 16”S; 27° 18’ 53”E
Portion 18 of the farm
Zwartkop 369 KQ
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7 BASELINE ENVIRONMENT
The baseline environment refers to the physical and social environment in 2009/2010 which
is pre-mining conditions/prior to the commencement of CCMSA mining and processing
activities in 2011. The information utilised in the section below is obtained from the various
specialist studies that were undertaken in 2009/2010 and 2015. The report provides
information on the conditions in 2015 and provides context with regards to Thaba Cronimet
Chrome Mine’s impact on the physical and socio-economic environment.
7.1 CLIMATE
7.1.1 Mean Annual Wind Speed And Direction
From the data used (January – December 2006), the prevailing winds were spread evenly in
all directions, with slightly more frequent winds from the southeast and less frequently from
the north western sector. During the day time 24 percent of the wind speeds were below
1m/s, with winds prevailing from the southeast at frequency of 10 percent and north-easterly
winds seven percent of the time. The winds from the west were the most infrequent, but
were associated with the highest wind speeds. During the night time, calm conditions were
experienced with wind speeds of less than 1m/s occurring for 28.1 percent of the time. This
is typical of night time conditions and associated with the calm conditions is a reduction in
wind velocity. The predominant wind conditions during the night time were from the
southwest, with a marked decrease to the winds from the northeast.
Figure 7:4 Period, Daytime and Night-Time Wind Roses For Cronimet For The Period 2006.
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7.1.2 Mean Monthly Ambient Temperature
Air temperature is important both for determining the effect of plume buoyancy and in
determining the development of the mixing and inversion layers. The Thaba Cronimet
Chrome Mine has temperatures that are typical to the region; the highest temperatures were
found at mid-day in the summer months of November to January. During the winter months,
the temperatures drop during the night time and the day time temperatures were far lower.
7.1.3 Precipitation
Precipitation is a key factor in air pollution studies as it is an effective mechanism in the
removal of atmospheric pollutants and inhibits dust generation potentials. The Thaba
Cronimet Chrome Mine has summer rainfall with the maximum rainfall in the summer
months and little or no rainfall in the winter months. The annual average rainfall for 2006 was
51mm and 61mm for 2007, with February yielding the highest rainfall month with 294mm of
rain recorded for 2006. October was the highest yielding rainfall month in 2007 with 404mm
rainfall recorded. The figure below shows the monthly rainfall for 2006 and 2007 in
Thabazimbi.
Figure 7:5 Monthly Precipitation at Thabazimbi for the Period 2006-2007
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7.2 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.
7.3 SOILS AND LAND CAPABILITY
Land type data for the site was obtained from the Institute for Soil, Climate and Water of the
Agricultural Research Council. In addition, aerial photographs from Google Earth and
orthophotos from the Directorate Surveys and Mapping in Mowbray were used to interpret
aspects such as land use and land cover, as well as historic land uses. A detailed soil
survey was conducted within the Thaba Cronimet Chrome Mine according to standard
accepted methodology.
7.3.1 Land Use Categories The table below presents the categories as well as the total area they covered in 2009 from
the spatial results of the aerial photograph interpretation.
Table 7:5 Land Use Categories and 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
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7.3.2 Soil CategoriesThe soil survey of the site yielded four main categories of soil namely: Structured and
swelling soils, high base status red soils, soils in drainage canals and shallow and rocky
soils as provided in the table below
Table 7:6 Soil Groups and the surface area they cover
Soil Group Soils Hectares Coverage (%)
Structured and swelling soils Ar/Rg 1184 60.5
High base status red soils Hu/Sd 620 31.7
Soils in drainage canals Oa/Du/Rg/Streambed 50 2.5
Shallow and rocky soils Gs/Ms/R 104 5.3
Total 1958
7.3.3 Land Capability The land capability of the site was identified for the delineated soil areas and the categories
are presented in the table below. Most of the soils were suited to grazing and the structured
swelling and high base status red soils were considered arable but with restrictions. The
area in the drainage canal was strictly speaking considered as a wetland area but then
specifically as a riparian zone due to the regular movement of water through it.
Table 7:7 Land Capability Derived From Soil and Land Use Data for the Survey Site
Soil Group Derived Land Capability
Hectares Mapped
Coverage (%)
Structured and swelling
soils
Grazing/Arable with
restrictions
1184 60.5
High base status red soils Grazing/arable with
restrictions
620 31.7
Soils in drainage canals Wetland (Riparian
zones)
50 2.5
Shallow and rocky soils Grazing 104 5.3
Page 23 of 108
Total 1958
7.3.4 Soil Quality and Land UseFor 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.
7.3.5 Agricultural PotentialThe structured and swelling soils can be used for the production of crops; however their high
clay content, variable depth and poor internal and external drainage make them very difficult
to manage if irrigated. The quality of irrigation water has to be very good with very low salt
(especially sodium) content as leaching practices cannot be applied to get rid of excessive
salts. Due to climatic constraints (rainfall quantity and distribution) these soils were not
productive under dryland cropping conditions. Their overall agricultural potential was
therefore considered to be medium to low. The high base status red soils were suited to
irrigation agronomic uses as internal and external drainage of water was inherently good.
Although irrigation water quality should still be high these soils could handle slightly higher
salt loads than the structured soils as leaching practices can be applied to flush salts out of
the profile. The rockiness of these soils could pose problems when tilled. The agricultural
potential of these soils were therefore considered to be medium to high, especially if
irrigated. Due to a range of restrictions, the soils in the drainage canals and the shallow and
rocky soils were considered to be of low agricultural potential. Post mining agricultural
potential depends to a very large extent on the rehabilitation efforts by the mining company
but previous experience has shown that it will be low at best.
7.4 GEOLOGY
The study area is situated in the north-western sector of the Bushveld Igneous Complex and
is underlain by the mafic rocks of the Rustenburg layered Suite, which dip at an angle of
between 30 degrees and 15 degrees to the south-east with an average dip of around 22
degrees. The Bushveld Igneous Complex is a layered mafic intrusion which intruded into and
Page 24 of 108
below the Pretoria Group Sediments (Transvaal Sequence). The resistant quartzites of the
Transvaal Sequence lie to the west and north of the study area, forming the Witfonteinrand
Mountains. The regional geology for CCMSA is discussed with reference to the 1:250 000
Geological Map Series of South Africa – Sheet 2426 Thabazimbi (1974). Figure 10-3 is a
clipped map extract from the above mentioned 1:250 000 Geological Map. The study area is
generally flat and featureless with the underlying geology being covered by a thin layer of
“black turf” soils. The underlying geology at the mine is predominantly confined to the main
and critical zone stratigraphy of the Bushveld Igneous Complex and ranges from Gabbro’s
through to norites, anorthosites and pyroxenites.
Figure 7:6 Regional Geological Map for the Cronimet Study Area (Council For Geosciences)
Due to the nature of the Igneous Complex, which dips towards the south-east, the surface
geology inherently becomes younger from the north-west towards the south-east. The north-
western extent of the study area is underlain by pyroxenites of the upper pyroxenite suite.
The pyroxenites are the oldest lithologies within the study area and are overlain by younger
interlayered norites and anorthosites of the Grasvally Norite-anorthosite formation. The
norites and anorthosites are entirely overlain by anorthosites to the south east. These
anorthosites host the Merensky Reef as well as the three chromitite bands, namely the LG,
MG and UG chromitite layers. These chromitite bands have a large economic potential and
have been further subcategorised and numbered accordingly. The chromitite layers have
Page 25 of 108
high concentrations of chrome which can be economically mined by open cast methods. The
norites are overlain gabbros of the Mapela Gabbro-Norite formation, which are
predominantly noritic at the base across the south eastern extent of the study area. The
geology of the study area indicates normal contact zones between the layers identified
above, with no localised intrusions.
The Merensky Reef is a pegmatoidal feldspathic pyroxenite, with a strike length of 20km and
average thickness of between 1.0 and 1.5m. In places, relatively minor dip and strike
variations of the Merensky Reef are related to faulting. The major aberration of the Merensky
reef exists within the central parts of the study area, where large scale faulting and an iron
rich pegmatoidal pipe-like body cause a major disruption of the Merensky Reef. Pentlandite
and chalcopyrite are the main base metal sulphides associated with the Merensky reef.
Pyrrhotite is the main iron sulphide which gives rise to troilite in areas where iron-rich
pegmatoids replace the reef (Viljoen et al (1986)). Troilite is simply the iron rich variety of
Pyrrhotite.
7.4.1 FaultsThe main geological features across the study area are two north-west to south-east striking
faults across the central to northern parts of the study area. Aeromagnetic data clearly
justifies and delineates these features. These faults have throws of up to 530m and are
bound by a 2.5 km wide graben structure. These fault zones are geohydrologically
considered as potentially water bearing features at depths greater than 20m.
7.4.2 Iron Rich PegmatoidsThe study area is characterized by the widespread development of iron-rich pegmatoidal
bodies, which appear to be associated with zones of structural. The major iron-rich
pegmatoid, known as the Middellaagte pipe, averages 1.6km in diameter and occurs within
the bounds of the graben structure. Numerous smaller iron-rich ultramafic pegmatoids occur
within the study area. They are generally pegmatoidal pyroxenitic to duntic bodies and are
not identified by the surface geology. These iron-rich ultramafic pegmatoids are however
evidently identified by aeromagnetic data and are delineated by the anomalously light pink
areas in the Figure below.
Page 26 of 108
7.4.3 DykesFour major and a number of smaller dykes occur across the central and south-western
regions of the study area. They all have a very consistent north-west to south-east trending
strikes, but their widths vary from a few centimetres up to 50m. The dykes are all diabase or
dolerite dykes, are competent lithologies and are related to the same tectonic event, the
Pilanesberg Dyke Swarm. These Pilanesberg Age dykes have a negative magnetic
signature and are identified by the linear blue (to green or yellow) features. Carbonate rich
dykes are also present across the north-eastern sections of the study area. These dykes
have brecciated appearances and contain many inclusions and have kimberlitic affinities.
Figure 7:7 Aeromagnetic Map for the Mineral Lease Area
7.5 FLORA AND FAUNA
7.5.1 FloraThe Thaba Cronimet Chrome Mine lies within the Savanna biome which is the largest biome
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
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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. 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
Moddergat 389 KQ was managed as two separate game farms.
The vegetation units for the mineral lease area differed in terms of the state of the
vegetation. A species list applicable to each of the units of the woody structure is included.
Purple highlighted areas indicate the presence of the species in 2009/2010
Table 7:8 Vegetation Units Occurring in the Study Area
Vegetation unitsModdergat 389 KQ
Zwartkop 369 KQ, Schildpadsnest 385 KQ Middellaagte 382 KQ
Middellaagte 382 KQ, Roodedam 368 KQ, Elandskuil 378 KQ
Acacia tortilis – Ziziphus
mucronata – Peltophorum
africanum woodland
Acacia mellifera woodland
Acacia tortilis – Acacia nilotica
woodland
Drainage channels &
floodplains
Ziziphus mucronata - Grewia
flava shrubveld / grassland
Rocky outcrops and ridges
Page 28 of 108
Vegetation unitsModdergat 389 KQ
Zwartkop 369 KQ, Schildpadsnest 385 KQ Middellaagte 382 KQ
Middellaagte 382 KQ, Roodedam 368 KQ, Elandskuil 378 KQ
Degraded bushveld (old mining
dumps; tribal land)
Old fields
Dense Knobthorn Thickets
7.5.2 SensitivityThe classification of the study area into different sensitivity classes and development zones
was based on information collected at various levels on different environmental
characteristics. The mining lease area was low in sensitivity.
7.5.3 Fauna
7.5.3.1 BirdsA 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 below.
Table 7:9 List of Red Data Birds Potentially Occurring in the Study Area
English Name Afrikaans Name StatusProbability Of Occurrence On Site
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
Page 29 of 108
English Name Afrikaans Name StatusProbability Of Occurrence On Site
Secretarybird Sekretarisvoël Near threatened Medium
Cape Vulture Kransaasvoël Vulnerable Medium
Whitebacked Vulture Witrugaasvoël Vulnerable Medium
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
Blue Crane Bloukraanvoël Vulnerable Low to zero
African Finfoot Watertrapper Vulnerable Low
Kori Bustard Gompou Vulnerable Medium
Stanley's Bustard Veldpou Vulnerable Medium
Whitebellied Korhaan Witpenskorhaan Vulnerable Medium
Old World Painted Snipe Goudsnip Near threatened Low
Blackwinged Pratincole Swartvlerksprinkaanvoël Near threatened Medium
Yellowthroated Sandgrouse Geelkeelsandpatrys Near threatened Medium
Grass Owl Grasuil Vulnerable Low
Halfcollared Kingfisher Blouvisvanger Near threatened Low
Redbilled Oxpecker Rooibekrenostervoël Near threatened Medium to high
7.5.3.2 MammalsThe table below outlines red data mammal species that could occur according to Friedman
and Daly (2004), in the study area in 2009/2010.
Table 7:10 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
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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
7.5.3.3 HerpetofaunaThe 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.
7.6 AIR QUALITY
The baseline study (2009) included the review of the site-specific atmospheric dispersion
potential, relevant air quality guidelines and limits. The dispersion model used namely
ADMS 4, required hourly average meteorological data as input, including wind speed, wind
direction, atmospheric stability, ambient air temperature and mixing height. No on-site
meteorological data was measured, and use was made of simulated data. The US-EPA
CALMET model (which forms part of the CALPUFF suit of models) is a three-dimensional
wind field model using surface and upper air data as well as topography and land-use
information. A three dimensional wind field model was compiled for the region with a point
nearest to the site office extracted for the period January to December 2006.
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Table 7:11 Atmospheric Stability Classes
Designation Stability Atmospheric Conditions
A Very unstable Calm wind, clear skies, hot daytime conditions
B Moderately unstable Clear skies, daytime conditions
C Unstable Moderate winds, slightly overcast daytime conditions
D Neutral High winds or cloudy days and nights
E StableModerate wind, slightly overcast night time
conditions
F Very Stable Low wind, clear skies, cold night time conditions
Particulates represent the main pollutant of concern when assessing open cast mining
operations. Particulates are divided into different particle size categories with Total
Suspended Particulates associated with nuisance impacts and the finer fractions of PM10
(particulates with a diameter less than 10 μm) and PM2.5 (diameter less than 2.5 μm) linked
with potential health impacts. Gaseous pollutants (such as sulphur dioxide, oxides of
nitrogen, carbon monoxide etc.) will be derived from vehicle exhausts but are regarded as
negligible in comparison to particulate emissions.
In characterising the baseline air quality in a region, ambient monitoring data was analysed
and reported on. No ambient monitoring or dust fallout data exists at the proposed Thaba
Mine site and reference was made to the dust fallout data recorded at the neighbouring
Amandelbult Mine. Data were available for the period May 2007 to October 2008. In
addition, existing sources contributing to the current (baseline) air quality in the region were
identified, and the main pollutants associated with these operations reported. Various
components of the bio-physical and socio-economic environment may be impacted by
atmospheric emissions associated with the various phases of the project. These
components include the possible impact on:
Ambient air quality;
The aesthetic environment;
Local residents and neighbouring communities; and,
Employees.
Sources identified in 2009/2010 as possibly impacting on air quality in the region included,
but were not limited to:
Fugitive emissions from mining operations;Page 32 of 108
Vehicle tailpipe emissions from national and main roads;
Biomass burning (veld fires in agricultural areas within the region); and,
Various miscellaneous fugitive dust sources (agricultural activities, wind erosion of
open areas, vehicle-entrainment of dust along paved and unpaved roads).
7.6.1 Mining Operations in the RegionFugitive dust sources associated with mining activities included drilling and blasting
operations, materials handling activities, vehicle-entrainment by haul vehicles and wind-
blown dust from tailings impoundments and stockpiles. Mining operations were potentially
the most significant sources of fugitive dust emissions (PM2.5, PM10 and total suspended
solids) with small amounts of oxides of nitrogen, carbon monoxide, sulphur dioxide,
methane, and carbon dioxide being released during blasting operations and from mine
trucks. Experience has shown that fugitive dust emissions due to on-site operations are
typically only of concern within three km of the mine boundary, depending on the location of
the mine boundary and the extent of the mining operations. Existing mining operations in the
area included Amandelbult directly east of the proposed Thaba Cronimet Chrome Mine,
Thabazimbi Iron Ore mine located approximately 17km to the north-northeast, Northam
Platinum to the southeast (approximately eight km), and Union mine (approximately 23km to
the southwest).
7.6.2 Industrial Operations in the RegionStack, vent and fugitive emissions from the industrial operations included various criteria
pollutants greenhouse gases, volatile organic compound, semi-volatile organic compounds,
various heavy metals and other toxins such as dioxins and furans. The Rustenburg region
hosts a number of Ferrochrome smelters and Platinum smelters. Ferrochrome operations
include Xstrata (Rustenburg and Wonderkop operations), SA Chrome and Murafe
Ferrochrome. Impala and Anglo are the main platinum operators in the Rustenburg area with
Lonmin Platinum located further to the east. Sources of emission at these operations
typically included stack emissions, including main stack releases which comprised furnace
and converter off-gases, acid plant stack emissions and releases from flash dryer stacks.
7.6.3 Vehicle Tailpipe EmissionsAir pollution from vehicle emissions may be grouped into primary and secondary pollutants.
Primary pollutants are those emitted directly into the atmosphere, and secondary, those
pollutants formed in the atmosphere as a result of chemical reactions, such as hydrolysis,
oxidation, or photochemical reactions. The significant primary pollutants emitted by vehicles
Page 33 of 108
include carbon dioxide, carbon monoxide, hydrocarbons, sulphur dioxide, oxides of nitrogen,
particulates and lead. Secondary pollutants include: nitrogen dioxide, photochemical
oxidants (e.g. ozone), sulphur acid, sulphates, nitric acid, nitric acid and nitrate aerosols.
Toxic hydrocarbons emitted include benzene, 1.2-butadiene, aldehydes and polycyclic
aromatic hydrocarbons. Benzene represents an aromatic present in petrol, with 85% to 90%
of benzene emissions emanating from the exhaust and the remainder from evaporative
losses. Vehicle tailpipe emissions are also localised sources and unlikely to impact far-field.
The R510, a national road is located next to the mine site.
7.6.4 Domestic Fuel BurningDomestic 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 Mine
was not known.
7.6.5 Agricultural ActivitiesThe 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.
7.6.6 Biomass BurningCrop-residue burning and general wild fires (veld fires) represent significant sources of
combustion-related emissions associated with agricultural areas. This is typically a concern
in savannah regions where biomass-burning results in incomplete combustion with carbon
monoxide, methane and nitrogen dioxide being emitted during the process.
Page 34 of 108
7.6.7 Fugitive Dust SourcesFugitive dust emissions may occur as a result of vehicle entrained dust from local paved and
unpaved roads, and wind erosion from open areas, including tailings storage facilities. The
extent of particulate emissions from the main roads will depend on the number of vehicles
using the roads and on the silt loading on the roadways. The extent, nature and duration of
agricultural activities and the moisture and silt content of soils are required to be known in
order to quantify fugitive emissions from this source. The quantity of wind-blown dust is
similarly a function of the wind speed, the extent of exposed areas and the moisture and silt
content of such areas. The pollutants listed above are released directly by sources and are
therefore termed 'primary pollutants'. 'Secondary pollutants' which form in the atmosphere as
a result of chemical transformations and reactions between various compounds include:
nitrogen oxide, various photochemical oxidants (e.g. ozone), hydrocarbon compounds,
sulphur acid, sulphates, nitric acid and nitrate aerosols.
7.6.7.1 Measured Dust FalloutA dust fallout network existed for the Amandelbult Mine located directly east of the proposed
Thaba Cronimet Chrome Mine and data was provided for the period May 2007 to October
2008. The dust fallout varied significantly over the 18 month period and between sites.
During 2007, the highest dust fallout was measured at site one during August with the
second highest recording during July at site two. The most frequent high dust fallout levels
were recorded during the months of August, July and December 2007 with the most
exceedances of the SANS residential limit (600 mg/m²/day) recorded at site two. During
2008, the month with the highest number of dust fallout recordings were March, September
and June. Site two again recorded the highest dust fallout levels. Site two also exceeded the
SANS residential limit and the industrial limit for more than three months in a year and more
than two consecutive months.
7.7 NOISE
The rural environment on which Thaba Mine is situated had typically low levels of
background noise, dominated by the natural sounds of wildlife (primarily birdsong), and man-
influenced sounds such as livestock, farming activities, domestic activity and road and air
traffic, but especially with noise from existing entrenched mining activity in the area. Site
measurements were carried out on 2 and 3 July 2009 in accordance with the procedures
specified in SANS 10103. Measurements were carried out at six positions on or near the
Page 35 of 108
boundaries of the property and descriptive results as per the table below with summary of
the results as per the Table below.
Table 7:12 Recommended Noise Levels SANS 10103:2008
Type of DistrictEquivalent Continuous Rating Level For Noise (dBA)
Outdoors Indoor with open windows
Day-nightLR,dn
1)
Day-timeLReq,d
2)
Night-timeLReq,n
2)
Day-nightLR,dn
1)
Day-timeLReq,d
2)
Night-timeLReq,n
2)
a) Rural districts 45 45 35 35 35 25
b) Suburban districts with little
road traffic50 50 40 40 40 30
c) Urban districts 55 55 45 45 45 35
d) Urban districts with one or
more of the following:
workshops; business
premises; and main roads
60 60 50 50 50 40
e) Central business districts 65 65 55 55 55 45
f) Industrial districts 70 70 60 60 60 50
Table 7:13 Summary of Noise Monitoring Positions and Results
Positions Results
At the entrance to the northern part of the
section of the site west of the R510 road, in
line with the fence
The area was natural bush with the intrusion of existing
opencast mining activities to the south. The primary
noise sources in the area were remote traffic on the
R510, which was audible and measurable from this
position, and remote plant noise, loading operations, and
haul trucks from other mines already operating in the
area.
Page 36 of 108
Positions Results
Measurement position two is 20m from the
centerline of the R510 at the 104km post
towards the northern boundary of the site
The noise climate on the site along the R510 corridor
was dominated by traffic noise up to 600m from the road.
The measured values tabulated above area also in
agreement with the calculations using the SANS
recommended method.
Measurement position three is on the
northeast corner of the proposed treatment
plant site at the entrance gate
This was typical of a rural area with little or no man-made
noise, primarily natural noise from birds and insects.
Noise was sometimes audible from remote mining plants
and operations on neighbouring mines, but was not loud
enough or frequent enough to contribute to the
measurements. Noise from the neighbouring mine’s
ventilation fans were not measurable at this position
Perimeter of the dirt road on the eastern
boundary of the Moddergat 389 KQ site and in
line with the axis of the neighbouring mine’s
existing ventilation fans
The noise from the existing mine ventilation fan
completely dominated the noise climate over a large
area of the eastern side of the Moddergat 389 KQ. Note
that this noise was continuous and the measurement
values were highly repeatable and stable
Perimeter of the dirt road on the eastern
boundary of the Moddergat 389 KQ site 150m
from the existing mine ventilation fans on the
neighbouring mine
Noise from this existing mine ventilation fan completely
dominated the noise climate of the area.
Perimeter dirt road on the eastern boundary of
the Moddergat 389 KQ site. It is 350m from
the existing mine ventilation fans on the
neighbouring mine
The noise from the existing mine ventilation fan
completely dominated the noise climate of the area.
7.7.1 Measurement Position OneAt the entrance to the northern part of the section of the site west of the R510 road, in line
with the fence as shown in the following photographs (GPS co-ordinates – S24 46.176,
E27 18.992) Height 943m (4.2m)). The following noise measurements were taken at
position 1 and can be seen below.
Page 37 of 108
Table 7:14 Noise Measurements Taken At Position 1
Day/Date TimeTC
RH% Wind m/s Leq L90
Fri 03/07/09 08:21-08:31 6.5 66 still 44.5 41
Fri 03/07/09 08:32-08:42 6.5 66 still 43.0 40
Fri 03/07/09 09:17-09:27 11 55 still 40.8 35
Fri 03/07/09 12:35-12:45 19 29 still 35.0 27
Fri 03/07/09 12:46-12:56 19 29 still 35.7 27
Thur 02/07/09 13:53-14:03 21.5 24 <3.2 35.8 27
Thur 02/07/09 14:04-14:17 21.5 24 <3.2 35.6 26
Thur 02/07/09 14:18-14:28 21.5 24 <3.2 38.6 30
Thur 02/07/09 16:15-16:25 19.5 27 still 37.0 28
Thur 02/07/09 16:26-16:36 19.5 27 still 32.1 26
The area is natural bush with the intrusion of existing opencast mining activities to the south.
The primary noise sources in the area are remote traffic on the R510, which is audible and
measurable from this position, and remote plant noise, loading operations, and haul trucks
from other mines already operating in the area.
7.7.2 Measurement Position 2Measurement position two is 20m from the centerline of the R510 at the 104km post towards
the northern boundary of the site. (GPS co-ordinates – S24 45.693, E27 19.504. Height
947m (6m). The following noise measurements were taken at position 2 and can be seen
below.
Table 7:15 Noise Measurements Taken At Position 2
Day/Date TimeTC
RH%Wind m/s
Leq L90
Fri 03/07/09 08:48-08:58 6.5 66 still 64.4 40
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Day/Date TimeTC
RH%Wind m/s
Leq L90
Fri 03/07/09 09:00-09:10 6.5 66 still 61.5 38
Fri 03/07/09 12:08-12:18 19 29 <2.5 65.7 41
Fri 03/07/09 12:19-12:29 19 29 <2.5 64.4 35
Thur 02/07/09 15:24-15:34 21 26 <2.4 64.9 40
Thur 02/07/09 15:36-15:46 21 26 <2.4 65.3 37
Thur 02/07/09 15:48-15:58 21 26 <2.8 65.0 40
Thur 02/07/09 15:59-16:09 21 26 <2.8 64.6 42
The noise climate on the site along the R510 corridor is dominated by traffic noise up to
600m from the road. The measured values tabulated above area also in agreement with the
calculations using the SANS recommended method.
7.7.3 Measurement Position 3Measurement position three is on the northeast at the entrance gate (GPS co-ordinates –
S24 49.323, E27 15.683. Height 987m (5m)).The following noise measurements were
taken at position 3 and can be seen below.
Table 7:16 Noise Measurements Taken At Position 3
Day/Date Time TC RH% Wind m/s Leq L90
Fri 03/07/09 11:23-11:33 18 30 still 35.9 28
Fri 03/07/09 11:34-11:44 18 30 still 32.8 26
Fri 03/07/09 11:45-11:55 18 30 still 32.0 27
This is a typical of a rural area with little or no man-made noise, primarily natural noise from
birds and insects. Noise is sometimes audible from remote mining plants and operations on
neighbouring mines, but is not loud enough or frequent enough to contribute to the Page 39 of 108
measurements. Noise from the neighbouring mine’s ventilation fans are not measurable at
this position
7.7.4 Measurement Position 4Measurement position four, on the perimeter of the dirt road on the eastern boundary of the
Moddergat site and in line with the axis of the neighbouring mine’s existing ventilation fans
(GPS co-ordinates – S24 50.078, E27 16.138. Height 969m (4.2m)). The following noise
measurements were taken at position 4 and can be seen below.
Table 7:17 Noise Measurements Taken At Position 4
Day/Date Time TC RH% Wind m/s Leq L90
Fri 03/07/09 10:10-10:12 17.5 37 <0.5 71.2 70
Fri 03/07/09 10:22-10:24 17.5 37 <0.5 70.9 69
From the table above, it can be said that the noise from the existing mine ventilation fan
completely dominates the noise climate over a large area of the eastern side of the
Moddergat. Note that this noise is continuous and the measurement values are highly
repeatable and stable.
7.7.5 Measurement Position 5Measurement position four, is on the perimeter of the dirt road on the eastern boundary of
the Moddergat site 150m from the existing mine ventilation fans on the neighbouring mine
(GPS co-ordinates – S24 49.986, E27 16.080. Height 970m (5m)). The following noise
measurements were taken at position 5 and can be seen below.
Table 7:18 Noise Measurements Taken At Position 5
Day/Date Time TC RH% Wind m/s Leq L90
Fri 03/07/09 10:42-10:47 17.5 37 still 54.2 52
From the table above, it can be seen that noise from this existing mine ventilation fan
completely dominates the noise climate of the area.
Page 40 of 108
7.7.6 Measurement Position 6Noise measurement position six can be found on the perimeter dirt road on the eastern
boundary of the Moddergat site. It is 350m from the existing mine ventilation fans on the
neighbouring mine (GPS co-ordinates – S24 49.909, E27 16.033. Height 972m (6m)).
The following noise measurements were taken at position 6 and can be seen below.
Table 7:19 Noise Measurements Taken At Position 6
Day/Date Time TC RH% Wind m/s Leq L90
Fri 03/07/09 11:02-11:07 17.5 37 still 45.5 43
The above table shows that the noise from the existing mine ventilation fan completely
dominates the noise climate of the area.
7.8 ARCHEOLOGY
The following evaluation criterion was used for determining the significance of archaeological
and heritage sites at Thaba Mine:
The unique nature of a site;
The integrity of the archaeological deposit;
The wider historic, archaeological and geographic context of the site;
The location of the site in relation to other similar sites or features;
The depth of the archaeological deposit (when it can be determined or is known);
The preservation condition of the site;
Uniqueness of the site; and
Potential to answer present research questions.
In addition, site significance classification standards prescribed by the South African
Heritage Resources Agency (2006) and approved by the Association for Southern African
Professional Archaeologists for the Southern African Development Community region, were
used for the baseline conditions.
Table 7:20 Heritage Site Significance and Mitigation Measures
Field rating Grade Significance Recommended Mitigation
Page 41 of 108
National Significance Grade 1 -Conservation; National Site
nomination
Provincial Significance Grade 2 -Conservation; Provincial Site
nomination
Local Significance Grade 3A High Significance Conservation; Mitigation not advised
Local Significance Grade 3B High SignificanceMitigation (Part of site should be
retained)
Generally Protected A -High / Medium
SignificanceMitigation before destruction
Generally Protected B -Medium
SignificanceRecording before destruction
Generally Protected C - Low Significance Destruction
Cultural resource management surveys, e.g. van Schalkwyk (2004), van der Walt (2010 &
2014) conducted in the area and Huffman (2006) to the north of the area provided a good
basis for understanding the local archaeology. From these studies it was clear that sites and
artefacts dating to the Stone Age, Iron Age, historical cemeteries, farm worker homesteads,
european homesteads and historic/recent mining activities have been recorded and occur in
the larger study area.
For the study area Iron Age activity is concentrated along water courses and rocky outcrops
or hills marked by ceramic clusters or dry stone walling. Material was also found in these
areas especially at the base of hills and along watercourses. Archival documents indicated
that the farms under investigation were established during the 19th century. The Figure
below provides the location of recorded sites for the greater study area. It was noted that
some artefacts occur on farms not part of the CCMSA mineral lease area. These sites
provided an indication of the heritage context of the greater study and placed the sites found
and expected for the area in perspective.
Page 42 of 108
Figure 7:8 Recorded Heritage Artefacts for the Area
7.8.1 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.
Site 14: Site 14 is located on the farm Moddergat 389 KQ. The site consists of a
cattle enclosure and grinding hollows on a low running ridge next to the Bierspruit.
Site 15: Site 15 is located on the farm Moddergat 389 KQ. The site consists of a
cattle enclosure.
Page 43 of 108
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.
7.8.2 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
Page 44 of 108
platform indicating Middle Stone Age occupation. Raw material consists of igneous
rock, Hornfels and possibly Silcrete
7.8.3 Iron Age SitesTwenty 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:
7.8.4 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 sites.
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.
Page 45 of 108
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.
7.8.5 CemeteriesDetails 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.
7.8.6 European HomesteadSeveral modern structures occurred 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.Page 46 of 108
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
7.8.7 Historic/Recent MiningThe hill on the farm Zwarkop 369 KQ that is called Mooskop was previously mined in the
recent past by other mining entities.
7.9 WETLANDS
7.9.1 Wetland Delineation and Classification
The study area is drained by the Bierspruit and its associated tributaries. Three different
wetland types were identified within the study area, namely:
Channelled valley bottom wetlands;
Unchannelled valley bottom wetlands; and
Seepage wetlands.
In addition, several riparian zones occurred within the study area, while numerous small
dams also occurred within the riparian zones and valley bottom wetlands. Small drainage
lines that displayed no clear wetland or riparian zone characteristics but that are classified as
a watercourse also occurred on site.
Page 47 of 108
Figure 7:9 Delineated Wetlands and Riparian Zones within the Mineral Lease Area
Table 7:21 The Hydro-Geomorphic Classification System (Adapted From Brinson, 1993;
Kotze, 1999 And Marneweck And Batchelor, 2002).
Hydro-geomorphic type Description
Channelled Valley Bottom
Valley bottom areas with a well defined stream channel but lacking
characteristic floodplain features. May be gently sloped and
characterised by the net accumulation of alluvial deposits or may
have steeper slopes and be characterised by the net loss of
sediment. Water inputs from the main channel and adjacent slopes.
Unchannelled valley bottom
Valley bottom areas with no clearly defined stream channel usually
gently sloped and characterised by alluvial sediment deposition,
generally leading to a net accumulation of sediment. Water inputs
mainly from channel entering the wetland and also from adjacent
slopes.
Riparian zone Riparian habitats (as defined by the NWA) include the physical
Page 48 of 108
Hydro-geomorphic type Description
structure and associated vegetation of the areas associated with a
watercourse which are commonly characterised by alluvial soils
(deposited by the current river system), and which are inundated or
flooded to an extent and with a frequency sufficient to support
vegetation of species with a composition and physical structure
distinct from those of adjacent areas.
Drainage line
Small, narrow watercourses that display no clear wetland or riparian
zone characteristics yet represent preferential flow paths for water
and convey water intermittently following rainfall events. As
watercourses they are also afforded a degree of protection under the
NWA.
Across the mineral lease area, there were well-developed riparian zones which were
delineated along the Bierspruit and one of its larger, seasonal tributaries. In addition, three
small drainage lines feeding into the Bierspruit were also identified. The tributaries of the
Bierspruit which occurred within the study area were dry at the time of the site visit and were
expected to hold water only for short periods after rainfall events. A narrow riparian zone
was associated with the largest of these tributaries, which was characterised further by a
clearly defined channel, mostly devoid of vegetation, with the exception of an occasional
grass species. The small drainage lines on site represent preferential flow paths within the
landscape with poorly defined channels and vegetation that does not differ from the
surrounding terrestrial vegetation in species composition or structure.
Numerous wetland types and two riparian zones were identified within the mining site, which
together with the six dams identified; covered approximately 162ha of the mining site. Two of
the dams identified on site appear to have been constructed to receive water from the
existing mining activities in the area. Leakage and overflow from these dams appeared to
have been sustaining the seepage wetlands on site. As such, the seepage wetlands could
be labelled as artificial wetlands, though they are nonetheless considered to potentially play
an important role in trapping pollutants and contaminants that might be contained in the
water from the mines.
The large dam constructed across the Bierspruit roughly in the centre of the mining site,
together with the roughly 3.7Ml per day (values for December 2008) of mine water
discharged into the Bierspruit from Amandelbult Mine (quoted
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fromwww.angloplatinum.com/pdf%5C2009%5Cwater.pdf), was believed to have contributed
towards the formation of the wetland conditions along this portion of the river due to the
extended retention and increased flow of water. Further upstream and downstream of the
large dam and the Amandelbult Mine the Bierspruit was again associated with a riparian
zone. The retention of water and the large expanse of openwater and muddy shoreline
provided by the large dam had created an ideal water bird habitat and numerous species of
water birds were recorded on site.
Several smaller tributaries of the Bierspruit associated with riparian zones or channelled
valley bottom wetlands also occurred on site, while an unchannelled valley bottom wetland
occured in the north eastern corner of the site. The unchannelled valley bottom was located
in a broad, flat valley dominated by grasses with little woody vegetation. A small farm dam
hasd been constructed across this wetland, while two excavations located adjacent to the
valley bottom wetland were also likely to have collected water during the rainy season.
7.9.2 Functional Assessment
7.9.2.1 Riparian ZonesRiparian areas can perform a variety of functions that are of value to society, especially the
protection and enhancement of water resources, and provision of habitat for plant and
animal species. The riparian areas on site are expected to play a role in protecting and
enhancing the local water resources through the stabilisation of the river banks as well as
through sediment trapping. Sediment trapping is expected to occur when the river overtops
the channel banks – the water spreading out over a larger surface as well as the resistance
to flow offered by the increased surface roughness provided by the riparian vegetation slows
done the flow velocity, thus creating a depositional environment. In slowing down flow
velocities during flood flows, riparian zones can also contribute to temporary storage of flood
flows and reduce downstream flood damage. The riparian zone also has the potential to
improve water quality through the trapping of nutrients and by acting as a buffer between the
aquatic environment in the river channel and adjacent terrestrial land uses.
7.9.2.2 Channelled Valley Bottom WetlandsWithin the study area, the channelled valley bottom wetland was directly associated with the
large dam built across the Bierspruit. It is likely that the building of the dam has resulted in
the wet land conditions along this section of the Bierspruit replacing the riparian zone that
would have been expected to occur here in the absence of the dam. As such, in assessing
the functions performed by the valley bottom wetland, it is important to alsoPage 50 of 108
7.9.2.3 Seepage WetlandsAlthough it is assumed that the seepage wetlands on site have formed through artificial
means, i.e. through the seepage and leakage of water out of adjacent mine dams, these
wetlands are nonetheless considered to support various functions of value. Besides their
role in supporting biodiversity through the provision of different habitats, they are also
expected to play a role in improving water quality through the trapping of pollutants and
nutrients that might be found in the water derived from the mining activities.
7.9.3 Present Ecological Status Within the study area past and current mining activities have taken place, numerous dams
have been built, and portions of the site fall within communal land (characterised by
overgrazing and the setting of snares), resulting in extensive impacts on the wetlands and
riparian zones in these areas. The mining activities within and adjacent to the proposed
mining area were expected to have impacted on the riparian zones in two ways, namely by
increasing flows within the Bierspruit through release of water used in the mines/pumped
from the mines and through deteriorating water quality, while the dams have altered the
hydrology supporting the systems. The above activities and their impact on the wetlands
and riparian zones were clearly reflected in the results of the present ecological status
assessment done in 2009. The scores for the wetlands and riparian zones within the study
site ranged from moderately modified to seriously modified.
7.9.4 Ecological Importance and Sensitivity Ecological importance of a water resource is an expression of its importance to the
maintenance of ecological diversity and functioning on local and wider scales. Ecological
sensitivity refers to the system’s ability to resist disturbances and its capability to recover
from disturbance once it has occurred. The Bierspruit, consisting of the riparian zone, the
large dam and the valley bottom wetland, was considered to be of high ecological
importance and sensitivity despite being considered a largely modified system on site, given
its importance in terms of maintaining biodiversity and supporting Red Data species, its
ecological integrity as well as the various functions the riparian zone associated with the
Bierspruit is expected to perform. The remaining wetlands and riparian areas on site varied
from low/marginal ecological importance and sensitivity from the artificially maintained
seepage wetlands to moderate importance and sensitivity for the remaining wetlands and
riparian zones on site. The unchannelled valley bottom wetland was also considered to be of
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moderate importance and sensitivity, despite the impacts of the mining dam located within
the upper reaches of this stream and the small farm dam located onsite.
7.10 AQUATIC
Thaba Mine is situated in the western side of the Limpopo Province and includes the
Waterberg Mountain Range. The availability of water is the most crucially limiting resource
for Province, however, during the high flow sampling season there are a number of running
streams and rivulets occurring in the veld. These include the Bierspruit River and its
surrounding tributaries, which occur in the study area and constitute a part of the catchment
area for the Limpopo River Basin. The Bierspruit River is one of two large tributaries of the
Lower Crocodile River and it joins the Crocodile River south-west of Thabazimbi. There are
no large dams occurring in the study area, however, some smaller dams do occur on the
Bierspruit. Various sites were chosen to conduct the bio-monitoring and the table below
provides a description of each of the chosen sites and their associated significance.
Table 7:22 Location, Description and Significance of the Chosen Bio-Monitoring Sites at
Thaba Mine
Site Description Significance
BS01 Located on the Moddergat farm at
the point where the Bierspruit River
enters the property.
The site indicates the condition of the Bierspruit
upstream of any impacts likely to affect the river as
a result of any activities during the life of the
proposed project. The site serves as a spatial
reference for the BS02 site.
BS02 Located on the Moddergat farm at
the point where the Bierspruit exits
the property.
The site indicates the condition of the Bierspruit
downstream of any impacts occurring as a result of
activities undertaken during the life of the proposed
project and upstream of the Anglo Platinum mining
activities. This site can be compared spatially to
the BS01 site.
BS03 Located at a bridge at the point
where the Bierspruit exits the Anglo
Platinum Mine mining area.
Indicates the level of ecological integrity on the
Bierspruit downstream of the Anglo Platinum Mine
mining activities. The site can be compared
spatially to the BS02 site.
BS04 A dam situated on the Bierspruit on The site serves to support the investigation of the
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Site Description Significance
the Schildpadnest farm before
flowing out into a channelled
wetland along the Bierspruit.
fish and macro-invertebrate diversity in the study
area. Water quality is also indicated.
BS05 Located on downstream of the dam
and wetland on the Schilpadnest
farm.
Indicates the level of ecological integrity on the
Bierspruit River downstream of the dam and
wetland and opencast activities of the proposed
project. The site can be compared spatially to the
BS03 site.
BS06 Located on the Schilpadnest farm at
the point where the Bierspruit exits
the study area.
This site serves to indicate the effect on the
Bierspruit of any impacts occurring as a result of
activities undertaken during the life of the proposed
project.
7.10.1 In Situ Water QualityIn situ water quality is important as it assists in the interpretation of biological results due to
the direct influence water quality has on aquatic life forms. The general water quality
throughout the area can be considered as poor at the time of the assessment as it had:
Relatively high concentrations of dissolved salts. In addition, the Electrical
Conductivity (EC) shows a high variability between sampling points, this level of
change between the sites exceed the DWAF target water qualities for aquatic
ecosystems. It is likely that the osmotic stress due to spikes and drops in EC may
affect the aquatic communities colonising the area;
Fair concentrations of dissolved oxygen were present in the system, however, some
impact from reduced dissolved oxygen may occur preventing sensitive community
members from colonising this section of the Bierspruit; and
The temperature values at the site can be regarded as being natural and any
variations may be attributed to natural diurnal variations. Cognisance must be taken
of the fact that the water quality was determined by hand held equipment.
7.10.2 Habitat AssessmentHabitat assessment can be defined as the evaluation of the structure of the surrounding
physical habitat that influences the quality of the water resource and the condition of the
resident aquatic community. The general habitat integrity of each site is discussed below,
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based on the application of the Intermediate Habitat Integrity assessment for use in rapid and
intermediate habitat assessments. It is important to assess the habitat of each site in order to
aid in the interpretation of the results of the community integrity assessments by taking habitat
conditions and impacts into consideration. This method describes the Present Ecological
State of both the in-stream and riparian habitat at each site. The method classifies Habitat
Integrity into one of six classes, ranging from unmodified/natural (Class A), to critically
modified (Class F). Reference conditions for the area were considered as unmodified/natural
(class A).
Table 7:23 Classification of Present State Classes in terms of Habitat Integrity (DWAF,
1999)
Class Description Score (% of total)
A Unmodified, natural. 90-100
B Largely natural, with few modifications. 80-90
C Moderately modified. 60-79
D Largely modified. 40-59
E Extensively modified. 20-39
F Critically modified. <20
A summary of the results of the Intermediate habitat assessment are included in the table
below and are outlined below:
Habitat structure and diversity are not suitable for supporting a diverse aquatic
macro-invertebrate community at sites BS02, BS03 and BS05, however sites BS01
and BS06 are suitable;
The system as a whole has been largely impacted upon by ever increasing mining
activities in the surrounding areas, as well as the historical impacts from farming;
It is a relatively still and slow flowing system throughout and impacts from in stream
barriers, road crossings and bridges are evident;
Little cover in the form of, aquatic vegetation and undercut root wads and debris were
present in the system as a whole with the exception of some anomalies at sites BS02
and BS06.
Limited spatial variation in habitat is evident at each of the sites; and
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Intermediate habitat assessment was not applied to the BS04 site as the index is
only applicable to riverine environments.
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Table 7:24 Intermediate Habitat Assessment Results
Type Of Result
Mcmillan, 1998 IHAS Description
IHAS Stones Biotopes
IHAS Vegetation Biotopes
IHAS Other Biotopes
IHAS General Stream Characteristics IHAS Score
IHAS Adjustment Score
BS01 Habitat structure
and diversity are
suited to
supporting a
diverse aquatic
macro-invertebrate
community.
There was an
excellent availability
of rocky substrate at
this point suitable for
supporting a diverse
aquatic community.
Good habitat
characteristics present
with dense leafy bankside
vegetation cover
There are
some gravel
and sand
deposits
present at the
site providing
habitat for
suitably
adapted
aquatic macro-
invertebrates.
A wide, still section of stream. The water
was fairly discoloured at the time of
assessment. Riparian vegetation consists
of a mix of grass, trees and reeds which
adequately protect the riparian zone from
erosion.
73 +13
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Type Of Result
Mcmillan, 1998 IHAS Description
IHAS Stones Biotopes
IHAS Vegetation Biotopes
IHAS Other Biotopes
IHAS General Stream Characteristics IHAS Score
IHAS Adjustment Score
BS02 Habitat structure
and diversity are
inadequate for
supporting a
diverse aquatic
macro-invertebrate
community.
No rocky substrate in
or out of current was
present at the time of
assessment.
Good habitat
characteristics present
with dense bankside
vegetation cover and
aquatic vegetation
present. The limited leafy
nature of the aquatic
vegetation and bankside
vegetation reduce the
suitability of the cover for
aquatic macro-
invertebrates.
There was limited gravel,
sand and mud biotopes
present at the site at the
time of the assessment.
A relatively wide, still section
of stream. The water was fairly
discoloured at the time of
assessment and there was
little flow variation at the time
of the assessment. Riparian
vegetation consists of a mix of
grass and trees.
51 +10
BS03 Habitat structure
and diversity are
inadequate for
supporting a
diverse aquatic
maco-invertebrate
There was adequate
rocky substrate
present at the time of
the assessment to
support suitably
adapted macro-
The leafy nature of the
overhanging vegetation
present at this point in the
system was adequate for
supporting a diverse
There is
muddy
substrate
present at the
site along with
A narrow, still section of the stream. The
water was fairly discoloured at the time of
assessment.
62 +17
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Type Of Result
Mcmillan, 1998 IHAS Description
IHAS Stones Biotopes
IHAS Vegetation Biotopes
IHAS Other Biotopes
IHAS General Stream Characteristics IHAS Score
IHAS Adjustment Score
community invertebrate
organisms
community structure. some sandy
deposits in
some areas,
providing
suitable habitat
for suitably
adapted
aquatic macro-
invertebrates.
There was no
gravel present
at the site at
the time of the
assessment.
BS05 Habitat structure
and diversity are
inadequate for
supporting a
diverse aquatic
maco-invertebrate
community
No rocky substrate in
or out of current was
present at the time of
assessment.
There was limited
vegetation present at this
point in the system for
supporting a diverse
aquatic community
structure.
There is
muddy
substrate
present at the
site along with
some sandy
deposits in
some areas,
providing
suitable habitat
A relatively narrow still section of stream
with little variation in flows. The water was
fairly discoloured at the time of
assessment. The riparian zone is severely
impacted on at this point by livestock
trampling.
58 +6
Page 58 of 108
Type Of Result
Mcmillan, 1998 IHAS Description
IHAS Stones Biotopes
IHAS Vegetation Biotopes
IHAS Other Biotopes
IHAS General Stream Characteristics IHAS Score
IHAS Adjustment Score
for suitably
adapted
aquatic macro-
invertebrates.
BS06 Habitat structure
and diversity are
adequate for
supporting a
diverse aquatic
maco-invertebrate
community
No rocky substrate in
or out of current was
present at the time of
assessment.
There was limited
bankside vegetation
present at this point in the
system. However, a fair
amount of aquatov
vegetation was present
for supporting a diverse
aquatic community
structure.
There were
limited muddy
biotopes
present at the
site at the time
of the
assessment.
A deep relatively still section of the stream
with little depth and flow variation. The was
discoloured at the time of the assessment.
65 +20
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7.11 GROUNDWATER
A drilling program was commissioned by JMA Consulting in March 2009 in order to obtain
geo-hydrological and geological information of the aquifer. The site information, borehole
logs and multi-parameter data of the drilled boreholes are attached in appendices to the
report contained in Appendix B. Geohydrological and hyrdo-chemical information was
collected by JMA Consulting during a hydro-census at the proposed Thaba Cronimet
Chrome Mine study area. The hydro-census was performed in May 2009, covering the total
Thaba Cronimet Chrome Mine area. The census included a compilation of groundwater use
data, owner information, borehole yields and water level measurements. Hydro-chemical
samples were also taken at selected sites. A total of eight boreholes were drilled to cover the
total study area. The borehole logs and geohydrological descriptions can be seen in the
2009 Groundwater report attached in Appendix B.
7.11.1 Depth of the Water TableWater level information was obtained from the hydro census done in 2009 on the CCMSA
mineral lease area. Historical water levels, measured by DWS in the greater study area,
yielded information on 276 boreholes. The database shows initial ground water intersection
on an average of 21.4m, with rest water levels at around 17.1m. The average weathering
depth of Norite/Gabbro units is 24.7m, indicating a poorly-established, saturated shallow
weathered zone aquifer. Ground water level fluctuations of up to 10m over the geo-
hydrological cycle show a distinct seasonal trend.
Table 7:25 Summary of the Water Levels in External and Monitoring Boreholes in the Study
Area
SitesDWS monitoring boreholes
External users identified during hydro census
Newly drilled boreholes for Cronimet
Number of sites 276 19 8 (6dry)
Minimum level (m)
2.9 2.87 8.5
Maximum level 55.2 50.0 17.38
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(m)
Average level (m) 17.1 20.8* ~^
Correlation with topography
Unknown 0.62 ~^
* Average for boreholes currently in use
^ Only two boreholes yielded water levels during the geohydrological investigation. Drawing
statistical conclusions from two points is not representative.
The DWS monitoring boreholes indicated water level distributions from near-surface, to
basically the maximum depth of weathering of the Norite/Gabbro aquifers. Water strikes
deeper than the limit of weathering are extremely rare. The likelihood for deeper water
strikes was given as 1 percent. Given the number of observations in the DWS database, the
average water level recorded (17 m) is viewed as the undisturbed, background ground water
levels of the area. The water level distribution on the farms Zwartkop, Roodedam, Langpan,
Moddergat, Oskuil and Kaalvlakte indicate that some water levels are lowered due to
pumping activities. The water level distribution for the newly drilled boreholes showed values
for only two of the newly drilled boreholes. The very low seepages in the other six boreholes
were not expected. For geohydrological calculations in the shallow weathered
Norite/Gabbro aquifers, the representative depth is taken as 17m below surface.
7.11.2 Presence of Boreholes and Springs and their Estimated YieldsThe depths of water strikes and weathering reported in regional exploration boreholes, as
well as the newly drilled boreholes at the Thaba Mine, were on average 24m. Boreholes with
yield data showed a reportable (blow) yield ranging between 0.69 and 20l/s. The yields
reported by the external users are higher than the average reported for the greater study
area.
7.11.3 Ground Water QualityThe assessment of the current status of the ground water quality distribution is based on the
water quality data generated during the 2009 hydro census. An assessment of all drilled
monitoring boreholes was made to derive a representative background ground water quality
as outlined in the Table below. Previous studies indicate a variable level of nitrates pollution
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due to human and agricultural activities. Nitrates was not used in isolation as an indicator for
mining related impacts.
Table 7:26 Typical Background Ground Water Quality for the Study Area
Variable Minimum Maximum Average
pH 8.1 8.6 8.3
EC (mS/m) 35 101 85
TDS (mg/l) 159 620 455
Ca (mg/l) 5 47 38
Mg (mg/l) 80 180 130
Na (mg/l) 13 38 25
K (mg/l) 1 7 3
T-Alk (mg/l) 135 418 265
Cl (mg/l) 6 88 55
SO4 (mg/l) 2 62 35
F (mg/l) 0.010 0.140 0.022
Al (mg/l) 0.010 0.070 0.030
Fe (mg/l) 0.010 0.030 0.022
Mn (mg/l) 0.010 0.045 0.013
The following conclusions were reached regarding the chosen 2009/2010 background
ground water quality for the study area:
1The background ground water was dominated largely by magnesium bicarbonate.
Elevated magnesium levels were due to geological conditions;
The background ground water quality was alkaline;
Elevated levels of sulphates were not primarily indicative of mining related impacts;
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1Nitrate was excluded from the list, since previous studies indicate impacts due to
human and agricultural activities. However, mining activities can also have an impact
on nitrates. The source of potential nitrates in ground water resources must be clearly
identified;
The chosen background ground water quality was considered as marginal in terms of
total salt load. This was mainly due to natural, geological considerations. Any mining
related impact can clearly be identified, using the above as the pre-impacted quality.
7.11.4 Groundwater Quality Distribution and Compliance1The compliance criteria used to assess ground water quality distribution is the SABS 241
Drinking Water Standard.
1The pH distribution and compliance map alkaline to slightly elevated alkaline values
in the total study area. These include monitoring boreholes and external users falling
in the adjacent Anglo mining area. Previous and current studies have proven that no
mining or metallurgical activities will have an influence in the form of lowered pH
levels;
Total dissolved solids is a representation of the total salinity of a water sample. The
total dissolved solids showed mainly full compliance with respect to the SABS
Drinking Water Standard;
The calcium distribution and compliance showed full compliance. No direct mining
impacts will manifest as calcium, so this element cannot be used as an indicator of
mining related impacts;
The magnesium distribution and compliance showed mainly non-compliance. Given
the naturally elevated levels of magnesium, care should be taken when using
magnesium as an indicator for mining-related impacts;
The sulphates distribution and compliance showed full compliance at all sites. With the
relatively large range in sulphate values for the chosen background ground water
quality, it was evident that sulphates cannot be used in isolation to assess any mining or
agricultural impact. The elevated levels adjacent to the Amandelbult section should be
monitored on a regular basis;
The majority of samples show full compliance for clorine and potassium;
Sporadic marginal compliance for total alkalinity and fluorine is once again due to
geological conditions;
Micro-element analyses showed full to marginal compliance;
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Isolated impacts due to human activities and metallurgical impact in the greater study
area were evident. Total dissolved solids and nitrates (site specific) were the major
parameters that will indicate impacts to the ground water system.
7.11.5 Groundwater UseIn the hydro census performed in 2009, a total of 49 external users’ boreholes were
identified. Approximately 30 percent of all boreholes were currently not in use, or were not
equipped. Extensive use of ground water was taking place, although the majority of the
boreholes were more than two km away from the Thaba Mine activities. The main area of
geo-hydrological concern was the use of borehole water by the Thabazimbi Local
Municipality on the farm Zwartkop 369 KQ. Irrigation also took place on a reported 20ha.
Table 7:27 The Current Groundwater Use in the Study Area
Farm name/ Locality
Number of boreholes in use
Purpose of borehole
Human use
Large stock
Small stock/Other
Zwartkop 18 Extensive >100 >1000
Roodedam 5 35 >100 ~50
Langpan 3 16 >120 ~30
Moddergat 3 45 200 Game
Oskuil 7 170 <200 Game
Kaalvlakte 0 0 0 0
7.11.6 Groundwater ZoneThe geological logs taken in 2009 from the drilled shallow boreholes in the Thaba Mine study
area yielded the following geological/geo-hydrological information:
0m – 2m Dark, brownish clay
2m – 24m Highly weathered to slightly weathered Gabbro and Norite (depending on
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position of geological sequence)
2m – 24m Fresh, occasionally fractured Gabbro and Norite
Ground water movement will essentially be horizontal in the weathered, coarser grained
Norite aquifer. Ground water flow and volumes in the deeper, unweathered Norite aquifer will
be determined by the extent and hydraulic conductivities of individual fractures. Ground
water strike and yield information showed that the deeper, fractured aquifer yields very few
strikes and low volumes of ground water. A non-defined aquifer type at this stage is the two
prominent fracture zones in the northern part of the mineral lease area.
The lateral extent of the aquifer around the mine was important in order to set definable
limits of any potential contaminant transport and lowering of water levels within the shallow
weathered zone Norite aquifer. The shallow weathered zone aquifer at the Thaba Cronimet
Chrome Mine had the following definable boundaries:
The Bierspruit in the centre of the study area (discharge boundary);
The tributaries of the Bierspruit to the north and south (discharge boundaries), a
number of unnamed tributaries;
The two fracture zones in the centre area. These zones can act as no-flow or as
preferential flow boundaries. Dewatering requirements during mining will indicate
the nature of these units.
The major transport zone was the saturated parts of the weathered zone Norite / Gabbro
aquifers. Taking the average depth of ground water for the study area (19m) and the
average depth of weathering into account (24m), the average saturated thickness of the
Norite /Gabbro aquifer is less than 5m. Please note that conditions can change on a regional
scale and that localised saturated aquifer thicknesses can exceed 15m. The average
porosity for Bushveld units was one percent and less, although the porosity in the weathered
zones could increase to five to eight percent. Aquifer effective porosity indicates the volume
of water that can be released from a rock, therefore the volume of connected pores that is
present within an aquifer. Effective porosity is a crucial parameter to determine since it is
used in ground water calculations within the aquifer. The average effective porosity/aquifer
storativity values for shallow Norite / Gabbro aquifers areas is 0.03 and the average for the
deep fractured Norite/Gabbro aquifers is 0.002.
Slug tests performed in the study area yielded transmissivity values for the shallow
weathered aquifers ranging between one and five m2/day. It is important to note that only two
boreholes yielded water levels. The areas concerning the footprint of the approved tailings
storage facility yielded very low seepages during drilling, indicating transmissivity values of Page 65 of 108
less than 0.5 m2/day. Given the average saturated thickness of this aquifer, hydraulic
conductivity was calculated as ranging between 0.005 and 0.025m/day. The representative
value for ground water calculations was 0.015 m/day. With regards to the CCMSA mineral
lease area, the following aquifer characteristics apply:
The aquifer type was indicated as a minor aquifer region or in other words a
moderately-yielding aquifer system of variable water quality;
The vulnerability, or the tendency or likelihood for contamination to reach a specified
position in the groundwater system after introduction at some location above the
uppermost aquifer, was indicated at least as vulnerable;
Aquifer susceptibility, a qualitative measure of the relative ease with which a
groundwater body can be potentially contaminated by anthropogenic activities and
which includes both aquifer vulnerability and the relative importance of the aquifer in
terms of its classification, was indicated as low.
8 INITIAL APPLICATION AND SCOPING PROCESS
The S&EIR and WUL Application processes for the Proposed Project are being undertaken
as one integrated process comprising of three phases, namely the:
Application phase
Scoping phase
Environmental impact reporting (EIR) phase
This report documents the tasks which have been undertaken as part of the Scoping phase
of the EIA process. These tasks include the public participation process and the
documentation of the issues which have been identified as a result of these activities.
8.1 APPLICATION PHASE
The application phase consists of completing the appropriate application form by the EAP
and the Proponent as well as the subsequent submission and registration of the Proposed
Project with the Competent Authorities.
The competent Authority for the WMLA is the Department of Mineral Resources.
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8.2 SCOPING PHASE
The Scoping phase will be undertaken in accordance with the NEMA, as read with GNR 982
of the NEMA. The objectives of the Scoping phase are to:
Identify the relevant policies and legislation relevant to the activity;
Motivate the need and desirability of the proposed activity, including the need and
desirability of the activity in the context of the preferred location;
Identify and confirm the preferred activity and technology alternative through an
impact and risk assessment and ranking process;
Identify and confirm the preferred site, through a detailed site selection process,
which includes an impact and risk assessment process inclusive of cumulative
impacts and a ranking process of all the identified alternatives focusing on the
geographical, physical, biological, social, economic, and cultural aspects of the
environment;
Identify the key issues to be addressed in the assessment phase;
Agree on the level of assessment to be undertaken, including the methodology to be
applied, the expertise required as well as the extent of further consultation to be
undertaken to determine the impacts and risks the activity will impose on the
preferred site through the life of the activity, including the nature, significance,
consequence, extent, duration and probability of the impacts to inform the location of
the development footprint within the preferred site; and
Identify suitable measures to avoid, manage or mitigate identified impacts and to
determine the extent of the residual risks that need to be managed and monitored.
Scoping is the process for determining issues and concerns related to the Proposed Project
and involves consultation with the stakeholders and authorities. In addition, the Scoping
phase includes the identification of required specialist studies and potential environmental
aspects for further investigation. The Scoping phase outlines the plan of study (PoS) for the
EIR phase and facilitates the input from stakeholders and authorities to inform the EIR
process.
8.2.1 Stakeholder Review Prior to Submission
The Draft Scoping Report (DSR) is made available to all stakeholders and authorities for a
40 day review period. The comments received from stakeholders will be recorded and
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incorporated into the Final Scoping Report (FSR) which will be submitted to DMR as well as
any other relevant commenting authorities.
8.2.2 Submission and Decision-Making
The delegated competent authorities will be allocated 43 days to review the FSR. The FSR
will be placed on stakeholder review for a reasonable time period during the Department’s
final review and decision-making process. Any comments received during this period will be
forwarded to the delegated authority. If the delegated competent authorities must within this
specified timeframe to issue a decision to proceed onto the next phase, the EIR phase.
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9 PUBLIC PARTICIPATION UNDERTAKEN TO DATE
The scoping process has included the activities listed below with further detail on key
aspects discussed in the following sub-sections:
A pre-consultation meeting was held at DMR Offices on the 11 August 2015
Desktop review of available baseline information;
Development of a stakeholder database;
Preparation and distribution of media notices (English adverts were placed in the “Die
Kwevoel” on 25 September 2015;
Placement of BIDs at public places including the Local Municipal Office
Landowners, I & Aps and stakeholders of the proposed development (25 September
2015);
Adjacent landowners were physically delivered a Background Information Document
(BID);
Recording of issues raised by stakeholders and compiling an Issues and Response
Report (IRR);
Collation of comments received during the initial commenting and registration period
into an Issues and Response Report (IRR);
Compilation of a Scoping Report (this document) and submission for a 30 day public
review period;
All comments and concerns raised during this commenting period will be collated and
addressed in the Scoping Report prior to submission to the DMR;
The Environmental Assessment Practitioner (EAP) identifies further investigations required
to investigate the positive and negative impacts identified with input from I&APs and the
relevant authorities;
Terms of Reference was drafted for the relative specialist studies. The main source of
information used to inform the scoping phase of the project is listed below:
Specialist investigations conducted for the mine expansion EIA;
Site visits conducted by the project team;
Regional geological, biodiversity, and land use maps;
Topographic maps (1:50 000 scale); and
Satellite imagery.
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9.1 INTERESTED AND AFFECTED PARTIES ISSUES AND RESPONSES
Table 9:28 Summary of Issues raised by Interested and Affected Parties
Interested and Affected Parties
List the names of persons consulted in this column, and
Mark with an X where those who must be
consulted were in fact consulted.
DateCommentsReceived
Issues raised EAPs response to issues as mandated by the applicant
ConsultationStatus (consensusdispute, notfinalized,etc)
AFFECTED PARTIES
Landowner/s XLandowner of portion 1 of
Middellaagte 382 KQ
(Danie Koekemoer)
X 25
September
2015
07 October
2015
Farm owners were notified of the integrated
waste management and water use licence
application for the proposed construction of
Thaba Mine mine additional tailings storage
facility and waste disposal.
DK indicated that he had been away but all
correspondence has been received. He
further outline that he is aware of the ongoing
project and will comment accordingly.
Landowner of portion 1 of X 25
September
Correspondence was made with the farm
owner notifying him of the integrated waste
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Zwartkop 369 KQ
(Peter Trollope)
2015 management and water use licence
application for the proposed construction of
Thaba Mine mine additional tailings storage
facility and waste disposal. PT indicated he
will contact us should any issues arise.
Lawful occupier/s of the land
Landowners or lawful occupierson adjacent properties
X
Anglo American Kumba Iron
Ore
Municipal councillor XMunicipality X 25
September
2015
Thabazimbi Local Municipality.
Sazi Environmental introduced themselves
and provided information regarding the
proposed project at Thaba Cronimet Chrome
Mine. Notification of the integrated waste
management and water use licence
application for the proposed construction of
Thaba Mine mine additional tailings storage
facility and waste disposal was granted and
the PPO of the Municipality, Mr T. Masilo
indicated that they were already aware of this
project and gave us the go ahead to paste
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site notices there.
Organs of state (Responsible forinfrastructure that may beaffected Roads Department,Eskom, Telkom, DWA e
X 25
September
2015
Formal letters were emailed to the DWS and
DMR to inform them of the proposed project
and to invite them to participate on the
project.
Waterberg Department of
Roads and Transport
(Mabel Makibelo)
Communities
Elinah Phantsi (Smashblock
community)
Miriam Mthiba (Smashblock)
Dept. Land Affairs
Melton Tshililo
Traditional Leaders
Nolizile Gcelu
(Smashblock)
Dept. Environmental Affairs
X 25
September
2015
Formal letters were emailed to the DWS and
DMR to inform them of the proposed project
and to invite them to participate on the
project.
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Other Competent Authorities affected
Thabazimbi Department of
Agriculture
(Charles De Kock)
OTHER AFFECTED PARTIESWard 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 mine
additional tailings storage facility and waste
disposal. SL indicated that they are aware of
the ongoing project and public participation
process however the community is not happy
because they get invited to partake in public
participation process and attend meetings but
their issues are never taken into
consideration or addressed accordingly
especially that of employing locals. S.
Lerumo further indicated that the community
is not pleased with this, and at some point
threatened to boycott the meetings or
demonstrate at the mines because when
construction commences, the mine hires
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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 mine additional tailings
storage facility and waste disposal was given.
The councillor acknowledged receipt and
urged me to invite them when a meeting
takes place as they are very much interested
in the socio-economic aspect of the project.
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10AN IDENTIFICATION OF THE ANTICIPATED ENVIRONMENTAL, SOCIAL OR CULTURAL IMPACTS
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 mining:
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.
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Air Quality:
Cumulative particulate and NO2 emissions.
Surface Water:
Sheet erosion and dust generation;
Potential pollution by hazardous substances; and
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; and
Increased risk of erosion and water quality deterioration.
Aquatic:
Destruction / disturbance of the Bierpruit and other rivers in the area.
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11PLAN OF STUDY FOR THE ENVIRONMENTAL IMPACT ASSESSMENT
A full EIA process will be conducted for the proposed project. The Draft and Final EIAR will
be submitted to the competent authority for decision making purposes.
The Scoping Phase is designed to identify impacts and determine whether they require
specialist investigation in the Impact Assessment Phase. The POS for EIA provides an
indication of the tasks to be undertaken during the Impact Assessment Phase of the project,
the impact assessment methodology, the PPP, and when authority consultation will take
place. The purpose of the POS is to layout an effective methodology to be followed during
the assessment of impacts, should this be deemed necessary, in order to meet the minimum
legal requirements.
11.1 TASKS TO BE UNDERTAKEN DURING THE ENVIRONMENTAL IMPACT ASSESSMENT PHASE
Once the FSR and the Plan of Study (PoS) for the EIR phase has been submitted and
accepted by the DMR, the proposed project will proceed into the detailed EIR phase, which
involves the detailed specialist investigations. Sazi will produce a Draft EIR after the
completion of the required specialist studies. The Draft EIR will provide an assessment of all
the identified key issues and associated impacts from the Scoping phase. All requirements
as contemplated in NEMA GNR 982 will be included in the Draft EIR. The Draft EIR will
contain, inter alia, the following:
Details of-
The EAP who prepared the report; and
The expertise of the EAP, including a curriculum vitae;
The location of the activity, including:
The 21 digit Surveyor General code of each cadastral land parcel;
Where available, the physical address and farm name; and
where the required information in items (i) and (ii) is not available, the coordinates of
the boundary of the property or properties;
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A plan which locates the proposed activity or activities applied for as well as the associated
structures and infrastructure at an appropriate scale, or, if it is-
A linear activity, a description and coordinates of the corridor in which the proposed
activity or activities is to be undertaken;
On land where the property has not been defined, the coordinates within which the
activity is to be undertaken;
A description of the scope of the proposed activity, including-
All listed and specified activities triggered and being applied for; and
A description of the associated structures and infrastructure related to the
development;
A description of the policy and legislative context within which the development is located
and an explanation of how the proposed development complies with and responds to the
legislation and policy context;
A motivation for the need and desirability for the proposed development, including the need
and desirability of the activity in the context of the preferred location;
A motivation for the preferred development footprint within the approved site;
A full description of the process followed to reach the proposed development footprint within
the approved site, including:
Details of the development footprint alternatives considered;
Details of the public participation process undertaken in terms of regulation 41 of the
Regulations, including copies of the supporting documents and inputs;
A summary of the issues raised by interested and affected parties, and an indication
of the manner in which the issues were incorporated, or the reasons for not including
them;
The environmental attributes associated with the development footprint alternatives
focusing on the geographical, physical, biological, social, economic, heritage and
cultural aspects;
The impacts and risks identified including the nature, significance, consequence,
extent, duration and probability of the impacts, including the degree to which these
impacts- can be reversed; may cause irreplaceable loss of resources; and can be
avoided, managed or mitigated;
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The methodology used in determining and ranking the nature, significance,
consequences, extent, duration and probability of potential environmental impacts
and risks;
Positive and negative impacts that the proposed activity and alternatives will have on
the environment and on the community that may be affected focusing on the
geographical, physical, biological, social, economic, heritage and cultural aspects;
The possible mitigation measures that could be applied and level of residual risk;
If no alternative development locations for the activity were investigated, the
motivation for not considering such; and
A concluding statement indicating the preferred alternative development location
within the approved site;
A full description of the process undertaken to identify, assess and rank the impacts the
activity and associated structures and infrastructure will impose on the preferred location
through the life of the activity, including-
a description of all environmental issues and risks that were identified during the
environmental impact assessment process; and
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;
An assessment of each identified potentially significant impact and risk, including
- Cumulative impacts;
- The nature, significance and consequences of the impact and risk;
- The extent and duration of the impact and risk;
- The probability of the impact and risk occurring;
- The degree to which the impact and risk can be reversed;
- The degree to which the impact and risk may cause irreplaceable loss of
resources; and
- The degree to which the impact and risk can be mitigated;
Where applicable, a summary of the findings and recommendations of any specialist report
complying with Appendix 6 to these Regulations and an indication as to how these findings
and recommendations have been included in the final assessment report;
An environmental impact statement which contains-
A summary of the key findings of the environmental impact assessment:
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A map at an appropriate scale which superimposes the proposed activity and its
associated structures and infrastructure on the environmental sensitivities of the
preferred site indicating any areas that should be avoided, including buffers; and
A summary of the positive and negative impacts and risks of the proposed activity
and identified alternatives;
Based on the assessment, and where applicable, 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 final proposed alternatives which respond to the impact management measures,
avoidance, and mitigation measures identified through the assessment;
Any aspects which were conditional to the findings of the assessment either by the EAP or
specialist which are to be included as conditions of authorisation;
A description of any assumptions, uncertainties and gaps in knowledge which relate to the
assessment and mitigation measures proposed;
A reasoned opinion as to whether the proposed activity should or should not be authorised,
and if the opinion is that it should be authorised, any conditions that should be made in
respect of that authorisation;
Where the proposed activity does not include operational aspects, the period for which the
environmental authorisation is required and the date on which the activity will be concluded
and the post construction monitoring requirements finalised;
An undertaking under oath or affirmation by the EAP in relation to:
The correctness of the information provided in the reports;
The inclusion of comments and inputs from stakeholders and l&APs;
The inclusion of inputs and recommendations from the specialist reports where
relevant; and
Any information provided by the EAP to interested and affected parties and any
responses by the EAP to comments or inputs made by interested or affected parties;
Where applicable, details of any financial provisions for the rehabilitation, closure, and
ongoing post decommissioning management of negative environmental impacts;
An indication of any deviation from the approved scoping report, including the plan of study,
including-
Any deviation from the methodology used in determining the significance of potential
environmental impacts and risks; and
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A motivation for the deviation;
Any specific information that may be required by the competent authority; and
Any other matters required in terms of section 24(4)(a) and (b) of the Act.
11.1.1 Specialist Studies
The table below provides a list of the Specialists that are involved in this study and their
areas of expertise.
Table 11:29 Description of specialist studies
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
Tailings Water Quality Aquatico Scientific (Pty) Ltd
Visual Specialist Study Newton Landscape Architects cc
Wetland Delineation and Impact Assessment Wetland Consulting Services (Pty) Ltd
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11.1.2 Terms of reference for specialist studies
11.1.2.1 Air Quality assessmentThe Air Quality Impact Assessment TOR must include the following:
The literature review with respect to air quality and climate for the study area must be
done in a radius of 5 km from the project area;
Undertaking of a site inspection to characterise the receiving environment, including
the sensitivity, proximity and direction, and review the suitability of the existing dust
monitoring network with respect to the proposed TSFs and WRDs location;
Assess existing monitoring systems, if available;
Develop an emissions inventory; excluding Greenhouse Gasses and carbon foot
print studies;
Set up and run an air dispersion model for dust and gas that integrates the
information obtained for 3 scenarios with respect to the concentrator plant location
and 3 scenarios with respect to the proposed TSF location and operation;
Identification of all sources of atmospheric emissions that are associated with the
proposed new infrastructure;
Simulations of the ground level PM 2.5, PM 10 concentrations and dust fallout for
highest daily and annual PM concentrations and total daily dust deposition due to
routine and upset emissions from the proposed new infrastructure.
11.1.2.2 Aquatic Assessment
The aquatic assessment must make allowance for the assessment of two
representative aquatic ecological assessment points to characterise a and to define
the Present Ecological State (PES) of aquatic resources at strategic points within on
the system. Allowance has been made for one round of assessment.
The aquatic ecological assessment must focus on, amongst other: On site biota
specific water quality testing (including pH, conductivity, dissolved oxygen and
temperature); Instream habitat integrity and conditions for aquatic macro-
invertebrates (IHAS, HCR and IHIA);
Assessment of the aquatic macro-invertebrate community based on the SASS5
index. Making use of the MIRIA Ecostatus tool to characterise and define the PES
and potential risks to the aquatic macro-invertebrate community; Assessment of the
fish community based on the FRAI11 Ecostatus tool to characterise and define the
PES and potential risks to the aquatic macro-invertebrate community;
Assessment of the riparian vegetation community integrity;
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Findings must be compiled into a report which will highlight the PES, Ecostatus and
Ecological Importance and Sensitivity (EIS) of the system
11.1.2.3 Faunal AssessmentThe faunal assessment will be conducted using the following methods:
Extensive consideration will be given to determining the ecological importance
and sensitivity (EISC) of the subject property according to relevant databases.
The relevant Limpopo Province databases for the QDS will also be consulted and
will serve as the reference data to which field surveys will be compared to;
Visual observations of actually occurring species;
Identification of evidence of occurrence, e.g. call spoor, droppings, etc.;
Capture of fauna by various methods including netting, trapping and
dragging. In this regard special mention is made of the use of pitfall traps and
sweep netting for invertebrates as well as the use of Sherman traps to
determine the composition of the small mammal community on the site. Rope
dragging methods will also be used to flush birds from areas where RDL avifaunal
species are deemed likely to occur;
Nocturnal studies to identify nocturnal animals in the area may take place if it is
deemed necessary;
The reports produced will include sensitive habitat types and impacts from habitat
disturbance, faunal assemblages at risk and an assessment of impacts on migratory
routes;
The RDSIS index will also be considered in order to quantify the importance of the
subject property in terms of RDL faunal conservation;
Based on the findings a detailed impact assessment on all identified significant risks
will take place; and
Recommendations on management and mitigation measures (including opportunities
and constraints) with regards to the construction and operation of the proposed
development in order to manage and mitigate impacts on the faunal assemblage of
the area will be provided.
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11.1.2.4 Flora Assessment The proposed methodology includes both a desktop review and a field work
component.
A desktop review of distribution lists (including Red Data Listed (RDL) species) and
available literature will be conducted to guide the field work component.
The vegetation type of the area will be defined according to sources such as Mucina
& Rutherford (2006). Extensive consideration will also be given to determining the
ecological importance and sensitivity (EISC) of the subject property according to
relevant provincial and national conservation databases. The SANBI and PRECIS
databases for the Quarted Degree Square (QDS) will also be consulted and will
serve as the reference data to which field surveys will be compared to.
The assessment will include a detailed assessment for the entire area to be affected
by mining activities as well as the surrounding zone of influence. The field
assessment will identify:
Various habitat types;
• A description of each habitat type based on conservation importance and
present ecological state;
• Floral species associated with each habitat component:
Focus on sensitive habitat types and impacts associated to them in order to fulfil the
requirements of the study.
Such sensitive areas will be mapped where detail will be given of the ecological
aspect of concern in each sensitivity zone;
Focus on establishing the presence of RDL species and other sensitive species
identified as well as suitable
habitats for any of these species;
Specific focus will also be given to identifying areas of severe weed and alien
vegetation encroachment, which will be mapped;
Medicinal plant species will also be identified and the location of special medicinal
species will be presented on maps;
Veld condition will be quantitatively assessed according to a pre-defined veld
condition index and will also be quantitatively compared to the typical vegetation for
the vegetation type of the area a ccording to Mucina & Rutherford (2006);
Species lists for each habitat unit will be developed;
Based on the findings a detailed impact assessment on all identified significant risks
will take place;
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Recommendations on management and mitigation measures with regards to the
construction and operation of the proposed development in order to manage and
mitigate impacts on the ecology of the area; and
Rehabilitation and closure requirements will be considered.
11.1.2.5 Wetland Assessment The wetland assessment will comprise of detailed desktop assessments of the
National Freshwater Ecosystem Priority Areas (FEPA) database as well as available
regional wetland layers in order to define the wetland features based on existing
desktop data. The wetlands will then be delineated in the field according to the
Department of Water Affairs (DWA) (2005) guideline methodology. Once the wetland
boundary has been defined it will be mapped and the relevant buffers applied.
Delineation of the wetland resources will take place according to the DWAF (2005)
guidelines and an assessment of the wetland Present Ecological State (PES), Index
of Habitat Integrity (IHI), WET-Health, and wetland function and ecoservices will take
place according to DWA approved protocols.
Recommendations for mitigating impacts on the aquatic environment will also be
provided.
Results will be compiled into a report which will include a discussion on the findings.
Specific attention will be given to the impacts associated with the proposed
development with impacts being assessed according to a pre-defined impact
assessment methodology.
Extensive attention will be given to the development of recommendations for
mitigating impacts on the receiving environment. These mitigation measures can
then be incorporated into the EMP for the development to ensure that the wetland
ecology of the area is adequately protected
11.1.2.6 Heritage Assessment The HIA and desktop Palaeontology Assessment must be conducted. The purpose of
the heritage survey is to ascertain if any archaeological or historical remains occur in
the survey area and if they are of aesthetic, architectural, historical, scientific, social,
spiritual, linguistic or technological value. Attention must be given to both tangible
and intangible heritage remains. The Heritage and desktop Palaeontology
Assessment TOR is not limited to, but must include the following:
Liaison with SAHRA and search SAHR Information Systems for existing reports and
information of the survey area;
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Compile detailed maps of the survey area indicating all cultural heritage resources
(Stone Age, Iron Age and Historical Period);
Utilise Geographic Information System (GIS) systems and Google Earth (also
topographic maps and aerial photographs);
Survey of the survey area; reconnoitre larger area with vehicle and foot survey of
sensitive spots and areas;
Random consultation with local people to ascertain aspects of intangible heritage;
Recording and documenting of all sites using standard archaeological field work
techniques;
Recording of site s with a Geographic Positioning System (GPS) and compiling
maps;
Detailed description of all archaeological and historical artefacts, structures (including
graves) and settlements documented in the area (including photographs) will be
included in the phase 1 heritage report;
Establish the level of sensitivity/importance of the archaeological and historical (both
tangible and intangible) remains in the area;
Cultural traditions related by the local communities will be a high priority when
establishing the significance of archaeological and historical remains as well as
graves in formal cemeteries and informal burials;
Provide the relevant authorities with appropriate documents for their review and
decision-making. In particular, copies of the Heritage Report must be sent to SAHRA
and the relevant Provincial Heritage Resource Agency;
The desktop Palaeontology Assessment must include:
- A description of significant fossil occurrences;
- Recommendation on whether a phase 1 Paleontological Impact Assessment
will be required.
11.1.2.7 Noise Assessment The Noise Assessment TOR is not limited to, but must include the following:
o Determine the prevailing noise levels in and around the proposed TSF and
MRD;
o This noise survey from an environmental noise point of view
must be done during the daytime period and the night-time period in order to
evaluate the recommended residual noise levels laid down by SANS 10103:2008 and
to get a representative residual noise level for the areas where the proposed
activities will or takes place;
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The proposed noise survey will consist out of the following:
o Preliminary survey and identification of measuring points;
o All measurements will be done on the boundary of the property;
o Sound pressure readings will also be done at the closest residential area – if
applicable;
Noise survey at the identified measuring sites – Ambient noise measurements;
Calculation of noise propagation;
Analysing of results;
Results of the survey, report and recommendations and mapping of noise contours
for the sites.
11.1.2.8 Soil and Land Capability AssessmentThe Soil, Land Use and Land Capability Assessment TOR are not limited to, but must
include the following:
A detailed soil survey must be conducted at the proposed area where the proposed
development project will be. The maps generated during the desktop study phase
must be used to determine a grid and these areas will be traversed on the pre-
determined transects and auger samples will be studied. In areas of great soil form
variety, more samples points must be evaluated as well as to establish soil form
boundaries;
Observations must be made regarding soil texture, depth of soil, soil structure,
organic matter content and slope of the area. The soil characteristics of each sample
point must be noted and logged with a GPS. The location of these auger points must
be indicated in a Survey Points Map to be included in the final specialist report. Soil
samples for chemical analysis must be taken at 25 sampling points and at each point
both topsoil (0-300mm) and subsoil (300-600mm) will be sampled;
The soils will be described using the S.A. Soil Classification Taxonomic System (Soil
Classification Working Group, 1991) published as memoirs on the Agricultural
Natural Resources of South Africa No.15. Soils will be grouped into classes with
relatively similar soil properties and pedogenesis. A cold 10% hydrochloric acid
solution will be used on site to test for the presence of carbonates in the soil;
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The 24 representative soil samples must be stored in perforated soil sampling plastic
bags on site and sent by courier to SGS Soil Laboratory in Somerset West for
chemical soil analysis;
Samples must be analysed for pH, phosphorus content, cations (calcium,
magnesium, potassium and sodium),
electrical conductivity, organic carbon content and relative fractions of sand, silt and
clay;
The results of the soil survey must be mapped and zones of similar soil forms
indicated. Once soil form groups have been outlined, soil potential and land capability
must be determined using the guidelines developed by the Agricultural Research
Council unless otherwise specified by the client;
The possible impacts of the proposed project on soil, agricultural potential and land
capability must be evaluated.
11.1.2.9 Visual AssessmentThe Visual Impact Assessment (VIA) TOR is not limited to, but must include the following:
The assessment must establish a view catchment area, view corridors, viewpoints
and receptors;
The assessment must indicate the potential visual impacts using established criteria;
The assessment must include amongst other potential lighting impacts at night;
The report must be based upon the WC Guidelines the proposed activities would
require a Level 3 assessment; and must include amongst other:
o Identification of issues raised during the EIA process;
o Undertake a desktop VIA analysis;
o Conduct a site visit to verify the scope of the VIA as well as gain an
understanding of the receiving environment;
o Describe the receiving environment with regards to the various elements
of the project;
o Conduct a viewshed analysis of the proposed expansions, identifying
potential sensitive receptors;
o Identify any potential mitigation measures (including lighting impacts –
should they be raised and potential
o impacts on tourism in the area); and
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o Identify potential alternatives, mitigation measures and monitoring
programmes
o The data required for the project includes, but is not limited to, structural
heights, alignments and footprint areas for the proposed expansions
Once these data are made available the following must be undertaken:
Review of the information based on information supplied;
Perform a desktop analysis to outline the baseline visual aspects of the site and to
identify preliminary sensitive visual receptors – the classification of the landscape’s
visual character and possible receptors to the proposed project;
Consult with the EAP to discuss the project and attend to any questions that may
have arisen from the EIA process;
Liaise with the EAP to obtain any I&APs concerns noted by the EAP regarding the
potential visual impacts the proposed expansions may have; and ·
The data required for the project includes, but is not limited to: structural heights and
footprint areas for the proposed TSFs and MRDs
The viewshed analysis must include the compilation of a preliminary spatial model
(based on the proposed expansions). Tasks will include:
o Compile a preliminary spatial model (based on the plans and contour information)
for the proposed expansions using a GIS three dimensional software modelling
package;
o Compile a set of viewpoints from areas that are deemed to be potentially visually
influenced by the proposed expansions;
o Using these viewpoints in conjunction with a site visit assess the visual impacts of
the proposed expansions;
o Provide descriptions of the possible visual impacts that the proposed expansions
may have on the surrounding landscape using viewshed analysis, including the
identification of potential sensitive viewers / receptors informed by the EIA
process, as well from the viewshed.
11.1.2.10 Surface Water Assessment
The Surface Water Assessment TOR is not limited to, but must include the following:
Water related considerations must be guided by the NWA Regulation 704 and the
DWS Best Practice Guidelines;
The surface water study must consider the following items:
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Assess crossings and diversions against details and visuals where the pipeline
crosses the rivers and identify if there are going to be additional impacts with the
construction of a new pipe crossing;
Identify areas where ponding / restriction of flow is occurring due to structural
restrictions or operational activities;
Assess stability of river banks at crossings and diversions. Relate findings to actual
suspended solids/turbidity data in BRPM's water quality database;
Assess crossings and diversions for potential to be impacted by spills and ability to
handle such spills, with specific reference to tailings and wastewater pipeline
crossings;
Review floodlines and revise as appropriate;
Identify any unauthorised activities within the floodline or 100m of the watercourse
including infrastructure, operations, storage of materials, dumping etc;
Document all erosion controls, energy dissipaters where stormwater releases occur
to the natural environment
Assess watercourses at crossings and diversions for erosion, signs of
current/previous flooding. Review inspection records, if any. Identify areas where
maintenance or rehabilitation have been implemented or are required e.g. energy
dissipation, erosion repairs/controls, removal of accumulated debris to maintain
capacity etc.
Stormwater Management Plan must include the following
o A site audit to understand the existing stormwater layout and the future
stormwater controls;
o Hydrology of the site to indicate the storm volumes emenating from the
various sub catchments within the site (Calculation of the stormwater runoff
based on impervious surface of the site);
o Describe the hydrology in relation to the position of the major pans in the
area;
o Provide layout drawings (3 drawings) of the following elements:
o Indicate the site in relation to watercourses in the area;
o Indicate the existing layout of where the stormwater flows are;
o Detailed property designed layout and demarcation clean and dirty water
areas as well as proposed stormwater controls and monitoring points;
o Describe what stormwater controls are required to ensure that the site will be
environmentally compliant from a stormwater point of view
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11.1.3 Stakeholder Review Prior to SubmissionThe Draft EIR will be made available to stakeholders and authorities for review, prior to
finalisation and submission of the report to authorities for review by the delegated competent
authorities. All stakeholders and authorities will be allocated 30 days to review the Draft EIR
before the Final Report is submitted to the delegated competent authorities for review and
decision making. Furthermore, stakeholders will be afforded an additional timeframe in which
to review the final EIR in parallel to the authority review period.
11.1.4 Submission and Decision-MakingIn accordance with the NEMA, the following process will need to be followed by the decision
making authority in order to process the EA:
Once the Final EIR (including comments received by stakeholders) has been submitted, the
DMR will be allocated 107 days to review the report in which time they may:
Accept the EIR
Notify the Proponent that the EIR has been referred for specialist review
Request the Proponent to make such amendments to the EIR as the delegated
authority may require for acceptance thereof or
Reject the EIR if it does not comply with the content requirements
11.2 IMPACT ASSESSMENT RATING AND ASSESSING SIGNIFICANCE METHODOLGY
11.2.1 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 Page 91 of 108
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
11.2.2 Quantitative Impact Assessment Methodology
11.2.2.1 Status 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 11:30 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
11.2.2.2 Certainty of Impact
The certainty or probability of the impact describes the likelihood of the impact actually occurring.
Table 11:31 Certainty of Impact and Ratings
Rating 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
percent probability of a particular fact or of the likelihood of an impact
3
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occurring.
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
percent probability of a particular fact or of the likelihood of an impact
occurring.
5
11.2.2.3 Frequency of Impact
The 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 11:32 Frequency Of Impact And Ratings
Rating 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
11.2.2.4 Spatial Extent of Impact
The 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 11:33 Spatial Extent of Impact
Rating 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
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International Beyond the boundaries of South Africa 5
11.2.2.5 Intensity of Impact
The severity or intensity of an impact is an attempt to quantify the magnitude of the impacts and
benefits associated with the proposed activities.
Table 11:34 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
Mitigation for negative impacts is very expensive, difficult or time
consuming
3
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
11.2.2.6 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 11:35 Duration of Impact and Ratings
Rating DescriptionQuantitativ
e 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 3
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mine
Permanent The environmental impact identified will be irreversible and will remain
post closure
4
11.2.2.7 Assessing Significance
After 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 11:36 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,
5-10
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Rating DescriptionThreshold of significance
alternative means for achieving this benefit are likely to be easier,
cheaper, more effective, less time consuming, or a combination of
these.
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 11:37 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
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