BASIC ASSESSMENT AND ENVIRONMENTAL MANAGEMENT …

BASIC ASSESSMENT AND ENVIRONMENTAL

MANAGEMENT PROGRAMME REPORT:

DECOMMISSIONING OF PARTS OF THE CULLINAN

DIAMOND MINE BENEFICIATION PLANT

NAME OF APPLICANT: CULLINAN DIAMOND MINE (PTY) LTD

TEL NO: (014) 544 6100

POSTAL ADDRESS: Private Bag X1015, Cullinan

PHYSICAL ADDRESS: Olienhout Road, Cullinan, 1000

BASIC ASSESSMENT REPORT AND ENVIRONMENTAL MANAGEMENT PROGRAMME REPORT

NAME OF APPLICANT: CULLINAN DIAMOND MINE (PTY) LTD

TEL NO: (012) 305 2487

POSTAL ADDRESS: Private Bag X1015, Cullinan

PHYSICAL ADDRESS: Olienhout Road, Cullinan, 1000

FILE REFERENCE NUMBER: TO BE PROVIDED

BASIC ASSESSMENT REPORT

AND

ENVIRONMENTAL MANAGEMENT PROGRAMME REPORT

SUBMITTED FOR ENVIRONMENTAL AUTHORIZATIONS IN TERMS OF THE

NATIONAL ENVIRONMENTAL MANAGEMENT ACT, 1998 IN RESPECT OF

LISTED ACTIVITIES THAT HAVE BEEN TRIGGERED BY APPLICATIONS IN

TERMS OF THE MINERAL AND PETROLEUM RESOURCES

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

DRAFT FOR PUBLIC COMMENT


OBJECTIVE OF THE BASIC ASSESSMENT PROCESS

The objective of the basic assessment process is to, through a consultative process-

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

complies with and responds to the policy and legislative context;

(b) identify the alternatives considered, including the activity, location, and technology alternatives;

(c) describe the need and desirability of the proposed alternatives,

(d) through the undertaking of an impact and risk assessment process inclusive of cumulative impacts which

focused on determining the geographical, physical, biological, social, economic, heritage, and cultural

sensitivity of the site and the risk of impact of the proposed activity and technology alternatives on these

aspects to determine:

(i) the nature, significance, consequence, extent, duration, and probability of the impacts occurring to; and

(ii) the degree to which these impacts—

(aa) can be reversed;

(bb) may cause irreplaceable loss of resources; and

(cc) can be managed, avoided or mitigated;

(e) through a ranking of the site sensitivities and possible impacts the activity and technology alternatives will

impose on the sites and location identified through the life of the activity to—

(i) identify and motivate a preferred site, activity and technology alternative;

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

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


TABLE OF CONTENTS

PART A .............................................................................................................................................................. 10

SCOPE OF ASSESSMENT AND BASIC ASSESSMENT REPORT ................................................................. 10

1. Contact Person and correspondence address ....................................................................................... 10

1.1 Details of the EAP .......................................................................................................................... 10

1.2 Expertise of the EAP. ..................................................................................................................... 10

1.3 Details of the project applicant ....................................................................................................... 11

2. Location of the overall Activity ................................................................................................................ 11

3. Locality map ........................................................................................................................................... 12

4. Description of the scope of the proposed overall activity ....................................................................... 13

4.1 Listed and specified activities ......................................................................................................... 13

4.2 Description of the activities to be undertaken ................................................................................ 18

5. Policy and Legislative Context ............................................................................................................... 24

6. Need and desirability of the proposed activities. .................................................................................... 28

7. Motivation for the overall preferred site, activities and technology alternative including a full description

of the process followed to reach the proposed preferred alternatives within the site. ................................... 37

7.1 Details of the development footprint alternatives considered. ....................................................... 37

7.2 Details of the Public Participation Process Followed ..................................................................... 37

7.3 Summary of issues raised by I&APs .............................................................................................. 39

7.4 The Environmental attributes associated with the alternatives. A baseline environment. ............. 42

7.5 Impacts and risks identified including the nature, significance, consequence, extent, duration and

probability of the impacts, including the degree to which these impacts .................................................. 66

7.6 Methodology used in determining and ranking the nature, significance, consequences, extent,

duration and probability of potential environmental impacts and risks. ..................................................... 70

7.7 The positive and negative impacts that the proposed activity (in terms of the initial site layout) and

alternatives will have on the environment and the community that may be affected. ............................... 74

7.8 The possible mitigation measures that could be applied and the level of risk. .............................. 74

7.9 Motivation where no alternative sites were considered. ................................................................ 74

7.10 Statement motivating the alternative development location within the overall site. ....................... 74

8. Full description of the process undertaken to identify, assess and rank the impacts and risks the

activity will impose on the preferred site (In respect of the final site layout plan) through the life of the

activity. ........................................................................................................................................................... 74

9. Assessment of each identified potentially significant impact and risk .................................................... 75

10. Summary of specialist reports. ........................................................................................................... 79

11. Environmental impact statement ........................................................................................................ 80

11.1 Summary of the key findings of the environmental impact assessment ........................................ 80

11.2 Final Site Map ................................................................................................................................ 81

11.3 Summary of the positive and negative impacts and risks of the proposed activity and identified

alternatives ................................................................................................................................................ 82


12. Proposed impact management objectives and the impact management outcomes for inclusion in the

EMPr ............................................................................................................................................................ 85

13. Aspects for inclusion as conditions of Authorisation. ......................................................................... 86

14. Description of any assumptions, uncertainties and gaps in knowledge. ............................................ 86

15. Reasoned opinion as to whether the proposed activity should or should not be authorised ............. 87

15.1 Reasons why the activity should be authorized or not. .................................................................. 87

15.2 Conditions that must be included in the authorisation ................................................................... 88

16. Period for which the Environmental Authorisation is required. .......................................................... 88

17. Undertaking ........................................................................................................................................ 88

18. Financial Provision ............................................................................................................................. 88

18.1 Explain how the aforesaid amount was derived. ............................................................................ 88

18.2 Confirm that this amount can be provided for from operating expenditure. ................................... 89

19. Specific Information required by the competent Authority ................................................................. 89

19.1 Compliance with the provisions of sections 24(4)(a) and (b) read with section 24 (3) (a) and (7) of

the National Environmental Management Act (Act 107 of 1998). the EIA report must include the: - ....... 89

20. Other matters required in terms of sections 24(4)(a) and (b) of the Act. ........................................... 89

PART B .............................................................................................................................................................. 90

ENVIRONMENTAL MANAGEMENT PROGRAMME REPORT ........................................................................ 90

1. Draft environmental management programme. ..................................................................................... 90

1.1 Details of the EAP .......................................................................................................................... 90

1.2 Description of the Aspects of the Activity ....................................................................................... 90

1.3 Composite Map .............................................................................................................................. 90

1.4 Description of Impact management objectives including management statements ...................... 92

1.5 Impact Management Outcomes ..................................................................................................... 99

1.6 Impact Management Actions ........................................................................................................ 103

1.7 Financial Provision ....................................................................................................................... 109

1.8 Mechanisms for monitoring compliance with and performance assessment against the

environmental management programme ................................................................................................ 110

1.9 Indicate the frequency of the submission of the performance assessment/ environmental audit

report. ...................................................................................................................................................... 112

1.10 Environmental Awareness Plan ................................................................................................... 112

1.11 Specific information required by the Competent Authority ........................................................... 120

2. UNDERTAKING ................................................................................................................................... 121


ANNEXURES

Annexure A: Plans

Annexure A1: Locality Map

Annexure A2: Layout Map

Annexure B: Specialist Studies

Annexure B1: Asbestos inventory

Annexure B2: Heritage Inventory

Annexure C: Environmental Authorisations and Government Correspondence

Annexure C1: Approval of the Environmental Management Programme for Cullinan Diamond Mine

Annexure C2: Query response from the DMR

Annexure C3: Waste Management Licence for Landfill site

Annexure C4: Application form for Environmental Authorisation

Annexure D: Risk Assessment Report

Annexure D1: Risk Assessment Report

Annexure E: Public Participation

Annexure E1: Proof of advertisement

Annexure E2: Proof of site notices

Annexure E3: Copy of the BID

Annexure E4: Proof of notifications


REFERENCES

• Shangoni Management Services (Pty) Ltd. 2012. Environmental Management Programme Report for

Cullinan Diamond Mine. June 2012.

• Cullinan Diamond Mine. 2013. Asbestos Inventory. March 2013.

• PGS Heritage and Grave relocation consultants. 2011. Heritage Inventory for Cullinan Diamond Mine.

August 2011.

• City of Tshwane. 2017. Integrated Development Plan (IDP) 2017- 2021.


BACKGROUND DESCRIPTION

Cullinan Diamond Mine Pty (Ltd) (“CDM”) is a company that mines Diamonds at the Cullinan Diamond Mine.

The site is situated approximately 1.8 km south west of Cullinan, the closest major town to the mine. Parts of

the current Beneficiation Plant will be decommissioned/dismantled and replaced with new infrastructure.

All material stripped out from the Beneficiation Plant will be sold to local Black Economic Empowerment Service

Level Agreement (“BEE SLA”) companies. Where indicated in specific areas the concrete will be demolished

and be placed at the CDM Landfill site. Any hazardous material will be removed and stored at the salvage yard

and disposed of by an appointed waste disposal certificated contractor to a permitted landfill site. Contaminated

soil will be stored in skips demarcated for this purpose and disposed of by an appointed waste disposal

certificated contractor to a permitted landfill site.

Shangoni Management Services (Pty) Ltd has been appointed as the independent environmental practitioner,

to conduct the required Basic Assessment (“BA”) for the Environmental Authorisation for the following activities

occurring as part of the decommissioning of part of the CDM’s Beneficiation Plant:

• Activity 1: Dismantling and removal of conveyor belts.

• Activity 2: Dismantling and removal of cabling.

• Activity 3: Deconstruction of building material and concrete, and the removal of building rubble/concrete

to the CDM Landfill.

• Activity 4: Decommissioning of Water reticulation system and water pipelines.

• Activity 5: Decommissioning of the Washing Plant.

• Activity 6: Decommissioning of the Washing Plant Workshop and old Murray & Roberts area.

• Activity 7: Decommissioning of the Old Polysius Plant (High-Pressure Grinding Rolls).

• Activity 8: Decommissioning of the Large Diamond Recovery Plant and Waste Sorting Plant.

• Activity 9: Decommissioning of the Primary Crusher Plant.

• Activity 10 Decommissioning of the Prep Plant.

• Activity 11: Decommissioning of Plant Main Thickeners and Dewatering pump station.

• Activity 12: Decommissioning of the Coarse Dense Media Separation Plant.

• Activity 13: Decommissioning of the Re-crush Plant.

• Activity 14: Decommissioning of the Retreat Plant.

• Activity 15: Decommissioning of the Old Degrit Plant.

• Activity 16: Decommissioning of the Optical Sorting Plant.

• Activity 17: Decommissioning of the Caustic Plant.

• Activity 18: Decommissioning of the Old Sort house.

• Activity 19: Decommissioning of the Old Recovery Plant.

• Activity 20: Decommissioning of the Fines Dense Media Separation Plant.

• Activity 21: Decommissioning of the KHD Crusher plant section with the Dump Treatment Plant Recovery.

• Activity 22: Decommissioning of the Slimes Disposal Unit Plant.

• Activity 23: Decommissioning of transformers and electrical switching equipment.


• Activity 24: Removal of contaminated soils to a permitted landfill site (where required).

• Activity 25: Transportation of workers, materials and waste to and from site.

• Activity 26: Establishment and operation of a contractor support area.

The table below provides a summary of the listed activities for which authorisation is applied for as per GNR

983 of 4 December 2014, as amended.

Table 1: Listed Activities triggered by the Decommissioning of parts of the CDM’s Beneficiation Plant

LISTED ACTIVITY LISTED ACTIVITY DESCRIPTION

GNR 983 Listing Notice

1 Activity 31(i) and (v).

31. The decommissioning of existing facilities, structures or infrastructure for-

(i) any development and related operation activity or activities listed in this Notice, Listing

Notice 2 of 2014 or Listing Notice 3 of 2014;

(v) any activity regardless the time the activity was commenced with, where such activity:

(a) is similarly listed to an activity in (i) and (ii) above; and

(b) is still in operation or development is still in progress;

excluding where-

(aa) activity 22 of this notice applies; or

(bb) the decommissioning is covered by part 8 of the National Environmental Management:

Waste Act, 2008 (Act No. 59 of 2008) in which case the National Environmental

Management: Waste Act, 2008 applies.


PART A

SCOPE OF ASSESSMENT AND BASIC ASSESSMENT

REPORT

1. Contact Person and correspondence address

1.1 Details of the EAP

Shangoni Management Services (Pty) Ltd was appointed to compile this Basic Assessment Report (BAR) for

the proposed project. Shangoni Management Services (Pty) Ltd details are provided in Table 2 below.

Table 2: Details of the Environmental Assessment Practitioner

Name Shangoni Management Services (Pty) Ltd

Postal address:

P.O. Box 74726

Lynwood Ridge

0040

Contact person: Minnette Le Roux

Affiliations: Founding member of EAPSA

SACNASP Reg. No. 200035/13

Tel: +27 (0)12 807 7036

Fax +27 (0)12 807 1014

Cell: +27 (0)83 660 0622

E-mail: [email protected]

A summary of the CV of the EAP involved in the conducting of the Basic Assessment Process and compiling

the BAR is given below:

1.2 Expertise of the EAP.

Minnette completed a B.Sc.(Hons) Environmental Science at the Pretoria University. She also holds a Certificate

in Implementing Environmental Management Systems (ISO 14001), Registered with the South African Council

for Natural Scientific Professions and is a Founding member of the Environmental Assessment Practitioner

Association of South Africa. Minnette has over 9 years’ experience in completing the Environmental Assessment

Processes for various projects, in the construction and large scale mining sectors, including amongst other;

Environmental Impact Assessments, Scoping Reports, Basic Assessment Reports, Environmental Management

Plans, Environmental Management Programmes, Integrated Water Use Licence Applications, Integrated Water

and Waste Management Plans, Regulation GN 704 Audits, Water Use Licence Audits, Waste Licence

Applications and various Application Forms as part of the Environmental Application Process.


1.3 Details of the project applicant

The details of the applicant proposing the project are given in Table 3.

Table 3: Details of the applicant

Name of Mine Cullinan Diamond Mine

Project Applicant Cullinan Diamond Mine Pty (Ltd)

Responsible Person Juan Kemp

Contact Person Dane Marais

Physical address Olienhout Road, Cullinan, 1000

Postal address Private Bag X1015, Cullinan, 1000

Telephone Number (012) 305 2487

E-Mail Address [email protected]

Company Registration No’s. 2007/021069/07

2. Location of the overall Activity

Table 4: Location of the Activity

Farm Name Portion 3 of the Farm Elandsfontein 480 JR

Application area (Ha) 32Ha

Magisterial district City of Tshwane Metropolitan Municipality

Distance and direction from nearest town The site is situated approximately 1.8km south west of

Cullinan, the closest major town to the mine.

21 digit Surveyor General Code for each farm

portion T0JR00000000048000003


3. Locality map

Figure 1: Locality Map of the project area


4. Description of the scope of the proposed overall activity

4.1 Listed and specified activities

ACTIVITY NO. NAME OF ACTIVITY

Aerial extent of the

Activity

Ha or m²

LISTED

ACTIVITY

(Mark with an X where

applicable or

affected.)

APPLICABLE LISTING NOTICE

(GNR 983, GNR 984 or GNR 985)

Total area covers approximately 32ha in size

Activity 1 Dismantling and removal of conveyor belts.

Within 32 ha X The National Environmental Management Act, 1998

(Act No. 107 of 1998).

Decommissioning of the facilities trigger activity 31(i) and

(v) in Listing Notice 1(GNR983).

Activity 2 Dismantling and removal of cabling. Within 32 ha X The National Environmental Management Act, 1998

(Act No. 107 of 1998).



Activity 3 Deconstruction of building material and concrete, and

the removal of building rubble/concrete to the CDM

Landfill.


(Act No. 107 of 1998).



Activity 4 Decommissioning of Water reticulation system and

water pipelines.


(Act No. 107 of 1998).



Activity 5 Decommissioning of the Washing Plant.


(Act No. 107 of 1998).






Activity

Ha or m²

LISTED

ACTIVITY


applicable or

affected.)


(GNR 983, GNR 984 or GNR 985)

Activity 6 Decommissioning of the Washing Plant Workshop and

old Murray & Roberts area.


(Act No. 107 of 1998).



Activity 7 Decommissioning of the Old Polysius Plant (High-

Pressure Grinding Rolls).


(Act No. 107 of 1998).



Activity 8 Decommissioning of the Large Diamond Recovery

Plant and Waste Sorting Plant.


(Act No. 107 of 1998).



Activity 9 Decommissioning of the Primary Crusher Plant.


(Act No. 107 of 1998).



Activity 10 Decommissioning of the Prep Plant. Within 32 ha X The National Environmental Management Act, 1998

(Act No. 107 of 1998).



Activity 11 Decommissioning of Plant Main Thickeners and

Dewatering pump station.


(Act No. 107 of 1998).






Activity

Ha or m²

LISTED

ACTIVITY


applicable or

affected.)


(GNR 983, GNR 984 or GNR 985)

Activity 12 Decommissioning of the Coarse Dense Media

Separation Plant.


(Act No. 107 of 1998).



Activity 13 Decommissioning of the Re-crush Plant. Within 32 ha X The National Environmental Management Act, 1998

(Act No. 107 of 1998).



Activity 14 Decommissioning of the Retreat Plant. Within 32 ha X The National Environmental Management Act, 1998

(Act No. 107 of 1998).



Activity 15 Decommissioning of the Old Degrit Plant.


(Act No. 107 of 1998).



Activity 16 Decommissioning of the Optical Sorting Plant.


(Act No. 107 of 1998).



Activity 17 Decommissioning of the Caustic Plant.


(Act No. 107 of 1998).






Activity

Ha or m²

LISTED

ACTIVITY


applicable or

affected.)


(GNR 983, GNR 984 or GNR 985)

Activity 18 Decommissioning of the Old Sort house.


(Act No. 107 of 1998).



Activity 19 Decommissioning of the Old Recovery Plant.


(Act No. 107 of 1998).



Activity 20 Decommissioning of the Fines Dense Media

Separation Plant.


(Act No. 107 of 1998).



Activity 21 Decommissioning of the KHD Crusher plant section

with the Dump Treatment Plant Recovery.


(Act No. 107 of 1998).



Activity 22 Decommissioning of the Slimes Disposal Unit Plant.


(Act No. 107 of 1998).



Activity 23 Decommissioning of transformers and electrical

switching equipment.


(Act No. 107 of 1998).






Activity

Ha or m²

LISTED

ACTIVITY


applicable or

affected.)


(GNR 983, GNR 984 or GNR 985)

Activity 24 Removal of contaminated soils to a permitted landfill

site (where required).

Within the 32 ha N/A N/A

Activity 25 Transportation of workers, materials and waste to and

from site.

Existing roads in and

outside of the mine

will be used.

N/A N/A

Activity 26 Establishment and operation of a contractor support

area.

Within the 32 ha N/A N/A


4.2 Description of the activities to be undertaken

Parts of the current Beneficiation Plant will be decommissioned/dismantled and replaced with new infrastructure.

All material stripped out from the Beneficiation Plant will be sold to local Black Economic Empowerment Service

Level Agreement (“BEE SLA”) companies. Where indicated in specific areas the concrete will be demolished

and be placed at the CDM Landfill site (Licence attached in Annexure C3). Any hazardous material will be

removed and stored at the salvage yard (Licence attached in Annexure C3) and disposed of by an appointed

waste disposal certificated contractor to a permitted landfill site. Contaminated soil will be stored in skips

demarcated for this purpose and disposed of by an appointed waste disposal certificated contractor to a

permitted landfill site.

The following activities are to be undertaken as part of the decommissioning of parts of the Beneficiation Plant

and are indicated in Figure 2 below:

Activity 1 Dismantling and removal of conveyor belts:

This activity includes the dismantling and removal of conveyor belts in the following plants:

• The Washing Plant;

• Old Polysius Plant;

• Large Diamond Recovery Plant;

• Primary Crusher Plant;

• Between the stockpile and wash plant;

• Prep Plant;

• Coarse Dense Media Separation;

• Recrush Plant;

• Retreat Plant; and

• Fines Dense Media Separation Plant:

All material stripped from the equipment will be sold to local BEE SLA companies. Reusable equipment will be

placed in a laydown area and will be sold as reusable equipment or auctioned off.

Activity 2 Dismantling and removal of cabling:

Powerlines and electrical cables in all the facilities to be decommissioned will be dismantled, removed and sold.

The three old 88kV feed power lines and MV switching yard with transformers will be decommissioned by Eskom.

Activity 3 Deconstruction of building material and concrete, and the removal of building

rubble/concrete to the CDM Landfill:

This activity includes the crushing and removal of building rubble, concrete structures and concrete floors during

the dismantling of the following facilities:

• The Washing Plant;

• Old Polysius Plant;

• Large Diamond Recovery Plant;

• Primary Crusher Plant;


• Prep Plant;

• Plant Main Thickeners and Dewatering Pump Station;

• Coarse Dense Media Separation;

• Recrush Plant;

• Retreat Plant;

• Old Degrit Plant;

• Optical Sorting Plant;

• Sorthouse;

• Recovery Plant;

• Fines Dense Media Separation Plant; and

• Slimes Disposal Unit Plant

The building rubble and concrete to be removed is approximately 2 200 m3 and will be disposed at the CDM

Landfill Site which is licenced to receive general waste.

Activity 4 Decommissioning of Water reticulation system and water pipelines:

Water pipes will be disconnected. Pipes at the Primary Crusher Plant, Dewatering Pump Station, Coarse Dense

Media and Old Degrit Plant will be stripped and sold.

Activity 5 Decommissioning of the Washing Plant:

This includes the removal of equipment in the Washing Plant; two steel floors with beams and braces and

recycling conveyors. Equipment stripped from the plant will be sold.

Activity 6 Decommissioning of the Washing Plant Workshop and old Murray & Roberts area:

This area will be cleared for emergency purposes, as it falls within the 100m boundary from the pit walls.

Activity 7 Decommissioning of the Old Polysius Plant (High-Pressure Grinding Rolls):

This activity includes stripping of the components of the Polysius Plant and includes the removal of two crushers

and all equipment and internal equipment structures to create space in the building. The shell will be retained,

and the plant will be used as a store.

Activity 8 Decommissioning of the Large Diamond Recovery Plant and Waste Sorting Plant:

This activity includes the stripping and demolition of the plant, its substation, feed conveyor 1636 and its

discharge conveyor 1636. Approximately 12 m3 of concrete will be removed and disposed at the CDM Landfill,

which is licenced to receive general waste.

Activity 9 Decommissioning of the Primary Crusher Plant:

The six vibrating feeders, four screens, pumps and sump pumps will be stripped out and sold as complete units

or equipment. The conveyor belts, chutes, old dust scrubbers, air pipes, water pipes and internal structures will

be stripped by local BEE SLA contractors and all the stripping’s will be sold to them. The building with the cranes

will be used for a loading point and storage facility.


Approximately 360 m3 of concrete and building rubble will be disposed at the CDM Landfill, which is licenced to

receive general waste.

Activity 10 Decommissioning of the Prep Plant:

This activity includes the demolition of the total Prep Plant with feed conveyor 1615, tripper car and conveyor

1616, discharge conveyors 01 and 02. The underground mud pipe and the pipe gantry will be retained through

this area. Total concrete and building rubble is estimated at 36 m3 and will be moved to the CDM Landfill site,

which is licenced to receive general waste. l.

Activity 11 Decommissioning of Plant Main Thickeners and Dewatering pump station:

This activity includes removing several pumps and sump pumps with valves. All steel and pipes will be removed

by BEE SLA contractors and sold to them as part of the scrap project. The thickener cavities are to be filled and

the surface concrete is to be demolished and the ground level to be restored.

Activity 12 Decommissioning of the Coarse Dense Media Separation Plant:

This activity includes stripping of four conveyors (1617A-D) that feed the Coarse Dense Media Separation Plant

(CDMS) Plant. These conveyors will be stripped by the BEE SLA contractors. The CDMS houses two pumped

Dense Media Separation (DMS) processes of high value that are resalable and need to be sold as soon as

possible to ensure the highest value is recovered; the value will depreciate over time due to standing equipment

and pitting of bearings, as also rubber lining will perish. The six cyclones, six screens, two large Warman pumps

and several Warman sump pumps will be stripped out and sold as complete units or equipment. The conveyor

belts, chutes, Cyclone feed & discharge boxes, rubber lined tanks, air pipes, water pipes and internal structures

will be stripped by local BEE SLA contractors and all the stripped items will be sold to the BEE Contractors. The

building with the cranes will be stripped to the ground and the sumps filled with soil. Some concrete plinths will

be broken down. The concrete and building rubble is approximately 45 m3 and will be moved to the CDM Landfill,

which is licenced to receive general waste.

Activity 13 Decommissioning of the Re-crush Plant:

This activity includes stripping the Re-crush Plant including the feed conveyors 19 and 19A tripper, six internal

belt feeders, three discharge conveyors 20, 21 & 22 as well as the old infield screening conveyors 18A & 18B

that will be removed by the BEE SLA contractors. The eight vibrating screens, two vibrating screens, sump

pumps and the cranes will be stripped and sold as complete units or equipment. The conveyor belts, chutes, old

dust scrubbers, air pipes, water pipes and internal structures will be stripped by local BEE SLA contractors and

all the strippings will be sold to them. The concrete and building rubble is approximately 250 m3 and will be

moved to the CDM Landfill, which is licenced to receive general waste.

Activity 14 Decommissioning of the Retreat Plant:

In this activity, the five fines DMS modules will be stripped, the equipment screens, pumps, magnetic separators,

densifiers, cyclones will be removed and sold as equipment. All other structures, conveyors, bins, tanks will be

stripped, removed and sold as equipment. The cranes will be removed and sold lastly before the building

structure will be stripped and sold. The concrete structures will be broken down and all concrete and building


rubble off approximately 460 m3 will be taken to the landfill site, which is licenced to receive general waste. The

thickener cavities are to be filled and the surface concrete is to be demolished and the ground level to be

restored.

Activity 15 Decommissioning of the Old Degrit Plant:

The plant is to be deconstructed partly and the pipe supports to be retained. Most of the structure will be sold

as scrap to BEE SLA Contractors. Some concrete structures will be broken down and all concrete and building

rubble off approximately 10 m3 will be taken to the CDM landfill site, which is licenced to receive general waste.

Activity 16 Decommissioning of the Optical Sorting Plant:

This activity includes deconstructing the optical sorter plant. The equipment will be sold, and scrap will be sold

to BEE SLA contractors. The concrete structures will be broken down and all concrete and building rubble off

approximately 25 m3 will be taken to the CDM landfill site, which is licenced to receive general waste.

.

Activity 17 Decommissioning of the Caustic Plant:

This includes the decommissioning of the processes undertaken in the Caustic Plant and the plant used as a

Control and Instrumentation Workshop. The structure will not be decommissioned.

Activity 18 Decommissioning of the Old Sort house:

This activity includes the removal of all reusable equipment that will be redistributed within the Petra Group if

not reused it will be sold off. The Sorthouse will be demolished. All the building structures will be broken down

and all concrete and building rubble off approximately 120 m3 will be taken to the CDM landfill site, which is

licenced to receive general waste.

Activity 19 Decommissioning of the Old Recovery Plant:

Most of the equipment will be removed from the recovery and be sold off. The structures inside the recovery will

be stripped down and sold. The building will be demolished to the point where the basements will be filled up to

natural ground level. The concrete structures will be broken down and all concrete and building rubble off

approximately 480 m3 will be taken to the CDM landfill site, which is licenced to receive general waste.

Activity 20 Decommissioning of the Fines Dense Media Separation Plant:

The two fines DMS modules will be stripped, the equipment screens, pumps, magnetic separators, densifiers,

cyclones will be removed and sold. All other structures, conveyors, bins, tanks will be stripped, removed and

sold to contractors. The cranes will be removed and sold lastly before the building structure will be stripped down

and sold. The concrete structures will be broken down and all concrete and building rubble off approximately

320 m3 will be taken to the CDM landfill site, which is licenced to receive general waste.

The sumps might be utilized to assist with the containment of process water overflow from the new recovery

and to pump back to the XRL process water tank. Minor concrete structures will be broken down and all concrete


and building rubble off approximately 35 m3 will be taken to the CDM landfill site, which is licenced to receive

general waste.

Activity 21 Decommissioning of the KHD Crusher plant section with the Dump Treatment Plant

Recovery:

This activity includes the removal of equipment from the old Dump Treatment Plant (“DTP”) recovery. This

equipment will be redistributed within the Petra Group or will be sold.

Activity 22 Decommissioning of the Slimes Disposal Unit Plant:

This plant with all the pipe gantries will be broken down. The pumps and sump pumps will be removed as

complete units and will be sold. The structures, tanks, piping and the piping gantries will be stripped by BEE

SLA Contractors and will be sold to them. The sumps will be demolished and filled to natural ground level at a

later stage. Minor building structures will be broken down and all concrete and building rubble off approximately

10 m3 will be taken to the CDM landfill site, which is licenced to receive general waste.

Activity 23 Decommissioning of transformers and electrical switching equipment:

This activity includes dismantling transformers and electrical switching equipment. Re-usable/recyclable

material will be removed and sold.

Activity 24 Removal of contaminated soils to a permitted landfill site (where required):

This activity includes the removal of contaminated soil present at the area to be decommissioned to a permitted

landfill site.

Activity 25 Transportation of workers, materials and waste to and from site:

Transport activities for the project will include contractors travelling to and from site, equipment /material

transported off site for selling, recycling, re-use, transport of waste to permitted landfill sites.

Activity 26 Establishment and operation of a contractor support area:

For day-to-day management of the operations, including portable chemical toilets, use of generators (if required

for power supply) and temporary material and waste storage areas. Temporary support infrastructure will be set-

up on site for the duration of the project. The area will be fenced with security and access control.


Figure 2: Layout Map of the project area


5. Policy and Legislative Context

APPLICABLE

LEGISLATION AND

GUIDELINES USED TO

COMPILE THE REPORT

REFERENCE WHERE

APPLIED

HOW DOES THIS DEVELOPMENT COMPLY WITH AND RESPOND TO THE LEGISLATION AND POLICY

CONTEXT

The Constitution of the

Republic of South Africa (Act

108 of 1996).

Throughout the whole

document

Section 2 of the Constitution of the Republic of South Africa (Act 108 of 1996) (CA) states that: “This Constitution is

the supreme law of the Republic; law or conduct inconsistent with it is invalid, and the obligations imposed by it must

be fulfilled.” Section 24 of the CA, states that everyone has the right to an environment that is not harmful to their health

or well-being and to have the environment protected, for the benefit of present and future generations, through

reasonable legislative and other measures that:

• prevent pollution and ecological degradation;

• promote conservation; and

• secure ecologically sustainable development and use of natural resources while promoting justifiable economic and

social development.

Section 24 guarantees the protection of the environment through reasonable legislative (and other measures) and such

legislation is continuously in the process of being promulgated.

Section 33(1) concerns administrative justice which includes the constitutional right to administrative action that is

lawful, reasonable and procedurally fair.

This document was accordingly prepared, submitted and considered within the constitutional framework set by, inter

alia, section 24 and 33 of the Constitution.

The Promotion of Access to

Information Act, 2000(Act

No.2 of 2000).


document

Without access to information, a person may be unable to determine whether or not his or her right to just administrative

action (or to an environment not harmful to human health or wellbeing or, for that matter, any other Constitutional right)

has been infringed. The purpose of the Promotion of Access to Information Act (“PAIA”) is to give effect to the

Constitutional right of access to any information held by the State and any information that is held by another person

and that is required for the exercise or protection of any rights, and to provide for matters connected therewith. In

addition to providing access to information, cognisance should be taken that PAIA also makes provision for the refusal

of access to information that is deemed to be of a sensitive, confidential or classified nature. This is captured under

Chapter 4 of part 2 and 3 of PAIA.


National Environmental

Management: Waste Act 59

of 2008

Section 4.2 of Part A

Section 20 of the NEMWA pertains to the consequences of listing waste management activities and states that no

person may commence, undertake or conduct a waste management activity, except in accordance with the

requirements or standards for that activity as determined by the Minister or in accordance with a waste management

licence issued in respect of that activity, if a licence is required. In terms of the current statutory framework with regards

to waste management, a waste management licence is required for those waste management activities identified in

the Schedule to GN 718. Certain of the waste management activities listed in the Schedule are governed by specific

thresholds. Where any process or activity falls below or outside the thresholds stipulated, a waste management licence

is not required.

Consideration was given to additional waste management activities and potential licencing. A waste license will not be

required in terms of the National Environmental Management: Waste Act 59 of 2008. The demolition of concrete may

be seen as treatment of general waste, but the threshold required during the project falls below the daily rate for

treatment of waste as specified in the NEM: WA. Concrete will be disposed of at the licenced CDM landfill site, which

is licenced to receive general waste. Hazardous material will be stored at the salvage (which is licenced to receive

hazardous waste) and disposed of by an appointed waste disposal certificated contractor to a permitted landfill site.

Contaminated soil will be stored in skips demarcated for this purpose and disposed of by an appointed waste disposal

certificated contractor to a permitted landfill site. Compliance to the Waste Management Licence (Licence attached in

Annexure C3) should be adhered to.

The Mineral and Petroleum

Resources Development Act,

2002 (Act No. 28 of 2002)


document

The MPRDA was passed in order to make provision for equitable access to and sustainable development of the nation’s

mineral and petroleum resources, and to provide for matters connected therewith. The Preamble to the MPRDA inter

alia affirms the State’s obligation to:

• protect the environment for the benefit of present and future generations;

• ensure ecologically sustainable development of mineral and petroleum resources, and;

• promote economic and social development.

The aforesaid MPRDA preamble affirms the general right to an environment provided for in section 24 of The

Constitution of the Republic of South Africa, Act 108 of 1996 (then Constitution).

The national environmental management principles provided for in section 2 of the National Environmental

Management Act (NEMA), Act No.107 of 1998 apply to all prospecting and mining operations and any matter relating

to such operation. These principles apply throughout the Republic to the actions of all organs of state including, inter

alia, the Department of Mineral Resources (DMR), previously known as the Department of Minerals and Energy (DME),

that may significantly affect the environment. Any prospecting or mining operation must be conducted in accordance


with generally accepted principles of sustainable development by integrating social, economic and environmental

factors into the planning and implementation of prospecting and mining projects in order to ensure that exploitation of

mineral resources serves present and future generations.

The National Environmental

Management Act, 1998 (Act

No. 107 of 1998).

The Environmental Impact

Assessment Regulations, R.

982 dated December 2014,

and amended.




and amended.




and amended.




and amended.


document

The overarching principle of the National Environmental Management Act 1998 (Act 107 of 1998) (NEMA) is

sustainable development. It defines sustainability as meaning the integration of social, economic and environmental

factors into planning, implementation and decision making so as to ensure the development serves present and future

generations. Section 2 of the NEMA (Act no 107 of 1989) provides for National Environmental Management Principles.

These principles include:

• Environmental management must place people and their needs at the forefront of its concern.

• Development must be socially, environmentally and economically sustainable.

• Environmental management must be integrated, acknowledging that all elements of the environment are linked and

interrelated.

• Environmental justice must be pursued.

• Equitable access to environmental resources, benefits and services to meet basic human needs and ensure human

wellbeing must be pursued.

• Responsibility for the environmental health and safety consequences of a policy, programme, project, product,

process, service or activity exists throughout its life cycle.

• The participation of all Interested and Affected Parties (I&APs) in environmental governance must be promoted.

• Decisions must take into account the interests, needs and values of all I&APs.

• The social, economic and environmental impacts of activities, including disadvantages and benefits, must be

considered, assessed and evaluated, and decisions must be appropriate in the light of such consideration and

assessment.

• Decisions must be taken in an open and transparent manner, and access to information must be provided in

accordance with the law.

• The environment is held in public trust for the people, the beneficial use of environmental resources must serve the

public interest and the environment must be protected as the people’s common heritage.

• The costs of remedying pollution, environmental degradation and consequent adverse health effects and of

preventing, controlling or minimising further pollution, environmental damage or adverse health effects must be

paid for by those responsible for harming the environment.


Section 24 of the NEMA, headed “Environmental Authorisations” sets out the provisions which are to give effect to the

general objectives of Integrated Environmental Management (IEM), and laid down in Chapter 5 of the NEMA. In terms

of section 24(1), the potential impact on the environment of listed activities must be considered, investigated, assessed

and reported on to the competent authority charged by the NEMA with granting of the relevant environmental

authorisation.

On 04 December 2014, the Department of Environmental Affairs (DEA) published the 2014 NEMA Environmental

Impact Assessment (EIA) Regulations and listed activities in Government Gazette No. 38282, which was amended in

2017.

The proposed development involves ‘listed activities’, as identified in terms of the NEMA read with the Environmental

Impact Assessment Regulations of 2014. In terms of section 24(2) and 24D of the NEMA no person may commence

an activity listed or specified in terms of the act unless the competent authority has granted an environmental

authorisation for the activity.

All proposed activities at the CDM’s Beneficiation Plant will undergo all of the required environmental authorisation

processes.


6. Need and desirability of the proposed activities.

6.1 Need and Desirability in terms of the Guideline on Need and Desirability, 2017

In 2017, the Department of Environmental Affairs published an Integrated Environmental Management

Guideline, the Guideline on Need and Desirability. The following table indicates on how the guideline

requirement were considered in this Basic Assessment Report:

1 Section 24 of the Constitution and section 2(4)(a)(vi) of NEMA refer. 2 Must consider the latest information including the notice published on 9 December 2011 (Government Notice No. 1002 in Government

Gazette No. 34809 of 9 December 2011 refers) listing threatened ecosystems in terms of Section 52 of National Environmental Management: Biodiversity Act, 2004 (Act No. 10 of 2004).

3 Section 2(4)(r) of NEMA refers. 4 Section 2(4)(n) of NEMA refers. 5 Section 24 of the Constitution and Sections 2(4)(a)(i) and 2(4)(b) of NEMA refer.

REQUIREMENT PART WHERE REQUIREMENT IS

ADDRESSED/RESPONSE

1. How will this development (and its separate

elements/aspects) impact on the ecological integrity of the

area?1

CDM’s Beneficiation Plant falls within the existing

disturbed and approved footprint area, and no further

clearance of indigenous vegetation will occur as a

result of the decommissioning of parts of the plant.

This will result in no change to the existing impacts on

the ecological integrity of the area.

1.1 How were the following ecological integrity

considerations taken into account?

1.1.1 Threatened Ecosystems.2

1.1.2 Sensitive, vulnerable, highly dynamic or stressed

ecosystems, such as coastal shores, estuaries, wetlands, and

similar systems require specific attention in management and

planning procedures, especially where they are subject to

significant human resource usage and development pressure.3

1.1.3 Critical Biodiversity Areas ("CBAs") and Ecological

Support Areas ("ESAs").

1.1.4 Conservation targets.

1.1.5 Ecological drivers of the ecosystem.

1.1.6 Environmental Management Framework.

1.1.7 Spatial Development Framework.

1.1.8 Global and international responsibilities relating to the

environment (e.g. RAMSAR sites, Climate Change, etc.).4

1.2 How will this development disturb or enhance

ecosystems and/or result in the loss or protection of biological

diversity? What measures were explored to firstly avoid these

negative impacts, and where these negative impacts could not be

avoided altogether, what measures were explored to minimise

and remedy (including offsetting) the impacts? What measures

were explored to enhance positive impacts?5

CDM’s Beneficiation Plant falls within the existing

disturbed and approved footprint area and the

decommissioning of parts of the CDM’s Beneficiation

Plant will not lead to the disturbance and/or

enhancement of ecosystems and will not result in the

loss or protection of biological diversity.

1.3 How will this development pollute and/or degrade the

biophysical environment? What measures were explored to firstly

The potential impacts that may occur as a result of the

proposed activity have been identified and discussed


6 Section 24 of the Constitution and Sections 2(4)(a)(ii) and 2(4)(b) of NEMA refer. 7 Section 24 of the Constitution and Sections 2(4)(a)(iv) and 2(4)(b) of NEMA refer. 8 Section 24 of the Constitution and Sections 2(4)(a)(iii) and 2(4)(b) of NEMA refer. 9 Section 24 of the Constitution and Sections 2(4)(a)(v) and 2(4)(b) of NEMA refer. 10 Section 24 of the Constitution and Sections 2(4)(a)(vi) and 2(4)(b) of NEMA refer.

avoid these impacts, and where impacts could not be avoided

altogether, what measures were explored to minimise and remedy

(including offsetting) the impacts? What measures were explored

to enhance positive impacts?6

in Section 7.5 of Part A. The impacts have also been

assessed and mitigation measures were explored to

minimise and remediate the impacts. .

1.4 What waste will be generated by this development?

What measures were explored to firstly avoid waste, and where

waste could not be avoided altogether, what measures were

explored to minimise, reuse and/or recycle the waste? What

measures have been explored to safely treat and/or dispose of

unavoidable waste?7

Building rubble will be generated from the demolishing

of structures and buildings. The rubble will be

disposed at the licenced CDM landfill site (if found not

be contaminated).

1.5 How will this development disturb or enhance

landscapes and/or sites that constitute the nation's cultural

heritage? What measures were explored to firstly avoid these

impacts, and where impacts could not be avoided altogether, what

measures were explored to minimise and remedy (including

offsetting) the impacts? What measures were explored to

enhance positive impacts?8

No sites or landscapes that constitute the nations

cultural heritage will be disturbed or enhanced as a

result of the decommissioning of parts of the

beneficiation plant.

1.6 How will this development use and/or impact on non-

renewable natural resources? What measures were explored to

ensure responsible and equitable use of the resources? How have

the consequences of the depletion of the non-renewable natural

resources been considered? What measures were explored to

firstly avoid these impacts, and where impacts could not be

avoided altogether, what measures were explored to minimise

and remedy (including offsetting) the impacts? What measures

were explored to enhance positive impacts?9

This project comprises the demolition and

reconstruction of existing facilities on site, and it does

not affect underground operations and non-renewable

natural resources.


proposed activity have been preliminarily identified

and discussed in Section 7.5 of Part A.

1.7 How will this development use and/or impact on

renewable natural resources and the ecosystem of which they are

part? Will the use of the resources and/or impact on the

ecosystem jeopardise the integrity of the resource and/or system

taking into account carrying capacity restrictions, limits of

acceptable change, and thresholds? What measures were

explored to firstly avoid the use of resources, or if avoidance is not

possible, to minimise the use of resources? What measures were

taken to ensure responsible and equitable use of the resources?

What measures were explored to enhance positive impacts?10

This project comprises the demolition and

reconstruction of existing facilities on site, and it does

not affect renewable natural resources.


proposed activity have been preliminarily identified

and discussed in Section 7.5 of Part A.

1.7.1 Does the proposed development exacerbate the

increased dependency on increased use of resources to maintain

economic growth or does it reduce resource dependency (i.e. de-


11 Section 24 of the Constitution and Section 2(4)(a)(vii) of NEMA refer. 12 Section 24 of the Constitution and Sections 2(4)(a)(viii) and 2(4)(b) of NEMA refer.

materialised growth)? (note: sustainability requires that

settlements reduce their ecological footprint by using less material

and energy demands and reduce the amount of waste they

generate, without compromising their quest to improve their

quality of life)

1.7.2 Does the proposed use of natural resources constitute

the best use thereof? Is the use justifiable when considering intra-

and intergenerational equity, and are there more important

priorities for which the resources should be used (i.e. what are the

opportunity costs of using these resources this the proposed

development alternative?)

1.7.3 Do the proposed location, type and scale of development

promote a reduced dependency on resources?

1.8 How were a risk-averse and cautious approach applied

in terms of ecological impacts?11

It should be noted that this application relates to the

decommissioning of parts of the existing beneficiation

plant at CDM, and will have no impact on the

ecological integrity of the area.

A conservative approach was followed in terms of the

identification and assessing of environmental impacts

associated with the proposed project. Part A Section

7.5 addresses potential impacts that the activities

have on the surrounding environment.

1.8.1 What are the limits of current knowledge (note: the gaps,

uncertainties and assumptions must be clearly stated)?

The knowledge gaps and uncertainties have been

identified during the process of the proposed project

and are discussed in Section14 of Part A.

1.8.2 What is the level of risk associated with the limits of

current knowledge?

The proposed project relate to the decommissioning

of parts of the CDM’s Beneficiation plant. Since a

detailed risk / impact assessment has previously been

undertaking as part of the current operations, the level

of risk (currently) associated with the limits of current

knowledge can be considered low.

1.8.3 Based on the limits of knowledge and the level of risk,

how and to what extent was a risk-averse and cautious approach

applied to the development?






1.9 How will the ecological impacts resulting from this development impact on people's environmental right in terms

following:12


13 Section 2(4)(b) of NEMA refer. 14 Regulations 22(2)(i)(i), 28(1)(g) and 31(2)(1) in Government Notice No. R. 543 refer. 15 Section 24 of the Constitution refers.

1.9.1 Negative impacts: e.g. access to resources, opportunity

costs, loss of amenity (e.g. open space), air and water quality

impacts, nuisance (noise, odour, etc.), health impacts, visual

impacts, etc. What measures were taken to firstly avoid negative

impacts, but if avoidance is not possible, to minimise, manage and

remedy negative impacts?


proposed activity have been identified and discussed

in Section 7.5 of Part A. The impacts have also been

assessed and mitigation measures were explored to

minimise and remediate the impacts. . 1.9.2 Positive impacts: e.g. improved access to resources,

improved amenity, improved air or water quality, etc. What

measures were taken to enhance positive impacts?

1.10 Describe the linkages and dependencies between

human wellbeing, livelihoods and ecosystem services applicable

to the area in question and how the development's ecological

impacts will result in socio-economic impacts (e.g. on livelihoods,

loss of heritage site, opportunity costs, etc.)?

The structures, tanks, piping and the piping gantries

will be stripped by BEE SLA Contractors and will be

sold to them.

1.11 Based on all of the above, how will this development

positively or negatively impact on ecological integrity

objectives/targets/considerations of the area?





1.12 Considering the need to secure ecological integrity and

a healthy biophysical environment, describe how the alternatives

identified (in terms of all the different elements of the development

and all the different impacts being proposed), resulted in the

selection of the "best practicable environmental option" in terms

of ecological considerations?13

Alternatives as part of the development footprint was

not considered as the activities relate to the

decommissioning of the existing CDM’s beneficiation

plant and related infrastructure.

1.13 Describe the positive and negative cumulative

ecological/biophysical impacts bearing in mind the size, scale,

scope and nature of the project in relation to its location and

existing and other planned developments in the area?14

The positive and negative cumulative impacts have

been described in Section 9 of Part A.

2. “Promoting justifiable economic and social development”15

2.1 What is the socio-economic context of the area, based on, amongst other considerations, the following considerations?

2.1.1 The IDP (and its sector plans' vision, objectives,

strategies, indicators and targets) and any other strategic plans,

frameworks of policies applicable to the area,

The Cullinan area falls within the City of Tshwane and

the socio-economic context of the area is contained in

the 2017–2021 IDP.

2.1.2 Spatial priorities and desired spatial patterns (e.g. need

for integrated of segregated communities, need to upgrade

informal settlements, need for densification, etc.),

According to the IDP (2017-2021), Cullinan is

presented as an emerging node and a Tourism node.

The spatial priorities and desired spatial patterns for

the Cullinan area includes developing Cullinan into a

fully-fledged node.


16 Section 2(2) of NEMA refers. 17 Sections 2(2) and 2(4)(c) of NEMA refers. 18 Section 3 of the Development Facilitation Act, 1995 (Act No. 67 of 1995) ("DFA") and the National Development Plan refer.

2.1.3 Spatial characteristics (e.g. existing land uses, planned

land uses, cultural landscapes, etc.), and

Planned land uses include: Hostel upgrading/

refurbishment; Social and rental housing in Refilwe;

Formalization of informal settlements (In Situ)

upgrading and relocations; and Installation of

streetlights and high mast lights.

2.1.4 Municipal Economic Development Strategy ("LED

Strategy").

According to the IDP (2017-2021) Cullinan is one of

the Priority quadrants for economic development.

2.2 Considering the socio-economic context, what will the

socio-economic impacts be of the development (and its separate

elements/aspects), and specifically also on the socio-economic

objectives of the area? Parts of the current Beneficiation Plant will be

decommissioned/dismantled and replaced with new

infrastructure, to ensure the continuation of mining

activities at Cullinan Diamond Mine. This will have a

positive effect on the continuation of employment at

the mine. The decommissioning of parts of the plant

will provide temporary employment to local Black

Economic Empowerment Service Level Agreement

companies.

2.2.1 Will the development complement the local socio-

economic initiatives (such as local economic development (LED)

initiatives), or skills development programs?

2.3 How will this development address the specific physical,

psychological, developmental, cultural and social needs and

interests of the relevant communities?16

2.4 Will the development result in equitable (intra- and inter-

generational) impact distribution, in the short- and long-term?17

Will the impact be socially and economically sustainable in the

short- and long-term?

In terms of location, describe how the placement of the proposed development will:18

2.4.1 result in the creation of residential and employment

opportunities in close proximity to or integrated with each other,



plant at CDM, and will not be a development for

placement on a specific location.

2.4.2 reduce the need for transport of people and goods,

2.4.3 result in access to public transport or enable non-

motorised and pedestrian transport (e.g. will the development

result in densification and the achievement of thresholds in terms

public transport),

2.4.4 compliment other uses in the area,

2.4.5 be in line with the planning for the area,

2.4.6 for urban related development, make use of

underutilised land available with the urban edge,

2.4.7 optimise the use of existing resources and infrastructure,

2.4.8 opportunity costs in terms of bulk infrastructure

expansions in non-priority areas (e.g. not aligned with the bulk

infrastructure planning for the settlement that reflects the spatial

reconstruction priorities of the settlement),


19 Section 2(4)(a)(vii) of NEMA refers. 20 Section 24(4) of NEMA refers.

2.4.9 discourage "urban sprawl" and contribute to

compaction/densification,

2.4.10 contribute to the correction of the historically distorted

spatial patterns of settlements and to the optimum use of existing

infrastructure in excess of current needs,

2.4.11 encourage environmentally sustainable land

development practices and processes,

2.4.12 take into account special locational factors that might

favour the specific location (e.g. the location of a strategic mineral

resource, access to the port, access to rail, etc.),

2.4.13 the investment in the settlement or area in question will

generate the highest socio-economic returns (i.e. an area with

high economic potential),

2.4.14 impact on the sense of history, sense of place and

heritage of the area and the socio-cultural and cultural-historic

characteristics and sensitivities of the area, and

2.4.15 in terms of the nature, scale and location of the

development promote or act as a catalyst to create a more

integrated settlement?

2.5 How were a risk-averse and cautious approach applied

in terms of socio-economic impacts?19 It should be noted that this application relates to the





identification and assessing of socio economic

impacts associated with the proposed project. Part A

Section 7.5 addresses potential impacts that the

activities have on the surrounding environment.

2.5.1 What are the limits of current knowledge (note: the gaps,

uncertainties and assumptions must be clearly stated)?20

2.5.2 What is the level of risk (note: related to inequality, social

fabric, livelihoods, vulnerable communities, critical resources,

economic vulnerability and sustainability) associated with the

limits of current knowledge?

2.5.3 Based on the limits of knowledge and the level of risk,

how and to what extent was a risk-averse and cautious approach

applied to the development?

2.6 How will the socio-economic impacts resulting from this development impact on people's environmental right in

terms following

2.6.1 Negative impacts: e.g. health (e.g. HIV-Aids), safety,

social ills, etc. What measures were taken to firstly avoid negative

impacts, but if avoidance is not possible, to minimise, manage and

remedy negative impacts?

No negative impacts on the socio-economy as a result

of the proposed project have been identified.

2.6.2 Positive impacts. What measures were taken to enhance

positive impacts?

The positive impacts of the proposed

decommissioning of parts of the beneficiation plant on

the socio-economy, is that it creates for future mining


21 Section 2(4)(b) of NEMA refers. 22 Section 2(4)(c) of NEMA refers. 23 Section 2(4)(d) of NEMA refers. 24 Section 2(4)(e) of NEMA refers. 25 Section 2(4)(f) of NEMA refers. 26 Section 2(4)(f) of NEMA refers.

activities, continuation of employment and creation of

temporary employment locally.

2.7 Considering the linkages and dependencies between

human wellbeing, livelihoods and ecosystem services, describe

the linkages and dependencies applicable to the area in question

and how the development's socioeconomic impacts will result in

ecological impacts (e.g. over utilisation of natural resources, etc.)?





2.8 What measures were taken to pursue the selection of the

"best practicable environmental option" in terms of socio-

economic considerations?21



sold to them.

2.9 What measures were taken to pursue environmental

justice so that adverse environmental impacts shall not be

distributed in such a manner as to unfairly discriminate against

any person, particularly vulnerable and disadvantaged persons

(who are the beneficiaries and is the development located

appropriately)?22 Considering the need for social equity and

justice, do the alternatives identified, allow the "best practicable

environmental option" to be selected, or is there a need for other

alternatives to be considered?






2.10 What measures were taken to pursue equitable access

to environmental resources, benefits and services to meet basic

human needs and ensure human wellbeing, and what special

measures were taken to ensure access thereto by categories of

persons disadvantaged by unfair discrimination?23



sold to them.

2.11 What measures were taken to ensure that the

responsibility for the environmental health and safety

consequences of the development has been addressed

throughout the development's life cycle?24






2.12 What measures were taken to:

2.12.1 ensure the participation of all interested and affected

parties,

Refer to Section 7.2 of Part A for a description of the

Public Participation Process conducted.

The Public Participation presents the details of all

I&APs that were identified, how the I&APs were

notified and involved in the process, any issues and

concerns raised by the I&APs and the final results of

the Public Participation Process.

2.12.2 provide all people with an opportunity to develop the

understanding, skills and capacity necessary for achieving

equitable and effective participation,25

2.12.3 ensure participation by vulnerable and disadvantaged

persons,26


27 Section 2(4)(h) of NEMA refers. 28 Section 2(4)(k) of NEMA refers. 29 Section 2(4)(g) of NEMA refers. 30 Section 2(4)(q) of NEMA refers. 31 Section 2(4)(g) of NEMA refers. 32 Section 2(4)(j) of NEMA refers.

2.12.4 promote community wellbeing and empowerment

through environmental education, the raising of environmental

awareness, the sharing of knowledge and experience and other

appropriate means,27

2.12.5 ensure openness and transparency, and access to

information in terms of the process,28

2.12.6 ensure that the interests, needs and values of all

interested and affected parties were taken into account, and that

adequate recognition were given to all forms of knowledge,

including traditional and ordinary knowledge29, and

2.12.7 ensure that the vital role of women and youth in

environmental management and development were recognised

and their full participation therein were be promoted?30

2.13 Considering the interests, needs and values of all the

interested and affected parties, describe how the development will

allow for opportunities for all the segments of the community (e.g.

a mixture of low-, middle-, and high-income housing opportunities)

that is consistent with the priority needs of the local area (or that

is proportional to the needs of an area)?31



sold to them.

2.14 What measures have been taken to ensure that current

and/or future workers will be informed of work that potentially

might be harmful to human health or the environment or of

dangers associated with the work, and what measures have been

taken to ensure that the right of workers to refuse such work will

be respected and protected?32

All contractors, sub-contractors and workers will

attend compulsory environmental awareness training

and inductions. This training will highlight the dangers

associated with the workplace. Procedures relating to

environmental risks will also be put in place and will

be regularly updated.

2.15 Describe how the development will impact on job creation in terms of, amongst other aspects:

-

2.15.1 the number of temporary versus permanent jobs that will

be created,



sold to them.

2.15.2 whether the labour available in the area will be able to

take up the job opportunities (i.e. do the required skills match the

skills available in the area),

2.15.3 the distance from where labourers will have to travel,

2.15.4 the location of jobs opportunities versus the location of

impacts (i.e. equitable distribution of costs and benefits), and

2.15.5 the opportunity costs in terms of job creation (e.g. a mine

might create 100 jobs, but impact on 1000 agricultural jobs, etc.).


33 Section 2(4)(o) of NEMA refers. 34 Section 240(1)(b)(iii) of NEMA and the National Development Plan refer. 35 Section 2(4)(p) of NEMA refers. 36 Section 2(4)(b) of NEMA refers. 37 Regulations 22(2)(i)(i), 28(1)(g) and 31(2)(1) in Government Notice No. R. 543 refer.

2.16 What measures were taken to ensure:

2.16.1 that there were intergovernmental coordination and

harmonisation of policies, legislation and actions relating to the

environment, and

Refer to the Public Participation Process in Section

7.2 of Part A. Other government departments are

included on the list of I&APs and stakeholders and

received the notifications of the proposed activity as

well as notifications on the availability of the report for

review.

All applicable environmental legislation was

considered during the Basic Assessment process.

2.16.2 that actual or potential conflicts of interest between

organs of state were resolved through conflict resolution

procedures?

2.17 What measures were taken to ensure that the

environment will be held in public trust for the people, that the

beneficial use of environmental resources will serve the public

interest, and that the environment will be protected as the people's

common heritage?33

During the initial Public Participation Process, all

issues and concerns raised by the I&APs,

stakeholders and the Organs of State are taken into

account and responses provided.

2.18 Are the mitigation measures proposed realistic and what

long-term environmental legacy and managed burden will be

left?34

Mitigation measures for each of the identified impacts

will be described in detail in the EMPr. The proposed

mitigation measures will be realistic to protect both the

bio-physical and socio-economic environment in both

the short- and long-term.

2.19 What measures were taken to ensure that the costs of

remedying pollution, environmental degradation and consequent

adverse health effects and of preventing, controlling or minimising

further pollution, environmental damage or adverse health effects

will be paid for by those responsible for harming the

environment?35

The applicant will be responsible for the costs of any

remediation of pollution, environmental degradation

and consequent adverse health effects and of

preventing, controlling or minimising further pollution,

environmental damage or adverse health effects.

The Financial Provisioning for the proposed project

have been included in Section 18 of Part A.

2.20 Considering the need to secure ecological integrity and

a healthy bio-physical environment, describe how the alternatives

identified (in terms of all the different elements of the development

and all the different impacts being proposed), resulted in the

selection of the best practicable environmental option in terms of

socio-economic considerations?36

Alternatives as part of the development footprint were

not considered as the activities relate to the

decommissioning of parts of the existing Beneficiation

Plant.

2.21 Describe the positive and negative cumulative socio-

economic impacts bearing in mind the size, scale, scope and

nature of the project in relation to its location and other planned

developments in the area?37

The positive cumulative impact on the socio-economy

by the continuation of mining, continuation of

employment and employment of local contractors are

in line with the planned development of the area i.e


7. Motivation for the overall preferred site, activities and technology

alternative including a full description of the process followed to

reach the proposed preferred alternatives within the site.

7.1 Details of the development footprint alternatives considered.

Alternatives as part of the development footprint were not considered as the activities relate to the

decommissioning of parts of the existing Beneficiation Plant at CDM.

7.2 Details of the Public Participation Process Followed

The public participation process for this project was conducted in terms of:

• The procedures and provisions in terms of the NEMA;

• Chapter 6 of the 2014 EIA Regulations;

• GN 807 of 2012; Public Participation Guideline; and

• Other relevant legislation such as the Promotion of Access to Information Act (PAIA), 2000.

A detailed public participation process was undertaken, and included the following:

• Key Stakeholder identification;

• Method of notifications, e.g. advertisements, site notices, BID, email notifications;

• Registration of Interested and Affected Parties (I&AP’s) and key stakeholders;

• Access and opportunity to comment on the draft BAR by I&AP’s; and

• Consultation with the relevant authorities.

The following key stakeholder were identified and notified of the project:

• Landowner/s;

• Lawful occupier/s of the land;

• Landowners or lawful occupiers on adjacent properties;

• Municipal councillor;

• Municipality;

• Organs of state;

• Communities; and

• Other Competent Authorities affected.

The following notification and consultation methods were used:

• Newspaper advertisement in the Streeknuus placed on the 13th of June 2018 (refer to Annexure E1 for

proof of the advertisement placed);

Cullinan is a priority area for economic development

(IDP 2017-2021).


• Site notices were placed at CDM boom gate, Cullinan Spar, Eskom entrance, Refilwe Municipality and

Telkom offices (refer to Annexure E2 for proof of site notices placed); and

• Background Information Document (BID) sent to key stakeholders with email notifications (refer to

Annexure E3 for a copy of the BID and Annexure E4 for proof of the notifications sent).

The potential key stakeholders were notified of the project and have been provided with the opportunity to

register as an I&AP by 27 July 2018.

The draft BAR and EMPr is available to the public for review for a period of thirty (30) days, from 27 June 2018

to 27 July 2018. An electronic copy of the BAR and EMPr will also be posted on the Shangoni’s website

(www.shangoni.co.za) for public comment for the same period of thirty days.

A meeting was held with the DMR on 16 April 2018 and response on the meeting was provided on the 4th of

May 2018 (refer to Annexure C2 for a copy of the response). Once the public review of the draft BAR has been

completed, the report will be finalised inclusive of the comments from I&APs and will be submitted to the DMR

for review. Once DMR has made a decision, registered stakeholders will be notified of the decision.


7.3 Summary of issues raised by I&APs

The table below will be completed when the final BAR is compiled and will provide a summary of the comments and issues raised and reaction to those responses.

INTERESTED AND

AFFECTED PARTIES DATE COMMENTS RECEIVED ISSUES RAISED

EAPS RESPONSE TO ISSUES

AS MANDATED BY THE

APPLICANT

SECTION AND PARAGRAPH

REFERENCE IN THIS REPORT

WHERE THE ISSUES AND OR

RESPONSE WERE

INCORPORATED.

Landowner/s

Cullinan Diamond Mine

(Pty) Ltd.

Lawful occupier/s of the land

Cullinan Diamond Mine

(Pty) Ltd.

Landowners or lawful occupiers on adjacent properties

Windy Bow Game Reserve

Municipal councillor

Ward 100 Councillor

Municipality

City of Tshwane

Metropolitan Municipality.

City of Tshwane

Metropolitan Municipality.-

Region 5

Organs of state (Responsible for infrastructure that may be affected Roads Department, Eskom, Telkom, DWA etc.

Gauteng Department of

Roads and Transport.

Eskom

Telkom

Transnet



Water and Sanitation


Water and Sanitation

Department of Agriculture,

Forestry and Fisheries

(DAFF) -Gauteng Regional

Office

Communities

Community Development

Forum

Other Competent Authorities affected

Department of Mineral

Resources


Agriculture and Rural

Development


Agriculture and Rural

Development

Dept. Rural Development

and Land reform – Gauteng

Region

Department of Public

Works

Provincial Heritage

Resources Authority

Gauteng

Gauteng Conservancy and

Stewardship Association.


South African Heritage

Resources Agency

(SAHRA).


7.4 The Environmental attributes associated with the alternatives. A baseline

environment.

7.4.1 Type of environment affected by the proposed activity

This section of the report provides a description of the environment that may be affected by the proposed project.

Aspects of the biophysical, social and economic environment that could be affected by, or could affect, the

proposed project have been described.

This information has been sourced largely from existing information available for the area, existing documents

approved by the various governmental departments and specialist studies undertaken as part of other

authorisation and monitoring process.

7.4.1.1 Geology

The following information was obtained from the CDM approved Environmental Management Programme dated

2012.

CDM is located within the Main Zone of the Bushveld Complex (Council of Geoscience,

www.geoscience.org.za). The Bushveld Complex is comprised of large masses of Waterberg Conglomerate

with diamond bearing Kimberlite volcanic pipes. The Kimberlite is situated within the stable 3 billion year old

Kaap-Vaal Craton and intrudes rocks of the Transvaal Supergroup (Pretoria and Rooiberg Groups), Bushveld

complex and the younger Waterberg Group.

The Bushveld complex is the largest known layered mafic intrusion on earth and covers an area extent of some

65 000 km², attaining a thickness of between 7-9 km. Its age is estimated to be 2 billion years. The mafic rocks

of the Bushveld complex were emplaced discordantly into the Transvaal Supergroup, forming horse-shoe

shaped belts of mafic rock outcrop.

These outcrops surround an acidic central region, consisting of felsite, intrusive granophyres and post-bushveld

granites. In the south, between the eastern and western limbs of the complex and in the Bethal limb, younger

sedimentary cover and intrusions dominate at surface. It is in this region that the Cullinan Kimberlite occurs,

along with 11 other Kimberlite diatremes in the Cullinan-Rayton area.

A mass of Waterberg quartzite covers almost half of the area of the pipe and it is conspicuous in draw-points of

the eastern portion of the BA5 mining block. Although there is no longer any evidence of these quartzites

exposed around the pipe, this mass of ‘floating‘ Waterberg, along with other smaller rafts of material, provides

evidence of intrusion into the Waterberg at surface some 1 200 million years ago (mya).

The erosion of this cover exposed the felsite which is part of a large transgressive sill found in the area. This

has been tentatively correlated with the Rooiberg felsite (uppermost group of the Transvaal Supergroup). It may

however, be a meta-sediment formed by progressive feldspathisation of the quartzitic rocks of the Waterberg or

Pretoria Groups. In the stratigraphic column these respectively lie directly above and below the Rooiberg Group.


The diamond bearing ore body mined in the Cullinan-Rayton area is one of 12 Kimberlite diatremes found in the

area. Kimberlite is the underground ore deposit within an extinct volcanic pipe. The Cullinan Kimberlite pipe is

the largest known Kimberlite intrusion in the Republic of South Africa (RSA).

The Kimberlite pipe currently mined at CDM is oval in shape. On surface, the pipe has a maximum length of 860

m in an east-west direction and a width of 400 m in a north-south direction.

7.4.1.2 Topography


2012.

The mine is situated on the eastern foothills of the Magaliesberg range, and located at an altitude of ±1440

mamsl. The surrounding area is typically rolling hills with undulations of ±100 m between local hill rises and

valleys.

In the immediate vicinity of the mine, the topography is relatively gentle, sloping down to the No.7 dam, which

is located to the North. To the South East of the No.7 dam, a koppie rises sharply to a height of 1484 mamsl.

The local topography has been significantly altered by mining activities. Open cast mining, which started in the

early part of the previous century, has resulted in an open pit that is approximately 400 m deep. Tailings dumps

have also altered the natural topography of the area immediately adjacent to the pit and surface infrastructure

of the mine. These tailings dumps cover an area of approximately 440 ha, and rise above the natural topography

to a height of 1484 mamsl. Refer to Figure 3 for the topographical map of the area.


Figure 3: Topography Map


7.4.1.3 Climate

The following information was obtained from the Cullinan Diamond Mine: Final Environmental Impact

Assessment for the return water dam dated 2015.

The mine is located in a typical Highveld climatic region, with warm to hot summers, moderate winters and with

an average rainfall that is higher than that of most parts of the country. Rainfall occurs mostly in the form of

thunderstorms during the summer months.

Mean annual rainfall amounts to ± 680 mm per annum. The variability in the annual rainfall can be large. The

highest annual rainfall recorded for Cullinan was 1217 mm recorded during the 1966/67 hydrological year.

Lowest annual rainfall was measured at 150 mm during the 2002/2003 hydrological year. The 24 hour maximum

is 187 mm received in January 1978. The average number of days per annum with more than 0.1 mm of rain is

85.9. The Cullinan area receives most of its rainfall in the summer months between October and March.

January is generally the warmest month of the year with a mean temperature of 22.1 ºC and June is generally

the coldest month of the year with a mean temperature of 11.3 ºC.

Due to the absence of any relevant information for the area, data from the closest station weather station were

utilised. This station is managed by the South-Africa Weather Bureau (SAWB) and is situated in Pretoria,

roughly 45 km from the mine. The data was interpreted as follows:

• Pretoria experiences 36.1% of calm conditions throughout the year;

• The predominant winds in the area come from an East North Easterly direction, a North Easterly

direction and an Easterly direction; and

• Wind speeds in the area blow predominantly between 0.5 and 2.5 km/h, and rarely reach wind speeds

of between 3.5 and 5.6 km/h.

The evaporation rates as measured by the DWS at the Roodeplaat Dam (station number A2E013) are results

indicate that the highest evaporation levels generally occur between October and January, and the lowest

evaporation levels occur in June and July. The total annual evaporation for the area is estimated at 1323 mm.

Extreme weather conditions, as measured at the Pretoria University Experimental Farm, the results indicate

that hail, snow and fog are not regular occurrences in the area. However, thunderstorms are frequent and

provide a large part of the rainfall to the area.

7.4.1.4 Soil

The following information was obtained from the CDM approved Environmental Management Programme

dated 2012.

The mine is situated on a generalised soil pattern described as red, yellow and/or greyish soils with low to

medium base status comprising primarily of Hutton, Avalon, and Bainsvlei soil types.


South facing slopes of the quartzite koppie have shallow gravel and sandy soil. North facing slopes have

shallow stony soils. Ridge area has shallow, sandy soils with a rock cover of 60%. Topsoil is found and the

crushed rock is approximately 7.5 mm in diameter. The Protea caffra ridge veld is predominantly found on

southing facing slopes of quartzite ridges where there is shallow gravel and sandy soil. Burkea africana ridge

veld vegetation type covers approximately 90 ha (6%) of the game farm and occurs mainly on north facing

quartzite slopes where there are shallow stony soils.

Tristachya leucothrix mountain grassland area is 163 ha (10%) in extent and occurs in the south, west and

north-eastern parts of the game farm on shallow, sandy soils with a rock cover of 60%.

7.4.1.5 Vegetation


2012.

The regional area under investigation forms part of the Grassland and Savanna Biome. Each biome comprises

various vegetation types. The Grassland Biome is represented by Rand Highveld Grassland in this specific case,

and the Savanna Biome by Marikana Thornveld. It was found that the bulk of the site conformed to the Marikana

Thornveld vegetation type, as the vegetation along the ridge and the road is distinctly more thornveld than

grassland. Information from the Precis database also indicates that the 464 plant species that occur in the

quarter degree grid lean more towards the Thornveld than grassland. However, for completeness both the

vegetation types are described below.

Rand Highveld Grassland

Rand Highveld Grassland is found in the highly variable landscape with extensive sloping plains and ridges in

the Gauteng, North-West, Free State and Mpumalanga Provinces. The vegetation type is found in areas

between rocky ridges from Pretoria to Witbank, extending onto ridges in the Stoffberg and Roossenekal regions

as well as in the vicinity of Derby and Potchefstroom, extending southwards and northeastwards from there.

The vegetation is species rich, sour grassland alternating with low shrubland on rocky outcrops. The most

common grasses on the plains belong to the genera Themeda, Eragrostis, Heteropogon and Elionurus. High

numbers of herbs, especially Asteraceae are also found. In rocky areas shrubs and trees also prevail and are

mostly Protea caffra, Acacia caffra, Celtis africana and Searsia (previously Rhus spp).

This vegetation type is poorly conserved (approximately 1 %) and has a target of 24 % of the vegetation type to

be conserved. Due to the low conservation status this vegetation type is classified as endangered. Almost half

of the vegetation type has been transformed by cultivation, plantations, urbanisation or dam-building. Scattered

aliens (most prominently Acacia mearnsii) are present in the unit.

Marikana Thornveld

The Marikana Thornveld vegetation type occurs on plains from the Rustenburg area in the west, through

Marikana and Brits to the Pretoria area in the east. The vegetation type is typified by open Acacia karroo


woodland occurring in the valleys and undulating plains. Shrubs are denser along drainage lines and it is

common for the drainage lines to be infested with aliens.

Marikana Thornveld is considerably impacted, with 48 % of the vegetation type being transformed, mainly due

to cultivated and built-up areas. Most agricultural development of this unit is in the western regions towards

Rustenburg, while in the east (near Pretoria) industrial development is a greater threat of land transformation.

This vegetation type is rated as endangered as only 0.7 % of the unit is conserved. No natural vegetation is

present at the existing Beneficiation plant.

7.4.1.6 Fauna


2012.

The habitat in and around Cullinan can be described as savannah and grassland. These habitats have been

largely disturbed but several game farms in the area conserve the natural habitat and the species that occur

there.

The Cullinan area has a large variety of species, most naturally occurring with some species that have been

reintroduced to the area. This includes 155 insect families, 24 spider families, 195 Bird Species, 22 reptile

families, 17 terrestrial small mammals and 18 Managed Game species (Holgate and Associates, 2004).

According to the Precis database a total of 268 animal species can be found in the quarter degree grid.

Cullinan Diamond Mine has introduced some game to the Premier Game Reserve where others were naturally

occurring in the vicinity: Blesbok (Damaliscus pygargus phillipsi), Blue Wildebeest (Connochaetes taurinus),

Bushbuck (Tragelaphus sylvaticus), Bushpig (Potamochoerus porcus), Common Duiker (Sylvicapra grimmia),

Giraffe (Giraffa camelopardalis giraffa), Impala (Aepyceros malampus), Kudu (Tragelaphus imberbis), Mountain

Reedbuck (Redunca fluvorufula), Nyala (Nyala angasiiv), Red Hartebeest (Alcelaphus caama), Steenbuck

(Raphicerus campestris), Tsessebe (Damaliscus lunatus lunatus), Vervet Monkey (Chlorocebus pygerythrus),

Warthog (Phacochoerus africanus), Waterbuck (Kobus ellipsiprymnus) and Burchell’s Zebra (Equus quagga,

formerly Equus burchelli).

The species of birds are common bushveld species including Cape Wagtail, Crowned Lapwing (Plover), Cape

Turtle Dove, Crested Barbet, Blackeyed Bulbul, Masked Weaver and Red Bishop.

7.4.1.7 Surface Water



CDM is located in the upper region of two sub-catchments; the Premiermynloop and the McHardyspruit. These

water bodies form part of the upper Pienaars river catchment area (A23B).


The McHardyspruit joins the Premiermynloop to form the Premierspruit that converges with the Rooispruit,

forming the Roodeplaatspruit, that, later flows into the Pienaars River downstream of the Roodeplaat Dam.

McHardy Stream and Premiermynloop consequently form part of the upper Pienaars river catchment area. The

Pienaars River is an important branch of the Crocodile River catchment, which forms part of the Crocodile West

(Marico) Catchment Area (Primary Catchment A).

CDM have an extensive water quality monitoring programme up and downstream of the mine. Water quality

monitoring are currently undertaken at 7 surface monitoring localities situated in the area of concern. These

localities are divided into the clean water monitoring localities, the spruit monitoring localities and CDM affected

water monitoring localities.

The clean water monitoring localities comprise of the Premier Game Park Lapa Dam, the McHardy Dam and

the Wilge River Dam. The spruit monitoring localities include the McHardy Stream, which are divided into

McHardy East and McHardy West, the Premiermynloop, No.7 FRD wall seepage point and the Roodeplaatspruit.

The CDM affected water monitoring localities consist of the No.1 PCD, the No.2 PCD and the Old Swimming

Pool sump. Sampling results are currently compared to the Target Water Quality Guideline Ranges (TWQGR).

7.4.1.8 Groundwater

The following information was obtained from the geohydrological assessment and modelling of the new RWD

at Petra Diamonds’ Cullinan Diamond Mine was undertaken by Shangoni Acquiescence in 2015.

A borehole and hydrocensus was conducted within a 15 km radius of the mining area by Shangoni Acquiescence

hydrocensus in 2014. Some 61 boreholes were sampled for groundwater levels, yields and quality analyses.

Additionally, borehole data has been acquired from the National Groundwater Database of the DWA to

supplement yield and water level data and provide geological drilling logs and water spikes. CDM monitors

groundwater levels and groundwater qualities using a number of boreholes. In general water levels in the area

mimic the surface topography.

Groundwater flow along the drainage of the Premiermynloop from South East to North West and along the

Elands River from the South to the North. The groundwater divide between the Premiermynloop catchment to

the West of the mine and the Elands River catchment to the East, is clearly visible.

The groundwater quality in and around the mine are monitored on a regular basis. Results indicate that the

majority of the samples comply with the recommended limits for domestic water use as stipulated by the South-

African Bureau of Standards (SABS), (2001).

Ingress of groundwater into the mine is limited due to the impermeable nature of the kimberlite pipe and any

water quality impacts are thus limited in extent. The groundwater is of an acceptable quality and the

geochemistry of the rocks is not considered to have a significant adverse effect on groundwater quality

downstream from the mine.


Bacteriological analyses of the samples reveal the absence of pathogenic or any disease forming bacteria.

Samples taken comply with the bacteriological standards as specified by the SABS for human consumption,

with the exception of the Mampa School borehole, which contains a high Total Viable Organism count. This

probably as a result of the school’s French drain that pollutes the borehole water.

7.4.1.9 Air Quality



The primary source of air pollution in and around the mine area is air-borne dust particles. Dust in the air has

the potential to affect both mine employees and nearby residents. Sources have been identified as the main

underground ventilation fans, dust extraction and scrubbing installations in the treatment facility on surface, and

wind-blown dust from the tailings dumps and the stockpile. Incorrect functioning of the dust suppression systems

could attribute to air pollution as the rock crushing process will ten contribute more to airborne dust. Air

discharging from the two main ventilation system fans is from air circulated within the production areas and from

the underground workings. The two main centrifugal fans are sited on surface on the north and south sides of

the Kimberlite pipe.

Cullinan was previously identified as a site that may be potentially impacted on by air pollution generated by the

mine (as it lies within 3 km from the source). However, fall-out dust samples taken and analysed indicated that

potential pollution was negligible and the mine required no migratory action.

Fall-out dust is measured at various points on CDM. The American Standard Test Method (ASTM) is used to

measure dust.

7.4.1.10 Noise

Noise incurred at the mine emanates primarily from the Cullinan Diamond Mine surface plants, underground

ventilation fans and underground ring-blasting activities.

In order to determine the background noise of the area the latest noise survey, dated 5 September 2015, from

Cullinan Diamond Mine was conducted and the noise measured in terms of the National Environmental

Management: Air Quality Act No 39 of 2004.

According to the survey the Maximum noise at 04:50 is 54.4 dB(A) the bulk of the contributing factors to the

noise was mainly due to traffic around the mine.

7.4.1.11 Visual


2012.


The infrastructure associated with the mine intrudes the natural skyline. The existing headgear and treatment

facility structures have been construed on high ground, rising above the surrounding landscape, resulting in

visual impact from most directions. Night lighting of the mining area is also visible to land owners in the

immediate surroundings.

Similarly, the numerous tailings dumps often break the sky-line and are considered to be a significant visual

intrusion on the environment. Limited rehabilitation of these dumps has been undertaken. Additional

management and vegetation of the dumps will significantly reduce the extent of visual impacts to the

environment but seeing that the tailings is still regarded as a resource to be re-mined the re-vegetation is

captured as a commitment in the conceptual closure plan of the mine.

The open pit and No.7 dam also impact on the visual quality of the area. The open pit is however considered a

tourist attraction, with approximately 30 000 tourists visiting the mine annually.

7.4.1.12 Cultural Heritage

Two heritage studies were done for surrounding area in 2011 by PGS Heritage and Grave Relocation

Consultants. Two surveys were done, one survey at the mine and one survey surrounding CDM. The survey

surrounding CDM comprises of a list with 91 sites. The survey at the mine comprise of a list with 250 sites.

In the dating of these sites the date limitations of the available aerial photographs and topographical maps were

used to define six different age groups. In the report each of these groups has been given a specific colour and

these colour markers used to indicate in which age group the specific site belongs. The age groups with

associated colours are as follows:

• Younger than 50 years (blue) – not shown in the table below

• Older than 50 years but younger than 72 years (yellow)

• Older than 72 years but younger than 80 years (orange)

• Older than 80 years but younger than 100 years (red)

• Older than 100 years (crossed red)

• Unknown (purple)

A historic overview is summarised in

Table 5. Refer to Table 6 for a summary of the sites surveyed at the CDM area. Refer to Figure 4 for locality of

these sites.


Table 5: Historic overview

DATE DESCRIPTION

2.5 million to

250,000 years

ago

The Earlier Stone Age is the first and oldest phase identified in South Africa’s archaeological history

and comprises two technological phases. The earliest of these technological phases is known as

Oldowan which is associated with crude flakes and hammer stones and dates to approximately 2

million years ago. The second technological phase in the Earlier Stone Age of Southern Africa is

known as the Acheulian and comprises more refined and better made stone artefacts such as the

cleaver and bifacial hand axe. The Acheulian phase dates back to approximately 1.5 million years ago.

Artefacts associated with the Earlier Stone Age are known to be located in riverbeds and eroded areas

in the wider vicinity of the study area. An important known site from this period is located on the farm

Kaalfontein 513-JR some 9km south of Cullinan. It was discovered when a road was constructed, and

comprises a living and manufacturing site. The stone artefacts observed here included cleavers and

hand axes (Bohlweki – SSI Environmental, 2008).

250,000 to

40,000 years

ago

The Middle Stone Age is the second oldest phase identified in South Africa’s archaeological history. It

is associated with flakes, points and blades manufactured by means of the prepared core technique.

40,000 years

ago to the

historic past

The Later Stone Age is the third phase identified in South Africa’s archaeological history. It is

associated with an abundance of very small stone artefacts known as microliths. Later Stone Age sites

are known from the areas north of the Magaliesberg as well

300–600 AD

During the construction of a dwelling on the farm Derdepoort 320-JR, archaeological material

(including decorated potsherds) associated with the Early Iron Age was uncovered. While the pottery

showed affinities with Dambwa pottery (from Zambia), Broederstroom pottery as well as Matola

pottery, it was felt that it was most likely associated with Matola (Nienaber et al, 1997).

1610–1636 The occupation of the settlement known as KwaManyamana by the Southern Ndebele of Musi. The

site is located in the vicinity of Bon Accord Dam (Van Vuuren, 1992).

c. 1636

After the death of Musi a succession dispute occurred between his two sons, Manala and Ndzundza.

It resulted in Ndzundza and his followers leaving KwaManyamana and moving in an eastward direction

past present day Cullinan, present day Bronkhorstspruit, present day Witbank, present day Middleburg

to eventually settle at KwaSimkhulu on the Steelpoort River (Van Vuuren, 1992). On their journey

eastward Ndzundza and his followers were attacked twice by the followers of Manala. One of these

skirmishes took place on the farm Brandbach 471-JR, roughly 8kms east of Cullinan.

1677–1717

After making peace with his brother at KoQoli, Manala and his followers settled in an area south-east

of Pretoria known as Ezothsaneni. Their settlement area was east of Pretoria between the present

N14 highway and the Delmas road (R50) and was situated approximately 20km south of Cullinan (Van

Vuuren, 1992).

1717-1747

During this time the Manala Ndebele stayed in a place known as Embilaneni (the place of Dassies).

The new settlement spread over the Bronberg mountains east of Pretoria and included an area that

can be defined by a number of present-day farms including Rietfontein 395-JR, Tweedracht 516-JR,

Tiegerpoort 371-JR, Kleinfontein 368-JR, Mooiplaats 367-JR, Donkerhoek 365-JR and Zwavelpoort

373-JR (Van Vuuren, 1992). It is apparent that the Embilaneni area extended further to the west than

Ezotshaneni, and at its closest point was approximately 12km south-west of Cullinan.

1747–c. 1825 During this time the Manala Ndebele stayed in a place known as KoNonduna (the place of the King)

(Van Vuuren, 1992). Located further west of Embilaneni, it was directly south of present-day Mamelodi.

1827–1832 Mzilikazi's Matabele settled north of the Magaliesberg (Bergh, 1999).


DATE DESCRIPTION

1841-1850 The first white people started arriving in the general vicinity of the study area and the first farms were

proclaimed (Bergh, 1999).

16 November

1855 Establishment of the town of Pretoria (Bergh, 1999).

1882

In this year the so-called Mapoch war took place between the Zuid-Afrikaansche Republiek and the

Ndzundza Ndebele. The latter had resided at a place known as KoNomtjarhelo (in the present day

Roossenekal area) since 1822. The Ndebele were defeated by the republican forces and were

removed from their ancestral land. Many settled on white-owned farms as farm labourers while others

moved to farms of the Manala Ndebele. In 1897 the Ndzundza Ndebele was indicated to be staying

on 18 farms east, south-east and south of Pretoria, including Boschkop (roughly 17kms south-west of

Cullinan) and Tygerpoort (roughly 22kms south-west of Cullinan).

Mid 1890s Percival Tracey started prospecting for diamonds on the boundary between the farms Beynespoort

and Elandsfontein (Helme, 1974). This area is approximately 3.5km from present-day Cullinan.

Late 1890s

Thomas Major Cullinan started prospecting for diamonds in the Franspoort area, some 10km west of

present-day Cullinan. During this time he is said to have heard from Tracey that a significant diamond-

bearing pipe was waiting to be discovered on the farm Elandsfontein (Simons, 2004). Cullinan sent a

messenger to the owner of Elandsfontein, Willem Prinsloo. He flatly refused any prospecting on his

farm. A couple of days later Cullinan sent another messenger who was told that in future messengers

will be shot.

August 1898 After Willem Prinsloo passed away in August 1898, the farm was inherited by his unmarried daughter

Maria Elizabetha Prinsloo. When Cullinan requested her permission to prospect she also refused.

1899

By this time large quantities of alluvial diamonds were being found on the boundary between the farms

Beynespoort 335-JR and Minnaar 292-JR. This area is roughly 8km north-west of present-day

Cullinan.

1899–1902

The South African War lasted for three long years and wrought havoc on the entire country and its

people. This impact was also felt by the Prinsloo family, the owners of Elandsfontein. While it is not

exactly known what the circumstances of Maria Elizabetha Prinsloo during the war was she was likely

forced to abandon the farm and placed in a concentration camp (as were thousands of other Boer

women and children and Black people). What is known is that the farm was destroyed in accordance

with the so-called “scorched earth” policy of Lord Kitchener.


DATE DESCRIPTION

8–12 June 1902

One of the most significant events of the South African War in the vicinity of the study area was the

Battle of Diamond Hill which took place between 8 and 12 June 1900. After the occupation of Pretoria

on 5 June 1900, the Boer forces totalling nearly 4,000 men under the overall command of General

Louis Botha ensconced themselves on the Magaliesberg Mountain to the east of Pretoria. Their

positions ranged from Zwavelpoort and Tygerpoort in the south to Doornpoort in the north. Lord

Roberts‟ force of nearly 20,000 men left Pretoria on 7 June 1900 and advanced on the Boer position.

On 8 June 1900 General French attempted to break through what he believed was the Boer right flank

and attacked the Boer positions on the farms Kameelfontein and Krokodilspruit. On 11 June 1900

fierce skirmishes took place between the forces of General French and these Boer forces under

General Koos de la Rey. In the end the battle was decided on another front when the strategic position

known as Diamond Hill (south-east of Pienaarspoort) was occupied by the British forces on 12 June

1900. On the evening of the same day General Botha instructed him men to retreat eastward along

the railway line (History of the War in South Africa, 1908). The Boer positions on the farms

Kameelfontein and Krokodilspruit and the scene of the subsequent skirmishes are approximately 9kms

north-west of Cullinan.

31 May 1902–

17 November

1902

After peace was declared on 31 May 1902, Cullinan approached the Prinsloo family again and offered

an amount of £150,000 payable over a period of time for the right to prospect on the farm. However,

due to the negative effect of the war on the family they rather offered to sell the farm directly to Cullinan

with immediate effect. A sum of £52,000 was agreed upon and the Prinsloo family asked this to be

paid over in gold sovereigns (Helme, 1974; Simons, 2004). On 7 November 1902 a 699 hectare portion

of the farm was transferred from the Prinsloo family to the Premier Syndicate Limited. This deeds

transfer was registered on 17 November 1902.

Incidentally, the company Premier Syndicate Limited was later changed to the Premier (Transvaal)

Diamond Mining Company Limited.

November

1902–31

December 1902

Work commenced immediately after the acquisition of the farm Elandsfontein by Cullinan's company.

The first step was to sink boreholes and in that way establish the extent of the diamond-bearing pipe.

Subsequently, excavation work commenced with picks and shovels on seven prospecting pits along

the location of the pipe as revealed by the boreholes (Lincoln, n.d.). By the end of the year CDM

excavations had reached an average depth of 9m and diamonds to the value of 187 carats had been

recovered.

April 1903

CDM’s first steam-driven gear, known as No. 1 Gear, was brought into operation (Lincoln, n.d.). During

the same time the first general manager for the Premier Mine was appointed. William McHardy and

his family arrived a few weeks later by ox-wagon from Kimberley. On their arrival they could not find

any habitable house on the mining property and had to live in tents. The McHardy house was

completed shortly thereafter and became the first permanent house in Cullinan (Lincoln, n.d.).

Late 1903

As a result of increases in profits and the steady growth of CDM, CDM village adjoining it also started

to develop. At first the accommodation here comprised corrugated iron dwellings, tents and in some

cases mud brick rondavels (Lincoln, n.d.). By this time CDM had approximately 57 white employees

and 308 black employees (Simons, 2004). Sometime during the end of 1903 or early 1904 a mine

compound was constructed. The compound was designed in accordance with the ones found on the

Kimberley diamond mines.

October 1904

As the result of amongst other things the erection of an almost two metre high, double row fence

around CDM property, CDM reported a decrease in diamond theft and a resulting increase in diamond

yield. By 31 October 1904 diamonds totalling 750,000 carats had been retrieved by CDM (Simons,

2004).


DATE DESCRIPTION

Late 1904

During the same time CDM also looked at expanding its property. One reason for this was that CDM

needed a constant supply of water, both to operate CDM but also to fill the increasing need from its

employees. As a result the farm Louwsbaken as well as the second portion of Elandsfontein (both well

supplied by natural springs and streams) were purchased (Helme, 1974).

January 1905

A number of infrastructural developments took place which attest to the development of CDM. For

example, a second steam-driven gear known as No. 2 Gear was brought into operation (Lincoln, n.d.).

The Director’s House had also now been completed and work had commenced on the white mine

worker cottages along Oak Avenue (Lincoln, n.d.). During the same year CDM’s recreation club was

completed and a hotel built (Lincoln, n.d.).

25 January

1905

On this day a 3,106 metric carat diamond was discovered by Fred Wells along the side wall of the pit

(Helme, 1974). Later to be known as the Cullinan Diamond, it was bought by the Transvaal

Government and presented to Kind Edward VII. The diamond was cut by Joseph Asscher of

Amsterdam into nine major stones. The two largest ones became part of the Crown Jewels, while the

remainder were given to Asscher as payment for his services. King Edward VII acquired one of these

and the remaining six were bought by the people of South Africa and presented to Queen Mary

(Lincoln, n.d.).

1906

By this time as much as 1,000,000 carats of diamonds had been recovered at Premier Mine (Lincoln,

n.d.). General offices were built for CDM in the vicinity of No. 1 Gear. During the same time CDM also

constructed a railway line from Cullinan to Rayton and built a station at Rayton (Lincoln, n.d.). Due to

the ever increasing demand for water, a new dam and pumping station were also constructed on the

Wilge River, some 37km south-east of Cullinan (Lincoln, n.d.).

1907

CDM’s first hospital for white staff was built. It was a 26 bed facility at the time (Lincoln, n.d.). During

the same time No. 3 Gear was completed, which at the time was the biggest diamond washing

machine in the world (Lincoln, n.d.). It was followed shortly thereafter by the construction of the No. 4

Gear. By this time CDM had no fewer than 500 permanent white employees and had constructed

some 250 permanent homes (Lincoln, n.d.).

1908

The town’s first church was built in this year. It was a Presbyterian Church (Lincoln, n.d.). At the same

time CDM had some 15,000 black employees (Lincoln, n.d.). They were all housed in the compounds

located on the south-eastern end of CDM pit.

1911 The first English school was completed in this year. Before this time schooling was undertaken in the

Presbyterian Church (Lincoln, n.d.).

1912 CDM’s new recreation club was completed (Lincoln, n.d.). At the same time CDM workings had

reached a depth of roughly 100m (Lincoln, n.d.).

1914-1918 During the Great War (also known as the First World War) CDM was closed. A number of CDM’s

employees and residents of Cullinan fought in the war (Lincoln, n.d.).

1918 At the end of the war CDM re-opened again. During this time the residents of Cullinan suffered severely

due to the influenza pandemic, with many families affected (Lincoln, n.d.).

1921 CDM’s first swimming pool as well as a garage was built. The latter was situated adjacent to the

Premier Hotel (Lincoln, n.d.).

1922 The worldwide economic downturn known as the Great Depression resulted in decreasing worldwide

demand for diamonds. This also led to the Premier Mine reducing its output (Lincoln, n.d.).

1926 The town’s first Afrikaans school was built (Lincoln, n.d.).

1932 CDM closed down and the town of Cullinan became a virtual ghost town (Lincoln, n.d.).


DATE DESCRIPTION

1939-1945

During the Second World War the Union Defence Force decided to establish a number of training and

mobilisation camps in and around Cullinan. The town was occupied by thousands of soldiers belonging

to regiments such as the Rand Light Infantry, Central Army Depot, Imperial Light Horse, the Kaffrairan

Rifles and the Second Royal Durban Light Infantry (Lincoln, 2006).

After 1945

Due to technological advances made during the war as well as the increasing demand for industrial

diamonds, CDM re-opened. Mining operations became underground, and required infrastructure such

as a winder house and headgear were constructed. The compounds were also modernised (Lincoln,

n.d.).

Table 6: Heritage buildings within the mine area

SITE BUILDING NAME DESCRIPTION

Precinct 1

Site 1 Surface workshops Several large corrugated iron sheds with entrances from gable ends facing north.

Site 2 Projects Offices Single storey gabled building. Entered from both the north and south (from a small

atrium).

Site 3 Planning offices One and a half volume gabled corrugated iron shed with main entrance along the western

gable end.

Site 5 Toilet addition Later addition to Building 3 along its eastern elevation.

Site 8 Ablution facility Small single storey red face brick building with gable and single entrance.

Site

10 Offices

Long east-west single storey building with semi detached structure and gable roof.

Entrances are from the covered stoep along its northern façade.

Site

11 Mining office Large gabled corrugated iron building.

Site

13 Change house

Small building almost the size of a single room added later to an existing building:

constructed with large compacted cement blocks and painted without plastering.

Site

16 Change house Red face brick building with decorative end gables and corbelling at the corners.

Site

17 Change house Red face brick building with decorative end gables and corbelling at the corners.

Site

22 Old wash bay

Small open pit/well used for washing boots – with steel frame supporting a light

corrugated iron sheet roof.

Site

24

Electric transformer

rooms

Plastered brick building with low pitched sheet iron roof and adjacent steel frame open

shelter with corrugated iron roof.

Site

25

Compressor storage

facility Large two and a half volume steel frame shed with IBR cladding.

Site

32 Training facility Gabled steel frame shed with corrugated iron cladding.

Site

33 Training facility

Gabled shed with timber frame and corrugated iron cladding and ventilation opening

along the ridging. Several rooms have been added to the sides.

Precinct 2

Site 1 Ablution facility Small unplastered brick building with gable roof

Site 2 Tea room Small unplastered brick building with gable roof

Site 8 Transfer shoot Steel frame structure with IBR cladding protecting connecting sections of conveyor belts.



Site

22 Hoist room workshop

Steel frame building clad with corrugated iron. Sections of the cladding may have been

redone.

Site

28 Old store

Green corrugated iron building which is probably one of the oldest buildings in the

precinct. It is in a fairly pristine condition. The structure is used as storage facility where

redundant office equipment is stored before being recycled. The aerial photographs

depict the site on the 1961 image but not on the 1939 one. As the building is much older

than the suggested 72 years, the indication is that it was relocated to its present position

from somewhere else after 1939 and before 1961.

Site

30 Old foundation The remains of a previous building. Only the foundations have remained intact.

Site

32 Primary crusher

This the most significant and largest shed type structure on the site and forms the core

of the processing plant.

Site

34 Head gear

This is the most significant landmark and engineering structure on the site and is the

highest structure towering over all the mining structures. Sections may have been

replaced over time.

Site

35 Old Conveyor sheds

These are some of the oldest remaining sheds covering sections of the conveyor system

near the entrance to CDM. Of special significance is the remaining conifer tree in front of

the buildings.

Precinct 3

Site 1 Safety and

environmental office

Single storey red-face brick building with corrugated iron roof. The building has been

altered and extended several times during its history.

Site 4 PPE Issue Single storey timber frame building with pitched roof and corrugated iron clad walls.

Site 5 Paint store and tea

room

Elongated storage facility constructed with red face bricks and with a flat corrugated iron

roof.

Site 7 Issuing store Exceptional storage facility constructed with yellow bricks, interior steel frame with IBR

sheeting roof. Monitor roof structure on top along the entire ridging.

Site 9 Mine store offices

Exceptional red face brick building with white washed plinth and steel frame windows.

Projecting red face brick pilasters occur at equal distances between the windows. The

building has a flat corrugated iron roof.

Site

11 Small red brick store

Exceptional small red face brick building with pitched corrugated iron roof, reinforced

concrete superstructure and heavy duty door hinges.

Site

15

Old corrugated iron

shed

Single storey pitched roof shed with steel frame windows, timber frame structure and old

corrugated iron sheet cladding.

Site

16 Open shed Infill single storey steel frame shed with IBR sheet cladding.

Site

17

Double volume open

shed Double volume steel frame shed with open gable-end, clad with corrugated iron.

Site

18 Geotech shed One and a half volume steel frame sheds with pitched roofs and corrugated iron cladding.

Site

19 Geotech shed

One and a half volume building with corrugated iron cladding. Of exceptional significance

are the wooden sash windows that have remained intact.

Site

20

Control and

instrumentation (C &

I) office

Plastered brick building with pitched corrugated iron roof and steel frame windows. A

lean-to was added at the back.



Precinct 4

Site 4 Substation control

room

Site

13 Concrete bases Foundations of shoot that had been removed.

Site

15 Thickener MCC

Site

16

Original shoot for

recycling tailings Older of the two structures

Precinct 5

Site 3 Old plant offices Single storey hipped roof building with unplastered brick walls, corrugated iron roof and

steel frame windows.

Site 4 Foundations Buildings were demolished here with only the foundations remaining. The open space

created by the demolition is used as storage space.

Site 6 Offices

Building consisting of two gables but with a single floor plan. It is located on the same

spot as original workshops which are older than 80 years. It is not presently certain

whether the original workshops were demolished, or whether they were retained but

modified to the building’s present appearance.

Site 8 Main plant mec sec

DMS workshop

Three storey building with pitched roof and monitor addition along the entire ridging. The

unplastered brick was white washed. The building is depicted on available cartographic

material as a „boiler shop‟.

Site 9 Recrush plant 4-5 storey corrugated iron shed building with conveyor belt entering from the south

across the road.

Site

11

Office of person in

charge of belt

storage

Small single space red brick building with single door and flat roof.

Site

16

Storage building of

brick

Double volume, face brick building. Some of the structure’s walls have been white

washed

Site

17

Old HMS thickener

pump house One and a half volume steel frame building with corrugated iron sheet cladding.

Site

18 Conveyor belt Old belt runs from left to right and is located at the bottom of all other belts.

Site

19 Old finds foundation Large concrete blocks and steel reinforcing are the only remains of the building.

Site

20 Old cones MCC

Single storey red-face brick building with pitched corrugated iron roof. It is elevated above

ground on concrete columns.

Site

21

Main plant thickener

pump house One and half volume pitched roof, steel frame structure with corrugated iron cladding.

Site

22 DMS

Diagonal conveyor structure covered with a corrugated iron structure along the entire

conveyor section.

Site

23 Transfer tower Seven storey vertical structures constructed with steel and clad with corrugated iron.

Site

24 Prep plant Multi-storey structure of steel with IBR cladding.



Precinct 6

Site 2 Nr. 7 Dam

Substation Small red face brick building with pitched roof.

Site 3 Demolished pump

house Only the concrete base and some mechanical equipment are left.

Site 4 Demolished

concrete bases Cluster of foundations

Site 5 Old incline shaft

entrance

Engineering structure partially constructed with reinforced concrete, red face bricks and

exposed steel. The shaft is known to have been excavated after the Second World War

when CDM re-opened with underground workings (Lincoln, n.d.).

Site 6 Large water

reservoir Reinforced concrete structure which is now redundant.

Site 7 Foundations Concrete foundations

Site

20 Red area

Precinct 7

Site 1 Old offices Old corrugated iron, double volume building with small steel frame windows typical of the

period since the 1920s. The building is known as the „Commando Offices‟.

Site 2 Old offices Double volume red face brick building with saddle roof and steel frame windows.

Site 3 Workshop Red face brick building with the same architectural vocabulary as the first two buildings,

with large concrete lintels above doors.

Site 9 Oak avenue office The dwellings are certainly older than 80 years, and may very well be older than 100

years as well.

Site

16

Security storage

facility Plastered brick building with flat cast concrete roof.

Site

24 Head office building

Face brick building with whitewashed walls. Designed around a central atrium with

covered stoeps around the atrium. The original red face bricks of the veranda columns

were left unpainted. A new annex was added at the back of the building and is used as

a conference centre. Special attention must be given to the preservation of the old

entrance gate. The gate has become almost redundant as it has been isolated and has

become a curiosity and monumental feature.

Site

26 Carport Iron frame corrugated iron carport with closed sides clad with corrugated iron.

Site

29 Old dwelling

Timber frame corrugated iron dwelling with front veranda. Building has been renovated

and used for commercial/official purposes. The dwelling is certainly older than 80 years.

However, according to historian John Lincoln the dwelling was thought to have been built

during the very early stages of CDM’s history. As a result it very well be older than 100

years as well (Lincoln, 2006).

Site

30

Old corrugated iron

dwelling

Historic timber frame corrugated dwelling now renovated for commercial/official use. The

dwelling is certainly older than 80 years. However, according to historian John Lincoln

the dwelling was thought to have been built during the very early stages of CDM’s history.

As a result it very well be older than 100 years as well (Lincoln, 2006).



Site

31

Old corrugated iron

dwelling

Redundant timber frame corrugated iron dwelling. It is sometimes used as a bar. Several

old outbuildings still occur on the site at the back of the dwelling. The dwelling is certainly

older than 80 years. However, according to historian John Lincoln the dwelling was

thought to have been built during the very early stages of CDM’s history. As a result it

very well be older than 100 years as well (Lincoln, 2006).

Site

32

Old corrugated iron

dwelling

Redundant dwelling with outbuilding comprising a timber frame corrugated iron garage.

The dwelling is certainly older than 80 years. However, according to historian John

Lincoln the dwelling was thought to have been built during the very early stages of CDM’s

history. As a result it very well be older than 100 years as well (Lincoln, 2006).

Site

39 Ablution building Small flat roof corrugated iron building.

Site

40 Church

Small Presbyterian church. Foundation stone was laid by Thomas Cullinan on 4 July

1908.

Site

41 Dwelling

Single storey red face brick dwelling with wide veranda. The dwelling is at least older

than 80 years, but may likely be as old as the church.

Site

42

Outbuilding of

dwelling Small flat roof face brick outbuilding on the same site as the red brick dwelling.

Precinct 8

Site 1 Offices Continuation of oak Avenue semi-detached dwellings later altered into offices. The

complex was erected around 1924-1926 and was constructed with yellow face bricks.

Site 2 Ablution facility Flat roof red brick support building with well-defined concrete lintels.

Site 6 Storage facility with

transformer house

Cluster of small buildings comprising a steel frame corrugated iron shed with gabled red

brick transformer room.

Site 8 Offices and storage

Secluded series of semi-detached dwellings that have been altered into offices and

support structures. The complex was constructed with dressed sandstone and altered

with red face bricks over time. Some sections of the buildings have been plastered and

white washed.

Site

11

Semi detached

dwelling

Single storey dwelling constructed with stone. The building has a sheet iron roof. The

dwelling is certainly older than 80 years, but may be older than 100 years as well.

Site

15 Ablution facility Outside ablution facility.

Site

16

Building does not

exist anymore.

Site

17 Outbuilding

Flat roofed plastered brick support building with ablution and room for the domestic

worker.

Site

18 Outbuilding Single roomed outbuilding constructed with plastered brick.

Site

19 Dwelling

Single storey timber frame corrugated iron building that has been renovated and is still

in use. The dwelling is certainly older than 80 years, but may be older than 100 years as

well.

Site

20 Dwelling Dwelling erected during the period 1960-1980, with saddle roof and plastered brick walls.



Site

21 Garage Face brick flat roof outbuilding.

Site

25 Dwelling

Single storey old timber frame corrugated iron dwelling now used as restaurant and

kiosk. The building is certainly older than 80 years, but may be older than 100 years as

well.

Site

27 Dwelling

Single storey old timber frame corrugated iron dwelling now used as tourism offices and

information centre. It is certainly older than 80 years, but may be older than 100 years

as well.

Site

28 McHardy House

Single storey timber frame corrugated iron dwelling, now used as house museum. The

building was constructed in 1903 as the residence for the first General Manager of CDM,

William McHardy (Lincoln, 2006).

Site

29 Outbuilding

Dilapidated timber frame corrugated iron building without use. The building is certainly

older than 80 years, but may be older than 100 years as well.

Site

30

Timber frame

corrugated iron

garage

Timber frame corrugated iron garage and storage facility at back of McHardy House.

Site

32 Outbuilding Red face brick domestic worker’s room with flat roof.

Site

33 Double garage Face brick building with a flat roof.

Site

34 Oak house

Large face brick dwelling later used as guest house. One of the exceptional dwellings

constructed with dressed stone masonry. The house was built for CDM’s resident

director, Ross Frames, in c. 1904.

Site

35 Transformer building Red face brick building with flat corrugated iron roof.

Site

36 Old shed

Historic shed now used as museum, information centre and auditorium for tourists.

Building has a steel frame structure with corrugated iron cladding some places replaced

with IBR sheeting. While the building is evidently old, it is not depicted on the 1961 aerial

photograph. This suggests that an existing building was relocated from another place to

this position after 1961.

Site

38 Garages Red face brick building with steel frame and corrugated iron hinged garage doors.

Site

40 Garages Red face brick building with steel frame and corrugated iron hinged garage doors.

Site

41

Commercial

buildings

Original old 1905 semi-detached dwelling now used as shops and restaurants for

commercial purposes. Original dwellings were constructed from dressed sandstone with

corrugated iron roofs. The roofs have been redone and guttering and downpipes have

been replaced.

Site

42

Ablution facility and

coal room Red brick structure with flat corrugated iron roof with outdoor toilet and storage facility

Site

43



Site

44





Site

46



Site

47



Site

48



Site

50

Commercial

buildings

Original old 1905 semi-detached dwelling now used as shops and restaurants for

commercial purposes. Original dwellings were constructed from dressed sandstone with

corrugated iron roofs. The roofs have been redone and guttering and downpipes have

been replaced.

The project, however, will not impact on any of the outlined heritage sites. However there are possibilities that

heritage finds could be present. Figure 4 is a display of the Heritage buildings within the plan area.

Figure 4: Heritage Buildings at CDM

7.4.1.13 Regional socio-economic structure

The local Municipal areas are influenced by the demographic and socio-economic trends of areas such as

Tshwane, Ekurhuleni and Johannesburg Metropolitan Municipality. The local Municipal area has been

described as predominantly rural in nature, lacking services, with high unemployment, high levels of poverty,

but large areas of potential agricultural, recreation and tourism development.


According to information provided by IDP for 2017-2021, the total population was 3 million in 2013 and has since

increased to over 3.3 million in 2017. For the period 2013-2017, the population grew by 298 117. The distribution

as per the different population groups over the 2013- 2017 follows: 77% African; 19% White, 4% Asian and

Coloured.

The Cullinan area present the following demographic profile:

• A largely poor community with a very large (70%) poor majority;

• The age distribution represents a population with a very large number of young people between the ages

of 19 and 59;

• The number of females to male is almost equal;

• The education levels in the Municipality are very poor with a very few people having passed matric and

gained tertiary education; and

• The income levels in the Municipality are very low with the majority of people living below an income of

R1 200 per month.

The Emergency Medical Services (EMS) is being coordinated by the Gauteng Department of Health. The station

is located on Dewagensdrift farm (plot 79). The station services the southern part of the municipal area and the

areas around Steve Bikoville are being serviced by the main Tshwane Emergency Medical Services.

The main form of Public transport is being provided through taxis and buses within the municipal area.

As a predominantly rural setting, the area has a significant, although somewhat underdeveloped, agricultural

base. During 1996, agricultural employment was estimated at 1548, a figure that increased by 50% by 2001.

The key strength of the Cullinan area is its central location and therefore access to markets as well as distribution

points such as Johannesburg International Airport.

The area can be considered a diamond-mining hub and Cullinan owes its existence to the discovery of the

world’s largest cut diamond. The existence of the Cullinan Diamond Mine and its history has served as an

important catalyst for tourism development in this area. Relative isolation as far as the pressures of urbanization

is concerned as well as its significant recreation, heritage and conservation assets is seen to contribute to its

tourism potential.

7.4.1 Description of the current land uses

Land use and development at the site

The project site has a footprint of 32 ha. It consists of different infrastructures that includes structures of steel,

rubber and concrete that support the mine’s Beneficiation Process. These infrastructures include plants,

conveyers, transformers and other plant related infrastructure. The land use for the site falls within the Built up

and Mine land use classes. Refer to Figure 5 below for an indication of the current land use for the site.


Figure 5: Land Use Map


7.4.2 Description of specific environmental features and infrastructure on the site.

No specific environmental features are located within the 32 ha area where the existing plant is located. In 2013

an asbestos inventory was compiled by the mine to identify the asbestos containing structures at the mine. The

table below provided for the infrastructure at the mine which contains asbestos.

Table 7: Asbestos containing structures

Location Type of structure Area (m2) Covered (Y/N)

SHE Offices & Drawing office Roof 761 Partially

White house Roof 627 No

Management office Roof 1785 Capped

Weighbridge office Roof 12 Yes

Old Auditors offices Roof 83 No

Boilermaker training room Roof 263 Partially

Survey shade Roof (stoep area) 212 No

NUM offices Roof 98 No

Oom Koos’s offices Roof 55 No

Shaft Maintenance offices Roof 72 No

Projects offices Roof 170 Partially

Back of Spaza Roof 114 No

C&I communication office Roof 91 No

Old Plant Offices Roof 599 No

Some of the old sewage pipes are also made of asbestos but are not available on plans. Please see the map

on below for the location of above mentioned structures.

Figure 6: Location of asbestos containing structures


7.4.3 Environmental and current land use map.

Figure 7: Environmental and Current Land Use Map


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

A detailed risk assessment has been undertaken, as contained in Annexure D1. The following table contains all the potential impacts identified for the activities described in the initial site layout.

NO. ASPECTS AFFECTED

ACTIVITY

whether listed or not

listed

POTENTIAL IMPACT

PHASE

in which impact is anticipated

SIZE AND SCALE

of disturbance

SIGNIFICANCE

if not mitigated

MITIGATION TYPE

(modify, remedy, control, or

stop) through e.g. noise

control measures)

Impact description

Re

ve

rsib

ilit

y

Irre

pla

cea

ble

lo

ss

Pro

ba

bil

ity

Ma

gn

itu

de

Sig

nif

ican

ce

1 Air Quality Activity 1 - 26

Impact description: Dust generation from internal access roads

and general demolition and crushing activities.

Extent of impact: Site and immediate surroundings.

Duration of impact: Lifecycle of the project.

Re

ve

rsib

le

Lo

w D

eg

ree

Decommissioning Phase Within the 32 ha 4 2

Me

diu

m

Control


Impact description: Unpleasant odours generated from poorly

maintained/ serviced portable chemical toilets and asbestos

related emissions from decommissioning of buildings and

pipelines.



Re

ve

rsib

le

Lo

w D

eg

ree


Me

diu

m

Control

3 Air Quality Activity 24

Impact description: Stored remediation chemicals

(biodegradable) and hazardous wastes may produce noxious

or irritating odours.



Re

ve

rsib

le

Lo

w D

eg

ree


Me

diu

m

Control

4 Ecology Activity 1 – 26

Impact description: Impacts on floral biodiversity due to alien

floral species invasion/proliferation.

Extent of impact: Site and surrounding area

Duration of impact Lifecycle of the project Pa

rtia

lly R

eve

rsib

le

Lo

w D

eg

ree


Me

diu

m

Control

5 Ecology Activity 1 - 26

Impact description: Destruction of habitat may impact on floral

biodiversity within the CDM Beneficiation Plant area.


Duration of impact Lifecycle of the project

Re

ve

rsib

le

Lo

w D

eg

ree


Lo

w

Control



ACTIVITY


listed

POTENTIAL IMPACT

PHASE


SIZE AND SCALE

of disturbance

SIGNIFICANCE

if not mitigated

MITIGATION TYPE



control measures)

Impact description

Re

ve

rsib

ilit

y

Irre

pla

cea

ble

lo

ss

Pro

ba

bil

ity

Ma

gn

itu

de

Sig

nif

ican

ce

6 Ecology Activity1 – 26

Impact description: General disturbance to overall floral

biodiversity due to dust generation, indiscriminate fires and

ineffective monitoring.



Re

ve

rsib

le

Lo

w D

eg

ree


Me

diu

m

Control

7 Groundwater Activity 1 – 26

Impact description: Groundwater may become contaminated

by hydrocarbons leaking from equipment and machinery,

stored materials at the contractor support area and temporarily

stockpiled hazardous waste.



Pa

rtia

lly R

eve

rsib

le

Lo

w D

eg

ree


Me

diu

m

Control

8 Noise Activity 1 – 26

Impact description: Increase in ambient noise levels by

demolition related machinery.

Increase in ambient noise levels by demolition activities

associated with the dismantling of structures.



Re

ve

rsib

le

Lo

w D

eg

ree


Lo

w

Control

9 Noise Activity 25


vehicles removing material and waste from the site.

Extent of impact: Site and surrounding area.

Duration of impact: Lasting one month to a year R

eve

rsib

le

Lo

w D

eg

ree


Lo

w

Control

10 Soil and Land Capability Activity 1 - 24

Impact description: Removal of potentially contaminated

material.

Extent of impact: Site

Duration of impact: Lifecycle of the project

Re

ve

rsib

le

Lo

w D

eg

ree


Me

diu

m

Control



ACTIVITY


listed

POTENTIAL IMPACT

PHASE


SIZE AND SCALE

of disturbance

SIGNIFICANCE

if not mitigated

MITIGATION TYPE



control measures)

Impact description

Re

ve

rsib

ilit

y

Irre

pla

cea

ble

lo

ss

Pro

ba

bil

ity

Ma

gn

itu

de

Sig

nif

ican

ce

11 Soil and Land Capability Activity 1 – 26

Impact description: Frequent movement of heavy machinery

may lead to the compaction of valuable soils.



Re

ve

rsib

le

Lo

w D

eg

ree


Me

diu

m

Control


Impact description: Disturbance and removal of soils may lead

to erosional processes;



Re

ve

rsib

le

Lo

w D

eg

ree


Me

diu

m

Control


Impact description: Soils may become contaminated by

hydrocarbons leaking from construction equipment and

machinery; stored materials at the contractor support area,

temporarily stockpiled hazardous waste



Re

ve

rsib

le

Lo

w D

eg

ree


Me

diu

m

Control

14 Visual Activity 1 – 26

Impact description: The visual environment will change once

the infrastructure has been decommissioned and the buildings

crushed/broken.



Pa

rtia

lly R

eve

rsib

le

Lo

w D

eg

ree


Me

diu

m

Control

15 Heritage and Cultural Activity 1 - 23

Impact description: Decommissioning of the beneficiation plant

and crushing of building structures could result in a loss of

heritage resources.

Extent of impact: Site.


Pa

rtia

lly R

eve

rsib

le

Lo

w D

eg

ree


Me

diu

m

Control



ACTIVITY


listed

POTENTIAL IMPACT

PHASE


SIZE AND SCALE

of disturbance

SIGNIFICANCE

if not mitigated

MITIGATION TYPE



control measures)

Impact description

Re

ve

rsib

ilit

y

Irre

pla

cea

ble

lo

ss

Pro

ba

bil

ity

Ma

gn

itu

de

Sig

nif

ican

ce

16 Socio-economic Activity 1 – 26

Impact description: Creation of Employment



Irre

ve

rsib

le

Lo

w D

eg

ree

Decommissioning Phase Within the 32 ha Positive Control

17 Traffic Activity 25

Impact description: Decrease in general condition of roads

and increased safety risk to third party road users due to heavy

vehicle traffic on roads.



Re

ve

rsib

le

Lo

w D

eg

ree


Hig

h

Control


7.6 Methodology used in determining and ranking the nature, significance,

consequences, extent, duration and probability of potential environmental

impacts and risks.

The environmental risk of any aspect is determined by a combination of parameters associated with the

impact. Each parameter connects the physical characteristics of an impact to a quantifiable value to rate the

environmental risk.

Impact assessments should be conducted based on a methodology that includes the following:

• Clear processes for impact identification, predication and evaluation;

• Specification of the impact identification techniques;

• Criteria to evaluate the significance of impacts;

• Design of mitigation measures to lessen impacts;

• Definition of the different types of impacts (indirect, direct or cumulative); and

• Specification of uncertainties.

After all impacts have been identified, the nature and scale of each impact can be predicted. The impact

prediction will take into account physical, biological, socio-economic and cultural information and will then

estimate the likely parameters and characteristics of the impacts. The impact prediction will aim to provide a

basis from which the significance of each impact can be determined and appropriate mitigation measures

can be developed.

The risk assessment methodology is based on defining and understanding the three basic components of

the risk, i.e. the source of the risk, the pathway and the target that experiences the risk (receptor). Refer to

Figure 8 below for a model representing the above principle (as contained in the DWA’s Best Practice

Guideline: G4 – Impact Prediction).

Figure 8: Impact prediction model

Table 8 below indicate the methodology to be used in order to assess the Probability and Magnitude of the

impact, respectively, and Error! Reference source not found. provides the Risk Matrix that will be used to

plot the Probability against the Magnitude in order to determine the Severity of the impact.


Table 8: Determination of Probability of impact

SCORE FREQUENCY OF ASPECT /

UNWANTED EVENT

AVAILABILITY OF

PATHWAY FROM THE

SOURCE TO THE

RECEPTOR

AVAILABILITY OF

RECEPTOR

1 Never known to have

happened, but may happen

A pathway to allow for the

impact to occur is never

available

The receptor is never available

2 Known to happen in industry


impact to occur is almost

never available

The receptor is almost never

available

3 < once a year


impact to occur is sometimes

available

The receptor is sometimes

available

4 Once per year to up to once

per month


impact to occur is almost

always available

The receptor is almost always

available

5 Once a month - Continuous


impact to occur is always

available

The receptor is always

available

Step 1: Determine the PROBABILITY of the impact by calculating the average between the Frequency of the Aspect, the

Availability of a pathway to the receptor and the availability of the receptor.


Table 9: Determination of Magnitude of impact

Score

SOURCE RECEPTOR

Duration of

impact Extent

Volume / Quantity /

Intensity

Toxicity / Destruction

Effect Reversibility

Sensitivity of environmental

component

1 Lasting days to

a month

Effect limited to the

site. (metres);

Very small quantities /

volumes / intensity

(e.g. < 50L or < 1Ha)

Non-toxic (e.g. water) /

Very low potential to

create damage or

destruction to the

environment

Bio-physical and/or social

functions and/or processes

will remain unaltered.

Current environmental

component(s) are largely disturbed

from the natural state.

Receptor of low significance /

sensitivity

2 Lasting 1 month

to 1 year

Effect limited to the

activity and its

immediate

surroundings. (tens of

metres)

Small quantities /

volumes / intensity

(e.g. 50L to 210L or

1Ha to 5Ha)

Slightly toxic / Harmful

(e.g. diluted brine) / Low

potential to create

damage or destruction to

the environment



might be negligibly altered

or enhanced / Still

reversible


component(s) are moderately

disturbed from the natural state.

No environmentally sensitive

components.

3 Lasting 1 – 5

years

Impacts on extended

area beyond site

boundary (hundreds

of metres)

Moderate quantities /

volumes / intensity

(e.g. > 210 L < 5000L

or 5 – 8Ha)

Moderately toxic (e.g.

slimes) Potential to

create damage or

destruction to the

environment



might be notably altered or

enhanced / Partially

reversible


component(s) are a mix of

disturbed and undisturbed areas.

Area with some environmental

sensitivity (scarce / valuable

environment etc.).

4

Lasting 5 years

to Life of

Organisation

Impact on local scale

/ adjacent sites (km’s)

Very large quantities /

volumes / intensity

(e.g. 5000 L –

10 000L or 8Ha–

12Ha)

Toxic (e.g. diesel &

Sodium Hydroxide)



might be considerably

altered or enhanced /

potentially irreversible


component(s) are in a natural

state.

Environmentally sensitive

environment / receptor

(endangered species / habitats

etc.).

5

Beyond life of

Organisation /

Permanent

impacts

Extends widely

(nationally or globally)

Very large quantities /

volumes / intensity

(e.g. > 10 000 L or >

12Ha)

Highly toxic (e.g. arsenic

or TCE)



might be

severely/substantially

altered or enhanced /

Irreversible


component(s) are in a pristine

natural state.

Highly Sensitive area (endangered

species, protected habitats etc.)

Step 2: Determine the MAGNITUDE of the impact by calculating the average of the factors above.


Table 10: Determination of Severity of impact

ENVIRONMENTAL IMPACT RATING / PRIORITY

MAGNITUDE

PROBABILITY 1

Minor

2

Low

3

Medium

4

High

5

Major

5

Almost Certain Low Medium High High High

4

Likely Low Medium High High High

3

Possible Low Medium Medium High High

2

Unlikely Low Low Medium Medium High

1

Rare Low Low Low Medium Medium

Step 3: Determine the SEVERITY of the impact by plotting the averages that were obtained above for Probability and Magnitude.


7.7 The positive and negative impacts that the proposed activity (in terms of the

initial site layout) and alternatives will have on the environment and the

community that may be affected.

Alternatives as part of the development footprint were not considered as the application relates to the

decommissioning of parts of the existing Beneficiation Plant.

7.8 The possible mitigation measures that could be applied and the level of risk.

The table below will be completed once the draft BAR has been reviewed by the public and will provide a

summary of the issues and concerns as raised by affected parties and an assessment of the mitigations or site

layout alternatives available to accommodate or address their concerns, together with an assessment of the

impacts or risks associated with the mitigation or alternatives considered.

CONCERNS AS RAISED BY

AFFECTED PARTIES

MITIGATION MEASURES OR SITE

ALTERNATIVE

IMPACT POST MITIGATION

PROBABILITY MAGNITUDE SEVERITY

7.9 Motivation where no alternative sites were considered.

The main objective of the proposed project is to decommission parts of an existing Beneficiation Plant; therefore,

no alternatives were considered as part of the development footprint.

7.10 Statement motivating the alternative development location within the overall

site.

Alternatives as part of the development footprint were not considered as the application relates to the

decommissioning of parts of the existing Beneficiation Plant.

8. Full description of the process undertaken to identify, assess and

rank the impacts and risks the activity will impose on the preferred

site (In respect of the final site layout plan) through the life of the

activity.

All impacts and risks as identified are contained within Section 7.5 Impacts and risks identified. As further

provided is an assessment of the significance of each issue and risk and an indication of the extent to which the

issue and risk could be avoided or addressed by the adoption of mitigation measures. The methodology applied

in assessing and ranking the impacts and risks on the preferred site is described in Section 7.6. The results of

this assessments are provided below, with the detailed impact assessment contained in Annexure D1.


9. Assessment of each identified potentially significant impact and risk

NO. ASPECTS

AFFECTED

ACTIVITY


listed

POTENTIAL IMPACT

PHASE

in which impact is

anticipated

SIGNIFICANCE

if not mitigated

MITIGATION TYPE

(modify, remedy, control,

or stop) through e.g.

noise control measures)

SIGNIFICANCE

If mitigated

Impact description

Re

ve

rsib

ilit

y

Irre

pla

cea

ble

los

s

Pro

ba

bil

ity

Ma

gn

itu

de

Sig

nif

ican

ce

Pro

ba

bil

ity

Ma

gn

itu

de

Sig

nif

ican

ce


Impact description: Dust generation from internal access

roads and general demolition and crushing activities.



Re

ve

rsib

le

Lo

w D

eg

ree

Decommissioning Phase 4 2

Me

diu

m

Control 2 1

Lo

w


Impact description: Unpleasant odours generated from

poorly maintained/ serviced portable chemical toilets and

asbestos related emissions from decommissioning of

buildings and pipelines.



Re

ve

rsib

le

Lo

w D

eg

ree


Me

diu

m

Control 2 1

Lo

w


Impact description: Stored remediation chemicals

(biodegradable) and hazardous wastes may produce

noxious or irritating odours.



Re

ve

rsib

le

Lo

w D

eg

ree


Me

diu

m

Control 2 1

Lo

w


Impact description: Impacts on floral biodiversity due to

alien floral species invasion/proliferation.



rtia

lly R

eve

rsib

le

Lo

w D

eg

ree


Me

diu

m

Control 2 2

Lo

w


Impact description: Destruction of habitat may impact on

floral biodiversity within the CDM Beneficiation Plant

area.



Re

ve

rsib

le

Lo

w D

eg

ree


Lo

w

Control 1 1

Lo

w


NO. ASPECTS

AFFECTED

ACTIVITY


listed

POTENTIAL IMPACT

PHASE

in which impact is

anticipated

SIGNIFICANCE

if not mitigated

MITIGATION TYPE




SIGNIFICANCE

If mitigated

Impact description

Re

ve

rsib

ilit

y

Irre

pla

cea

ble

los

s

Pro

ba

bil

ity

Ma

gn

itu

de

Sig

nif

ican

ce

Pro

ba

bil

ity

Ma

gn

itu

de

Sig

nif

ican

ce


Impact description: General disturbance to overall floral

biodiversity due to dust generation, indiscriminate fires

and ineffective monitoring.



Re

ve

rsib

le

Lo

w D

eg

ree


Me

diu

m

Control 2 2

Lo

w


Impact description: Groundwater may become

contaminated by hydrocarbons leaking from equipment

and machinery, stored materials at the contractor support

area and temporarily stockpiled hazardous waste.



Pa

rtia

lly R

eve

rsib

le

Lo

w D

eg

ree


Me

diu

m

Control 1 1

Lo

w



demolition related machinery.

Increase in ambient noise levels by demolition activities

associated with the dismantling of structures.



Re

ve

rsib

le

Lo

w D

eg

ree


Lo

w

Control 2 1

Lo

w

9 Noise Activity 25


vehicles removing material and waste from the site.


Duration of impact: Lasting one month to a year

Re

ve

rsib

le

Lo

w D

eg

ree


Lo

w

Control 1 1

Lo

w

10 Soil and Land

Capability Activity 1 - 24

Impact description: Removal of potentially contaminated

material.



Re

ve

rsib

le

Lo

w D

eg

ree


Me

diu

m

Control 2 1

Lo

w


NO. ASPECTS

AFFECTED

ACTIVITY


listed

POTENTIAL IMPACT

PHASE

in which impact is

anticipated

SIGNIFICANCE

if not mitigated

MITIGATION TYPE




SIGNIFICANCE

If mitigated

Impact description

Re

ve

rsib

ilit

y

Irre

pla

cea

ble

los

s

Pro

ba

bil

ity

Ma

gn

itu

de

Sig

nif

ican

ce

Pro

ba

bil

ity

Ma

gn

itu

de

Sig

nif

ican

ce

11 Soil and Land

Capability Activity 1 – 26

Impact description: Frequent movement of heavy

machinery may lead to the compaction of valuable soils.



Re

ve

rsib

le

Lo

w D

eg

ree


Me

diu

m

Control 2 1

Lo

w

12 Soil and Land


Impact description: Disturbance and removal of soils may

lead to erosional processes;



Re

ve

rsib

le

Lo

w D

eg

ree


Me

diu

m

Control 1 1

Lo

w

13 Soil and Land



hydrocarbons leaking from construction equipment and

machinery; stored materials at the contractor support

area, temporarily stockpiled hazardous waste



Re

ve

rsib

le

Lo

w D

eg

ree


Me

diu

m

Control 1 1

Lo

w


Impact description: The visual environment will change

once the infrastructure has been decommissioned and

the buildings crushed/broken.



Pa

rtia

lly R

eve

rsib

le

Lo

w D

eg

ree


Me

diu

m

Control 1 1

Lo

w


Impact description: Decommissioning of the beneficiation

plant and crushing of building structures could result in a

loss of heritage resources.



Pa

rtia

lly R

eve

rsib

le

Lo

w D

eg

ree


Me

diu

m

Control 1 1

Lo

w





Irre

ve

rsib

le

Lo

w D

eg

ree

Decommissioning Phase Positive Control Positive


NO. ASPECTS

AFFECTED

ACTIVITY


listed

POTENTIAL IMPACT

PHASE

in which impact is

anticipated

SIGNIFICANCE

if not mitigated

MITIGATION TYPE




SIGNIFICANCE

If mitigated

Impact description

Re

ve

rsib

ilit

y

Irre

pla

cea

ble

los

s

Pro

ba

bil

ity

Ma

gn

itu

de

Sig

nif

ican

ce

Pro

ba

bil

ity

Ma

gn

itu

de

Sig

nif

ican

ce


Impact description: Decrease in general condition of

roads and increased safety risk to third party road users

due to heavy vehicle traffic on roads.



Re

ve

rsib

le

Lo

w D

eg

ree


Hig

h

Control 1 1

Lo

w


10. Summary of specialist reports.

LIST OF

STUDIES UNDERTAKEN RECOMMENDATIONS OF SPECIALIST REPORTS

SPECIALIST

RECOMMENDATIONS

THAT HAVE BEEN

INCLUDED IN THE EIA

REPORT


applicable)

REFERENCE TO

APPLICABLE SECTION

OF REPORT WHERE

SPECIALIST

RECOMMENDATIONS

HAVE BEEN

INCLUDED.

Heritage Inventory

The following recommendations can be made:

• This heritage inventory should form the first step in managing the heritage

resources located within the study area. It must not be seen as a stagnant

document and should be regularly updated as new sites are located and study

areas changed. As such the area south of the open pit that was not included in

the present study should form part of such updated inventories.

• The next step would be the compilation of a heritage management plan that will

outline the way in which the identified heritage sites can be sustainably utilised

and conserved.

The following recommendations can be made in terms of the identified sites within the

mine area:

• Create a separate inventory with buildings and structures older than 60 years and

older than 100 years.

• Do detailed recording of buildings and structures older than 60 and 100 years.

• Do detailed investigation to „Determine the heritage/cultural significance‟ of each

of these buildings in order to -

1. Draft a statement of significance for each building and structure

2. Determine what the obligations arising from the significance for each building and

structure are (standard procedure according to the ICOMOS Burra Charter to which the

South African Heritage Resources Agency (SAHRA) is signatory).

3. Draft a Conservation Management Policy (CMP) framework for managing individual

sites and buildings.

X Section 7.4 and 7.5


11. Environmental impact statement

11.1 Summary of the key findings of the environmental impact assessment

This BAR has served to identify the potential impacts associated with the activities of the associated project. In

accordance with the relevant environmental legislation, reasonable measures to mitigate the potential impacts

arising from the proposed activities have been assessed and the significance of each of these impacts under

both the pre- and post-mitigation scenarios identified and detailed.

The methodology utilised to undertake the impact assessment has incorporated, amongst other skills,

professional experience, relevant literature and local knowledge of the site and surrounding area.

It is the EAP’s opinion that based on the process that has been followed and the findings of the impact

assessment, in conjunction with the proposed mitigation measures, that no unmanageable adverse impacts are

expected to occur and some positive impacts are expected.


11.2 Final Site Map

Figure 9: Site Layout Map


11.3 Summary of the positive and negative impacts and risks of the proposed

activity and identified alternatives

Table 11: Summary of significant environmental impacts (negative and positive), after mitigation.

NO. ACTIVITY POTENTIAL IMPACT

PHASE

in which impact

is anticipated

SIGNIFICANCE

If mitigated

Air Quality

1 Decommissioning of the Beneficiation

Plant and associated infrastructure;

crushing of building material and

concrete; removal contaminated soils

and transport of workers; material and

waste to and from site and

establishment and operation of a

contractor support area

Dust generation from internal

access roads and general

demolition and crushing

activities.

Decommissioning

Phase

Low




concrete; removal of contaminated

soils and transport of workers; material

and waste to and from site and



Unpleasant odours generated

from poorly maintained/

serviced portable chemical

toilets and asbestos related

emissions from

decommissioning of buildings

and pipelines.

Decommissioning

Phase

Low

3 Removal of contaminated soils to a

permitted landfill site (where required).

Stored chemicals and

hazardous wastes may

produce noxious or irritating

odours.

Decommissioning

Phase

Low

Ecology









Impacts on floral biodiversity

due to alien floral species

invasion/proliferation.

Decommissioning

Phase

Low









Destruction of habitat may

impact on floral biodiversity

within the CDM Beneficiation

Plant.

Decommissioning

Phase

Low



PHASE

in which impact

is anticipated

SIGNIFICANCE

If mitigated









General disturbance to overall

floral biodiversity due to dust

generation, indiscriminate fires

and ineffective monitoring.

Decommissioning

Phase

Low

Groundwater









Groundwater may become

contaminated by hydrocarbons

leaking from equipment and

machinery, stored materials at

the contractor support area,

temporarily stockpiled

hazardous waste

Decommissioning

Phase

Low

Noise









Increase in ambient noise

levels by demolition related

machinery.


levels by demolition activities

associated with the removal of

redundant structures;

Decommissioning

Phase

Low










levels by vehicles removing

material and waste from the

site.

Decommissioning

Phase

Low

Soil and land capability





soils.

Disposal of potentially

contaminated material.

Decommissioning

Phase

Low




Frequent movement of heavy

machinery may lead to the

compaction of valuable soils.

Decommissioning

Phase

Low



PHASE

in which impact

is anticipated

SIGNIFICANCE

If mitigated














Disturbance and removal of

soils may lead to erosional

processes

Decommissioning

Phase

Low









Soils may become

contaminated by hydrocarbons

leaking from construction

equipment and machinery;

stored materials at the

contractor support area,

temporarily stockpiled

hazardous waste

Decommissioning

Phase

Low

Visual









The visual environment will

change once the infrastructure

has been decommissioned and

the buildings crushed/broken.

Decommissioning

Phase

Low

Heritage and cultural




concrete.

Decommissioning of the

beneficiation plant and

crushing of building structures

could result in a loss of heritage

resources.

Decommissioning

Phase

Low

Socio Economic



PHASE

in which impact

is anticipated

SIGNIFICANCE

If mitigated








contractor support area;

Creation of Employment Decommissioning

Phase

Positive

Traffic

17 Transportation of workers, materials

and waste to and from site.

Decrease in general condition

of roads and increased safety

risk to third party road users

due to heavy vehicle traffic on

roads.

Decommissioning

Phase

Low

12. Proposed impact management objectives and the impact

management outcomes for inclusion in the EMPr

Table 12: Impact management objectives and the impact management outcomes

ENVIRONMENTAL

ASPECT OBJECTIVE SUMMARY OF IMPACT MANAGEMENT OUTCOME

Air Quality Prevent the deterioration of air

quality

Air quality monitoring programme

Ecology Minimise the loss of species

diversity and prevent the loss of

vegetation

cover. Minimise the disturbance

to the overall floral biodiversity.

Alien & Invasive Species Control Program.

Dust monitoring and dust suppression

Groundwater

Minimise the impact on

Groundwater Quality.

Groundwater monitoring programme

Noise Prevent and mitigate against the

effects of noise on sensitive

receptors.

Noise monitoring programme

Soil and Land

Capability

Reduce/prevent the

contamination of soil and

Minimise the removal of soils.

Soil sampling monitoring.

Waste Management License for salvage yard and landfill

site.

Visual Reduce the visual impact and

sense of the place

Rehabilitation, Decommissioning and Closure plans and

Closure Objectives.


ENVIRONMENTAL

ASPECT OBJECTIVE SUMMARY OF IMPACT MANAGEMENT OUTCOME

Heritage and Cultural Prevention of damage to heritage

and cultural structures/artefacts.

Apply for the necessary permits from SAHRA if required and

comply with permit requirements.

Socio-economic Prevent socio economic impacts

by employment opportunities.

Local companies and labour should be utilized where

possible.

Traffic Prevent dangerous traffic

occurrences and traffic

congestion.

Transport of materials and waste to comply with the

necessary road regulations and requirements.

13. Aspects for inclusion as conditions of Authorisation.

Should the DMR grant authorisation for this project, it should be subject to the following conditions:

• The project should remain in full compliance with the requirements of the EMPr and with all regulatory

requirements;

• The EMPr should be implemented by qualified environmental personnel who have the competence and

credibility to interpret the requirements of the BAR and the EMPr. Such persons must be issued with a

written mandate by mine management to provide guidance and instructions to employees and

contractors; and

14. Description of any assumptions, uncertainties and gaps in

knowledge.

In terms of the EIA Regulations GN R982 Appendix 1(3)(o), the Environmental Impact Assessment Practitioner

(EAP) must provide a description of any assumptions, uncertainties and gaps in knowledge upon which the

impact assessment has been based. The table below provides the assumptions and limitations applicable to the

various specialist assessments.

Table 13: Specialist assumptions and limitations

SPECIALIST ASSUMPTIONS AND LIMITATIONS

Heritage

Inventory

• The present study comprises the compilation of a heritage site inventory. As a result, it cannot be

seen as a heritage or archaeological impact assessment. Whenever any land use changes or

development is proposed (whether it be mining, residential, infrastructural etc.) a heritage impact

assessment or archaeological impact assessment will still have to be undertaken for that specific

development that is proposed.

• Not subtracting in any way from the comprehensiveness of the fieldwork undertaken, it is necessary

to realise that the heritage resources located during the fieldwork do not necessarily represent all

the heritage resources located there. This may be due to various reasons, including the

subterranean nature of some archaeological sites and dense vegetation cover.

• The work undertaken within the mine area (i.e. the areas north of the open pit in terms of the

Remaining Extent of Portion 3 of the farm Elandsfontein 480-JR) was focused on the identification

of sites belonging to the built heritage. No attention was therefore given to archaeological sites,


SPECIALIST ASSUMPTIONS AND LIMITATIONS

including rubbish dumps and archaeological material which may have been associated with some

of the buildings from this area.

• As the focus in the survey of the mine area was placed on the sections north of the open pit, the

black compound (and associated buildings and features) located south of the open pit is not

included in this heritage inventory. However, this must be seen as the result of the defined study

area and not that these buildings are not significant. It is recommended that this area also be

covered as part of the continuous updating of the heritage inventory.

Asbestos

Inventory

Some of the old sewage pipes are also made of asbestos but are not available on plans

The impact assessments have assumed that all specialist assessments are essentially correct.

15. Reasoned opinion as to whether the proposed activity should or

should not be authorised

15.1 Reasons why the activity should be authorized or not.

In accordance with the EIA Regulations GN R982 (3)(l), the Environmental Impact Assessment Practitioner

(EAP) must provide an opinion as to whether the 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 must be

stated.

An impact assessment has been undertaken applying the hierarchical approach to impact management, firstly

considered to avoid negative impacts, but where avoidance was not possible, to better mitigate and manage

negative impacts. Where impacts were found to be potentially significant, various mitigation measures to

manage and monitor the impacts of the project have been proposed.

In terms of collectively considering ecological, social and economic impacts it is important to remember that

while there might be some trade-offs between the considerations, in South Africa all development must in terms

of Section 24 of the Constitution be ecologically sustainable, while economic and social development must be

justifiable. There are, therefore, specific "trade-off” rules that apply. Environmental integrity may never be

compromised, and the social and economic development must take a certain form and meet certain specific

objectives in order for it to be considered justifiable.38

No high impacts have been identified associated with the decommissioning of parts of the Beneficiation Plant.

It is the EAP’s opinion that, given the already disturbed state of the environment in which the project will be

located, these impacts can be mitigated to prevent the environmental integrity from being compromised.

The mine is dependent on the upgrade of the Beneficiation Plant in order to improve the diamond recovery

process.

38 Guideline on need and desirability in terms of the Environmental Impact Assessment (EIA) Regulations, 2010 (GN 891 of 20 October 2014);


In terms of collectively considering ecological, social and economic impacts the economic development is

justifiable, and also considering the social benefit, the EAP is of opinion that this project should be authorized.

15.2 Conditions that must be included in the authorisation

15.2.1 Specific conditions to be included into the compilation and approval of the EMPr

Should the DMR grant authorisation for this project, it should be subject to the following conditions:

• The project should remain in full compliance with the requirements of the EMPr and with all regulatory

requirements;

• The EMPr should be implemented by qualified environmental personnel who have the competence and

credibility to interpret the requirements of the EMPr. Such persons must be issued with a written mandate

by CDM to provide guidance and instructions to employees and contractors; and

15.2.2 Rehabilitation requirements

Refer to the mitigation measures in the EMPr. The rehabilitation of the project area as a whole will be done as

part of the mining operations.

16. Period for which the Environmental Authorisation is required.

The decommissioning project is proposed to take 2 years:

STAGES OF OPERATION TIMEFRAME (YEARS)

Decommissioning Phase 2019 - 2021

TOTAL Period 2

17. Undertaking

The undertaking by the EAP is provided in Part 2 of Section B (Environmental Management Programme) below.

This undertaking confirms: the correctness of the information provided in the reports, the inclusion of comments

and inputs from stakeholders and I&APs, the inclusion of inputs and recommendations from the specialist reports

where relevant and the acceptability of the project in relation to the finding of the assessment and level of

mitigation proposed.

18. Financial Provision

18.1 Explain how the aforesaid amount was derived.

The project area falls within the CDM mining right area. CDM makes financial provision for closure by means of

the Rehabilitation Trust Fund, with any shortfall between the immediate closure cost estimate and the balance

in the Trust Account being funded by means of bank guarantees. The last annual review of the financial quantum

in terms of section 41(3) and Regulation 54 of the MPRDA was submitted to DMR in February 2017. The mine

will submit similar reviews on an annual basis.


18.2 Confirm that this amount can be provided for from operating expenditure.

The methodology for determining the closure cost for CDM is described in detail in the Closure Plan and is

based on the closure criteria and assumptions described in the Closure Report.

19. Specific Information required by the competent Authority

19.1 Compliance with the provisions of sections 24(4)(a) and (b) read with section

24 (3) (a) and (7) of the National Environmental Management Act (Act 107 of

1998). the EIA report must include the: -

19.1.1 Impact on the socio-economic conditions of any directly affected person.

RESULTS OF INVESTIGATION, ASSESSMENT AND EVALUATION OF IMPACT ON ANY

DIRECTLY AFFECTED PERSON

REFERENCE TO

WHERE MITIGATION IS

REFLECTED

Ambient dust and noise will be the main contributors to the direct environment Part A Section 12

19.1.2 Impact on any national estate referred to in section 3(2) of the National Heritage

Resources Act.

RESULTS OF INVESTIGATION, ASSESSMENT AND EVALUATION OF IMPACT ON ANY

NATIONAL ESTATE

REFERENCE TO

WHERE MITIGATION IS

REFLECTED

No impacts on any national estate referred to in section 3(2) of the National Heritage

Resources Act are foreseen as a result of the activities. Not Applicable

20. Other matters required in terms of sections 24(4)(a) and (b) of the

Act.

An impact assessment for the proposed project has been undertaken and will incorporate extensive consultation

with and participation of interested and affected parties. Applying the hierarchical approach to impact

management were firstly considered to avoid negative impacts, but where avoidance was not possible, to better

mitigate and manage negative impacts. Where impacts were found to be potentially significant, various

mitigation measures to manage and monitor the impacts of the project have been proposed. Furthermore, the

environmental impact statement (Part A Section 7.5) summarises the key findings of the environmental impact

assessment and negative implications of the project.


PART B

ENVIRONMENTAL MANAGEMENT PROGRAMME

REPORT

1. Draft environmental management programme.

1.1 Details of the EAP

The requirements for the provision of the detail and expertise of the EAP are included in PART A, Section 1.1.

1.2 Description of the Aspects of the Activity

The requirement to describe the aspects of the activity that are covered by the draft environmental management

programme is included in PART A, Section 4.

1.3 Composite Map

Refer to the figure below for a map that superimposes the proposed activity, its associated structures and

infrastructures on the CDM site.


Figure 10: Site Layout Map


1.4 Description of Impact management objectives including management

statements

1.4.1 Determination of closure objectives.

Closure Objectives for CDM will be applied to the project area. No changes to the existing Closure Objectives

for CDM is required.

1.4.2 Volumes and rate of water use required for the operation.

The CDM is connected to the municipality water system. Any water requirements for the project will be sourced

from the municipal water supply. Water may be required for the flushing of sewer and water pipelines. It is

unknown at this stage the volume of water needed.

1.4.3 Has a water use licence has been applied for?

No section 21 water uses have been identified for this project.


1.4.4 Impacts to be mitigated in their respective phases

Table 14: Measures to rehabilitate the environment affected by the undertaking of any listed activity

NO.

ACTIVITY

whether listed or not listed

PHASE


SIZE AND SCALE

of disturbance

MITIGATION MEASURES

COMPLIANCE WITH STANDARDS

TIME PERIOD FOR

IMPLEMENTATION

1 Activity 1 - 26 Decommissioning Phase Within the 32 ha

• Vehicles should be regularly serviced to minimise atmospheric

emissions.

• The Air quality monitoring programme will be continued with.

• Dust suppression of roads at regular intervals or during windy

periods

• Ensure adequate dust level monitoring is put in place, where

applicable

Dust suppressing methods to reduce dust to

comply with the Dust Control Regulation GNR

827 of 2013 and NEM: AQA, 2004.

2 years


• Ensure that portable chemical toilets are maintained at agreed

upon intervals by an appropriate contractor.

• Comprehensive asbestos survey to be undertaken prior to

decommissioning and demolishing.

• All asbestos containing material must be removed and disposed

in accordance with the Asbestos Regulations GNR 1637 of 2002

with specific reference to Section 20 (disposal) and Section 21

(demolition)

Air quality management in accordance with the

National Environmental Management: Air

Quality Act (Act No 39 of 2004); Regulations

there under and amendments thereto.

Emergency preparedness and response in

compliance with the compliance with the Mine

Health and Safety Regulations under the Mine

Health and Safety Act (1996);

Asbestos Management and Monitoring Plan.

2 years

3 Activity 24 Decommissioning Phase Within the 32 ha

• Chemicals to be stored in an appropriately designed container.

• Where possible, hazardous wastes are to be stored in sealed

receptacles.

• Hazardous chemicals are to always be stored in an area where

regularly maintained firefighting equipment is available.

• Where possible, polluted soils should be stored for the shortest

possible time period prior to disposal.


National Environmental Management: Air

Quality Act (Act No 39 of 2004); Regulations


2 years

4 Activity 1 – 26 Decommissioning Phase Within the 32 ha

• Inform employees about dominant alien vegetation species.

• Implement alien vegetation control plan specific for the

exotic/weed species identified within the area.

• All development footprint areas should remain as small as

possible and should not encroach onto more sensitive open veld

areas.

• Proliferation and a further increase of alien and invasive grass

species are expected within disturbed areas. These species

should be eradicated in line with the specialist recommendations

and controlled to prevent their spread beyond the site boundary.

• Removal of the alien and weed species encountered on the

property in order to comply with existing legislation

(amendments to the regulations under the Conservation of


System and Operational Procedures and

training programme in compliance with

ISO14001.

Biodiversity and alien invasive management in

accordance with NEMBA, 2004.

2 years


NO.

ACTIVITY


PHASE


SIZE AND SCALE

of disturbance

MITIGATION MEASURES


TIME PERIOD FOR

IMPLEMENTATION

Agricultural Resources Act, 1983 and Section 28 of the National

Environmental Management Act, 1998).


• All development footprint areas should remain as small as

possible and should not encroach onto surrounding more

sensitive open veld areas.

• All soils compacted as a result of activities should be ripped,

profiled and monitored to ensure establishment of natural

vegetation.

• Appropriate waste removal and disposal should be provided as

to prevent refuse dumping in surrounding open veld areas.



ISO14001.



2 years

6 Activity1 – 26 Decommissioning Phase Within the 32 ha

• It must be ensured that all roads and construction areas are

regularly sprayed with water or treated with other dust

suppression measures in order to curb dust generation. This is

particularly necessary during the dry season when increased

levels of dust generation can be expected. However, care should

be taken not to over-spray causing water run-off and subsequent

sediment loss into adjacent waterways.

• Ongoing monitoring of dust should be employed to ensure

identification of increased dust levels over time or in specific

areas.

• If any excessive dying out of vegetation occurs in areas of dust

generation, measures to mitigate the impact should be

immediately sought.

• All informal fires on the property should be prohibited.

• Identify areas where the value of the biological resource

warrants protection and therefore controlled access by the

contractors.

• Maintenance of fences to ensure that access control is

maintained.

• Compliance with regulations under the National Forest and Fire

Laws Amendment Act, 2001.

Dust monitoring and dust suppression to reduce

dust to comply with NEM: AQA, 2004 and

regulations there

under.

Compliance with regulations under the National

Forest and Fire Laws Amendment Act, 2001.

General implementation of activities taking

Mining and Biodiversity Guidelines into account.

2 years


• All equipment and machinery are to be appropriately maintained

and checked for leaks regularly;

• Standing machinery are to be equipped with drip trays.

• Hydrocarbons, materials and waste stored on site are to be

stored in areas approved by CDM Environmental and are to be

stored in a bunded area on an impermeable surface.

Water management measures in compliance

with NWA, 1998 and GN

704, 1999.

Compliance with DWS’s Best Practice Guideline

Series in terms of integrated water and waste

management and monitoring.

Groundwater monitoring programme.

2 years


NO.

ACTIVITY


PHASE


SIZE AND SCALE

of disturbance

MITIGATION MEASURES


TIME PERIOD FOR

IMPLEMENTATION


• Demolition activities are to take place during the approved work

hours, these are to be known to and agreed upon with all

contractors.

• Noise monitoring will be conducted during the decommissioning

phase in order to ensure compliance with the relevant standard.

• Generators must be switched off when not used.

SABS Code of Practice 0103 of 2008: The

measurement and rating of environmental noise

with respect to land use, health, annoyance and

to

speech communication.

SABS Code of Practice 0328 of 2008:

Environmental Noise Impact Assessments.

2 years


• Silencers shall be fitted to the heavy machinery where possible.

• Normal vehicles should have silencers as required by the

relevant Road Traffic Acts.

• Audible reverse alarms will not be removed as it reduces the risk

of incidents involving these vehicles.

• A complaints register should be in place at the site. All

complaints, solutions and agreements between the mine and

complaining parties will be kept in a specific file in the

Environmental Specialist’s office.

• The mine is advised to instruct drivers of trucks to use hooters

in a disciplined manner for purposes of safety only, not for

signalling or any other purpose.



with respect to land use, health, annoyance and

to



Environmental Noise Impact Assessments

2 years


• Removal of all potentially polluting infrastructure.

• Where appropriate separate clean material from polluted

material.

• Building rubble and concrete should be inspected for any

contamination before disposed of at the CDM licenced landfill

site. Should it be identified that the building rubble or concrete is

contaminated, these materials will need to be disposed of by an

appointed waste disposal certificated contractor to a permitted

landfill site.

• Store all hazardous material within the footprint of the salvage

yard area as per the requirements of the Waste Management

Licence for the salvage yard. Hazardous waste should be

disposed of by an appointed waste disposal certificated

contractor to a permitted landfill site.

• Contaminated soil should be stored in skips demarcated for this

purpose and disposed of by an appointed waste disposal

certificated contractor to a permitted landfill site.

• Excavation of the contaminated material for disposal to a

licensed landfill through waste classification analysis to

ascertain correct disposal methods in terms of the National

Norms and Standards.



ISO14001.

Reasonable precaution will be taken to prevent

spillage and in case there is spillage, cleaning

procedures to be undertaken in order to comply

with the principles of pollution prevention and

duty of care (NEMA, 1998).

In Compliance with the National Norms and

Standards for the Remediation of Contaminated

Land and Soil Quality (GNR.331 of 2014),

thereunder.

Managing general and/or hazardous waste in a

manner as to comply with NEM:WA, 2008.



704, 1999.

2 years


NO.

ACTIVITY


PHASE


SIZE AND SCALE

of disturbance

MITIGATION MEASURES


TIME PERIOD FOR

IMPLEMENTATION

• Remove existing asbestos containing material using a certified

asbestos removal contractor for appropriate disposal to a

certified site

• Remove any existing tyres stored onsite as these are the

potential source of contamination if burning where to be

undertaking again.

• Remove substations and surrounding contaminants,

• Where required, flush any pipelines to remove hazardous

material and treat material as waste

Compliance to the Waste Management Licence

for the Salvage yard and Landfill site.


• Other than working areas, heavy machinery is only to travel

along demarcated roads and are not to enter any areas that have

not been authorized.




thereunder.



ISO14001.

2 years


• Where soils are disturbed on slopes or within areas where soil

erosion is likely to take place, mitigation is to take place in the

form of the positioning of surface water flow barriers or gabions.

Rehabilitation in terms of MPRDA and NEMA

principles.



704, 1999.




2 years


• All equipment and machinery are to be appropriately maintained

and checked for leaks regularly;

• Standing machinery are to be equipped with drip trays.

• Hydrocarbons, materials and waste stored on site are to be

stored in areas approved by CDM Environmental., and are to be

stored in a bunded area on an impermeable surface.

• General waste receptacles are to be placed at areas where

demolition or decommissioning activities are to take place, these

are to be sufficient for waste that is expected to be generated in

a single day, not less, and the receptacle is to have a lid on it to

prevent litter from being dispersed by wind;

• Sites are to be cleaned and all refuse removed at the end of

each work day.



ISO14001.




with the principles of pollution prevention and

duty of care (NEMA, 1998).


manner as to comply with NEM: WA, 2008.



2 years


NO.

ACTIVITY


PHASE


SIZE AND SCALE

of disturbance

MITIGATION MEASURES


TIME PERIOD FOR

IMPLEMENTATION

704, 1999.


• The contractor is to ensure that all sites are cleared up at the

end of the day and all general refuse removed and disposed of

at a licensed facility.



ISO14001.

In compliance with the Rehabilitation,

Decommissioning and Closure plans and

Closure Objectives.




thereunder.

In compliance with principles contained in

the MPRDA, 2002, Mine Health and Safety Act,

1996, NEMA, 1998, NEM: WA, 2008,

Regulations there under and amendments

thereto.

The continued implementation of requirements

contained in the NEM:BA (2004) and the

regulations thereunder.

2 years


• Apply for the necessary permits from SAHRA,,if required.

• Comply with the conditions of the permits

• Only areas approved by the CDM Environmental Specialist, in

consultation with the heritage report and permits, may be

destroyed/impacted. Should any artefacts be unearthed, work

should be halted, and the heritage specialist should be

contacted immediately.


training programme incompliance with

ISO14001.

The management of heritage resources: In

compliance with the National Heritage

Resources Act (Act No. 25 of 1999), and

amendments thereto.

2 years

16 Activity 1 – 26 Decommissioning Phase Within the 32 ha • Local companies and labour should be utilized where possible.



ISO14001.

Social Labour Plan,

Mining Works Programme.

2 years


NO.

ACTIVITY


PHASE


SIZE AND SCALE

of disturbance

MITIGATION MEASURES


TIME PERIOD FOR

IMPLEMENTATION


• Where possible, heavy vehicle traffic should be discouraged

from using roads during peak hour traffic times.

• Road signage and speed limits should be adhered to.

• Any heavy load transport will be done in consultation with the

Roads Department

• Transport of materials and waste will comply with the necessary

road regulations.

Comply with municipal and departmental

(Roads Department) requirements for roads.

National Road Traffic Act; Regulations there

under and amendments thereto.

2 years


1.5 Impact Management Outcomes

Table 15: Impact management outcomes, identifying the stand of impact management required for the identified aspects


ACTIVITY


POTENTIAL IMPACT

PHASE


MITIGATION TYPE




STANDARD TO BE ACHIEVED

Impact description

Re

ve

rsib

ilit

y

Irre

pla

cea

ble

lo

ss


Impact description: Dust generation from internal access roads and

general demolition and crushing activities.



Re

ve

rsib

le

Lo

w D

eg

ree

Decommissioning Phase Control Minimise deterioration of ambient

air quality



maintained/ serviced portable chemical toilets and asbestos related

emissions from decommissioning of buildings and pipelines.



Re

ve

rsib

le

Lo

w D

eg

ree


air quality


Impact description: Stored remediation chemicals (biodegradable)

and hazardous wastes may produce noxious or irritating odours.



Re

ve

rsib

le

Lo

w D

eg

ree


air quality


Impact description: Impacts on floral biodiversity due to alien floral

species invasion/proliferation.



rtia

lly R

eve

rsib

le

Lo

w D

eg

ree

Decommissioning Phase Control Minimise the loss of species

diversity






Re

ve

rsib

le

Lo

w D

eg

ree

Decommissioning Phase Control Limit the loss of vegetation

cover.



ACTIVITY


POTENTIAL IMPACT

PHASE


MITIGATION TYPE





Impact description

Re

ve

rsib

ilit

y

Irre

pla

cea

ble

lo

ss


Impact description: General disturbance to overall floral biodiversity

due to dust generation, indiscriminate fires and ineffective

monitoring.



Re

ve

rsib

le

Lo

w D

eg

ree

Decommissioning Phase Control Limit the disturbance to the overall

floral biodiversity.


Impact description: Groundwater may become contaminated by

hydrocarbons leaking from equipment and machinery, stored

materials at the contractor support area and temporarily stockpiled

hazardous waste.



Pa

rtia

lly R

eve

rsib

le

Lo

w D

eg

ree

Decommissioning Phase Control Minimise the impact on

Groundwater Quality.


Impact description: Increase in ambient noise levels by demolition

related machinery.

Increase in ambient noise levels by demolition activities associated

with the dismantling of structures.



Re

ve

rsib

le

Lo

w D

eg

ree

Decommissioning Phase Control Minimise the noise impact on

sensitive receptors

9 Noise Activity 25

Impact description: Increase in ambient noise levels by vehicles

removing material and waste from the site.



Re

ve

rsib

le

Lo

w D

eg

ree

Decommissioning Phase Control Minimise the noise impact on

sensitive receptors.

10 Soil and Land Capability Activity 1 - 24

Impact description: Removal of potentially contaminated material.



Re

ve

rsib

le

Lo

w D

eg

ree

Decommissioning Phase Control Minimise the impact on soil and land

capability.



ACTIVITY


POTENTIAL IMPACT

PHASE


MITIGATION TYPE





Impact description

Re

ve

rsib

ilit

y

Irre

pla

cea

ble

lo

ss


Impact description: Frequent movement of heavy machinery may

lead to the compaction of valuable soils.



Re

ve

rsib

le

Lo

w D

eg

ree


capability.


Impact description: Disturbance and removal of soils may lead to

erosional processes;



Re

ve

rsib

le

Lo

w D

eg

ree


capability.



hydrocarbons leaking from construction equipment and machinery;

stored materials at the contractor support area, temporarily

stockpiled hazardous waste



Re

ve

rsib

le

Lo

w D

eg

ree

Decommissioning Phase Control Minimise impact on soils.


Impact description: The visual environment will change once the

infrastructure has been decommissioned and the buildings

crushed/broken.



Pa

rtia

lly R

eve

rsib

le

Lo

w D

eg

ree

Decommissioning Phase Control Minimise the visual impact and

sense of the place


Impact description: Decommissioning of the beneficiation plant and

crushing of building structures could result in a loss of heritage

resources.



Pa

rtia

lly R

eve

rsib

le

Lo

w D

eg

ree

Decommissioning Phase Control Minimise the impact on heritage

resources



ACTIVITY


POTENTIAL IMPACT

PHASE


MITIGATION TYPE





Impact description

Re

ve

rsib

ilit

y

Irre

pla

cea

ble

lo

ss





Irre

ve

rsib

le

Lo

w D

eg

ree

Decommissioning Phase Control

Increase impact

on local

economy


Impact description: Decrease in general condition of roads and

increased safety risk to third party road users due to heavy vehicle

traffic on roads.



Re

ve

rsib

le

Lo

w D

eg

ree

Decommissioning Phase Control

Minimise risk on

Road infrastructure and safety to

third party road users.


1.6 Impact Management Actions

Table 16: Impact management actions, identifying the manner in which the impact management objectives and outcomes will be achieved.

NO.

ACTIVITY


POTENTIAL IMPACT

MITIGATION TYPE



control measures)


TIME PERIOD FOR IMPLEMENTATION

Impact description

Re

ve

rsib

ilit

y

Irre

pla

cea

ble

lo

ss

1 Activity 1 - 26

Impact description: Dust generation from internal access roads and

general demolition and crushing activities.



Re

ve

rsib

le

Lo

w D

eg

ree

Control

Dust suppressing methods to reduce dust to

comply with the Dust Control Regulation GNR 827

of 2013 and NEM:AQA, 2004.

2 years

2 Activity 1 - 26


maintained/ serviced portable chemical toilets and asbestos related

emissions from decommissioning of buildings and pipelines.



Re

ve

rsib

le

Lo

w D

eg

ree

Control


National Environmental Management: Air Quality

Act (Act No 39 of 2004); Regulations there under

and amendments thereto.

Emergency preparedness and response in

compliance with the compliance with the Mine

Health and Safety Regulations under the Mine

Health and Safety Act (1996);

Asbestos Management and Monitoring Plan.

2 years

3 Activity 24

Impact description: Stored remediation chemicals (biodegradable) and

hazardous wastes may produce noxious or irritating odours.



Re

ve

rsib

le

Lo

w D

eg

ree

Control


National Environmental Management: Air Quality

Act (Act No 39 of 2004); Regulations there under


2 years

4 Activity 1 – 26

Impact description: Impacts on floral biodiversity due to alien floral

species invasion/proliferation.



Pa

rtia

lly R

eve

rsib

le

Lo

w D

eg

ree

Control


System and Operational Procedures and training

programme in compliance with ISO14001.



2 years


NO.

ACTIVITY


POTENTIAL IMPACT

MITIGATION TYPE



control measures)



Impact description

Re

ve

rsib

ilit

y

Irre

pla

cea

ble

lo

ss

5 Activity 1 - 26





Re

ve

rsib

le

Lo

w D

eg

ree

Control





2 years

6 Activity1 – 26

Impact description: General disturbance to overall floral biodiversity due

to dust generation, indiscriminate fires and ineffective monitoring.



Re

ve

rsib

le

Lo

w D

eg

ree

Control

Dust monitoring and dust suppression to reduce

dust to comply with NEM: AQA, 2004 and

regulations there

under.

Compliance with regulations under the National

Forest and Fire Laws Amendment Act, 2001.

General implementation of activities taking Mining

and Biodiversity Guidelines into account.

2 years

7 Activity 1 – 26

Impact description: Groundwater may become contaminated by

hydrocarbons leaking from equipment and machinery, stored materials

at the contractor support area and temporarily stockpiled hazardous

waste.



Pa

rtia

lly R

eve

rsib

le

Lo

w D

eg

ree

Control

Water management measures in compliance with

NWA, 1998 and GN

704, 1999.




Groundwater monitoring programme.

2 years

8 Activity 1 – 26

Impact description: Increase in ambient noise levels by demolition

related machinery.

Increase in ambient noise levels by demolition activities associated with

the dismantling of structures.



Re

ve

rsib

le

Lo

w D

eg

ree

Control



with respect to land use, health, annoyance and to



Environmental Noise Impact Assessments.

2 years


NO.

ACTIVITY


POTENTIAL IMPACT

MITIGATION TYPE



control measures)



Impact description

Re

ve

rsib

ilit

y

Irre

pla

cea

ble

lo

ss

9 Activity 25

Impact description: Increase in ambient noise levels by vehicles

removing material and waste from the site.



Re

ve

rsib

le

Lo

w D

eg

ree

Control



with respect to land use, health, annoyance and to



Environmental Noise Impact Assessments

2 years

10 Activity 1 - 24

Impact description: Removal of potentially contaminated material.



Re

ve

rsib

le

Lo

w D

eg

ree

Control






with the principles of pollution prevention and duty

of care (NEMA, 1998).




thereunder.


manner as to comply with NEM:WA, 2008.


NWA, 1998 and GN

704, 1999.

Compliance to the Waste Management Licence

for the Salvage yard and Landfill site.

2 years

11 Activity 1 – 26

Impact description: Frequent movement of heavy machinery may lead

to the compaction of valuable soils.



Re

ve

rsib

le

Lo

w D

eg

ree

Control




thereunder.



2 years


NO.

ACTIVITY


POTENTIAL IMPACT

MITIGATION TYPE



control measures)



Impact description

Re

ve

rsib

ilit

y

Irre

pla

cea

ble

lo

ss


Impact description: Disturbance and removal of soils may lead to

erosional processes;



Re

ve

rsib

le

Lo

w D

eg

ree

Control

Rehabilitation in terms of MPRDA and NEMA

principles.


NWA, 1998 and GN

704, 1999.




2 years


Impact description: Soils may become contaminated by hydrocarbons

leaking from construction equipment and machinery; stored materials

at the contractor support area, temporarily stockpiled hazardous waste



Re

ve

rsib

le

Lo

w D

eg

ree

Control






with the principles of pollution prevention and duty

of care (NEMA, 1998).


manner as to comply with NEM: WA, 2008.


NWA, 1998 and GN

704, 1999.

2 years


NO.

ACTIVITY


POTENTIAL IMPACT

MITIGATION TYPE



control measures)



Impact description

Re

ve

rsib

ilit

y

Irre

pla

cea

ble

lo

ss


Impact description: The visual environment will change once the

infrastructure has been decommissioned and the buildings

crushed/broken.



Pa

rtia

lly R

eve

rsib

le

Lo

w D

eg

ree

Control



In compliance with the Rehabilitation,

Decommissioning and Closure plans and Closure

Objectives.




thereunder.

In compliance with principles contained in

the MPRDA, 2002, Mine Health and Safety Act,

1996, NEMA, 1998, NEM: WA, 2008, Regulations


The continued implementation of requirements

contained in the NEM:BA (2004) and the

regulations thereunder.

2 years

15 Activity 1 - 23

Impact description: Decommissioning of the beneficiation plant and

crushing of building structures could result in a loss of heritage

resources.



Pa

rtia

lly R

eve

rsib

le

Lo

w D

eg

ree

Control


programme incompliance with ISO14001.

The management of heritage resources: In

compliance with the National Heritage Resources

Act (Act No. 25 of 1999), and amendments

thereto.

2 years





Irre

ve

rsib

le

Lo

w D

eg

ree

Control



Social Labour Plan,

Mining Works Programme.

2 years


NO.

ACTIVITY


POTENTIAL IMPACT

MITIGATION TYPE



control measures)



Impact description

Re

ve

rsib

ilit

y

Irre

pla

cea

ble

lo

ss

17 Activity 25

Impact description: Decrease in general condition of roads and

increased safety risk to third party road users due to heavy vehicle traffic

on roads.



Re

ve

rsib

le

Lo

w D

eg

ree

Control

Comply with municipal and departmental (Roads

Department) requirements for roads.

National Road Traffic Act; Regulations there under


2 years


1.7 Financial Provision

1.7.1 Describe the closure objectives and the extent to which they have been aligned to the

baseline environment described under the Regulation.

The project area falls within the CDM mining right area. Closure Objectives for CDM will be applied to the project

area. No changes to the existing Closure Objectives for CDM is required.

1.7.2 Confirm specifically that the environmental objectives in relation to closure have been

consulted with landowner and interested and affected parties.



1.7.3 Provide a rehabilitation plan that describes and shows the scale and aerial extent of

the main mining activities, including the anticipated mining area at the time of closure.

The rehabilitation of the project area as a whole will be done as part of the mining operations.

1.7.4 Explain why it can be confirmed that the rehabilitation plan is compatible with the

closure objectives.



1.7.5 Calculate and state the quantum of the financial provision required to manage and

rehabilitate the environment in accordance with the applicable guideline.

The project area falls within the CDM mining right area. CDM makes financial provision for closure by means of

the Rehabilitation Trust Fund, with any shortfall between the immediate closure cost estimate and the balance

in the Trust Account being funded by means of bank guarantees. The last annual review of the financial quantum

in terms of section 41(3) and Regulation 54 of the MPRDA was submitted to DMR in February 2017. The mine

will submit similar reviews on an annual basis.

1.7.6 Confirm that the financial provision will be provided as determined.

The methodology for determining the closure cost for CDM is described in detail in the Closure Plan and is

based on the closure criteria and assumptions described in the Closure Report


1.8 Mechanisms for monitoring compliance with and performance assessment against the environmental management

programme

Mechanisms for monitoring compliance with and performance assessment against the environmental management programme and reporting thereon, including

• Monitoring of Impact Management Actions

• Monitoring and reporting frequency

• Responsible persons

• Time period for implementing impact management actions

• Mechanism for monitoring compliance

SOURCE ACTIVITY IMPACTS REQUIRING MONITORING

PROGRAMMES

FUNCTIONAL REQUIREMENTS FOR MONITORING

ROLES AND RESPONSIBILITIES (FOR THE EXECUTION OF THE MONITORING PROGRAMMES)

MONITORING AND REPORTING FREQUENCY and TIME PERIODS FOR

IMPLEMENTING IMPACT MANAGEMENT ACTIONS

Dust generation from

internal access roads

and general demolition

and crushing activities.

Air Quality Dust suppression of roads at regular intervals

or during windy periods

Contractor Daily

Ensure adequate dust level monitoring is put in

place, where applicable

Environmental Specialist Monthly

Unpleasant odours

generated from poorly

maintained/ serviced

portable chemical toilets

and asbestos related

emissions from

decommissioning of

buildings and pipelines.

Air Quality Ensure that portable chemical toilets are

maintained at agreed upon intervals by an

appropriate contractor

Environmental Specialist Weekly

Stored chemicals and

hazardous wastes may

produce noxious or

irritating odours

Air Quality Ensure chemicals are stored in an appropriately

designed container.

Contractors, Environmental Specialist,

Environmental Compliance Officer

Daily


Ensure hazardous chemicals are to always be

stored in an area where regularly maintained

firefighting equipment is available

Restoration of

ecosystem function

through natural

improvement of water

and soils quality.

Ecology All hazardous materials should be stored in an

approved area where necessary surface

preparation and area bunding has taken place;

All vehicles should be frequently inspected for

oil leaks;

No vehicle maintenance is to take place in any

other area of the mine other than in the

demarcated maintenance yard.

Contractors, Environmental Specialist,

Environmental Compliance Officer

Daily

Potential impact of

underlying aquifers.

Groundwater Continuous groundwater monitoring should

take place to ensure that there are no persistent

sources of contamination to groundwater

Environmental Specialist, Environmental

Compliance Officer

Ongoing

Increase in ambient

noise levels by

demolition related

machinery.

Increase in ambient

noise levels by

demolition activities

associated with the

removal of redundant

structures;

Noise Demolition activities are to take place during the

approved work hours (7H00-18H00), these are

to be known to and agreed upon with all

contractors.

Environmental Specialist, Environmental

Compliance Officer

Daily

Intermittent increases to

the ambient noise

environment by

possible blasting, when

required.

Noise Blasting is to only occur during the day work

hours (07H00 – 18H00) and with due

notification of identified sensitive receptors.

Mining Contractor, Environmental

Specialist, Environmental Compliance

Officer

When required


1.9 Indicate the frequency of the submission of the performance assessment/

environmental audit report.

An environmental audit should be conducted annually and submitted to the DMR annually.

1.10 Environmental Awareness Plan

1.10.1 Manner in which the applicant intends to inform his or her employees of any

environmental risk which may result from their work.

The following Environmental Awareness Training will be implemented by CDM in order to inform employees and

contractors of the environmental risk that may result from their work, or the risk of their interaction with the

sensitive environment. The training will be conducted as part of the induction process for all new employees

(including contractors) that will perform work in terms of the proposed activities. Proof of all training provided

must be kept on-site.

The Environmental Awareness Training will, as a minimum cover the following topics:

• Air Quality

- Activities that may result or mitigate impact on air quality; speeding on roads, the requirements for dust

suppression, etc.

- Negative impacts on the receiving environment if mitigation measures are not implemented.

• Surface and groundwater

- Risks to surface and groundwater, e.g. fuel and chemical handling and further risks of erosion or

damage to riparian vegetation.

- How incidents should be reported, and emergency requirements.

- The importance of storm water control, maintenance of pollution control infrastructure.

- The importance to reuse water and to prevent spillages.

• Cultural Heritage

- The cultural significance of the area.

- To respect all cultures and believes.

- To remain within working areas and not to enter or interfere with any cultural heritage.

- How to report any sightings as identified during operation activities (e.g. fossils).

• Fauna

- Overview of the fauna found on site and the uniqueness thereof.

- Mitigation measures that all contractors and employees need to abide by.

- No contractor or personnel allowed to catch or kill any species, and how any sightings should be

reported if further actions are required (e.g. to catch and release).

• Flora

- Overview of the flora diversity on site, and the rare and endangered nature thereof.

- Measures taken by the mine to protect species.

- No contractor or personnel allowed to remove, harvest or destroy any flora species unless clearly

instructed based on the construction and operational plans.


• Waste management

- The correct segregation of general and hazardous waste.

- Do’s and don’ts with respect to waste disposal.

- Measures to avoid waste generation and to participate in waste minimisation/reduction strategies.

• Traffic

- Abide by traffic rules, no speeding allowed.

- To stay on designated roads (and not to drive on areas that are not fit and designed for this purpose).

- To be aware of the fauna species and to be on the lookout and avoid collisions.

• Natural Resource Consumption

- Optimise utilisation of mining and plant equipment, travelling routes etc.

• Emergency Preparedness and Response

- Designated smoking areas.

- How to report any emergency or incident.

- Incident and emergency reporting requirements

• General rules and conduct

- Respect for the sensitive environment.

- Do not litter.

- HIV/AIDS awareness.

- Respect for each other and for different cultures.

- Safety and health requirements.

1.10.2 Manner in which risks will be dealt with in order to avoid pollution or the degradation

of the environment.

Identification of Environmental Aspects

Environmental aspects for the operation are identified through the following process:

The following structure forms the basis for the aspect register and organises all environmental information

relevant to the Environmental Management Programmes of the System:

• Department;

• Section;

• Area;

• Activity Description;

• Aspect; and

• Impact.

Each aspect is described in detail adding information regarding volumes, current mitigation and potential

emergency conditions. The relevant Section Head / Mine Overseer is present when the aspects are described

to ensure accuracy and reliability.


The environmental aspects are identified or updated based on:

• The description of the activities in each area;

• The known impacts of the activities;

• Information contained in the EMP(r);

• EIA’s and risk assessments conducted for a new process;

• Legal requirements obtained from the legal register;

• Re-occurrence of incidents or non-conformances relating to an area, activity or product; and

• Known environmental factors such as neighbouring environmental hotspots.

The environmental aspects associated with activities, products and services are documented in the aspect

register. The potential impacts arising from the environmental aspect are also captured in the aspect register.

An aspect may lead to more than one impact.

Prioritisation of Environmental Aspects

In order to determine the significance rating of the environmental aspects, the following criteria are used:

Likelihood (Negative Impacts)

DESCRIPTION DEFINITION

Definite It is certain that the impact will materialize regardless of any preventive measure

Probable The likelihood that the impact will materialize exceeds 10%

Possible The likelihood of the impact materializing < 10%

Low Possibility of impact materializing is very low either because of design or historic experience

(likelihood < 1%)

Likelihood (Positive Impacts)


Definite It is certain that the impact will materialize under current practise and controls

Probable The likelihood that the impact will materialize exceeds 10%

Possible The likelihood of the impact materializing < 10%

Low Possibility of impact materializing is very low due to the circumstances occurring on an

ADHOC basis.

Extent (Negative Impacts)


International Impact on a scale beyond country boundaries

National Impact on a scale within country boundaries

Regional Impact on a regional scale

Local Impact extends locally: the site and its surroundings


Site Impact is confined to the site only

Immediate Impact is confined to the immediate vicinity of the activity itself

Extent (Positive Impacts)


International Impact on a scale beyond country boundaries

National Impact on a scale within country boundaries

Regional Impact on a regional scale

Local Impact extends locally: the site and its surroundings

Site Impact is confined to the site only

Immediate Impact is confined to the immediate vicinity of the activity itself

Severity (Negative Impacts)


Very High Environment: There is a total disruption of natural, social and cultural functions or processes

to the extent that these functions would permanently cease. Risk: Workforce fatality, Complete

disruption of operational integrity, Loss of company credibility, with key stakeholders, Non-

compliance with likelihood of prosecution, Premature close of operations

High Environment: There is a total disruption of natural, social and cultural functions or processes

to the extent that these cease functioning for the duration of the activity but resume functioning

after the operation has been terminated. Risk: Workforce reportable or disabling injury or

illness, Substantial disruption of operational integrity, Negative public perception, Non-

compliance with low likelihood of prosecution, required to position operation for imminent

closure, could have wider corporate implications

Moderate Environment: The natural, social and cultural functions or processes are notably altered but

continue (albeit in a modified way). The effect is reversible within the lifetime of the operation.

Risk: Minor injury, required to position the operation for closure, required to position the

operation for impending legislation

Low Environment: The natural, social and cultural functions or processes are minimally affected

(often only just measurable). Such effects are felt only during the life of the operation. Risk:

Incident

No Effect No effect e.g. a small oil spill in a bund wall

Severity (Positive Impacts)


Very High All Products; Services and Activities will function independently with long-term sustainability.

High All Products; Services and Activities will function with sustainability after closure of the mine

with limited company controls.

Moderate All Products; Services and Activities is sustainable during the life of the mine under controlled

conditions with increased resource investment.


Low The natural, social and cultural functions or processes are minimally improved (only just

measurable). Such effects are felt only during the life of the operation. Risk: Limited

investment of resources.

No Effect No positive effect.

Compliance (Negative Impact)


Not Compliant Operation is currently not compliant under normal operating conditions

Occasionally Not

Compliant

Operation is generally compliant but there is occasional non-compliance under normal

operating conditions

Potentially Not

Compliant

Operation is generally compliant but there is potential non-compliance under abnormal


Compliant / n/a Operation is compliant under normal AND abnormal operating conditions OR Compliance is

NOT APPLICABLE to this impact

Positive The Operation adds value by leading by example

Compliance (Positive Impact)


Not Compliant Operation is currently not compliant under normal operating conditions

Occasionally Not

Compliant

Operation is generally compliant but there is occasional non-compliance under normal


Potentially Not

Compliant

Operation is generally compliant but there is potential non-compliance under abnormal


Compliant / n/a Operation is compliant under normal AND abnormal operating conditions OR Compliance is

NOT APPLICABLE to this impact

Positive The Operation adds value by leading by example

Improvement (Negative Impact)


High Strong opportunity to improve management to reduce or eliminate impact.

Medium Management measures are in place to manage impact. Improved management could further

reduce or eliminate impact.

Low The activity/ aspect is currently well managed. There is little or no scope for improving current

management to further reduce impact.

Not Required No management is required

Improvement (Positive Impact)


High Strong opportunity to improve management to enhance the positive impact.


Medium Management measures are in place to sustain the positive the positive improvement.

Improved management could enhance the positive impact.

Low The Activity, Products and Services are currently well managed. There is little or no scope for

father improvement.

Not Required No management is required

Training Required (Negative Impact)


Yes Training is required for the aspect under review. Training will mitigate the severity of the

Impact.

No Training is not required for the aspect.

Training Required (Positive Impact)


Yes Training is required for further improvement

No Training is not required for the aspect.

Potential Emergency (Negative Impact)


Yes The activity and related aspects could lead to an environmental emergency taking place.

No The activity and aspect cannot lead to an environmental emergency situation.

Potential Emergency (Positive Impact)


Yes The activity and related aspects could lead to an environmental emergency taking place.

No The activity and aspect cannot lead to an environmental emergency situation.

Every aspect is evaluated according to the criteria listed above. Only the most suitable class of each criterion

will be selected taking note of normal, abnormal and emergency situations. All aspects are rated taking into

consideration current mitigation in place in the area under investigation i.e. the residual risk will be determined.

The type and effectiveness of mitigation that should be considered are, amongst others:

• Suitably competent personnel;

• Monitoring and management process and procedures in place;

• Physical barriers and controls to prevent or minimize the impacts;

• Emergency procedures and systems in place where applicable. The rating of aspects will be done in

conjunction with the responsible person of the area under investigation.


After all seven criteria had been selected on IsoMetrix, the calculation button will be used to reveal the calculated

risk class as well as recommended management priority. The calculation is done automatically by the electronic

system.

The responsible person of the area, taking note of both the risk class as well as the recommended management

priority, allocates final priority to the aspect under investigation. The responsible person may choose to agree

with recommended priority or to override the recommendation to a higher class.

The responsible person will not be allowed to override the recommendation to a lower priority.

For all HIGH Final Management Priorities, the mine will implement, either individually or in combination, any of

the following controls:

a) Monitoring and measurement (including inspections);

b) Engineering controls with the development of Environmental Management Programmes (EMPs); and

c) Administrative control (including operational procedures and training)

MEDIUM rated aspects will as a minimum have operational procedures in place to prevent the impact from

becoming worse. See Objectives and Targets procedures.

ALARP aspects will be so indicated in the User Defined Fields of IsoMetrix. These aspects must contain detailed

descriptions of the control measures already implemented. When an aspect is indicated as ALARP, no further

control will be implemented unless new technological options became available that is practicable for the mine

to implement.

It is not mandatory for the POSITIVE IMPACTS to be assigned with Objectives (EMP’s).

The Aspects register of each area must be communicated to all employees working in that specific area. They

must be aware of the significant impacts caused by their activities. Record of this communication must be kept

as prove of training.

Revision

The aspects register will be reviewed during December and January before budget review to ensure that

adequate budget is allocated to management plans:

• At least annually;

• After significant changes; and

• After the completion of Environmental Management Programmes that would change an aspect’s

significance rating.

In terms of minerals and labour legislation, contractors performing work on a mine are regarded as employees.

Therefore, the mine has the same legal responsibility in respect of contractors as to its own employees.


No Contractor will be allowed to commence any work on the mine unless the agreement between the mine and

the contractor has been finalised.

Contractors working on the mine’s premises for longer than 5 (consecutive) days are required to undergo the

mine’s full medical, safety, environmental, fire and security induction programme.

Contractors working on the mine’s premises for less than 5 days shall receive general SHE Induction from the

Security Reception Clerk.

Contractors working for more than 5 days will be issued with a temporary card for five days (window period) to

enable them to enter the mine in order to undergo all the relevant induction programmes.

Should the contract term be longer than one year, the contract holders will ensure that their employees go for

medical surveillance (to make appropriate arrangements) exactly one year after commencing work.

The Security official capturing the data to open a contractor’s access card will ensure that the card is valid for

12 (twelve) months.

Should the contract term be less than one year, the Security official capturing the data to open a contractor’s

access card will ensure that it is only valid for the duration of the contract. Should it be required that the contract

be extended, the contract holder must liaise with the relevant company official in that regard.

Contractors working on mine for a period of more than 5 consecutive days must be appointed under the

applicable Legal Appointment indicated in the Mine Health and Safety Act 29 of 1996. No contractor may

commence working on the mine before the legal appointment has been signed.

Legal Appointments are not required for contractors who are on the mine for less than 5 days.

The responsibility for the legal appointment of contractors lies with the company official, who is also responsible

for the day to day monitoring of the contractor.

The relevant appointed mine official to whom the contractor reports will ensure that the contract holder or his

duly appointed representative receive a copy of the SHE Contractors Manual.

The relevant appointed mine official to whom the contractor reports will ensure that the relevant training prior to

the appointment has been done.

In addition to the requirements set out in the General Conditions of Contract, Contractors will be required to

perform their work in accordance with the mine policies and procedures as set out in the contractors Manual,

which will be included with the Contract documentation and is obtainable from the Mine Store.


All Contractors shall submit a monthly report to the Chief Safety Officer to enable him/her to report on the current

strength of all contractor workers per contractor and per department.

Should a Contractor be required to work over weekends, they must attend the weekly Weekend Labour Planning

meeting. The appropriate weekend overtime labour lists must be authorised by the weekend overtime duty

manager and a copy forwarded to the Security Control Room.

The Contractor’s site supervisor shall attend all relevant departmental safety, health and environmental

meetings convened by mine management.

The Contractor shall furthermore hold monthly safety, health and environmental meetings for its own employees

and keep record of such meetings. Alternatively, the Contractor shall arrange that its employees attend safety,

health and environmental meetings convened by the relevant department, and will be required to maintain record

of attendance by its employees.

1.11 Specific information required by the Competent Authority

The following information will be required by the competent authority.

INFORMATION FREQUENCY OF SUBMISSION

Quantum of Financial Provision Annually

Environmental Audit Report Annually

Monitoring Report Monthly, Quarterly and Annual environmental

reports to Head office


2. UNDERTAKING

The EAP herewith confirms

(a) the correctness of the information provided in the reports

(b) the inclusion of comments and inputs from stakeholders and I&APs;

(c) the inclusion of inputs and recommendations from the specialist reports where relevant; and

(d) the information provided by the EAP to interested and affected parties and any responses by the EAP to

comments or inputs made by interested and affected parties are correctly reflected herein.

Signature of the environmental assessment practitioner:

Shangoni Management Services (Pty) Ltd

Name of company:

Date:

-END-

BASIC ASSESSMENT AND ENVIRONMENTAL MANAGEMENT …

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